Last Updated: 09/12/2025 

Kiwipop, Inc. (“we,” “us,” or “our”) respects your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, protect, disclose and share your Personal Information in connection with using our products and services (“Services”) when you use our mobile application (“App”). We have developed the Services and the App to help you establish and maintain good money habits and to celebrate your success when you make pay your bills on-time. 

If you have any questions about our privacy practices, please contact us by email at hello@kiwipop.co.

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1. PERSONAL INFORMATION

For purposes of this Policy, “Personal Information” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person. Personal Information does not include information that is publicly available or has been deidentified or aggregated in a way that it cannot be used to identify a specific person. 

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2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT?

We may collect the following categories of Personal Information from you, electronically or from third parties, including when you use the Services and the App or otherwise interact with us:

• Identifiers: name, email address, phone number, IP address, and other contact information
• Customer Records: transaction history data from your third party financial data aggregators, credit cards, bank and other financial institution accounts that you affirmatively choose to connect to the App 
• Protected Class Information: age, gender
• Internet Activity: IP address, operating system, browser type, device identifier, Internet, or other electronic network activity information, including, but not limited to, and information regarding your interaction with the App
• Geolocation Data: imprecise location information, such as the city, state, and ZIP code associated with your IP address
• Inferences: personal preferences, characteristics, psychological trends, behavior, predispositions, attitudes, intelligence, abilities, and aptitudes

3.  SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

Directly from You 

We collect your Personal Information directly from you, for example when you access, use, or otherwise interact our Services and  the App, create an account, link accounts to the App (such as information from your credit card accounts or bank accounts) and when you request information from us. 

From You Automatically

We may collect certain information about you automatically when you use the App, such as your IP address, mobile carrier, and other device identifiers that are automatically assigned to your computer or device when you access the Internet. For more information, see the “Cookies and Other Tracking Technologies” section below.

From Third Parties 

We may receive your Personal Information from service providers and other third parties in connection with providing the Services such as payment processors, and third-party financial data aggregator partners.

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4. PURPOSE FOR WHICH WE COLLECT PERSONAL INFORMATION 

We collect and use Personal Information for the following purposes:

• Communications. To communicate with you through emails or calls; provide you with alerts, updates, promotions, and other information; communicate with you regarding updates to the App or our Services; respond to you when you contact us; send technical notices, updates, security alerts, support and administrative messages; and to notify you of changes to our terms of service (“Terms”) or this Policy.
• Account Creation and Support. We use your Personal Information to create and service the App and your online account with us. 
• Access Financial Information. With your consent, we use Personal Information to assist you in linking your financial accounts to the App such as your bank, credit card or other financial institution accounts through one of our third-party financial data aggregator partners.
• To Operate and Improve the Services and the App. To analyze, operate, maintain, support, secure and improve our Services and the App.
• Develop Insights. We may use Personal Information collected from you to develop insights necessary to provide you a better user experience. 
• For Research and Development. We may use Personal Information that you have shared on a deidentified and aggregated basis to perform research and development for academic and scholarly reasons, to develop a data set or algorithm using a large learning model and to improve our Services or as otherwise permitted by applicable law. 
• Business Purposes: We may use Personal Information for our business purposes such as to (1) operate our business, and to provide the Services and the App; (2) carry out our obligations and enforce our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (3) conduct statistical or demographic analysis; (4) prevent fraud; (5) assess the success of our marketing and advertising campaigns; (6) inform our business strategies; (7) operate our information technology systems; (8) perform research and development as further described above; (9) administer surveys and solicit feedback; (10) engage in business transactions and (11) engage in other business purposes permitted under applicable law.
• Advertising and Marketing: We may use your Personal Information to serve customized advertising to you, to customize content, to improve our ability to contact you, to enhance our marketing capabilities and to inform our marketing and advertising strategies. We may use Personal Information to advertise and market to you including notifying you of special promotions, sweepstakes, contests, opportunities, offers and events, via e-mail and text messages. 
• Analytics: We use Personal Information to improve the Services, the content of the App and to enhance your user experience when using the App and our Services. We use Personal Information to generate statistical information about the usage and traffic patterns of the App and the Services and to prevent fraud.
• Law Enforcement/Legal Purposes: We may use Personal Information to respond to requests from law enforcement or for other legal purposes including to: (1) comply with legal and regulatory requirements; (2) satisfy contractual obligations; (3) cooperate with law enforcement or other governmental agencies for purposes of investigations, public safety or matters of public importance when we are legally required to do so or believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (4) protecting and defending against legal actions or claims or pursuing legal actions claims.
• At Your Direction: We may use Personal Information for any other purpose which you authorize.

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5.      DISCLOSING AND SHARING PERSONAL INFORMATION

We may share or disclose with service providers or other third parties certain Personal Information that we, or third parties acting on our behalf, have collected. We may disclose or share such Personal Information with the following parties:

• Service Providers: We may disclose Personal Information to our service providers who are contractually obligated to maintain the confidentiality of that Personal Information. For example, we may disclose Personal Information to service providers that: (a) help us host and manage the Services and the App; (b) help us improve the content and functionality of the Services and the App; (c) perform data analysis and statistical analysis services; (d) troubleshoot problems with the App or the Services; (e) provide email or text messaging services;  (f) provide marketing, advertising or public relations services for us; (g) provide data processing and storage services; (h) support or provide the security of the Services and the App; (i)  assist us in research and development and  (j)payment processors.

We use the following service provider platforms to operate the Services and interact with the App:

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• Method:  We use the services of Forward Lending, Inc. d/b/a Method Financial (“Method”) to validate your identity, prevent fraud, and serve as a payment processor when you authorize the use of Method to make bill payments using the App.  Please see their Terms of Service and Privacy Policy for information about your obligations when you use the Method Service and how they collect, use, secure, share and disclose Personal Information, see:

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• Terms of Service for End Users. The future of financial connectivity  

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• Privacy Policy:  Method: The future of financial connectivity.  

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The Method Privacy Policy and not this Privacy Policy applies to Personal Information you submit to Method.  Method does not share your account number with us. 

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• Plaid:  We use the services of Plaid AI Overview to provide a secure platform for connecting our Services and App with your bank accounts if you choose to use Plaid.  This allows you the ability to link your accounts and share financial information with Plaid without directly sharing your bank login credentials with us. Please see their Terms of Service and Privacy Policy for information about your obligations when you use the Plaid Service and how they collect, use, secure, share and disclose Personal Information, see its Privacy Policy at Privacy and security policies | Plaid

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• Third Parties.  We may share your Personal Information with third parties, including the following: 
  
  • Advertising and Analytics Providers.  We may provide your Personal Information to third parties that provide targeted advertising, analytics services or other services for us which also use that Personal Information for their own marketing purposes. 
  • Third-Party Financial Data Aggregator Partners:   With your consent, we may share certain Personal Information with third-party financial data aggregator partners to link to your accounts, maintain account information and allow you to use our Services.  These third-party financial data aggregator partners also allow you to compare and request financial products and services. We do not store your financial account credentials but only pass that information to our third-party financial data aggregator partners when you request services requiring confirmation of your identity, to prequalify for certain product offerings and to provide you access to your financial information on our App. Those third-party financial aggregator partners, include:

ML Enterprise Inc. (“Engine by Money Lion” or “Engine”).   With your consent, we may share your Personal Information, including account credentials, with Engine’s loan referral program which allows  us to help you match your financial needs with personalized offers from financial service providers such as banks, loan providers, self-secured credit card issuers, or other financial institutions.  Please see their Terms of Service and Privacy Policy for information about your obligations when you use the Engine Service and how they collect, use, secure, share and disclose your Personal Information:  For more information about how Engine uses your Personal Information, you can view their privacy statement here:   MONEYLION PRIVACY STATEMENT | MoneyLion

Self Financial, Inc. (“Self”) With your consent, we may share your Personal Information with Self. Self is a financial technology company that offers certain financial products including loans, a self-secured credit card and a rent builder offering to help consumers build and improve their credit. For more information about how Self uses your Personal Information, you can view their privacy statement here Credit Builder Loans by Self - Credit Building App Online - Self

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• Parties to Business Transactions: In the event of an anticipated or actual merger or acquisition, bankruptcy or other sale of all or a portion of our assets or equity or other similar transactions, we may transfer or allow third parties to use information owned or controlled by us, including Personal Information. We reserve the right, in connection with these types of transactions, to transfer, share, assign, or sell your Personal Information and other information we have collected to third parties or to authorize such third parties to use any such information, including for due diligence, as part of any of the transactions described in this paragraph. Any Personal Information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
• Government and Law Enforcement: We may share your Personal Information with individuals or private parties where necessary to enforce and comply with the law, to protect our property or legal rights, for the safety of the public or any person, to prevent harm, to protect the security and integrity of the App and any equipment used to make the Services or the App available.
• Professional Advisors: We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.

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6. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies, web beacons, pixel tags and other analytics or tracking technologies (collectively “Tracking Technologies”) on our App. Tracking Technologies allow the App to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons and pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

We use these tools to make the App function properly; perform data analytics, serve you with targeted advertising; provide personalized experiences; tailor our interactions with you; help with our marketing efforts; provide us with valuable data and statistics about the usage and effectiveness of the App and to help us improve the App and Services.

7. YOUR PRIVACY CHOICES

We offer you several choices with respect to how we use your Personal Information. 

• Update Your Information.  You may update or correct any Personal Information you have provided us by editing your account information on our App, or by contacting us at hello@kiwipop.co. 
• Opt out of marketing emails. If you opt in to receive electronic marketing communications from us, you consent to our sending such electronic communications to you using the email address you provide. We may use third-party providers to deliver electronic communications to you. If you no longer want to receive email marketing communications from us, you may opt out of such emails by using the unsubscribe link in the email you received from us or by contacting us at hello@kiwipop.co with “Unsubscribe” in the subject line. 
• Targeted Advertising. You may reduce the number of targeted advertisements by changing your preferences online. To change your preferences with respect to certain advertisements and to obtain more information about third-party ad networks and online behavioral advertising, visit National Advertising Initiative Consumer Mobile Opt Out Page or the Digital Advertising Alliance AppChoices Mobile App. Changing your settings with individual apps or ad networks will not necessarily carry over to other devices or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.

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8.      SOCIAL MEDIA

We are active on social media, including Facebook, Instagram, Tik Tok, LinkedIn, and Twitter (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the applicable Social Media providers. 

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9. SECURITY OF PERSONAL INFORMATION 

We are committed to protecting the security of your Personal Information. We use commercially reasonable safeguards to maintain the security and privacy of Personal Information we collect and use in connection with our Services and the App. 

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10. CHILDREN’S PRIVACY

We do not direct or target any content of our App or Services to children under the age of 18. If we learn that we have collected the Personal Information of anyone under the age of 18, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 18 and discover that your child has submitted Personal Information to us, please send us and email at the contact information below. We will make reasonable efforts to remove such information from our databases.

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11.   DATA MINIMIZATION AND RETENTION

We have adopted principles of data minimization, meaning we will only collect the Personal Information we need to provide you with the Services and the App, as further described in this Policy.  We will only retain your Personal Information for the time period we need it to provide the Services for you. We may continue to retain some of your Personal Information after you stop using the Services or you close your account to (a) comply with applicable laws and legal obligations and meet legal retention obligations; (b) for data security and fraud prevention activities;  (c) to comply with our financial, tax and accounting obligations,  (d) to comply with a contractual obligation and (e) to provide you the ability to reestablish your account

We may continue to use aggregated and deidentified information for any legal business purpose described in this Policy after we have deleted the Personal Information from which it was created.

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12. CALIFORNIA SHINE THE LIGHT

Under California Civil Code Section 1798.83, California residents have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us as set forth at the end of this Privacy Policy to receive this information.

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13. CHANGES AND UPDATES TO THIS POLICY

This Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will prominently display that we have made updates on the top of this Policy, on the App or will communicate to you in another manner. Please check back periodically to see if our Policy has been updated. 

14. CONTACT US

We welcome your questions, comments, and concerns about our privacy practices. Please contact us through using the information below with any questions or feedback you have pertaining to our privacy practices:

hello@kiwipop.co

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