Privacy Policy | Earnin

PRIVACY POLICY

(Last Updated 2021-09-22)

At Activehours, Inc. d/b/a Earnin ("Earnin"), we are building a financial system that works for people and is based on our goal to be fair and transparent. The purpose of this Privacy Policy is for you to understand how we collect and use your information, your privacy rights, and what information Earnin is required to keep. Please visit the California Consumer Privacy Act section of this Privacy Policy for more information about rights you may have under California law. You may also contact uswith any privacy related questions you may have.

This Privacy Policy does not apply to the practices of the third-party services or applications, including third parties with which we partner and may make information available to. These third-party services are governed by the third party's privacy policy.For more information, see the "Information from Third Parties" Section.

Summary of Information We Collect
Introduction
Collection of Personally Identifiable Information
   Information You Provide
   Information We Collect Automatically
   Information from Third Parties
   Service Specific Collection of Information:
     Advocacy
     Earnin Express
     Financial Calendar
     Max Boost
     Pay It Forward
     Tip Yourself
   Non-Personally Identifiable Information (Aggregated and Anonymized Data)
How We Use The Information We Collect
Information We Share
Do Not Track Signals
Security
Push Notifications, Email and SMS Communications
Collection of Information from Children
General Information
Specific Rights
   Federal Privacy Notice
   California Consumer Privacy Act
     How can I request my data from Earnin?
     How can I request that Earnin delete my data?
  Shine the Light
  Nevada State Bill 220

How Earnin uses Personal Identifiable Information

Collection and Sale of Data
Does Earnin sell you Personally Identifiable Information? No
Does Earnin sell aggregate information? No
Does Earnin share aggregate information? Yes
Does Earnin share your data with third party partners? Yes, with your consent
Does Earnin use your phone contact list if you allow us access? Yes, with your consent
Does Earnin delete your data when you request an account deletion See details
Does Earnin retain your data for as long as we need it unless you request deletion? See details
Tracking
Does Earnin need your device location for the service to work? Yes
Does Earnin track your device location while you are not using the app? Yes
Does Earnin use cookies? Yes
Does Earnin track your browsing activities on other sites? Yes, with your consent
Communication
Does Earnin give you notice when we make important changes to our Privacy Policy? Yes
Does Earnin send you marketing communications with the option to opt out? Yes
Does Earnin send you push notifications with the option to opt out? Yes

Introduction

At Earnin, we believe that visitors to the Earnin website and/or mobile application ("Visitors") and Earnin Community Members ("Community Members,") (herein, Visitors and Community Members are collectively referred to as "you" or "your") deserve clarity and transparency as to how Earnin uses Personally Identifiable Information.

Throughout this Privacy Policy, Earnin uses the term "Personally Identifiable Information" ("PII")to describe information that can be associated with you and/or identify you. Personally Identifiable Information does not include information that has been aggregated, de-identified or anonymized so it does not identify you.

If Earnin collects Personally Identifiable Information on behalf of Evolve Bank & Trust in connection with Tip Yourself and Earnin Express, it does so pursuant to Evolve Bank and Trust's Privacy Policy, and such Personally Identifiable Information is not subject to this Privacy Policy.

This Privacy Policy applies when you use or access the Earnin Site and Services, which comprise of:

  1. our website located at: https://www.earnin.com, and all of our other websites where this Privacy Policy is posted (collectively the "Website");
  2. our mobile application (herein "Application" or "App"); (the Website and App are collectively referred to as ("Earnin Site " ) and
  3. any services, content, and/or features made available by us through the Website or App ("Services").

Please also read our Terms of Service which sets out the terms governing the Earnin Site and Services. Capitalized terms not defined in the Privacy Policy will be defined in the Terms of Service.

1. Collection of Personally Identifiable Information

Earnin collects Personally Identifiable Information when you use the Earnin Site and Services. This Personally Identifiable Information helps us deliver and improve the Earnin Site and Services. We receive information in a few different ways:

A. information you provide;
B. information Earnin collects automatically;
C. information Earnin collect from third parties; and
D. information collected when you use specific Earnin services.

A. Information You Provide

In general, you can visit the Website and download the App without telling us who you are or sharing any Personally Identifiable Information with Earnin. In some circumstances, we may work with third parties to provide services on our Website. These Third Parties may place their own cookies to collect information about your activities on our Website and/or the advertisements you have clicked on.

When you register for an account and become a Community Member (a registered user of Earnin), use the Services and/or communicate with Earnin, we may ask you to provide certain Personally Identifiable Information to us, to identify you, such as:

  • first and last name (including legal names);
  • e-mail address;
  • home address;
  • work address;
  • date of birth;
  • employer;
  • whether you are employed, unemployed, or furloughed;
  • Social Security Number or Individual Taxpayer Identification Number;
  • Government Identification Number;
  • Driver's License information or other state identification;
  • A copy of a utility bill, bank statement, affidavit, or other bill, dated within three months of our request;
  • a phone number, a text-enabled cellular or wireless telephone number; and/or
  • a password and/or pin.

In order to use the Services, Community Members may be required to provide us with Bank Account information. You may also be required to provide our Third Party Partners with certain login access credentials (e.g., username and password) or other account or financial information. This information allows the third parties we work with to gain online access to the accounts you maintain with a third party financial institution ("Bank Account") and that you choose to designate for use in connection with Earnin Services. You may only provide third party account access credentials and authorize our vendors to access valid accounts that you hold in your own name. You may not provide us credentials or access accounts that are held by anyone other than you.

When you provide your Bank Account login credentials to our third party vendors, you authorize Earnin to use the information the third party vendors provide to enhance your use of the Earnin Services. More information about how we use this third party information can be found in the "Information from Third Parties" Section. Theauthorization will remain in effect until you update this information in the App. Removing your Bank Account may affect your ability to receive the Earnin Services.

Your Earnin account information and some of the additional information you provide can be reviewed and changed by logging into the Earnin App. However, you must contact us directly in order to correct certain information, such as your email address.

In accordance with our routine record keeping we may delete records that contain Personally Identifiable Information you have submitted through the Earnin Site and Services. Unless otherwise required by applicable law, Earnin is under no obligation to store such Personally Identifiable Information indefinitely and disclaims any liability arising out of, or related to, the destruction of such Personally Identifiable Information.

If you choose, you may add your contacts' information into the App by connecting your

contacts from your mobile device to the App. If you choose to share your contacts with Earnin, Earnin will, in accordance with your instructions, access and store your contacts' information in order to identify connections and help you connect with them.

Earnin may ask you to complete questionnaires or participate in user research regarding the Earnin Site and Services, labor and employment issues in your state and generally,other topics to improve the Earnin Site and Services and to help create a more fair financial system.

B. Information We Collect Automatically

Earnin may automatically collect the information in this Section about your use of the Earnin Site and Service. This information may be collected through cookies, web beacons, log files and other technologies. This information is used to improve the delivery of the Earnin Site and Services and tailor communications to you.

  1. Usage Information : Generally, Earnin collects usage information when you use the Earnin Site and Service such as how many times you visit our Website or App and how often you use the Earnin Services. This type of aggregate data enables us, and if applicable, third parties authorized by us, to determine how often parts of the Services are used so that we can analyze and improve those Services. Earnin also collects information that identifies incomplete Service registration. Earnin may also use recency and frequency scores to create advertising and outreach tailored to you.
  2. Location: Earnin collects and processes location information when you sign up for and use the Services. For example, we track your device location to understand when you go to work and leave work in order to calculate your earnings for Cash Out, to provide you with and allow you to share information about events you may be interested in and provide specific products and communications relevant to your location. This may result in Earnin using your location when you do not have the App open. You can stop sharing your device location at any time by adjusting your device settings. However, if you do not agree to our collection of location Information, our Services (e.g., Cash Out) may not properly function when you try to use them. Earnin will also use SCF (the first three digits of your postal code) to send you personalized communications, and provide information for the Earnin Services (e.g., Advocacy Programs).
  3. Device Identifiers: When you use the mobile version of our Website and our App, we may collect unique device identifiers assigned to that device, such as device type, machine or mobile device identification number, by phone makers, carriers, and/or makers of the operating system ("Device ID"). We may also collect time zones, language settings, and mobile network information. Device ID information allows Earnin developers to uniquely identify your device for the purpose of storing application preferences and other data.
  4. Technical and Navigational Information: Earnin may collect your computer or mobile browser type, Internet Protocol address, pages visited, average time spent on the App and/or Website and standard web log information, such as your browser type traffic. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality. 5. Cookies : Earnin uses cookies to enable our servers to recognize your web browser and explain to us how and when you use the Website. Cookies are small data files stored on your computer or device when you access a website. Your browser stores cookies in a manner associated with each website you visit. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. It may be possible to disable some cookies through your device or browser settings. Please note, however, that certain features of our Website may not be available if cookies are disabled.
  5. Software Development Kits (SDKs). SDKs allow Earnin to transfer or collect information through a server request. Earnin uses SDKs on the App to help provide the Services. For example, we use SDKs for the following purposes: client/server communication, analytics, push notifications, logging, customer support, targeted advertising, application stability tracking or advanced user interface widgets.
  6. Web Beacons: Earnin may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or Messages. We may use web beacons to deliver cookies, count visits, understand usage, and determine whether an email has been opened and acted upon.

C. Information from Third Parties

We may receive information about you from third parties, such as your financial institutions, identity verification service providers, and payment processors. We may also receive information about you from records held by third parties, such as marketing-related or demographic information. We use third party information to supplement the information we collect about you through the Services in order to enhance our ability to serve you, to tailor our features to you, and/or to offer you opportunities to use new Services or features that we believe may be of interest to you. If Earnin collects Personally Identifiable Information on behalf of Evolve Bank & Trust in connection with Tip Yourself and Earnin Express it does so pursuant to Evolve Bank and Trust's PrivacyPolicy. Excluding Personally Identifiable Information described in the preceding sentence, to the extent other third party information, is combined with the data Earnin collects through the Services, will be subject to this Privacy Policy.

  1. Capital One ("Capital One"). If applicable, Earnin may use Capital One to gather your account transaction data from Capital One. By using our Services, you authorize Earnin and Capital One to access and transmit your personal and financial information from Capital One. You agree to your personal and financial information being transferred, stored, and processed by Capital One in accordance with itsTerms and Conditions and Privacy Policy. The account login credentials of your Bank Account (e.g., usernames and passwords) are not stored at or accessible to anyone at Earnin.
  2. Evolve Bank & Trust. Earnin has partnered with Evolve Bank & Trust to provide consumers with certain deposit and financial services. Earnin collects your Account Number and other Personally Identifiable Information from and on behalf of Evolve Bank & Trust. All data collected or provided to Earnin by or on behalf of Evolve Bank & Trust in connection with Tip Yourself or Earnin Express is governed by Evolve Bank & Trust'sPrivacy Policy.
  3. Fincity ("Fincity"). If applicable, Earnin may use Fincity to gather your account transaction data from financial institutions. By using our Services, you authorize Earnin and Fincity 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 Fincity in accordance with its Terms and Conditions and Privacy Policy. The account login credentials of your Bank Account (e.g., usernames and passwords) are not stored at or accessible to anyone at Earnin.
  4. Plaid Inc. ("Plaid"). If applicable, Earnin may use Plaid to gather your account transaction data from financial institutions. By using our Services, you authorize Earnin and Plaid 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 its Privacy Policy. The account login credentials of your Bank Account (e.g., usernames and passwords) are not stored at or accessible to anyone at Earnin.
  5. MX Technologies ("MX"). If applicable, Earnin may use MX to gather your account transaction data from financial services. By using our Services, you authorize Earnin and MX 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 MX in accordance with the Terms and Conditions and Privacy Policy. The account login credentials of your Bank Account (e.g., usernames and passwords) are not stored at or accessible to anyone at Earnin.
  6. Wells Fargo Bank, NA ("Wells Fargo"). If applicable, Earnin may use Wells Fargo to gather your account transaction data from Wells Fargo. By using our Services, you authorize Earnin and if applicable Wells Fargo to access and transmit your personal and financial information from Wells Fargo. You agree to your personal and financial information being transferred, stored, and processed by Wells Fargo in accordance with its Terms and Conditionsand Privacy Policy. The account login credentials of your Bank Account (e.g., usernames and passwords) are not stored at or accessible to anyone at Earnin.

D. Service Specific Collection of Information:

When you use certain Earnin Services, we need to collect additional information from you and third parties. The collection of this Personally Identifiable Information helps us deliver these additional services to you.

1. Advocacy Program

If you participate in Earnin's advocacy and engagement efforts, Earnin will share your information with, FiscalNote and/or other similar platforms (collectively the "Advocacy Program"). Please visit FiscalNote's Privacy Policy to learn more about how your information is shared. FiscalNote and/or other similar programs, collects the following information from you and shares it with Earnin:

  • First and last name;
  • Email address;
  • Residential address;
  • Phone number;
  • City; and
  • Zip Code

This information is used to help determine your local, state and federal representatives and direct your emails and calls to the appropriate representative or third party.

Earnin will also communicate with you outside FiscalNote using email, SMS, text messages or push notifications (collectively "Messages") about Earnin's advocacy efforts, to request your input or participation in advocacy or other engagements on behalf of Earnin.

Earnin may use this information to let you know about certain products, features, campaigns, or advocacy efforts we think you may be interested in. You can opt out from future notifications by clicking on the unsubscribe link in emails from FiscalNote or Earnin, and/or via opt out language from any texts received.

2. Earnin Express

For Earnin Express ("Earnin Express Service"), we may use the Personally Identifiable Information you provide to Earnin for additional purposes such as:

● to provide and deliver the Earnin Express Services you request, process transactions, and send you related information, including confirmations and/or verifications;

● create a record of the account transaction data and thereafter maintain and use data in connection with the operation of the Earnin Express Service; and

● detect, prevent and investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Earnin Express Service.Your use of certain features of the Earnin Express Services requires Earnin to collect account numbers, balances, and other information about your bank accounts unrelated to your relationship with Earnin. Earnin may collect this information through a payment processor that facilitates a transfer to a Earnin partner bank account, a partner bank or through a third-party secure access tool.

The deposit account is provided by Evolve Bank & Trust and is subject to a deposit agreement between you and Evolve Bank & Trust, an Arkansas-chartered depository institution. By using the Earnin Express Service, you authorize Earnin and Evolve Bank & Trust to access and transmit your personal and financial information from your Evolve Bank & Trust account to Earnin in accordance with Evolve Bank & Trust's Privacy Policy. All such information is governed by Evolve Bank & Trust'sPrivacy Policy.

If Earnin collects Personally Identifiable Information on behalf of Evolve Bank & Trust in connection with Tip and Earnin Express it does so pursuant to Evolve Bank & Trust'sPrivacy Policy.

4. Financial Calendar.

When you use Financial Calendar, Earnin will use third party informationto populate the Financial Calendar. Earnin may also use aggregated and anonymized data to allow you to compare how expenses track against other similar providers and/or Community Members.

5. Max Boost

When you use the Max Boost Feature, either as a Requestor or Grantor, Earnin will share some of the following Personally Identifiable Information with the Requestor or Grantor:

  • First Name and Last Initial of the Community Members asking for and granting a Max Boost
  • Date of Request and Grant.

When using Max Boost, Earnin will collect and share messages and community participation such as:

  • "Likes" or interactions with the request notification using emojis;
  • The number of Community Members you have provided Max Boosts to;
  • The number of Community Members you have received Max Boosts from;
  • The number of new Community Members you have created via referrals (i.e invitation program and the Max Boost referral link);
  • Time till you have another Max Boost to use;
  • The number of Max Boosts you have left to give; and
  • How to share a Max Boost request.

7. Pay It Forward

When you Pay It Forward, Earnin may use the Personally Identifiable Information we collect for other purposes such as:

  • Sharing your First Name and Last Initial, as well photo or avatar with Community Members in the Pay it Forward chain, and
  • Allow Pay it Forward chain members to exchange Thank You messages with you via push notification and/or email if you have opted-in to messaging from Earnin.

8. Tip Yourself

For Tip Yourself ( " Tip Yourself Service"), we may use the Personally Identifiable Information Earnin collects for additional purposes such as:

● to provide and deliver the Tip Yourself Services you request, process transactions, and send you related information, including confirmations and/or verifications;

● verify your identity and prevent fraud;

● create a record of the transaction data and thereafter maintain and use data in connection with the operation of the Tip Yourself Service; and

● detect, prevent and investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Tip Yourself Service.

Some Personally Identifiable Information is public information (including your first name and the first initial of your last name, profile photo, and public tip reasons you decide to share), and may be seen by anyone accessing the Tip Yourself Service on the App, by any Tip Yourself logged in user.

Evolve Bank & Trust. The deposit account is provided by Evolve Bank & Trust and is subject to a deposit agreement between you and Evolve Bank & Trust, an Arkansas-chartered depository institution. By using Tip Yourself Services, you authorize Earnin and Evolve Bank & Trust to access and transmit your personal and financial information from your Evolve Bank & Trust account to Earnin in accordance with Evolve Bank & Trust's privacy policy. All such information is governed by Evolve Bank & Trust's Privacy Policy.

If Earnin collects Personally Identifiable Information on behalf of Evolve Bank & Trust in connection with Tip Yourself it does so pursuant to Evolve Bank & Trust'sPrivacy Policy.

E. Non-Personally Identifiable Information (Aggregated and Anonymized Data)

Earnin may aggregate and modify Personally Identifiable Information in a manner that does not personally identify you or any other individual and therefore is no longer Personally Identifiable Information. For example, we may use this non-Personally Identifiable Information to generate aggregate user statistics, create infographics and other data graphs, to train artificial intelligence models, for demographic information, or for usage information.

2. HOW WE USE INFORMATION WE COLLECT

Earnin uses Personal Identifiable Information we collect to: provide the Services, help us verify your identity, set up your account, and provide you with customer service. We also use some of this Personal Identifiable Information to improve the Earnin Site and Services, provide you with information on events you may be interested in, provide specific communications and Earnin Services relevant to your location, advertisements and to develop new services and let you know they are available.

Earnin may use your Personally Identifiable Information to facilitate transactions and activities that need to occur for the Services to take place, such as:

  1. To establish and verify your identity;
  2. To establish the existence and condition of your Bank Account;
  3. To assist with a transaction;
  4. To establish you are over the age of 18 and a resident of the United States;
  5. To determine your eligibility to use the Services;
  6. To enable our third party financial services partners to implement fund transfers;
  7. To connect with you if there is a problem related to a transaction you requested or to discuss a problem with your Earnin account; and
  8. To provide you with customer service,

Generally, we may use the Personal Identifiable Information we collect from you or that you provide to us:

  1. To maintain, protect, improve and provide our Services, including for the development of new Services;
  2. To notify you about changes to the Earnin Site and Services;
  3. To keep records of your communications with our Customer Support team;
  4. To enforce and apply our Terms of Service, ACH agreement and any other agreements between you and Earnin;
  5. To share information with you about events you may be interested in;
  6. To offer Earnin Services relevant to your location;
  7. For Earnin's marketing purposes, such as to offer our products and services to you, such as advertisements, by us, through third parties;
  8. To offer you tailored content by giving you more relevant search results and ads;
  9. To conduct and report on certain analytics, benchmarking, and performance tracking through the use of anonymous, aggregated information comprised of the categories above; and/or
  10. To comply with any court order, law, or legal process, including retaining personal data or responding to any government or regulatory request.

3. INFORMATION WE SHARE

We do not sell your Personally Identifiable Information. To ensure that the Earnin Site and Services work, we may need to share your Personally Identifiable Information with third parties and service providers, as well as other users. This section explains how Earnin shares your information.

A. Partners and Service Providers

Some of the Services offered by Earnin may be provided by third-party service providers. We also outsource some of Earnin's functions to third-party service providers, such as data storage providers, platform administrators, customer service and/or other services. Earnin may share information about or from you with these third-party service providers so that they can perform the requested services or complete your requests. We may also use and share aggregated and other anonymous data with partners, service providers and third parties to help improve how Earnin delivers the Services.

Earnin may use your Personally Identifiable Information to verify your identity, comply with and support our bank partners' compliance with applicable laws, including Anti-Money Laundering (AML) and sanctions screening rules, prevent, detect and investigate fraud, hacking, infringement or other suspected or actual misconduct, crime, or violation of an agreement involving the Services.

In order to accomplish these business purposes described above, Earnin may disclose financial and/or Personally Identifiable Information to the following categories of third-party service providers: our bank partners, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and app usage trackers , data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personally Identifiable Information which we disclose or otherwise entrust to them.

In some cases, we share aggregated and anonymized data with our employer partners. Examples of such information that may be shared include: the number of registered users who work with the employer, the number of weekly Cash Outs, total number of Cash Outs, average total amounts Cashed Out.

B. Sharing Between Earnin Community Members and Referrals to New Community Members

Some of your Personally Identifiable Information (including your Earnin profile photo, Earnin profile first and last name) will be publicly displayed through the Services and may be seen by anyone with an Earnin account. This sharing enables portions of the Services that allows users to connect and communicate. For example, this Personally Identifiable Information may be disclosed to enable you to select the contacts with whom you would like to send a Max Boost, show your information about Community Members in a Pay It Forward chain, to connect with another user who referred you to the Services, or to connect with an individual whom you would like to refer to the Services.

Referral Programs.We may, from time to time, run referral programs.If you refer someone to Earnin through an applicable Referral Program, we will let them know that you generated the referral. If another Community Member referred you, Earnin may share information about your use of Earnin with that Community Member. For example, you may be notified after your friends are verified and cash out for the first time that either you or Earnin covered their tip. Or when you send an non-Community Member a Max Boost request, you will be notified if they install and they will have the option to send you a one-time max boost.

C. Links

The Earnin Site may contain links to third-parties we have partnered with, except as described in this Privacy Policy, we do not share your Personally Identifiable Information with them and are not responsible for their privacy practices.

D. Law Enforcement

Earnin will share information with law enforcement, government officials, or other third parties if Earnin is compelled to do so by subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of Personally Identifiable Information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Terms of Service or as otherwise required by law.

4. DO NOT TRACK

Certain internet browsers have incorporated "Do Not Track" features. Most of these features, when turned on, send a signal or preference ("DNT Signal") to the websites you visit indicating that you do not wish to be tracked. Earnin does not currently respond to DNT Signals.

Earnin may engage in behavioral advertising on third-party sites (e.g., retargeting, tracking), through information collected about the pages you visit the Website. For example, Earnin may use this information to display ads on Services on third-party websites.

5. SECURITY

We store and process your Personally Identifiable Information using data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to Personally Identifiable Information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that Personally Identifiable Information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Earnin credentials with anyone.

If Earnin learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that Earnin may communicate with you electronically. Earnin may post a notice on the Earnin Site if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at [email protected].

6. PUSH NOTIFICATIONS, EMAIL AND SMS COMMUNICATIONS

Earnin may communicate with You about summaries of your Account Information, User Research, products and Earnin Services, Earnin's Advocacy Program, to request your input or participation in the Advocacy Program or other engagements on behalf of Earnin, using email, SMS, text messages or push notifications (collectively "Messages"). If we communicate with you via Messages, we may collect information regarding the Messages (e.g., email opening confirmations, read text message data or received push notification data). We may also allow users to subscribe to Messages and from time to time may transmit Messages promoting Earnin and advocacy efforts with third parties or third-party goods or services. We may also send you Messages (e.g., SMS, text messages, push notifications, announcements, newsletters, promotional materials) about the Services, Earnin, or third-party products and services that we think might be of interest to you.

Opt Out

If at any time you do not wish to receive the Messages, you have the ability to opt out of receiving our promotional emails and to terminate newsletter subscriptions by following the instructions in the emails and turn off notifications using the functionality made available in the browser, application or device settings. Opting out in this manner will not end transmission of Services related Messages. To stop receiving marketing-related messages please refer to the TOS: (link to TOS).

7. COLLECTION OF INFORMATION FROM CHILDREN

We do not intend to collect information from children under 13 years of age. If we learn that we have collected such information from a child under the age of 13, we will promptly take all reasonable steps to delete the data from our systems. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

8. GENERAL INFORMATION

Earnin is headquartered in Palo Alto, California and our Services are provided to you by Activehours, Inc. Questions or comments about this information may be submitted by mail to the address below or you can contact us.

ActiveHours, Inc. d/b/a Earnin

200 Portage Ave.

Palo Alto, CA 94306

This policy was written in English, to the extent a translated version conflicts with the English version, the English version controls. This Privacy Policy does not apply to third party products or services and/or companies Earnin does not own or control.

Changes to This Information

We reserve the right to modify this information at any time. Please review it occasionally. If Earnin makes changes to this information, the updated information will be posted on the Earnin Site.

9. SPECIFIC RIGHTS

A. Federal Privacy Notice:

FACTS WHAT DOES ACTIVEHOURS, INC. d/b/a EARNIN 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:
· Account information and balances
· Employment and Income information
· Transaction information and history
· Government ID numbers, such as Social Security numbers
How? All financial companies need to share their members' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers' and customers' personal information; the reasons ActiveHours, Inc. d/b/a Earnin ("Earnin") chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does Earnin share? Can you limit this sharing?
For our everyday business purpose – such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations Yes No
For our marketing purposes– to offer our products and services to you Yes No
For joint marketing with other financial companies No No
For our affiliates' everyday business purposes- information about your transactions and experiences Yes No
For our affiliates to market to you No We don't share
For nonaffiliates to market to you No We don't share
Questions?
Email us at [email protected] or visit Earnin.com
Who we are
Who is providing this notice? Earnin is providing this privacy notice and is applicable to all products and services offered to all Community Members.
What we do
How does Earnin protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with industry standards. These measures include computer safeguards and secured files and buildings.
How does Earnin collect my personal information? We collect your personal information, for example, when you:
·Open an Earnin account or provide account information,
·Give us your contact information
·When you use the Earnin Services
We also collect your personal information from others, such as affiliates and other companies.
Why can't I limit all sharing? Federal law gives you the right to limit:
· Affiliates from using your information to market to you
· Sharing for nonaffiliates to market to you
· Sharing for joint marketing with other financial companies
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.
· Earnin ActiveHours 1, LLC
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
·Nonaffiliates we share with can include financial institutions, identity verification service providers, financial services companies, banks, and payment processors.
Joint Marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
· We do not currently engage in Joint Marketing;
· In the future, our joint marketing partners can include companies such as financial services companies and other financial institutions.
Other important information
FORVERMONT RESIDENTS: In accordance with Vermont law, we will not share information we collect about you with nonaffiliated third parties, except as permitted, such as to process your transactions or to maintain your account.
FOR CALIFORNIA RESIDENTS: We will not share information we collect about you with nonaffiliated third parties, except as permitted by California law, such as to process your transactions or to maintain your account. We will limit sharing among our companies to the extent required by California law.
FOR NEVADA RESIDENTS:. Nevada law requires that we provide you with the following contact information. Nevada Attorney General, 555 E. 55 E. Washington Street, Suite 3900, Las Vegas, NV 89101, phone number (702) 486-3132, email [email protected]
State laws may also provide you with specific privacy protections. We will comply with applicable state laws with respect to our use of your information.

B. California Consumer Privacy Act:

With respect to the Services, the rights under the California Consumer Privacy Act ("CCPA") will be available to all Earnin Community Members for Personally Identifiable Information not otherwise excluded by the terms of CCPA or any associated regulations or guidance. The CCPA provides the right to request that we disclose the specific pieces of information we have collected about you, which Earnin will do after we receive and validate your request.

Earnin does not sell your Personally Identifiable Information. However, Earnin may use a Third Party to collect Personally Identifiable Information and or/ may disclose certain Personally Identifiable Information for a business purpose, as set forth above (i.e., Sections 1)(C) Information from Third Parties and Section 3 Information We Share).

When you make a request for your Personally Identifiable Information, we will include a list of the categories of Personally Identifiable Information that we may have disclosed about you, as well as the categories of third parties to whom your Personally Identifiable Information may have been disclosed.

Earnin does not deny Services, provide different quality of Services, offer its products at a different price, limit your eligibility for products, or otherwise discriminate against you because you exercise any rights conferred by the CCPA.

How can I request my data from Earnin?

Community Members may find the form to request their information from Earnin here, per CCPA requirements. Note that this is open to all Community Members.

How can I request that Earnin delete my data?

Community Members may submit a request to delete their information through our Privacy Manager. Earnin may still retain the data in aggregated or anonymized form in compliance with CCPA. All Community Members may submit a deletion request regardless of state of residence.

What information will Earnin ask for when I make a request?

Earnin must verify your identity before we will fulfill your request. As part of this process, Earnin may ask you to provide Personally Identifiable Information you previously provided to Earnin. You will also be asked to verify your email address.

How long does this take?

For California residents, Earnin will respond to your information or deletion request within 45 days, though we may request an additional 45 days if needed. For non-California residents, we will respond to your request as soon as we are able to. Note that we will only process one request per individual at time.

Can I have an agent make a request on my behalf?

You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must:

  • Provide the authorized agent signed permission to do so;
  • You must directly verify your identity with Earnin; and
  • You must confirm with Earnin you've provided the authorized agent permission to submit the request.

C. Shine the Light

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits those of you who are California residents to request and obtain from us once a year, free of charge, information about the Personally Identifiable Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share your Personal Identifying Information with third parties for the third parties' own and independent direct marketing purposes unless we receive your permission.

If you are a California resident and would like to make such a request, please submit your request to [email protected] In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information covered will be included in our response.

D. Nevada State Bill 220

We do not sell your covered information, as defined by Section 1.6 of Chapter 603A of the Nevada Revised Statutes. If you reside in Nevada, you have the right to submit a request to our designated request address [email protected] regarding the sale of covered information.

This Policy was last updated on September 22, 2021

1Earnin does not charge hidden fees for use of its services. Restrictions and/or third party fees may apply. For more info visit earnin.com/TOS.

2Disclaimer: Balance Shield cash out is subject to your available earnings and daily pay period max. Other restrictions and/or third party fees may apply. For more information visit Earnin.com/TOS.

3Source: Internal analysis conducted by Earnin on December 10, 2020.

1Restrictions on use of Services and/or third party fees may apply, see earnin.com/privacyandterms for details.

2Balance Shield cash out is subject to your available earnings and daily pay period max. Other restrictions and/or third party fees may apply. For more information visit earnin.com/privacyandterms.

3Tip Yourself Account funds are held with Evolve Bank & Trust, Member FDIC and FDIC insured up to $250,000. Tip Yourself is a 0% APY and $0 monthly fee service. Other restrictions and/or third party fees may apply, see earnin.com/privacyandterms for details.

1Fees may apply to use Lightning Speed. Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection. Restrictions and/or third party fees may apply, see  Earnin.com/TOS for details.

2Restrictions and/or third party fees may apply, see Earnin.com/TOS for details.

3Balance Shield cash out is subject to your available earnings and your daily pay period max. Other restrictions and/or third party fees may apply, see Earnin.com/TOS for details.

4Tip Yourself Account funds are held with Evolve Bank & Trust, Member FDIC and are insured by the FDIC up to the standard maximum deposit insurance amount per depositor, per FDIC-insured bank, and per ownership category. Tip Yourself is a 0% Annual Percentage Yield and $0 monthly fee service. Other restrictions and/or third party fees may apply. For more information/details visit earnin.com/tos.

5Up to two days early is based on comparison with traditional banks. Exact timing is dependent on your employer’s payroll policies. For more information on eligibility and requirements of Earnin Express, visit Earnin.com/TOS.

6Your Max on Earnin Express is up to 80% of your payroll or $1000, whichever is less. The 80% is dependent on you routing your full paycheck to Earnin Express. For more information on eligibility and requirements of Earnin Express, visit Earnin.com/TOS.

7Learn how we collect and use your information by visiting our Privacy Policy.

1Disclaimer: Restrictions and/or third party fees may apply, see earnin.com/privacyandterms for more details. Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection.

2Disclaimer: Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection. Restrictions and/or third party fees may apply, see earnin.com/privacyandterms for details

3Disclaimer: Community Member must have had at least 1 successful debit with Earnin. Limit to 1 Max Boost per pay period. A boost will not adjust a Community member's daily max. Restrictions may apply, see earnin.com/privacyandterms for more details

*Disclaimer: Balance Shield Cash Out is subject to your available earnings and daily pay period max.Other restrictions and/or thirdparty fees may apply. For more information visit earnin.com/privacyandterms

1Restrictions may apply, see earnin.com/privacyandterms for more details. Tip Yourself Account funds are held with Evolve Bank & Trust, member FDIC and FDIC insured up to $250,000. Tip Yourself is a 0% Annual Percentage Yield and $0 monthly fee service. Your Tip Yourself Account and any Tip Jars are not Savings Accounts. For more information/details visit earnin.com/privacyandterms

2Disclaimer: NO PURCHASE NECESSARY TO ENTER OR WIN. Must be 18 years of age or older and a legal resident of the U.S. or DC. Games begin each Sunday starting 12/6/20 at 9:01 p.m. ET and end the following Monday at 9:00 p.m. ET with the last Game ending 12/19/21. To download the App, view the Official Rules, odds disclosures, prize details, and alternate means of entry, visit https://www.Earnin.com/wewin/game-rules/. Void where prohibited. $10,000,000 grand prize payable over 29 years. Sponsor: Activehours, Inc. (d/b/a Earnin), 200 Portage Ave, Palo Alto, CA 94306.

3Disclaimer: Restrictions Apply. See Earnin.com/wewin/pool-rules/ for more information

*Survey conducted in February 2020 with 889 participants.

7Learn how we collect and use your information by visiting our Privacy Policy.

1. Earnin does not charge hidden fees for use of its services. Restrictions and/or third party fees may apply. For more info visit earnin.com/TOS.

1. Disclaimer: Earnin does not charge hidden fees for use of its services. Restrictions and/or third party fees may apply. For more info visit earnin.com/privacyandterms.
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