Privacy Notice

PLEASE CAREFULLY READ ALL OF THE TERMS AND CONDITIONS THAT APPLY TO YOUR NETSPEND EARNED WAGE ACCESS ACCOUNT (“NETSPEND ACCOUNT”), EARNED WAGE ACCESS PORTAL ACCOUNT (“EWA PORTAL ACCOUNT”), OR TO YOUR USE OF NETSPEND EARNED WAGE ACCESS SERVICES, AND KEEP A COPY OF THIS PRIVACY NOTICE FOR YOUR RECORDS.

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By using the Netspend Earned Wage Access mobile app (the “Netspend App”), Earned Wage Access Portal, or by using any of the related products or services (each individually or collectively, as the case may be, the “Services”), including your Netspend Account, EWA Portal Account, or electronic fund transfer (EFT) services, You acknowledge and agree that You are bound by the terms and conditions of this Privacy Notice.

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Consumer Financial Privacy Notice

Netspend Holdings, Inc. (“Netspend”) provides this consumer financial privacy notice for an individual’s use of the Netspend App, Earned Wage Access Portal, any part of the Services, or any website that connects to this notice (“Netspend’s EWA Privacy Notice”).

For the purposes of Netspend’s EWA Privacy Notice, the term “You” or “Your” relates to the individual who, primarily for personal, family, or household purposes, (i) downloads or uses the Netspend App, (ii) uses or accesses the Earned Wage Access Portal with an EWA Portal Account or (iii) applies for or obtains any part of the Services or any other financial product or service from Netspend.

Netspend’s EWA Privacy Notice applies to personally identifiable information about You (sometimes defined as “nonpublic personal information”), which we refer to as “Your information.” In connection with Netspend’s treatment of Your information, Netspend’s EWA Privacy Notice describes the policies and procedures (including a summary of the relevant security controls) that Netspend uses when

collecting, maintaining, using, or transmitting (or “disclosing”) to others any of Your information.

Netspend reserves the right to modify any aspect of Netspend’s EWA Privacy Notice, and Netspend may make these modifications at any time. In some circumstances, Netspend may modify Netspend’s EWA Privacy Notice in one or more ways that may affect the treatment of Your information without first notifying You of those modifications. Please review the “Effective Date” of Netspend’s EWA Privacy Notice each time you use the Netspend App or use any of the Services.

For information about Netspend, or any entity that is or may in the future be an affiliate of Netspend, in connection with the treatment of your information under Netspend’s EWA Privacy Notice, please see the section below entitled “Contacting Netspend.”

Overview

Netspend provides financial products or services to consumers, as well as to corporate persons, such as entities that employ consumers to be their employees. Netspend’s mission is to provide to a consumer certain tools for greater access and control over his or her financial health by providing innovative financial products and services, such as solutions for electronic fund transfer services (EFT services). Among other products and services covered by the Netspend EWA Privacy Notice is Netspend’s product and service that provides ways for a consumer to control funds that he or she owns, including by transferring those funds to (or from) his or her primary bank account. Netspend also offers and provides to a consumer an “Earned Wage Payment,” as that term is defined in Netspend’s Earned Wage Access Terms of Service .

Netspend’s EWA Privacy Notice is designed to provide a straightforward explanation of how Netspend collects and maintains Your information, as well as how Netspend may disclose Your information to other persons. However, Netspend’s EWA Privacy Notice does not apply to the treatment of data by another person that is not affiliated with Netspend, such as an employer (even if the other person has a contract or arrangement in place for Netspend’s Services). Whether and how another person, such as an employer, could use, collect, maintain, or transfer data about You, including through the other person’s websites, is governed by the other person’s privacy policy.

Netspend’s Privacy Practices Information We Collect

1. Information You provide. We collect various categories of Your information that You provide, either directly or indirectly, to us, such as:

• Identifying information, such as Your mobile telephone number, email address, and residential address;
• Financial information, such as information You provide on an application to us or from data we collect from transactions you conduct using the Services; and
• Information about Your status or personal characteristics, such as whether You are employed, where You do or could work, and the number of days You work in a month.

When You connect one or more of Your accounts with other financial institutions to the Netspend App or to your Netspend Account, we also may collect information to identify You, or to help verify that You are the true owner of the account(s), before connecting Your account(s).

2. Information received from your devices. When You use your device to connect to the Services, we receive information about that device, including IP address, hardware model, operating system, and other technical information about the device. Netspend reserves the right to capture cookies or similar tracking technologies to collect usage statistics and to help us provide and improve the Services.
3. Information collected from Your financial institutions. Whether Netspend collects or maintains Your information collected from the financial institutions You use, such as Your Bank (as that term is defined in the Netspend Earned Wage Access Terms of Service), may depend on how You use the Netspend App or the Services. Generally speaking, when You link Your Primary Bank Account (as that term is defined in the Netspend Earned Wage Access Terms of Service) to the Netspend App or to the Services (such as for EFT services), we may collect several categories of Your information, including:
   

• Account information, including Your financial institution’s name, the account type you use (such as a “checking account” or “savings account”), account number(s), and the institution’s routing number; and
• Information about any balance or transactions in Your Primary Bank Account.

2. Information we receive about You from other sources. Netspend also collects, directly or indirectly, Your information from other sources or persons, such as from service providers that help Netspend to identify You and to verify that You are the individual who is authorized to use the Services. We may also receive Your information from an administrator when they create an account for You.

How We Use Your Information

We use the information we collect to operate, improve, and protect the services we provide, and to develop new services. For example, we use Your information:

• To operate, provide, and maintain the Netspend App and Services;
• To improve, modify, or develop the Services or Netspend’s other financial products or services;
• To protect you, Netspend’s service providers, or Netspend from fraud, malicious activity, or other privacy and security-related concerns;
• To provide customer service to You;
• To investigate any misuse of the Netspend App or of the Services; and
• To develop new services.

Our Steps to Protect Your Information

We take steps designed to protect Your information that we collect, maintain, or disclose. These steps include maintaining information security controls, such as encryption technologies when transferring data or when storing data, firewalls, and controls over the physical access to our systems. We evaluate the security controls that we use, as well as the controls that our service providers use, for protecting the security and confidentiality of Your information. Our goal is to maintain effective security controls, as measured by relevant industry standards or by independent security auditors, for all of the ways that You can use the Services and other financial products and services provided by Netspend.

Netspend may keep Your information for as long as necessary to fulfill the purposes for the information is collected. In addition, for some types of Your information, Netspend may apply a longer retention period, such as for research or statistical analyses, except when storing or using that information for longer periods of time is not permitted under applicable law. As permitted under applicable law, even after You stop using the Netspend App or terminate your account with Netspend, we may retain Your information.

Our Rights to Disclose Your Information

Netspend reserves the right to disclose, or even to sell, some or all of the categories of Your information that Netspend collects to any person that is not an affiliate of Netspend—and under some circumstances You may be allowed to prevent Netspend from doing so by exercising Your right to “opt out” of certain disclosures. Netspend also may disclose some or all of the categories of Your information to any person that is an affiliate of Netspend, and you may opt out of some of those types of disclosures among the affiliate(s). Depending on Your state of residence, you may have additional rights under that state’s law that affect whether and to what extent Netspend may disclose Your information to other persons, including an affiliate of Netspend. However, as of the Effective Date of this Privacy Notice, Netspend

does not disclose Your information to persons in ways that present an opportunity for you to exercise Your opt-out or other rights relating to those types of disclosures.

Netspend discloses Your information to various type of persons as permitted by law, and those disclosures may apply to some or all of the categories of Your information that we collect. For example, Netspend may disclose all of the types of Your information with Your employer or with Your financial institution, consistent with Your consent or instruction or Your request for the Services. Netspend also discloses, or reserves the right to disclose, Your information:

• With Netspend’s service providers in connection with the services they perform for Netspend;
• If Netspend believes in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
• In connection with a change in ownership or control of all or a part of Netspend’s business (such as a merger, acquisition, or bankruptcy);
• Between and among Netspend and Netspend’s future affiliates (such as subsidiaries or other companies under common control or ownership); or
• With your consent (by any reasonable method, including when you orally give your consent), unless you timely revoke your consent.

Netspend may collect, use, process, or disclose Your information in an aggregated or anonymized manner (i.e., in a manner that does not identify you personally) for any purpose permitted under applicable law.

Netspend reserves the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Contacting Netspend

If you have any questions about Netspend’s EWA Privacy Notice, please reach us by email at EWAsupport@netspend.com.