CLARITY MONEY PRIVACY POLICY

Last Updated: December 15, 2016

Clarity Money, Inc. respects your privacy. This Privacy Policy describes our practices in connection with the information collected through the Clarity mobile application (the “App”). By using the App, you agree to the terms of this Privacy Policy.

We use information that we collect from and about our customers in accordance with our Consumer Privacy Notice, which provides choices about our sharing and use of information.

INFORMATION YOU PROVIDE

The App collects the information you choose to provide (“User Information”). This may include, for example:

Name

Address

Phone number

Email address

Social Security number

Occupation and income

Date of birth

Payment card information

Information about your financial accounts

Information about subscriptions or other services you receive

Social media account ID

If you provide or permit us to collect any information relating to another person, you are telling us that you have the authority to do so and to permit us to use the information as described in this Privacy Policy.

We may combine the information you provide with information we receive about you from other sources, such as public databases, joint marketing partners, providers of demographic information, social media platforms, people with whom you are connected on social media platforms and other third parties.

We use Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance

with the Plaid Privacy Policy, available at https://plaid.com/legal.

HOW WE USE AND DISCLOSE THE INFORMATION YOU PROVIDE

We may use the information you provide:

To provide you with the App’s functionality.

To respond to your inquiries and fulfill your requests.

To provide you with customer service.

To send administrative information to you, such as information regarding the App and changes to our terms, including through push notifications and text messages.

To send you marketing communications that we believe may be of interest to you, including through push notifications and text messages.

To personalize your experience on the App, including by presenting products and offers tailored to you.

To facilitate social sharing functionality.

To allow you to send messages to a friend through the App.

For our business purposes, such as data analysis; audits; fraud monitoring and prevention; developing new products; enhancing, improving or modifying our products and services; identifying usage trends; determining the effectiveness of our promotional campaigns; and operating and expanding our business activities.

The information you provide may be disclosed:

To third parties whose products or services you request. Such third parties may use and disclose your information in accordance with their own privacy policies.

To our third-party service providers, to provide services such as payment processing, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

To identify you to anyone to whom you send messages through the App.

To your friends associated with your social media account, to other App users and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your App account or log-into your App account from your social media account. By connecting your App account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy.

To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

We may also use and disclose the information you provide as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may aggregate the information that you and other App users provide. If we do, we may use and disclose such aggregated information for any purpose. Aggregated information does not personally identify you or any other user.

OTHER INFORMATION

We may use cookies and other technologies to recognize you as you use or return to the App so that we can understand how the App is used and personalize and enhance your experience. These technologies collect certain information automatically, such as:

Information about your device, such as your screen resolution, operating system, device manufacturer and model, language and browser type. We use this information to ensure that the App functions properly.

Information about your use of the App, including content viewed, features used and when you interact with the App. We use this information to understand App usage and to improve the App.

Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the App and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/ privacy/partners/.

We may use and disclose the information described in this section for any purpose, except where we are required to do otherwise under applicable law. If we combine the information described in this section with information that is deemed “personal information” under applicable law, we will treat the combined information as “information you provide,” as described above, for as long as it is combined.

LOCATION INFORMATION

We may collect your device’s location through, for example, GPS, WiFi, satellite or cell phone tower signals. We use your device’s physical location to provide you with location-based services and content. You may be able to control such collection and/or use through your device settings.

OUR ADVERTISING

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you use other applications, based on information relating to your access to and use of the App and other apps. To do so, these companies may place or recognize a unique identifier on your device. If you would like more information about this practice, please visit http://www.aboutads.info/. To learn how to opt out, go to www.aboutads.info/appchoices to download the App Choices app.

THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the information collection, use, disclosure or security, or other practices, of any third party, including any third party operating a service to which the App links or which is framed within the App. Such third parties may include, for example, lenders, credit card companies and other providers of products and services. The inclusion of a link within the App or the App’s framing of a third party’s online service does not imply our endorsement of the third party. In addition, we are not responsible for the practices of any other app developer or provider; social media platform, operating system or wireless service provider; or device manufacturer.

INFORMATION SECURITY

We use reasonable organizational, technical and administrative measures designed to protect the information you provide to us. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as set forth in the “Contact Us” section below.

CHOICES AND ACCESS

You may stop the receipt of push notifications through your device settings.

If you would like to review, correct, update, suppress or delete personal information that you have provided to us through the App, you may contact us at support@claritymoney.com. In your request, please tell us what personal information you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. For your protection, we may only implement requests with respect to the personal information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

CHILDREN

The App is not directed to children under the age of thirteen (13), and we do not knowingly collect personal information from such individuals. If you are at least 13 but under 18, you must obtain your parent’s or legal guardian’s permission before downloading the App.

CROSS-BORDER TRANSFER

The App is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. The information we collect through the App may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Any changes will become effective when we post the revised Privacy Policy in the App. Your use of the App following these changes means that you accept the revised Privacy Policy. This Privacy Policy was last updated as of the “Last Updated” date shown above.

CONTACT US

Please contact us if you have any questions:

Clarity Money, Inc. c/o TH Productions

599 Broadway, 10th Floor New York, NY 10012