Privacy policy.

Last Updated: November 8, 2023

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAYS Zilch USA, Inc. and its affiliates (“Company,” “we,” “our,” “us”) COLLECTS, USES, DISCLOSES, AND OTHERWISE PROCESSES PERSONAL INFORMATION IN CONNECTION WITH OUR SERVICES, INCLUDING OUR WEBSITES, MOBILE APPLICATION OR ANY OTHER SERVICES, TECHNOLOGY OR PRODUCTS WE MAY OFFER FROM TIME TO TIME (COLLECTIVELY, “SERVICES”). PLEASE READ THIS PRIVACY POLICY CAREFULLY.

Remember that your use of our services is at all times subject to our Terms of Use. Our Services are intended for users in the United States If you visit our website or mobile application or use any of our services, your information may be processed in the United States and/or transferred outside of the United States to other third parties in connection with the services rendered by us. This Privacy 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 Privacy 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. It 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. Personal information includes, without limitation, information we collect when you access or use the services to view, manage, or conduct transactions using the Zilch Card or obtain financing from our partnering financial institution (“Bank”), both of which are made available by the Bank. However, this Privacy Policy does not apply to the financial products offered by the Bank itself. 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 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.

Non-Public Information You Provide

We collect non-public information, including the following personal information, you provide in connection with our services:

Identity Data: includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, tax identification or social security number or any other government issued identification number, government identity document, personal image, and any other form of identification that you provide to us so that we can verify your identity.

Contact Data: includes billing address, email address and telephone numbers.

Financial Data: includes bank account and payment card details, and information about your credit score and credit history provided to us by credit reporting agencies.

Transaction Data: includes details about purchases you have made in connection with our services, payments we have made on your behalf, repayments made by you to us or Bank, and cashback payments that have been made or may be due to you.

Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.

Usage Data: includes information about how you use our website and services.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Other Information: employment-related information, such as your job title and salary information, 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/or personal information you affirmatively disclose to us in connection with your interactions with us, including through your use of our services.

We also collect, use, and share aggregated data such as statistical or demographic data for various purposes including, but not limited to, the following: (a) use it for internal management purposes, (b) share it with current or prospective retailers, (c) use it to target offers that are made to users through our services, and (d) to calculate the percentage of users accessing a specific website feature. This type of information includes, for example, the types of product that a user purchases, the value of those purchases and the web, app, instore or other channels through which the purchases are made. However, if we combine or connect aggregated data with other data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

Personal Information Automatically Collected

We collect certain personal information automatically when you visit our online services, including, but not limited to:

-Usage Data.
Technical Data, such as log file data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
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, including your general geographic location based on your IP address or more precise location when accessing our services through a mobile device.
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.
“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 visit our Cookie Notice below.

Personal Information from Other Sources and Third Parties

We also obtain other public and non-public personal information from other sources, which we often combine with personal information we collect either automatically or directly from you. We receive certain 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 receive: Technical Data from analytics providers such as, but not limited to, Google; demographic data from advertising sources such as, but not limited to, Facebook, Snapchat, Instagram, Twitter, and Google; Transaction Data from merchants who you make transactions with using our services; data from affiliate advertising networks such as, but not limited to, Quidco, Awin, Viglink, and CJ; data from technical monitoring and error reporting service providers, such as, but not limited to, DataDog, MixPanel and SmartLook; Contact Data, Financial Data and Transaction Data from credit reporting agencies; and contact and document information from identity verification providers such as, but not limited to, Onfido.

Biometric Identity Verification

We may use identity verification services provided by a third-party provider to verify your identity documents, confirm your identity, and protect against fraud and abuse. When you create an account or enter into certain transactions, you may be asked to submit a valid government ID, along with a selfie image. Our third-party provider may use a combination of machine learning tools and optical scans to authenticate your identity document and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." We do not receive the biometric identifier generated from the images. The biometric identifier is instead generated and held by our third-party provider until we inform them that the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 3 years after your last interaction with us. For identity verification and security purposes, we will have access to the selfie image and will receive the information extracted from the identity scan of the ID document as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, and protect against fraud and misrepresentation. We do not use, disclose, or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements.

Our Use of Personal Information

We may 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;
to 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 by unsubscribing from marketing e-mails from us;
to 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 you relevant coupons and otherwise personalizing content for you (e.g., through appropriate ads and search results);
to 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;
to verify information you have provided to us or to protect against fraudulent or illegal activities, including using information to validate your address through third party databases. Service providers, such as Onfido, may use your personal information to verify your identity on our behalf;
to comply with all applicable laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, 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;
to enforce and carry out contracts and agreements between us and you;
to register you as a new customer;
to assess each proposed transaction that you request through or in connection with services;
to process approved transactions on your behalf;
to process cashback payments and referral fees;
to manage your account and process repayments that you owe to us or Bank;
to collect and recover money owed to us or Bank;
to manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy; and (b) asking you to leave a review or take a survey;
to process, manage and investigate any claim or complaint raised by you regarding cashback owed; and
to retain records of our financial transactions and contracts with you in order to maintain adequate accounting records and meet legal requirements.

In addition, we may use your personal information described above (i) in connection with performing the contract we are about to enter into or have entered into with you; or (ii) when it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
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 Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Our Disclosure of Personal Information

We may disclose your personal information in the following ways:

Merchants: We may share your personal information with merchants in order to process your purchase and refunds.
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. We also share personal information, including, but not limited to, your identity documents and images, with our service providers, such as Onfido, to verify your identity. 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.
Credit bureaus and collection agencies: Depending on circumstances, we may share your personal information with credit bureaus and collection agencies, as permitted by law
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. We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.
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, and terms of use;
- 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.
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 service 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 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 providers, like Google, to help us measure usage and activity trends for our online services and better understand our customer base. We may disclose your site-use information to these analytics providers. To learn more about Google Analytics and how to opt out, please visit https://support.google.com/analytics/answer/181881?hl=e.
Although we disclose your personal information to third parties as described above, we do not sell your personal information, nor have we done so in the preceding 12 months.

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 Privacy 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 Privacy 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.

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, and we do not 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 websites or online 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.

Jurisdiction-Specific Disclosures

California

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 contact us at [email protected].

Nevada

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 [email protected].

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 Privacy Policy, this Privacy 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 visit their respective privacy notices and/or privacy policies.

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 Privacy 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.

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 any country where permitted by law. You further acknowledge that such personal information may be transferred to, processed and stored outside the U.S.A. from time to time by our service providers and other third parties we work with in connection with the services rendered by us or our affiliates or service providers. We will always take steps to ensure your personal information is afforded equivalent levels of protection and rights as are required under your country of residence.

Updates to This Privacy Policy

This Privacy Policy (and Privacy Notice provided below) is initially provided to you, and you must execute it, before completing your registration for use of the Services and before any customer relationship is established between you and us. You will not be permitted to complete any transaction utilizing the Services, including entering into any loan, without first consenting to this Privacy Policy and acknowledging receipt of the privacy notice. At the time that you give your consent to the Privacy Policy (and Privacy Notice), we record and retain your consent. Additionally, this Privacy Policy (and Privacy Notice) is publically available on our website.

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the "Last Updated" date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you or by e-mail to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All such revisions to the initial privacy notice wil be made pursuant to § 12 CFR 1016.8 and delivered pursuant to 12 CFR § 1016.9. All changes shall be effective from the date of publication unless otherwise provided.

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to [email protected].
Alternatively, inquiries may be addressed to:
Zilch USA, Inc.
1111 Brickell Ave., Suite 1870,
Miami, Florida 33131.

Exporting, Removing & Deleting Your Information

Zilch retains information about you as a customer in order to provide you with our services. Your specific rights as a consumer may vary depending on the type of information, and where you reside, and are fully described in our Privacy Policy.

In general you retain the right to:

A. Request a copy of the data we collect about you
You have the right to request a copy of your personal data. In order to do so, please send a request to:
[email protected]

Zilch USA, Inc.
1111 Brickell Ave., Suite 1870,
Miami, Florida 33131.

B. Request that we rectify inaccurate or incomplete information about yourself
You may come to realize that the information referring to you may be wrong or incomplete, you have the right to request the information to be rectified or completed.

If you want to make such changes, you simply contact us via our Chat Bot found in the Help section of your Zilch app or by contacting our support team at [email protected], describing your request.

C. Terminate a product, service, or your whole relationship with Zilch
By terminating a product or service you thereby terminate the connected terms and conditions. Should you have any questions on how to terminate a product or service, you are welcome to chat with us via our Chat Bot found in the Help section of your Zilch app or by contacting our support team at [email protected].

D. Request deletion of your personal data
You have the right to request for personal data – that Zilch is not obliged to keep – to be deleted. Please note that as a consequence, you will no longer, for example receive any marketing material from us nor be able to log in to our web portal or mobile app once this process has been completed. If you wish to request your personal data to be deleted.

In order to do so, please send a request to: [email protected]

Or
Zilch USA, Inc.
1111 Brickell Ave., Suite 1870,
Miami, Florida 33131.
If you wish to limit specific type of data you share with us, you can e.g. always opt out from marketing send-outs, (this can be done via the “Unsubscribe” link at the bottom of any emails you may receive from Zilch)..

Information Regarding Retention of Certain Data:

Please note that there may be instances where access to data or the right to delete specific information may be limited. For example, as a financial institution, we are required to retain certain data by law, for example for Anti-Money Laundering purposes. In addition to legal requirements, we may also retain certain information to protect both you and us, e.g. for fraud prevention purposes.

Identification Before Receiving Access or Erasure of Data:

In order to exercise your right to have your data erased or your right of access to your personal data, Zilch will need to identify you via, for example, via your identification information and information only you would have access to. As a countermeasure to wrongfully disclose or delete personal data, we will always be required to properly identify you first.

Zilch Privacy Notice.

Rev. 04/2022

Facts	What does Zilch USA, Inc. (“Zilch”) do with your personal information?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and checking account information Income and account transactions Credit history and account balances When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Zilch chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Zilch share?	Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes— to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don’t share
For our affiliates' everyday business purposes-- information about your transactions and experiences	No	We don’t share
For our affiliates' everyday business purposes-- information about your creditworthiness	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?

Call 855-909-4524 or go to https://www.zilch.com/

Who we are
Who is providing this notice?	Zilch
What we do
How does Zilch protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Zilch collect my personal information?	We collect your personal information, for example, when you - Open an account or give us your income information - Apply for financing or give us your contact information - Show your driver’s license We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can't I limit all sharing?	Federal law gives you the right to limit only - sharing for affiliates' everyday business purposes-information about your creditworthiness - affiliates from using your information to market to you - sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. [See below for more on your rights under state law.]
Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. - Zilch does not share any nonpublic personal information with our affiliates.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. - Zilch does not share any nonpublic personal information with nonaffiliates so they can market to you.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. - Zilch doesn’t jointly market by providing any nonpublic personal information.
Other important information
Special Notice For State Residents For Alaska, Illinois, Maryland, and North Dakota Residents. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization. For California Residents. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing-without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us. For Massachusetts, Mississippi, and New Jersey Residents. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing without your authorization. For Vermont Residents. We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Cross River Bank Privacy Notice.

Rev. 11/2018

Facts	What does Crorss River Bank do with your personal information?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: - Social Security number and Account balances - Payment history and Transaction history balances - Account transactions and Wire transfer instructions When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Cross River Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Zilch share?	Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes— to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don’t share
For our affiliates' everyday business purposes-- information about your transactions and experiences	No	We don’t share
For our affiliates' everyday business purposes-- information about your creditworthiness	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?

Call toll free 1-877-55CRB55 or go to www.crossriverbank.com

What we do
How does Cross River Bank protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.
How does Cross River Bank collect my personal information?	We collect your personal information, for example, when you - Open an account or Apply for a loan - Make deposits or withdrawals from your account or Provide employment information - Give us your contact information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Federal law gives you the right to limit only	Federal law gives you the right to limit only - sharing for affiliates' everyday business purposes-information about your creditworthiness - affiliates from using your information to market to you - sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. - Cross River Bank does not share with our affiliates.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. - Nonaffiliates we share with can include loan finance companies.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. - Our joint marketing partner(s) include loan finance companies.
Other important information
Special Notice For State Residents For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing-without your authorization. For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing-without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us. For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing-without your authorization. For Vermont Customers. We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at www.crossriverbank.com or call 1-877-55CRB55.