Privacy Policy

This Privacy Policy (“Policy”) explains how Zolve Innovations, Inc. along with its 100% Indian subsidiary, Zolve Innovations Private Limited and their respective agents, representatives, assigns, successors and service providers (collectively, “Company”, “Zolve”, “we,” “us,”), collect, store, use, share, transfer and protect your personal information, which we obtain when you visit our websites, use our mobile application or use our services. You accept this Policy and all of its terms whenever you access or use our products, website, services, features and technologies, including our mobile application (collectively, the “Services”). Please read this Policy carefully

Remember that your use of our Services is at all times subject to our (i) Zolve Innovations Terms of Service, (ii) Zolve India Terms & Conditions; (iii) Community Federal Savings Bank privacy policy; (iv) The Bank of Missouri’s Privacy Policy; (v) Continental Bank’s Privacy Policy; (vi) US Consumer Privacy Notice, in case of each privacy policy to the extent as applicable to the respective services or products.

This Policy covers how we treat “personal information” that we gather or collect from you when you access or use our Services. This includes, without limitation, information we collect when you access or use the mobile application operated by us to view, manage, or conduct transactions on the deposit or credit account or [name] Deposit Account (and Security Deposit Account) (“Banking Account”) or the Zolve Debit Card or Credit Card or Card (each, a “Zolve Card”), both of which are made available by a partnering financial institution (“Bank”). However, it does not apply to the Banking Account or Zolve Card themselves. Please refer to the terms and conditions you enter into with the Bank and the Bank’s privacy policy for information concerning those products and your privacy rights with respect to those products.

Our Services are intended for users in the U.S.A. and in India (“Territory”). If you visit or use one of our Services, your information may be processed in the Territory and/or transferred outside the Territory to other third parties in connection with the Services rendered by us. We currently do not offer products or services to customers outside the Territory.

This Policy only applies to us and not to any third-party sites or services you may access through our website, our mobile application, or by using any of our Services and does not apply to information submitted or collected by websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third-party websites or services rendered by such parties.

What is Personal Information?

When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, including without limitation sensitive personal information. The term “personal information” does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

Our Collection of Personal Information

From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes, we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

Personal Information You Provide

We collect the following personal information you provide in connection with our Services:

• account registration information, such as your name, email, postal address, user name and password, telephone number, and preferences when using our Services;
• information about your personal characteristics, such as your full name, age, phone and/or cell number, date of birth, nationality, gender, signature, utility bills, citizenship, disability, military status, and photographs;
• government-issued identification, such as your social security number or equivalent, driver’s license number, taxpayer identification number/permanent account number, and passport number);
• financial information, such as your bank account information, including without limitation, account and routing numbers, tax information; credit and debit card information, credit history, and credit scores;
• Biometric information (such as a facial image), for the purpose of uniquely identifying an individual.
• employment-related information, such as your job title and salary information;
• your contacts and their information – With your permission, we access and store information about your contacts when you import or synchronize your contacts with our services and application. We collect contacts and their information on a regular basis during the validity of the permission to access and store. We use this information to help you send money and referrals. You have the ability to unlink or disconnect your contacts at any time. When you unlink or disconnect your contacts, we no longer have access to your contacts going forward.
• other information you may provide, such as information you provide when you contact us with questions, feedback, survey responses, participation in contests, promotions or other prospective seller marketing forms or devices, suggestions for improvements of our services or products, referrals, or otherwise communicate with us; and
• personal information you affirmatively disclose to us in connection with your interactions with us, including through your use of our Services.

In order to use the facilities and Services, you may be required, from time to time, at the request of Zolve or other third parties to provide certain additional personal information. Our collection, use, and disclosure of such personal information may be subject to additional privacy disclosures that we will make available to you in accordance with applicable law in the Territory.

Personal Information Automatically Collected

As is true of most digital platforms, we collect certain personal information automatically when you visit our online services, including:

• log file data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited;
• For fraud protection purposes only, we through our third-party service provider collect (1) Telephony and SIM information; (2) enough information to determine if the user’s location is being masked by using a Virtual Protocol Network (VPN), VPN apps with location spoofing, or other related tools.
• analytics data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”);
• location data. In accordance with your device permissions, we collect including but not limited to your general geographic location based on your IP, address information about the precise location of your device including latitude, longitude, etc. You may stop the collection of precise location information at any time (see the Location Information section below for details).
• information sent by your mobile device or web browser. We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services; and
• “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please see our Cookie Notice below.

Location Information

When you first launch our mobile app, or when you visit portions of our Services that collect precise location information, you'll be asked to consent to the collection of this information and the duration of the collection of the same information while the Zolve app is installed on your device. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. It is important to note that some Services may not function without precise location information. You may also stop a mobile app's collection of location information by following the standard uninstall process to remove the app from your device.

Personal Information from Other Sources and Third Parties

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.

We receive the same categories of personal information as described above from the following sources and third parties:

• public databases and ID verification partners. We obtain information about you from public databases and ID verification partners to verify your identity and information you may provide us.
• third party sources and credit reporting agencies. We also obtain information about you from third party sources. Such information may include credit report information, identity verification information, fraud detection information, collection information, and information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
• data append services, data brokers, and joint marketing partners. We receive personal information from these sources so that we can better understand which of our Services may be of interest to you.
• external bank account information providers. When you use certain Services, we may collect from you, e.g., usernames, passwords, account numbers, and other account information for third-party websites and Internet banking services. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf.
• lenders, financial institutions, and brokers. We obtain information about you from your lender, financial institution, or broker.

We also collect account information from you when you open or apply for a Banking Account, obtain loans from lending/financial institutions and/or obtain or apply for a Zolve Card through our Services. This information is used to obtain your account, transaction, and other banking information from the relevant financial institution on your behalf in order to display the information to you or to fulfil your requests for certain products, services, or transactions through a Service.

Our Use of Personal Information

We use personal information we collect to:

• to provide you with our Services. We use your personal information to provide you with our Services;
• to fulfill your requests for our products, programs, and Services, to respond to your inquiries about our Services, and to offer you other products, programs, or services that we believe may be of interest to you.
• to improve our Services and run our Services. We may use personal information to research, analyze, and understand how users access and use our Services, both on an aggregated and individualized basis, in order to help us improve our Services and develop new products. We also use personal information to operate, maintain, test, improve (including developing new products and services), enhance, update, monitor, diagnose, fix, and improve our Services;
• to correspond with you. We use personal information to provide you with customer support anytime you reach out to us with questions or issues arising from your account. We also use personal information to send customers technical alerts, updates, security notifications, and administrative communications;
• personalize your experience. When you use our services and sites, as well other third-party sites and services. In this case, we might use tracking technologies like cookies;
• for marketing purposes. We may use your personal information to communicate with you regarding certain products, services or promotions offered by us or certain third-party products and services we believe you may be interested in, provided that you have not already opted out of receiving such communications;
• send you locally relevant options. We can only do this if you make your location available to us. If you do, this can help us enhance the security of our sites and services, and customize our Services by sending your relevant coupons and otherwise personalizing content for you (e.g., through appropriate ads and search results);
• make it easy for you to find and connect with others. For example, if you let us access your contacts, we can suggest connections with people you may know;
• to detect, investigate, and prevent fraud and security issues. We use your personal information as necessary to protect our Company, our customers, and our business partners, including by investigating and preventing fraudulent activities, unauthorized access to the Services, and other illegal activities;
• Verify information you have provided to us or to protect against fraudulent or illegal activities, including using information to perform a check using Form I-94 and to validate your address through third party databases;
• comply with all applicable laws and regulations in the Territory. We use your personal information as we believe necessary or appropriate to comply with applicable laws in the Territory, lawful requests, and legal processes, such as to comply with applicable anti-money laundering laws, to report to credit bureaus, and to respond to subpoenas or requests from the respective government authorities; and
• prevent, investigate, or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you.

You acknowledge that if we determine that any personal information you have provided or uploaded violates this Policy, we have the right, in our absolute discretion, to delete or destroy such personal information without incurring any liability to you.

If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

We may also use personal information for geo-location and geo-tagging in connection with our Services. We may also use personal information for any other purposes disclosed to you at the time your information is collected or pursuant to your consent.

Our Disclosure of Personal Information

We share your personal information with the following types of recipients and in the following ways:

• service providers. We share your personal information with service providers that we have engaged to perform services on our behalf, including to third parties, in connection with the Services we provide to you. This includes service providers that: conduct research and analytics; create content; provide customer, technical or operational support; conduct or support marketing (such as email or advertising platforms); host the Services; maintain databases; send or support online or mobile advertising; allow you to conduct transactions in connection with the Services; and otherwise support or help us provide the Services. Service providers also include payment processors, payment networks, external bank account information providers, credit reporting and scoring agencies, providers of identity services, risk investigation and mitigation service providers, hosting, technology and communication providers, security and fraud prevention consultants, risk investigation and mitigation service providers, support and customer service vendors and product fulfillment and delivery providers. You acknowledge that such third parties will have access to your personal information on a need basis, in connection with the Services rendered by us;
• advertising and marketing partners. We share your personal information with other third parties, including advertising/analytics partners who enable the delivery of interest-based advertising to users, as well as vendors that provide specific services we do not;
• business transaction or reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership;
• affiliates, investors and business partners. We share your personal information with our affiliates to support the Services and investors and business partners, subject to the terms of this Policy or otherwise as we disclose to you at the time the data is collected;
• credit bureaus and collection agencies. Depending on circumstances, we may share your personal information with credit bureaus and collection agencies, as permitted by law;
• legal obligations and rights. We may disclose personal information to third parties, such as legal advisors and law enforcement:
• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process;
• to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, Zolve Innovations Terms of Service and (ii) Zolve India Terms & Conditions ;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or
• as otherwise required by applicable law; and
• consent. We may disclose personal information about you to certain other third parties with your consent.

Cookie Notice

Scope of Cookie Notice

This provision explains how we and our business partners and services providers use cookies and related technologies in the course of managing and providing our online services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them. In some cases, we may use cookies and related technologies described in this provision to collect personal information, or to collect information that becomes personal information if we combine it with other information.

What are cookies?

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or work more efficiently, as well as to provide reporting information and assist with service or advertising personalization.What We Collect When Using Cookies

Own Cookies refer to cookies that are placed on your web browser by us when you visit our website.

Third Party Cookies refer to cookies that are placed on your web browser by another party when you visit or use our website.

Essential Cookies are cookies that are indispensable for visiting the website in order to be able to benefit from full functionality. If the use of this type of cookies is switched off, some parts of the website will not function as intended.

Functionality Cookies are cookies that allow the website to remember choices you make and provide enhanced features. These cookies are also used to provide services you have asked for such as watching a video, commenting or using a chatbot. These cookies can be our Own Cookies or Third- Party Cookies and information maybe shared with third party service providers.

Performance Analysis Cookies are cookies used to collect general information about the way in which visitors use the website. The information gathered through these cookies is used to make statistical analyses. These statistics offer us insight into how often our web pages are visited, on which pages visitors spend most time etc. This enables us to create the structure, navigation and content of our website in the most user-friendly way possible and allows for continuous improvement.

Advertising Cookies are cookies used to offer personalised and more relevant advertisements, to determine how many times a certain advertisement has already been shown, to calculate the effectiveness of a certain advertising campaign, to keep track of data from a previous visit and to share the data collected with the third parties involved, such as the advertisers. These cookies are used on websites and placed on your device by third parties such as companies linked to us and our advertisers belonging to the advertising network of the website.

Social Media Cookies are cookies that allow you to share the content of our website on social media and to enable other interaction with social media via our website.

What We Collect When Using Cookies

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, websites and other online services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics data or use third-party analytics tools, such as Google Analytics, to help us measure usage and activity trends for our online services and better understand our customer base.c

Third-party partners and providers may also collect personal information about your online activities over time and across different websites when you use our websites and online services.

How We Use That Information

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online services; (b) provide and monitor the effectiveness of our websites and online services; (c) monitor online usage and activities of our websites and online services; (d) diagnose errors and problems with our websites and online services; (e) otherwise plan for and enhance our online services; and (f) facilitate the purposes identified in the Our Use of Personal Information section of this Policy. We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in this Policy.

Your Choices About Cookies

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online services, as some features and services on our online services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

How long are cookies stored on your device?

The period during which a Cookie is stored on the device you are browsing with depends on whether it is a Permanent Cookie or a Session Cookie. Session Cookies are only stored on a device until the web browser is closed. Permanent Cookies remain on the device after you have finished browsing until they expire or are deleted.

Please note that if you set your web browser or device settings to disable Cookies, You may not be able to access secure areas of the website/mobile application, other parts of the website/mobile application and its features may not function properly.

You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy here. You can also view Google’s currently available opt-out options here.

Your Choices About Online Ads

We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info.If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Children’s Personal Information

Our websites and online services are not directed to children under the age of 13, and we do not either intend to or knowingly collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

State Disclosures

USA

California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to hello@zolve.com.

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at hello@zolve.com.
To limit our sharing of your information, please contact us at hello@zolve.com.

INDIA

Under Indian laws, with respect to Indian residents, personal information shall be retained by us for the period during which you are availing Services from us and for a further period as may be required under applicable laws. Further, if an Indian resident is desirous of having his/her name personal information removed from the records of Zolve, the resident may send a written request to us requesting to remove and/delete all such information. We shall, within 72 (seventy two) hours of receipt of such request, remove/delete the personal information. To submit such a request, please contact us at legal@zolve.com. Upon withdrawal of consent, we will not be able to render the Services contemplated herein.

Third-Party Websites

Our websites and online services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Policy, this Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please refer to their respective privacy policies.

We partner with Rakuten Advertising, which may collect personal information when you interact with our site. The collection and use of this information are subject to the privacy policy located here: Rakuten's privacy policy: https://rakutenmarketing.com/legal-notices/services-privacy-policy To submit an opt-out request: https://rakutenmarketing.com/legal-notices/subject-requests

Protecting Your Information

While we take reasonable steps to protect your personal information, nothing on the internet is 100% secure. For these reasons, we cannot guarantee that all of your personal information will never be disclosed in ways you do not expect, or which are not described in this Policy. While we protect our systems and services, we cannot guarantee the security of your information during transmission and any transmission is at your own risk. Also, you are responsible for keeping your password(s) and account information safe and private. You are also responsible for making sure your personal information is accurate and up-to-date.

Updates to This Policy

We will update this Policy from time to time. When we make changes to this Policy, we will change the "Last Updated" date at the beginning of this Policy. If we make material changes to this Policy, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels, as determined by us in our sole discretion. All changes shall be effective from the date of publication unless otherwise provided.

Storage and Processing

Regardless of where you live, you acknowledge that any personal information you make available to us may be processed and stored in the Territory. You further acknowledge that such personal information may be transferred to, processed and stored outside the Territory from time to time by our service providers and other third parties we work with in connection with the Services rendered by Zolve.

Contact Us

USA

If you have any questions or requests in connection with this Policy or other privacy-related matters, please send an email to hello@zolve.com.

INDIA

In the event an Indian resident has any discrepancies and grievances under this Policy or with respect to the processing of personal information by Zolve, please contact the grievance officer below:

Name: Manish Sharma
Email ID: legal@zolve.com