Consumer Privacy Notice

‍What does Cleo AI Inc do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security Number 
• Income and account balances
• Checking account information, payment history or transaction history
  

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Cleo chooses to share; and whether you can limit this sharing.

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Reasons we can share your personal information

For our everyday business purposes—

‍such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, report to credit bureaus, or as otherwise permitted by law 

Does Cleo share?

Yes

Can you limit this sharing?

No

‍

For our marketing purposes—‍

to offer our products and services to you

Does Cleo share?

Yes 

Can you limit this sharing?

No 

‍

For joint marketing with other financial companies

Does Cleo share?

No

Can you limit this sharing?

We don’t share

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For our affiliates’ everyday business purposes—‍

information about your transactions and experiences

Does Cleo share?

No

Can you limit this sharing?

We don’t share

‍

For our affiliates’ everyday business purposes—‍

information about your creditworthiness

Does Cleo share?

No

Can you limit this sharing?

We don’t share

‍

For our affiliates to market to you

Does Cleo share?

No

Can you limit this sharing?

We don’t share

‍

For nonaffiliates to market to you

Does Cleo share?

No

Can you limit this sharing?

We don’t share

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Who we are

Who is providing this Privacy Policy?

This privacy notice is provided by Cleo (collectively, “Cleo”) and is applicable to your personal Cleo account. 

What we do

How does Cleo protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Cleo collect my personal information?

We collect your personal information, for example, when you

• provide us your contact information
• open an account, provide account information
• link your bank account, credit or debit card to your Cleo account
• use your Cleo account to send or receive funds

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

• sharing for affiliates’ everyday business purposes— information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

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Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies. 

• Cleo does not have any affiliates. 

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Cleo does not share with nonaffiliates so they can market to you.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Cleo doesn’t jointly market.

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Other important Information 

California Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. 

Vermont Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. We will not disclose creditworthiness information about you within or outside the Cleo group except as permitted by law, unless we otherwise obtain your consent.

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. 

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WebBank Privacy Notice

What does WebBank do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number and account balances
• Payment history or transaction history

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons WebBank chooses to share; and whether you can limit this sharing.

‍

Reasons we can share your personal information

For our everyday business purposes—

‍such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, report to credit bureaus, or as otherwise permitted by law 

Does WebBank share?

Yes

Can you limit this sharing?

No

‍

For our marketing purposes—‍

to offer our products and services to you

Does WebBank share?

Yes 

Can you limit this sharing?

No 

‍

For joint marketing with other financial companies

Does WebBank share?

No

Can you limit this sharing?

We don’t share

‍

For our affiliates’ everyday business purposes—‍

Does WebBank share?

No

Can you limit this sharing?

We don’t share

‍

For our affiliates’ everyday business purposes—‍

Does WebBank share?

No

Can you limit this sharing?

We don’t share

‍

For our affiliates to market to you

Does WebBank share?

No

Can you limit this sharing?

We don’t share

‍

For nonaffiliates to market to you

Does WebBank share?

No

Can you limit this sharing?

We don’t share

‍

Who we are

Who is providing this notice?

This privacy notice is provided by WebBank and is applicable to your personal WebBank account. 

What we do

How does WebBank protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We restrict our employee access to your information so that it is only accessible when they need it to do their work, and we require companies that work for us to protect your information.

How does WebBank collect my personal information?

We collect your personal information, for example, when you

• provide us your contact information
• open an account, provide account information, login to your  account, or use WebBank services
• link your bank account, credit, or debit card to your WebBank account
• use your WebBank account to send or receive funds

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

• sharing for affiliates’ everyday business purposes— information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

‍

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies. 

• WebBank does not share with our affiliates 

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• WebBank does not share with nonaffiliates so they can market to you.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• WebBank does not jointly market.

‍

Other important Information 

California Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law.

Vermont Residents: We will not share your information with non-affiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. We will not disclose creditworthiness information about you within or outside the WebBank group except as permitted by law, unless we otherwise obtain your consent.

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