Last Modified: May 30th, 2019 Pinch Money, LLC. Privacy Policy 1. GENERAL This Online Privacy Policy describes the types of information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, the steps that we take to safeguard the information and to protect your privacy; and other important privacy terms (as updated from time-to-time, this "Online Privacy Policy") that apply when you visit the Pinch Money website (www.pinchmoney.com), and any associated or successor websites, products, services or mobile applications (collectively, the "Site"). By using the Site, you are accepting the terms of this Online Privacy Policy and you are consenting to our collection, use, disclosure and protection of your information as described in this Online Privacy Policy. As used throughout this Online Privacy Policy, the terms (1) "Pinch Money," "we," "us" or "our" means Pinch Money, Inc. and its affiliates, successors, agents; (2) "you" or "your" means any user of the Site; and (3) "includes" or "including" means "including but not limited to" or "includes but is not limited to. We may include links to websites or applications, or make available products or services, that are owned, provided, offered and/or issued by third parties (collectively, "Third-Party Product Providers") available on or through the Site. These Third-Party Product Providers operate independently from us. The personal information processed by such Third-Party Product Providers is not subject to this Online Privacy Policy or any of our privacy policies. Information collected by such Third-Party Product Providers, including the information you request, direct or consent for us to send to such Third-Party Product Providers on your behalf, will be governed by their privacy policies. The inclusion of a link, button, or similar functionality within the Site or the Site's framing of a third party's website does not imply our endorsement of the third party. In addition, we are not responsible for and have no liability for the content, features, products, services, privacy policies or terms of service of any other third party, social media platform, operating system or wireless service provider; or device manufacturer. We may change this Online Privacy Policy occasionally. If we make changes to this statement, we will update the "Last Modified" date at the top of this page. If we make changes to this statement that we consider to be material, we will notify you in accordance with Section 4 of the Site Terms of Use. Any changes to this Online Privacy Policy will become effective when posted unless indicated otherwise. Your continued use of the Site following the posting of any changes will mean that you accept those changes. 2. SOURCES OF INFORMATION The personal information we collect about you comes primarily from the information that you provide to us during the course of your relationship with us. We may also collect information about your experiences with us relating to your use of the Site. Information may also be collected about you indirectly through monitoring or other means (for example, monitoring emails we send you and information collected through your use of the Site). By communicating with us, you acknowledge that your communication may be monitored or recorded without further notice or warning. Information That You Provide When you use the Site, or otherwise interact with us, the typical information we may collect about you may include: • Your first name, email and other contact details and similar information; • Account login credentials; • Transaction data and related information from accounts that you link to via the Site; • Financial information (for example, information about your income and your full bank account or payment card numbers); For Pinch Money to scan your credit card and/or debit card and/or checking and/or savings statements, you will need to provide us with your third party account credentials. This information includes the credentials asked by your financial institution, your financial institutions' name and your credit and/or debit card names. We keep your Personal Information in strict confidentiality and we will only such use information to provide you with the requested Services. We may collect your financial Personal Information through the services of a third party that will assist us in providing you with our Services, in which case you acknowledge and agree to review and be bound by the terms of use and privacy policy of said third party service provider. We've engaged Plaid Corporation, a trusted, industry-standard third party provider to provide us financial account aggregation services. The account credentials of your credit/debit card online statements that you provide us during registration are passed on to Plaid Corporation and securely stored on their servers. For improved safety, we purposefully do not store any of your credit/debit/checking/savings card account credentials. • Information about subscriptions or other services you receive; • Other personal information that you disclose as part of any Site enrollment or in other communications with us. Of course, you are not required to supply any of the personal information that we request. However, your failure to do so may result in your being unable to interact with our Site. Automatically Collected Information In addition to the information that you provide to us, we collect certain information automatically through your use of the Site. For example, we may collect data regarding your use of the Site, such as computer and connection information, statistics on your page views, pathways to and from the Site, referral URL, ad data, IP address (which can be used to derive the location of your device), device identifiers, the type of operating system and browser you use, device settings, browsing history, transaction history, and your web log information and other information that may be aggregated and/or de-identified. This information may be collected directly by us (or by third parties on our behalf, such as Third-Party Service Providers as defined below) using cookies, pixels, tags or related technology. In addition, when you interact with other websites or our advertisements, this information may be collected and provided to us as well. This information may be used by us or the Third-Party Service Providers for the purposes described in this Online Privacy Policy or for other business purposes as permitted by law. For more information about how the Site uses cookies, web beacons, page tags, pixels and similar choices and your rights and choices, please see Cookies and Other Tracking Technologies below. Location Information We may receive information about your location and your mobile device, including a unique identifier for your device. In addition, in some instances, location information can be derived from your IP address or through your Wi-Fi connection. We may use your device's physical location to provide you with location-based services and content. Location information may be inaccurate or approximate and that may impact the accuracy of any location-based services and content. You can change whether you share specific geo-location information in your device settings; however, some features in the Site may not function properly without this information. 3. OUR USE OF YOUR INFORMATION We use your information to provide you with services on our Site and to help us personalize and continually improve the Site, including fulfilling requests for information, analyzing and compiling trends and statistics, and communicating with you. We may also use your information as follows: • Administer, operate and manage your relationship with us. This may include sharing such information internally as well as disclosing it to third parties, as described in this Online Privacy Policy and other privacy notices that we may provide to you in connection with the Site; • Contact you through various channels, including mail, text message, and Site messaging including push notifications, and email; • Provide you with customized information and reports, tailored content and marketing messages, including through push notifications and text messages; • Authenticate your identity, including during the Site sign-up process; • Support our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements; • Comply with contractual obligations, relevant industry standards and our policies; • Mitigate fraud, enhance the security of the Site and manage institutional risk; • Operate, evaluate and improve our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions); • Improve Site performance and personalize your experience with the Site; • Notify you about changes to the Site, and policies; • Perform analytics concerning your use of our Site, including your responses to our emails and the pages and advertisements you view; • To present you with third party products and services we think may be of interest to you; • Respond to your requests and otherwise fulfill any purpose for which you provide personal information to us; • To fulfill any request or direction you give us to share your information with a Third-Party Product Provider; • To allow you to send messages to a friend through the Site and facilitate social sharing functionality; • For any other purpose that we disclose at the time you provide, or when we collect, your information; and • Other purposes permitted by applicable law. You may stop the receipt of push notifications through your device settings. In addition to the list above, we may use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations. In order to provide an efficient and reliable Site experience and to improve product and service options available to you, we may share your personal information with our affiliates. For example, one affiliated entity might share your information with another in order to facilitate your requested actions, assist in the account set-up process, for the maintenance of your account or for other purposes permissible under applicable law. When we share your personal information in this way, we adhere to all applicable legal requirements. We also may use or combine information that we collect offline or that we receive from third-party sources, including 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 for many reasons, including to enhance, expand and check the accuracy of our records. Additionally, data collected from a particular browser, device or application may be used with another browser, device or application linked to you. If your relationship with us ends, we may continue to maintain, use, and share your information as necessary to comply with applicable law, in connection with any legal or regulatory proceeding, consistent with our internal record keeping policies and procedures, or for any other purpose permitted by this Online Privacy Policy or the privacy policy in effect when you gave us your personal information. 4. YOUR DISCLOSURES OF YOUR PERSONAL INFORMATION If you post your personal information on blogs and other services to which you are able to post information and content, please note that any information that you post or disclose through these services will become public and may be available to other users and the general public. We recommend you do not post personal information in this manner. If you share personal information with your friends associated with your social media account, to other users of the Site, or to your social media account provider, 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. 5. DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES We share your personal information with third parties as described below. In addition, we may share information that does not specifically and personally identify you, such as aggregated information, device identifiers or other unique identifiers to third parties. Third-Party Service Providers: We may share your personal information with non-affiliated companies that perform support services for the Site ("Third-Party Service Providers"). Third-Party Product Providers: We may also share your personal information with other third parties whose products or services you request within the Site (Third-Party Product Providers) upon your consent or at your direction or request. By requesting we provide a Third-Party Product Provider with your information, you understand they will treat your information in accordance with their privacy policies and terms of service, which may allow them to further share your information with additional third parties. Law Enforcement, Legal Process and Emergency Situations: Your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations. Examples include responding to a subpoena or similar legal process, protecting against fraud and cooperating with law enforcement or regulatory authorities. We may also disclose your information if we believe it is necessary or appropriate to protect our rights, property or safety or the rights, property or safety of our employees, customers or others, or to enforce our contractual rights. Sale, Assignment or Change of Control: In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities, some of the personal information that we hold may be among the assets or liabilities transferred to a buyer or other successor. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or liabilities or any line of business, change in ownership control or financing transaction. 6. COOKIES AND OTHER TRACKING TECHNOLOGIES Like many online services, we use tracking technologies such as cookies, web beacons and similar technologies. We may also use these technologies to record your preferences, track your use of the Site across multiple devices, measure exposure to our online advertisements, monitor traffic, improve the Site and make the Site easier to use. You have choices to limit some tracking mechanisms that collect information when you use the Site. Many web browsers automatically accept cookies, but you can usually modify your browser's setting to decline cookies if you prefer. If you choose to decline cookies, certain features of the Site may not function properly or may not remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that, if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences. For more information about your choices, see Interest-Based Advertising below. Cookies Cookies are small text files that may be placed on your device when you use the Site or when you view advertisements that we have placed on other websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. When you quit your browser, some cookies are stored in your computer's memory, while some expire or disappear. Tags, Pixels, Web Beacons, Clear GIFs A web beacon, also known as an Internet tag, pixel tag or clear GIF, is typically a one-pixel, transparent image located on a webpage or in an email. These may be used when you are served with advertisements, when you interact with advertisements outside of our online services or when you interact with our communications. They are generally used to transmit information back to a web server. Interest-Based 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 and online services, based on information relating to your access to and use of the Site and other apps and online services. To do so, these companies may place or recognize a unique identifier on your device. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device from which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/ and http://optout.networkadvertising.org/ . To opt out in the mobile application, go to www.aboutads.info/appchoices to download the App Choices app. If you choose to opt-out, a cookie will be placed on your browser or device indicating your decision. This cookie is specific to a particular device and browser, so if you use different browsers or devices, you will need to opt-out on each. In addition, because the opt-out is facilitated via cookies, if you clear your cookies you will need to opt-out again. Additional Technology We use Mixpanel, an event analytics service, on the Site. Mixpanel uses tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site's activity and provide other services related to Site activity and usage. The technologies used by Mixpanel may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. 7. INFORMATION SECURITY: HOW WE PROTECT YOUR PRIVACY We employ protections to keep data secure, but no data transmission or storage system can be guaranteed to be 100% secure. We seek to limit access to your personal information to authorized employees, agents, contractors or Third-Party Service Providers. We also maintain physical, electronic and procedural safeguards designed to protect your personal information against loss, misuse, damage or modification and unauthorized access or disclosure while in our possession. 8. OTHER IMPORTANT INFORMATION You must be an individual of at least eighteen (18) years of age and reside in the United States or on a United States military base, or in a United States Territory in order to use the Site. If you do use the Site outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing and storage of your personal information in, the United States and elsewhere. The laws in the United States and these countries regarding personal information may be different from the laws of your state or country. Except as provided in the next sentence, this Privacy Policy shall be governed by and construed in accordance with federal law and any applicable laws of the State of Utah without regard to rules concerning conflicts of law or choice of law. If you are a New York resident, this Privacy Policy shall be governed by and construed in accordance with federal law and the laws of the State of New York, without regard to rules concerning conflicts of law or choice of law. 9. DO NOT TRACK SIGNALS Your browser or device may include Do Not Track functionality. The Site is not built to respond to Do Not Track signals. That means that, even if your browser is set to "Do Not Track," our information collection and disclosure practices (including the choices that we provide to customers) will continue to operate as described in this Online Privacy Policy. © 2019 Pinch Money, LLC unless otherwise noted. All rights reserved.