clearXchange Privacy Notice

CLEARXCHANGE, LLC PRIVACY NOTICE

Effective on: January 1, 2023

NOTE: THE CLEAREXCHANGE SERVICE IS NO LONGER OPERATIONAL AS OF JULY 5, 2022

clearXchange, LLC provided a network directory service (the “Network Directory”) to U.S. financial institutions that participate in the Network Directory ( the “Network Financial Institutions”) to enable convenient transfers of money from their deposit account holders (each, a “Network Financial Institution Customer”) to individuals who did not have a deposit account with a Network Financial Institution (each, a “User”) using the User’s email address or U.S. mobile phone number (the “Service”).

This privacy notice (“Privacy Notice”) explains our information privacy practices about the collection, use, disclosure, and retention of information you submitted or we collected through our website, clearXchange.com (the “Site”). The Site is owned and operated by Early Warning Services, LLC.

To make this Privacy Notice easy to find, we make it available on the clearXchange.com homepage. You may also call 844.428.8542 (Sunday- Saturday 10am to 10pm ET, excluding New Year’s Day, Independence Day, Thanksgiving and Christmas) to request a copy by US mail.

What do you want to learn more about?

1. Scope and consent
2. Personal information we've collected, used, and/or disclosed
3. Categories of sources of personal information we collect
4. How we use personal information
5. Who we disclose personal information to
6. Your choices
7. Your rights regarding your personal information
8. Verification process and required information
9. Authorized agents
10. Our data retention practices
11. Notice to California residents
12. Links to third party websites
13. Security
14. Minors’ privacy
15. Territorial scope and processing
16. Changes to this Privacy Notice
17. How to contact us

clearXchange.com Privacy Notice

1. Scope and consent

When you use the Site, you are contracting with Early Warning Services, LLC, located at 5801 N Pima Rd, Scottsdale, AZ 85250. By using the Site, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Notice. Do not use the Site if you do not agree to these terms.

2. Personal information we've collected, used, and/or disclosed

If you’ve used the Site in the past 12 months, we may have collected, used, and/or disclosed the following categories of personal information for a business purpose(s):

Categories of personal information collected in the last 12 months:	Categories of sources from which information is collected:	Business purpose(s) for collection, use, and disclosure:	Disclosed for business purpose(s) to the following categories of third parties:	Sold or shared to the following categories of third parties:	Length of time personal information is intended to be retained: (unless subject to a legal hold)
Personal and online identifiers (e.g., first and last name, email address, unique online identifiers)	All categories listed below in Section 3.	All purposes listed below in Section 4.	All categories listed below in Section 5.	None.	4 years after profile is deactivated/closed
Certain identifying personal information (e.g., address, telephone number, financial account numbers, other financial information)	All categories listed below in Section 3.	All purposes listed below in Section 4.	All categories listed below in Section 5.	None.	Up to 5 years after profile is deactivated/closed
Characteristics of protected classifications under applicable California state and federal law (i.e., date of birth)	All categories listed below in Section 3.	All purposes listed below in Section 4.	All categories listed below in Section 5.	None.	Up to 5 years after profile is deactivated/closed
Transaction information (e.g., records of transactions made through clearXchange when you use the Site)	All categories listed below in Section 3.	All purposes listed below in Section 4.	All categories listed below in Section 5.	None.	5 years
Internet or other electronic network activity information (e.g., browsing history, search history, interactions when you use our Site)	Your device when you use the Site.	All purposes listed below in Section 4.	All categories listed below in Section 5.	None.	Up to 26 months
Other information about you that is linked to the personal information above (e.g., information you associate with your clearXchange profile, call recordings if you call Customer Support for help with the site).	All categories listed below in Section 3.	All purposes listed below in Section 4.	All categories listed below in Section 5.	None.	Call recordings – Up to 3 years Profile information – Up to 5 years after profile is deactivated/closed

3. Categories of sources of personal information we collect

We collect personal information when you use the Site, including:

1. Directly from users of the Site (when accessing or using the Site);
2. Passively from users’ devices (when accessing or using the Site);
3. From our Network Financial Institutions; and
4. From our service providers.

4. How we use personal information

When you use the Site, we collect, use, and disclose personal information for the following business reasons:

1. legal compliance;
2. responding to your requests;
3. providing other services you request;
4. internal operations; and
5. other one-time uses.

5. Who we disclose personal information to

We may disclose personal information with the following categories of third parties for the business purposes we described above in Section 4.

1. the Early Warning Services, LLC corporate family (Early Warning is the parent company of clearXchange);
2. our Network Financial Institutions (e.g., when you sent or received money, we shared information with them to facilitate the transaction);
3. our service providers;
4. law enforcement, government agencies, and other authorized third parties (we may be required by law to share information for legal reasons);
5. existing owners and their employees and agents;
6. new owners (in the event we plan to merge with or be acquired by that business entity); and
7. other entities with your consent.

6. Your choices

We communicate with you based on the contact information you provide to us.

You may not opt-out of administrative emails (for example, emails about policy changes).

7. Your rights regarding your personal information

We provide the clearXchange service pursuant to the Gramm-Leach-Bliley Act (“GLBA”) and as such are exempted from certain data privacy laws. We provide notice of the following rights you have, regardless of whether we are obligated by law to observe them and regardless of your state of residence:

• For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties;

o We do not share personal information with third parties for their own direct marketing purposes. Therefore, we have not shared your personal information for such purposes within the last 12 months.

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, our business purposes for collecting such personal information, categories of third parties with whom we share personal information, the categories of sources from which we collected your personal information, whether we have disclosed, sold, or shared your personal information to a third party in the preceding 12 months, and the categories of third parties with which we have shared or sold your personal information;

o In the past 12 months, we have not sold or shared personal information from the Site. For purposes of this Privacy Notice, “sale” means the disclosure of personal information to a third-party for monetary or other valuable consideration and “share” means the disclosure of personal information to a third party for cross-context behavioral advertising.

• The right to correct inaccurate personal information that we maintain about you;

o To the extent required by, and in accordance with applicable law, we will use commercially reasonable efforts to correct your personal information as directed by you , considering the nature and the purposes of maintaining your personal information. Under certain circumstances, we may not be able to correct your information because we have a legal obligation or other reason in which we must retain it in its current state (e.g., the nature of the data, the source of the data, to comply with law).

• The right to request that we delete the personal information we have collected from you or maintain about you;

o Under certain circumstances, we may not be able to delete your information because we have a legal obligation or other reason that we must retain it.

• The right to opt out of our sale(s) or sharing of your personal information;

o As stated above, we do not sell or share personal information that we’ve collected from the Site.

• The right to be free from discrimination for exercising your privacy rights;

o We will not discriminate against you for exercising your choices and rights.

• The right to access your personal information that we have about you going back for a 12-month period following your request; and

o You may request that we disclose the above information beyond the 12-month period for personal information collected on or after January 1, 2022, unless doing so proves impossible or would involve a disproportionate effort.

• The right to appeal if we decline to act on any of the above requests you’ve made.

Please note the above-listed rights are subject to certain exceptions. For instance, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us or the security of our systems or networks. We may decline your request if we cannot verify your identity or confirm the personal information that we maintain belongs to you. If we cannot honor your request, we will let you know.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

• Submit your request be email to DataPrivacyConsumerSupport@earlywarning.com. In your email request, please include the following information to help us process your request:

o Date(s) you used the clearXchange service

o Your full name as registered with the clearXchange service

o Your contact numbers as registered with the clearXchange service

o Your postal mailing addresses as registered with the clearXchange service

o Your enrolled email address

• Reach us by phone at 844.212.9102 (Monday through Friday, 8am to 5pm AZ, excluding federal holidays) to submit your request.

We will acknowledge receipt of your request and let you know how long we expect it will take us to complete your request (typically 45 days or less for most requests).

8. Verification process and required information

We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.

We may need to contact you to verify your identity. At a minimum, your identity will be verified by matching certain personal information provided by you with personal information maintained by us. We may use a third-party identity verification service to assist us with verifying your identity.

9. Authorized agents

You may designate an authorized agent to make a request on your behalf. Your authorized agent will be required to produce a signed authorization from you and additional identity verification may be required. Authorized agent requests may be made by phone at 844.212.9102 (Monday through Friday, 8am to 5pm AZ, excluding federal holidays).

10. Our data retention practices

We generally retain information for as long as it is necessary and relevant for our operations and to comply with applicable law. See Section 2 for more information.

11. Notice to California residents

How We Respond to Do Not Track Signals for California Residents: California Business & Professions Code Section 22575(b)(as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to "Do Not Track" browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

12. Links to third party websites

Our Site may contain links to other third-party websites, such as our Network Financial Institutions. When you leave our Site and visit those websites, you are subject to the privacy notices of those websites. We are not responsible for the privacy practices of these third party websites, which are governed by their own privacy notices and practices.

13. Security

To help us protect the privacy of your data, we maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls.

14. Minors’ privacy

The Service Agreement defines eligibility requirements to use the Site. Our Site is not intended for anyone under the age of 18. For information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.

We do not sell or share personal information collected from the Site. Therefore, we would not sell or share information about minors.

15. Territorial scope and processing

We are located in the United States. Our services are available for eligible United States Users only. Our operations use a network of computers, cloud-based services, and other infrastructure and information technology that are based in the United States.

Additionally, we may use third-party service providers that may be located in and process or store your personal information in the United States, the European Union, and other countries. If you create a profile, you consent to the collection and/or processing of your personal information and tracking technologies/cookies as described in this Privacy Notice.

16. Changes to this Privacy Notice

From time to time, we may update this Privacy Notice. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site. You should check the Site frequently for updates.

17. How to contact us

If your questions are not answered in this Privacy Notice, you may email us at privacyoffice@earlywarning.com, or write to us at Early Warning Services, LLC., Attn: Privacy Office, 5801 N Pima Rd, Scottsdale, AZ 85250.