Privacy

February 2024

Thank you for visiting Early Money (“Early”). Please read the Privacy Policy before using Early’s website. Early is the owner of this website, www.getearlymoney.com (the “Website”), and the hosting, content, and other functionality of this Website is supported by Early and other third parties that provide software and other services to Early.

This Privacy Policy describes the type of information we collect from you, what we do with the information we collect, how we protect your personal information we have collected, and how you may update and control the information you provide on our Website.

This Privacy Policy applies to Early, and this policy is incorporated into and a material term of the Early Website Terms of Service which establishes your consent and/or use of Early’s products and services (collectively, “Services”), including the Website.

This Privacy Policy applies to all prospective, current and former Early customers and all users of Early’s Website. By accessing or using Early ’s Website or Services, you consent to this Privacy Policy. If you have questions or complaints regarding our Privacy Policy or practices, please contact us at privacy@getearlymoney.com.

Information Early Collects About You

Information Early Collects From You Online

You can visit our Website without revealing any personal information, in which case our servers collect information about your internet browsing activity on our Website (as described under “Tracking Technologies”).

If you use our Website to manage an account that you have with a bank or other lender, your bank or lender may provide some of your personal and banking information to us. You may also be asked to provide other pieces of your personal and banking information. The personal information we collect from your bank or lender, or directly from you may include but is not limited to your:

• Name, address, and phone number
• Social Security number
• Date of Birth
• Employment information
• Salary and income
• Email address
• Bank account number, routing number, and name of your bank
• Login credentials (user ID and password) you plan to use to access our Website

If you provide us with additional personal information during the time that you have an account or loan that is serviced by Early, we may use this additional information in conjunction with any other information you have provided to:

• Service your account (provide statements, apply payments, resolve errors, etc.)
• Provide you with products or services that you have requested
• Notify you of other products or services that Early offers
• Improve our Services and develop additional services or products

Information Early collects from Third Parties About You

During the process of servicing your account, we may collect information from credit bureaus and other partners to determine your current financial situation and to evaluate risks associated with your account and to offer you additional products or services. The credit bureau information we collect includes information about your:

• Credit score
• Open and closed accounts
• Credit inquiries
• Late payments and collections activity
• Public records, including bankruptcy, judgments, tax liens, payment statuses

Information Early Collects Based on Your Activity on the Early Website

Early collects information about your transactions and activity, in addition to other internet browsing data. We collect information about your computer and your visits to the Website, including your IP address, geographical location, browser type, referral source, length of visit, button clicks and page views. If you have a loan that is serviced by Early, we will also collect information about your payment history.

Tracking Technologies

If you visit our Website without revealing any personal information, our servers still collect information about your internet browsing activity on our Website, and other information such as your IP address, browser type and platform, and information about the link that brought you to our Website. This information is collected anonymously and is used by us and our service providers to better understand a user’s experience on our Website and to improve our Website.

Cookies and Web Beacons. Cookies are data files stored by your internet browser on your computer’s hard drive. Early and some of our business partners and service providers use technologies such as cookies, beacons, tags, and scripts to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis. Cookies are also used to gather statistical data, such as which pages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to our Website.

If you have an account that can be managed on our Website, we use cookies when you sign in to your account to keep track of your personal session, help authenticate your account, and detect fraud. You can control the use of cookies within your web browser. However, if you reject cookies, your ability to use some features or areas of our websites may be limited or unavailable. Usage Data & Site Activity. Early also uses local storage to store your preferences and other information. Various browsers offer their own tools for managing content persisted in the browser’s local storage.

Third Party Technologies. We also partner with third parties to manage our advertising on other sites and evaluate our overall Website performance. Our third-party partners may use technologies such as cookies or other similar technologies to gather information about your activities on our Website and other sites in order to provide you advertising based upon your browsing activities and interests or help us track the success of our marketing efforts or overall Website performance. If you do not wish to have this information used to provide you with interest-based advertisements, you may opt-out by clicking here. Please note that this opt-out only applies to interest-based advertisements provided through certain networks and third-parties. You may continue to receive other generic advertisements.

Do-Not-Track Signals

We do not respond to “do not track” signals from your browser at this time. To learn more about how “do not track” works, please visit http://allaboutdnt.com/ .

How Early Uses Your Information

Servicing Your Account

If you manage your loan or account using the Early Website, we will use your information to help facilitate the servicing of your account. The information collected in connection with your loan or account may include:

• Generating your borrower profile
• Enabling automatic payments and fund transfers with other financial institutions
• Reviewing your payment history
• Implementing collection activities as needed
• Communicating with you concerning your account and transactions
• Addressing any disputes you may raise concerning your account.

Marketing Communications

Early may also use your personal information to select you for certain marketing offers. Early may use your personal information both to select you for an offer and to communicate that offer to you. If you do not wish to receive these communications, you may call us, or email us at privacy@getearlymoney.com, and we will remove you from future marketing communications.

Data Analysis & Business Optimization

Early also uses your information to conduct analyses related to our Services and our Website. We use this information to improve our Services in order to provide you with a simple and streamlined experience. We also use this information to improve our Websites’ usability and to evaluate the success of marketing campaigns and other activities.

Sharing Your Information

Early may use and disclose your personal information that is collected through our Website and Services to run our everyday business and in accordance with applicable law. We do not share, sell, rent or trade your personal information with any third party other than as described in this Privacy Policy including to our service providers to provide the Services to you or those which you request and with your bank or lender in connection with any loan or account. We may share your information with law enforcement, government officials, or other third parties as required by law and when we believe that such disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, regulatory request or other legal process. We may also aggregate information and statistics and use them in our business and provide them to third parties so long as they do not contain any personally identifiable information.

Protecting your Information

Our goal is to protect the personal information you submit to us through this Website, both in transmission and once received. We and our service providers have implemented technical and organizational measures designed to protect against loss or unauthorized access, disclosure, alteration or destruction of the information you provide on our Website. Despite these efforts, no security measures, however thorough, are perfect. Accordingly, we do not guarantee the security of the information you provide to us.

Data security is achieved through technical safeguards that include a combination of firewalls, intrusion detection system, malware detection system, and data loss prevention systems. Early also conducts vulnerability scans of applications and systems regularly. Access to the system is limited to only those who have a need to access information. Administrative safeguards such as a security awareness program, background checks, and our information security policy ensure that only trained and trusted staff are permitted to access personal information. Some additional features of our security program include:

Secure Data Center

Early uses an industry leading infrastructure service provider for its computing infrastructure needs. Early’s cloud infrastructure facility (provided through the service provider) is enabled with encryption and data protection capabilities for the systems and services we develop and/or deploy within. Early’s infrastructure provider is SOC 1, SOC 2, and SOC 3 compliant.

Physical access to the data center is strictly controlled and we use the latest threat prevention technologies such as network and web application firewalls, VPN, antivirus, intrusion detection systems, web filtering and antispam technologies.

Website Security Certificates

Early equips all customer-facing services with an Extended Validation (EV) Secure Socket Layer (SSL) certificate to ensure that when you connect to our websites you can tell that you are actually on our Website and that all data entered into the websites are transmitted to us in a secure encrypted channel. Once on our system, personal information can only be read or written through defined service access points, the use of which is password-protected.

Session Time-Outs

We employ session time-outs to protect your account. You will be logged out of the Website automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

Passwords

You should always choose a password that is difficult for others to guess and change your password frequently. At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question.

You should never share your password with anyone. Your password is not known to any Early employee or third party, and we will never ask for your password by phone or email. If you ever receive a communication claiming to be from Early that asks for your password, you should immediately report it by contacting us at privacy@getearlymoney.com.

Security Awareness Training

We conduct security awareness training for all staff at least annually, and provide additional training on Early privacy and security-related policies and procedures for personnel that have access to sensitive information. We instruct staff that access must be used only in adherence with the principles set forth in this Policy and applicable laws, and for no other purpose. Personnel who misuse customer information are subject to disciplinary action.

Additional Steps You Should Take to Ensure the Security of Your Information

Secure your Email Account and User ID. Early sends important communications regarding your account via email. You should therefore take steps to secure and restrict access to your email account and change your email account password frequently. If your email address changes, you should promptly update your contact information through the Website.

You should not include any personally identifying information in your Early User ID. We are not responsible for any personal information that you may choose to reveal in your User ID.

Beware of suspicious emails. You should be aware of fraudulent emails known as “phishing,” from companies claiming to be Early and requesting your login information or other account information. Early WILL NEVER ASK FOR YOUR LOGIN INFORMATION IN AN EMAIL.

Regularly Remove Cache Files. When you are finished using our Website, you should log out completely, then close the browser window and clear the browser’s cache files. This step is particularly important if you use a computer that is accessed by other people, such as in a public library or Internet café.

Create Strong Passwords. You should use passwords that are at least 10 characters long and contain letters, numbers, and symbols.

California Privacy Notice

The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide certain notices to California residents regarding the collection, use, and share of personal information. If you are a California resident, this section applies to you.

Categories of information we collect:

• Personal Identifiers
• Commercial Information
• Internet or other Network Activity Information
• Geolocation Data
• Professional or Employment-related Data
• Audio, Electronic, or Visual Information
• Protected Classification Information

Your Rights under the CCPA

If you are a California resident, you have the right to request that we disclose to you the personal information we collect, use, disclose, or sell. While Early does not sell any of your personal information, you have the right to opt-out of the sale of any of your personal information under the CCPA as well.

You may exercise your rights under the CCPA by sending an email request to Early at privacy@getearlymoney.com. If you have authorized someone else to make requests on your behalf, we will require that you provide notarized authorizations confirming the identity and authority of the appointed representative.

Children’s Privacy

We will not knowingly collect personal information from individuals who are under the age of 13. We request that such individuals do not provide any personal information through the Website or services. For more information about the Children’s Online Privacy Protection Act (“COPPA”), visit the FTC website at www.ftc.gov.

Additional Policy Disclosures

We reserve the right to modify this Privacy Policy at any time, without advance notice. If we make any material change to this Policy, we will update our Website to include such changes. We recommend that you review this Website regularly for updates to our Privacy Policy.