Privacy Policy

Last Updated: August 20, 2024

WELCOME TO THE MONEYLION PRIVACY POLICY!

Welcome to the MoneyLion Technologies Inc. (which may also be referred to as “MoneyLion”, “we,” “us,” and “our”) Privacy Policy. This Privacy Policy describes how we collect, use, and disclose your information in connection with our website (the “Site”) and mobile application (the “MoneyLion App”, and, together with the Site, the “MoneyLion Platform”). The Site and the MoneyLion App are operated by MoneyLion and have been created to provide our visitors (“you,” “your”) with information about our company and with online content, tools, products, services, memberships, and other offerings, including financial products and services (collectively, “Services”). This Privacy Policy describes how MoneyLion collects, uses, and discloses information from users of the Services, including information that can be used to identify you, directly or indirectly, as defined by applicable laws (“Personal Information”). For residents of California, please see our Notice at Collection below.

WHY THIS MATTERS 

We built the MoneyLion Platform to give everyone the power to make their best financial decisions. Knowing certain things about our users helps us do that better.  Please be sure to read this entire Privacy Policy and our Financial Privacy Notice before using or submitting information through the Services. By using or submitting information through the Services, you are indicating that you agree to the collection, transfer, manipulation, processing, storage, disclosure, and other uses of your Personal Information as described in this Privacy Policy, and you agree to be bound by the terms of this Privacy Policy and our Financial Privacy Notice. You also agree that such Personal Information may be transferred from your current location to our offices and servers.This Privacy Policy is incorporated by reference into MoneyLion’s Terms of Service and any other agreement entered into by and between you and MoneyLion. If you do not agree with any aspect of this Privacy Policy, our Financial Privacy Notice, or the Terms of Service, you should immediately discontinue access to or use of our Services.

CONTENTS

1. WHAT PERSONAL INFORMATION WE COLLECT 
2. HOW WE USE PERSONAL INFORMATION 
3. HOW WE DISCLOSE PERSONAL INFORMATION 
4. OTHER IMPORTANT INFORMATION 
5. YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION

1. WHAT PERSONAL INFORMATION WE COLLECT

Because we are a financial institution regulated under the Gramm-Leach-Bliley Act, the Personal Information that we collect in connection with your request for consumer financial products and services constitutes “nonpublic personal information” subject to our Financial Privacy Notice, and we may be exempt from certain state privacy laws. 

When you visit the MoneyLion Platform or use our Services to apply for a financial product or service, to open or maintain an account with us, to enroll in a membership, to take advantage of deals and other offerings, or, in the context of a business-to-business relationship, to complete vendor and partner due diligence, you signify acceptance to the terms of this Privacy Policy and the Financial Privacy Notice and consent to the collection, use, and disclosure of your Personal Information as described herein and therein. 

I. PERSONAL INFORMATION THAT YOU PROVIDE OR AUTHORIZE US TO COLLECT 

The Personal Information you will be asked to provide when using our Services may vary depending on your business relationship with us and the type of financial product or service you are seeking. This information may be directly provided by you, sourced from identity verification and fraud prevention partners or public databases, collected from our affiliates and non-affiliated third-party partners, pulled from any external accounts that you may link, or obtained from consumer reporting agencies when we perform a “soft” credit inquiry, in connection with your enrollment in credit monitoring services, or as otherwise appropriate where there is a legitimate business need in connection with a transaction initiated by you, in each case in accordance with your instructions.  

The Personal Information that you provide or authorize us to collect may include:

1. PRODUCTS AND OFFERS INFORMATION: To the extent that you navigate to the “Products and Offers” tab on our MoneyLion App or page on our Site, you may be asked to provide any of the information described in the section of the Engine by MoneyLion Privacy Policy entitled “WHAT PERSONAL INFORMATION WE COLLECT” in connection with your search for financial products or services.  Please refer to that document for additional information on the Personal Information that we collect in this context, including how we use and disclose that Personal Information. 
2. CONTACT AND DEMOGRAPHIC INFORMATION: This may include your name, username (e.g., RoarTag), date of birth, address, phone number, email address, telephone number, military status, Social Security number, driver’s license number, passport number, or other similar identifiers. 
3. PROFESSIONAL OR EMPLOYMENT INFORMATION: This may include the name of your employer, the amount of your income, the frequency of your pay cycles, and the dates on which you receive direct deposits.  
4. FINANCIAL ACCOUNT INFORMATION: This may include account balances, trading activity, loan amounts and account history for any MoneyLion accounts, as well as information about external linked accounts, such as your bank account number, account balance, account activity (including, but not limited to, direct deposit or spending activity and trading activities), account history, and any other transaction data, to the extent you have chosen to link an external account to your MoneyLion account. 
5. CONSUMER REPORTING INFORMATION: This may include your credit score, credit data status (for example, how long you’ve had a credit file, whether your credit is frozen), your credit, payment and bankruptcy histories, and the type and amount of any outstanding loans.  
6. IDENTITY VERIFICATION AND AUTHENTICATION INFORMATION: In limited circumstances we may receive Personal Information such as photographic images, including selfies or images from your government-issued photo identification. We partner with third parties to complete identity verification, some of whom may collect biometric identifiers, such as your faceprint, from these images (such identifiers, “Biometric Data”). 
7. LOCATION INFORMATION: This may include precise location information, device motion information, or both, to the extent you choose to use certain features in the MoneyLion App, such as Driver Score, and grant the app permission to track your location in your mobile device location settings. Any precise location information is collected by our automobile insurance partner, Zendrive, and passed back to MoneyLion via an application program interface (API) endpoint. When you opt-in to Driver Score, you authorize Zendrive to collect and use your location information for the purpose of searching for automobile insurance discounts. Before signing up for the Driver Score feature, please review and ensure that you understand the Zendrive Privacy Policy. We may also collect location information based on your IP address and the geolocation of your device.
8. SUPPORT INFORMATION: This may include audio, electronic or similar information, such as the information collected when you email or call our customer support center, which may include your name, email address, voice recording, and any other content or communications that you send to or share with us.
9. SURVEY INFORMATION: We will collect this information if you elect to complete surveys about your user experience.
10. UNSOLICITED INFORMATION: We will collect this information if you elect to provide additional information to us through the MoneyLion Platform or through any other means. This includes, but is not limited to, information posted to any public areas of the MoneyLion Platform when you engage with our content, including by commenting or using chat or messaging features, information volunteered in connection with participation in webinars or other events hosted through the MoneyLion Platform, information posted when you comment or engage with MoneyLion social media pages or handles on third-party platforms, ideas for new products or for enhancements, improvements, or modifications to our Services, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and shall be subject in full to Sections 5(D) and 5(E) of the MoneyLion Terms of Service. Please take care and avoid providing any Personal Information through the public forums on the MoneyLion Platform. Remember that when you share information publicly, it may be indexable by search engines or otherwise further disclosed. 
11. SENSITIVE PERSONAL INFORMATION: This may include your precise location information, military status, Social Security number, driver’s license number, passport number, or other similar identifiers. 
12. INFERENCES: We may also derive Personal Information about you in the form of inferences, which are derivations of information, data, assumptions, or conclusions from facts, evidence, or other sources of information or data about you.  These inferences may be derived from the Personal Information that you provide to us or authorize us to collect, from the Personal Information automatically collected, from the Personal Information that we collect from third parties, as well as from the information collected by cookies, web beacons, and other tracking technologies.

By voluntarily providing us with Personal Information, you represent that the Personal Information you provide is true, accurate, current, and complete, and that you are authorized to provide it to us. 

If you’d like to view a summary of our data collection, use, and disclosure practices in table format, please see Appendix A below.  

II. PERSONAL INFORMATION AUTOMATICALLY COLLECTED

Whenever you interact with the Services, MoneyLion may automatically receive and record information from your computer, browser and/or mobile device, which may include the following:

1. IP ADDRESS: 

Your interactions with MoneyLion may transmit your IP address (the Internet address of your computer). We may use visitors’ IP addresses for various purposes, including to display customized content, to analyze and report upon usage of the Services, to diagnose and prevent service or technology problems affecting the Services, and to monitor and prevent fraud and abuse. We may also use the IP address associated with your login to determine your general location in order to comply with applicable privacy regulations and serve you necessary notifications and/or consent mechanisms.

2. DEVICE IDs: 

We may collect information on the type of device you are using, operating system, settings, browser and OS information, unique device identifiers, mobile carrier, browser type and language, network information and other device-specific information. The information collected may depend on the type of device you use and its settings. We collect this data to better tailor our services to you, to audit ad impressions, and for compliance with various specifications and standards.

3. LOCATION DATA: 

In addition to the location data collected if you enroll into our Driver Score feature, we may collect location data based on your IP address and the geolocation of your device. We collect this data to better tailor our services to you and to help provide service offerings available to you in your geographic area.

4. USAGE INFORMATION: 

We collect information about how you use our Services, such as the types and categories of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities on the Site.  We use data analytics with this usage information to better understand your use of the Services and to improve the Services offered. 

III. COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES:  

In operating the Services, we may use cookies, web beacons, fingerprinting, and similar technologies to collect and use Personal Information about you, including for analytics purposes, and to serve you interest-based advertising. This Privacy Policy covers the use of these technologies by MoneyLion only. Uses of these technologies by third-party advertisers or websites linked from the Services, including third parties with which we partner, are governed by each such third party’s privacy policy.

1. COOKIES & ANALYTICS:

A cookie is a small text file placed in visitors’ computer browsers to store their preferences.  Cookies help provide additional functionality to the Services, customize users’ experiences with the Services and help us analyze Services usage more accurately for research, advertising, and marketing purposes. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notifications when you are receiving a new cookie and on how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’ features, and, if you block or delete cookies, the MoneyLion Platform may not work properly.

• Google Analytics: Please note that we use Google Analytics cookies for data analytics purposes.  You can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. You may choose to opt-out of Google Analytics by installing their opt-out browser add-on https://tools.google.com/dlpage/gaoptout/.

• Lookalike Audiences: Additionally, we may share certain information with companies like Facebook and Taboola, that allow us to build aggregated user profiles and segments and to create custom or Lookalike Audiences. For more information about Facebook Lookalike Audiences, click here. To opt out of having such activity sent to Facebook, click here. You may find more information about Taboola and their cookie practices here.  If you wish to opt-out of such activity sent to Taboola, click here.
  • Learn More: You can learn more about cookies on the following third-party websites:
    • All About Cookies: http://www.allaboutcookies.org/
    • Network Advertising Initiative: http://www.networkadvertising.org/

• Advertising and Marketing Cookies: Advertisements appearing on the Services may be delivered to you by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers. We use providers such as LinkedIn, Instagram, Twitter, TikTok, and YouTube for advertising and marketing support. 

If you are interested in learning more about and/or opting out of online behavioral advertising, sometimes called interest-based advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as youradchoices.com. You can also learn more about industry-developed opt-out mechanisms for mobile apps here.

2. PIXEL TAGS/WEB BEACONS:

In addition to cookies, we may use web beacons (also known as “clear GIFs” or “pixel tags”), which are pieces of code embedded on the MoneyLion Platform that collect information about users’ engagement on a web page. These help us to measure traffic to or from or use of our online forms, tools or content items, and related browsing behavior, and to improve your experience when using the Services. We may also use customized links or other similar technologies to track hyperlinks that you click, and we associate that information with your Personal Information in order to provide you with more focused communications. Web beacons may be placed on the Service by third parties, such as analytics providers, in order to support functionalities described in this Privacy Policy. The information collected by these third parties in this manner is subject to these third partys’ own privacy policies.

3. SESSION REPLAY TECHNOLOGIES:

We also use research vendors, including session replay service providers, in order to better understand our users’ needs and to optimize our Services. Such technologies and third-party-provided services may observe or record user activities when using our Services, including certain movements, scrolling, visit duration, clicks, chatbot conversations and other interactions. These services may use cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Certain analytics may be removed via our privacy cookie controls.

4. “DO NOT TRACK”

Please note that our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy, whether or not a DNT signal is received. 

IV. PERSONAL INFORMATION COLLECTED FROM OTHER SOURCES:

We may collect Personal Information about you from third parties to operate the MoneyLion Platform and to provide you with our Services. As previously discussed, this may include information about you from one or more consumer reporting agencies, in connection with your use of our “Products and Offers” marketplace, your enrollment in credit monitoring services, or your application for a Credit Builder Loan.  We may also collect any of the above categories of Personal Information from third parties, such as marketplace partners, bank verification partners, identity verification partners, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, public databases, and data brokers. We may also collect information about you from our corporate affiliates, which we use to streamline and personalize your experience with our MoneyLion Platform and our Services.

As of the date of this Privacy Policy, Incode Technologies, Inc. (“Incode”) and Onfido Inc. (“Onfido”), facilitate our identity verification processes.  In order to provide these solutions, Incode and Onfido directly collect, use, and retain photographic and Biometric Data. Incode and Onfido may disclose such data to service providers or government entities that facilitate the Services, and as required by law.  You may exercise your privacy rights vis a vis Incode and Onfido by contacting [email protected] (Incode) or [email protected] (Onfido).  To learn more about how Incode and Onfido use your Personal Information, please read Incode’s Privacy Policy and Onfido’s Privacy Policy.  You may choose to link an external bank or other financial account to the MoneyLion Platform, using third parties, such as Plaid Technologies Inc. (“Plaid”), to allow MoneyLion to gather data from other financial institutions with whom you have a relationship. By linking your external financial account through these service providers, you grant us and these service providers, including Plaid, the right, power, and authority to act on your behalf 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 these service providers, including Plaid, in accordance with their privacy policies. You can find Plaid’s privacy policy here.

2. HOW WE USE PERSONAL INFORMATION 

We may use the Personal Information we collect for the following purposes: 

• A) TO PROVIDE PRODUCTS AND SERVICES 
  • To verify your identity, set up, and maintain your account (if applicable). 
  • To provide information relevant to the underwriting models and eligibility criteria of our marketplace partners, who may provide you with personalized offers.
  • To personalize the Services when you visit our Site and/or use one of our online forms, tools, widgets, or content items.
  • To monitor your use of the Services. 
  • To maintain our Services and operations. 
• B) TO ENSURE THE INTEGRITY AND SECURITY OF OUR SERVICES 
  • To perform identity verification in compliance with applicable laws and regulations. 
  • To detect and protect against security incidents and malicious, deceptive, fraudulent, or illegal activity, and prosecute the same.
  • To debug to identify and repair errors in our systems.
  • To verify or maintain the quality of our services, and to improve, upgrade, or enhance our services.
  • To conduct due diligence or other reviews in connection with our vendor onboarding processes.
• C) FOR ANALYTICS, RESEARCH, AND SERVICE IMPROVEMENT 
  • To monitor and measure your use of our products and Services in an effort to better understand you and our other users. 
  • To conduct testing, research, and surveys to understand how our Services are being used and how they can be improved.
  • To conduct analytics, such as usage trends.
  • To perform financial analysis to better understand pricing and other financial matters. 
  • To improve the content and functionality of the Services. 
  • To test and improve the quality of our matching process. 
  • To better understand user needs. 
  • To pre-populate certain fields in our forms, helping to streamline your experience. 
• D) FOR QUALITY ASSURANCE AND TRAINING PURPOSES 
  • To monitor communications and interactions with you to ensure the quality of our support services and the appropriate training of our people, and to respond to and resolve your inquiries.  
• E) TO COMMUNICATE WITH YOU 
  • To contact you by email, postal mail, push notifications, in-app messages, phone, or SMS, as permitted by applicable law, to provide you with:
    • Information regarding your application status, or other transactional information relevant to your account.
    • Opportunities, alerts, and promotions related to your submitted request(s) available through the services or products of our marketplace partners that we think may be of interest to you. 
    • Information or content – such as articles, white papers, and event registrations – that we believe would be of interest to you. 
    • Each marketing-related e-mail communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. Generally, you can unsubscribe from our marketing emails or direct mail by submitting an unsubscribe request through our Preference Center or emailing [email protected] and asking to be removed from any correspondence. Although we will remove you from our marketing lists, you may still receive transactional messages related to your interactions with our Services. This process will not unsubscribe you from marketing communications from marketplace partners; in order to stop receiving these communications, please follow each partner’s own unsubscribe processes.
• F) FOR PERSONALIZATION AND ADVERTISING 
  • To serve you with relevant advertising and content, which may include providing service offerings available in your geographic area, or to serve you with advertising for marketplace partner products or services, or the products or services of our corporate parent entities and their wholly-owned subsidiaries and affiliates, including, but not limited to, ML Enterprise Inc. (“MoneyLion Related Companies”) on third party properties (cross-context behavioral advertising).  
  • To draw inferences to build a user profile reflecting your preferences, characteristics, or behavior, or to build aggregated user profiles and segments, which we may use to target “lookalike” audiences on other platforms or to improve our efforts to target appropriate advertising to you. 
  • To provide to MoneyLion Related Companies for marketing purposes.
    • For more information, see our Financial Privacy Notice.
  • To assess the effectiveness of ads displayed to you. 
  • To display ads on the services of third-party advertising companies and social media companies.
    • These companies may use cookies and similar technologies to track your activity, and the information collected by these third parties in this manner is subject to that third party’s own privacy policies. 
    • We may also use aggregated information from these sources to create similar audiences in order to better target advertisements on their networks to potential consumers who appear to have shared characteristics. You may opt out of “similar audiences” in Google at https://adssettings.google.com/authenticated.  You can also learn more about how to opt out of their collection in general by going to www.aboutads.info/choices, www.networkadvertising.or and/or www.youronlinechoices.com.
• G) TO RUN SWEEPSTAKES AND CONTESTS 
  • To run sweepstakes, contests, and other promotions (“Promotions”) via the MoneyLion Platform or other social media or digital platforms.
    • Some Promotions may be administered by third parties, in which case you should review the privacy policies of the administering parties to understand their practices with respect to your Personal Information.
    • You should carefully review the official rules of any Promotions in which you participate, including any option to opt out of the use of your information for future promotional, marketing, or other purposes.
• H) TO COMPLY WITH ANY APPLICABLE LAWS, REGULATIONS OR LEGAL PROCEEDINGS
  • To investigate disputes or claims related to our Services. 
  • To respond to legal, government or regulatory requests.
  • To comply with applicable laws.
• I) FOR SAFEGUARDING AND DEFENDING OUR VITAL INTERESTS, FOR EXERCISING ANY RIGHTS, ASSERTING ANY CLAIMS, AND FOR ANY OTHER LAWFUL BUSINESS PURPOSE
  • This includes any incidental business purpose related to or in connection with any of the above, or any other purpose disclosed to you at the point at which we collect your Personal Information.
• J) FOR ANY OTHER LEGITIMATE BUSINESS PURPOSES NOT OTHERWISE PROHIBITED BY LAW

NOTE ON OUR USE OF AGGREGATED PERSONAL INFORMATION: 

In an ongoing effort to better understand and serve our users, MoneyLion often conducts research on consumer demographics, interests, and behavior based on Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and MoneyLion may share this aggregated data with MoneyLion Related Companies, and with its agents, service providers, marketplace partners, and other third parties with whom we do business.  This includes, but is not limited to, information such as consumer financial trends, choices, and comparisons. We may also use aggregated information from these sources to create similar audiences in order to better target advertisements on third-party advertising and social media networks to potential consumers who appear to have shared characteristics. MoneyLion may also disclose aggregated user statistics in order to describe our Services to current and prospective marketplace partners, and to other third parties for other lawful purposes. This aggregated information does not identify you personally. We will not attempt to re-identify the data once in aggregated or non-personally identifiable form.

3. HOW WE DISCLOSE PERSONAL INFORMATION 

We may disclose your Personal Information to the following categories of recipients for our business or commercial purposes: 

• A) MONEYLION RELATED COMPANIES:  We may disclose your Personal Information to MoneyLion Related Companies for purposes consistent with this Privacy Policy (including for marketing and advertising purposes).
• B) THIRD-PARTY SERVICE PROVIDERS: MoneyLion, like many businesses, hires other companies and contractors to provide certain business-related services (for example, verifying your identity, facilitating mailings, maintaining databases, providing customer service, cloud storage providers, and business analytics and marketing providers). We may also disclose this information to consumer reporting agencies, acting in a service provider capacity, as part of data studies intended to test the reliability of our internal data and to improve the quality of our Services. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we ensure that we have appropriate contractual provisions in place to protect your Personal Information.
• C) BUSINESS PARTNERS: When we partner with other businesses to provide content, products, or services to you or to such business partners, we may disclose relevant Personal Information in connection with such content, products, or services. For example, when you enable our Driver Score feature, your location information is disclosed to Zendrive, our automobile insurance partner, in order to track your driving habits to seek out automobile insurance discounts and savings. Or, when you use our “Products and Services” offering to search for financial products or services from our marketplace partners, we will disclose the information you provide when using these services to marketplace partners whose pre-qualification criteria you may satisfy. In addition, we may provide summarized purchase information, on an aggregated and anonymized basis, to marketplace partners in order to support the accuracy of their financial and business analytics. We may also share this information with marketplace partners to improve efforts to target appropriate advertising content to you. 
• D) CONSUMER REPORTING AGENCIES: We may disclose basic Personal Information to consumer reporting agencies, either for purposes of completing a “soft” credit inquiry with your authorization, or as part of data studies, with the consumer reporting agencies acting in a service provider capacity, which are intended to test the reliability of our internal data and improve the quality of our Services.
• E) POTENTIAL PARTIES TO A CORPORATE TRANSACTION (AND THEIR AGENTS AND ADVISORS): We may disclose your Personal Information to actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, reorganization, financing, bankruptcy, receivership, sale of company assets, or transition of service to another provider. In this event, we will inform the transferee that it must use your Personal Information only for the purposes disclosed in this Privacy Policy.
• F) LAW ENFORCEMENT BODIES, REGULATORS, GOVERNMENT AGENCIES, COURTS OR OTHER THIRD PARTIES: We may disclose your Personal Information to competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts, or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish, or defend our legal rights; (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent, or otherwise address security, fraud, or technical issues.

4. OTHER IMPORTANT INFORMATION 

YOUR CHOICES: 

In general, you can visit the Services without providing all of the Personal Information described under “WHAT PERSONAL INFORMATION WE COLLECT.” If you choose not to provide certain Personal Information, however, you may not be able to use certain features of the Services.

REGISTRATION/ACCOUNT INFORMATION:

If you choose to create an account, we may collect the same information described above under “WHAT PERSONAL INFORMATION WE COLLECT” and/or other information to provide account related functionalities to our users. By registering, you agree to provide and maintain true, accurate, current, and complete information about yourself.

Please note that if you allow others to use your account (including others who you permit to set up profiles under your account), they may be able to view information about your account or any of the profiles under your account.

If you no longer want to maintain an account, you can deactivate your account by contacting us at [email protected] or at the address below.

DATA RETENTION: 

We keep your Personal Information for only as long as necessary to provide you with the Services and for legitimate and essential business purposes, such as maintaining the performance of the website and associated services, making data-driven business decisions about new features and offerings, conducting audits, complying with our legal obligations, and resolving disputes. When we are no longer required to retain the Personal Information as described above, we will destroy, erase, or de-identify it. Legal data retention requirements, however, may require us to retain some or all of the Personal Information we hold for certain periods of time.

ACCURATE INFORMATION: 

We rely on you to ensure your information is accurate and up-to-date. If you have reason to believe that the Personal Information we possess about you is incorrect or is not current, you can correct it on the MoneyLion App by clicking on your profile in the bottom right of the main screen, then selecting “personal information” from the main menu and clicking on the arrow next to the Personal Information you wish to update. You may also edit your profile information on the Site. Alternatively, you can contact us at [email protected] and we will take reasonable steps to update or correct your Personal Information.

CHILDREN’S PRIVACY ONLINE: 

MoneyLion Services are not directed to, or intended for, minors. MoneyLion does not knowingly collect Personal Information from minors. If you are under the age of 18, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their minor children’s Internet usage and to help enforce our Privacy Policy by instructing their minor children never to provide Personal Information on the Services without their permission. If you have reason to believe that a minor has provided Personal Information to MoneyLion through the Services, please contact us, and we will delete that information from our databases.

LINKS TO OTHER WEBSITES: 

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by MoneyLion (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that MoneyLion endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

SECURITY:

We take steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the Personal Information) designed to protect against unauthorized use, disclosure or access to Personal Information, and we regularly adapt these controls to respond to changing requirements and advances in technology.

However, no Internet or email transmission is ever fully secure or error free. If you are, or believe you have become, a victim of identity theft, you may visit the website of the Federal Trade Commission at https://www.identitytheft.gov/#/ for free information to help guard against identity theft and guidance on the recovery steps you can take.

SERVICE FOR U.S. USERS ONLY: 

The Service is hosted and intended solely for consumers in the United States. All Personal Information is stored on servers in the United States and is subject to United States law. 

If you are visiting the Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and the global processing of such information. By providing your Personal Information, you consent to any transfer and processing in accordance with this Privacy Policy.

UPDATES TO MONEYLION’S PRIVACY POLICY:

We may update our Privacy Policy from time to time to reflect changes to our businesses and to account for changing privacy laws. We will obtain your consent to any material changes if and where this is required by applicable laws. Please review this Privacy Policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

5. YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION  

This section discusses applicable privacy rights as required by certain U.S. state privacy laws, including California, Oregon, and other future U.S. states that pass privacy legislation to which we are subject.  This section includes our Notice at Collection for California residents, including those with whom we interact in our business-to-business relationships. To understand the types of Personal Information we collect, and how they are sold and shared, please view Appendix A. We will retain your Personal Information as described under “Data Retention”. To view our full Privacy Policy, please click here. We do not sell your Personal Information, but we do “share” your Personal Information as defined under California law. To review your Notice of Right to Opt-Out, please click here.

Because we are a financial institution regulated under the Gramm-Leach-Bliley Act, the Personal Information that we collect in connection with your request for consumer financial products and services constitutes “nonpublic personal information” subject to our Financial Privacy Notice, and we may be exempt from certain state privacy laws. In light of these exemptions, this Notice does not apply to the collection, processing, sale, or disclosure of any information (i) that a consumer provides to us to obtain a financial product or service, (ii) about a consumer resulting from any transaction involving a financial product or service; (iii) about a consumer resulting from a consumer’s express direction to disclose the consumer’s information; or (iv) that we otherwise obtain about a consumer in connection with providing a financial product or service to that consumer. For information about our data collection practices in those contexts, please refer to our Financial Privacy Notice.

The definition of “Personal Information” may be different under individual state laws and regulations. As used in this Notice only, “Personal Information” refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. 

1. HOW WE COLLECT, USE, AND DISCLOSE YOUR INFORMATION 

For a table that describes how we currently collect, use, and disclose your Personal Information, and how we have collected, used, and disclosed your Personal Information over the last 12 months please see Appendix A. 

All categories exclude text messaging originator opt-in data and consent; this information will not be shared with any non-affiliated third parties.

2. YOUR PRIVACY RIGHTS

Under applicable law, you may have certain rights, such as:

1. Right to Know: You have the right to request, no more than twice in a 12-month period, any of the following, for the period that is 12 months prior to the request date:
   • The specific pieces of Personal Information we have collected about you in the 12 months preceding your request
   • The categories of Personal Information we have collected about you
   • The business or commercial purposes for our collection of your Personal Information
   • The categories of third parties, or a list of the specific third parties with whom we have disclosed or shared your Personal Information
   • The categories of sources from which we have collected your Personal Information 
   • A list of the categories of Personal Information sold or shared about you in the prior 12 months, or a statement that no sale or sharing occurred. If we have sold or shared your Personal Information, we will explain:
     • The categories of your Personal Information that we have sold or shared
     • The categories of third parties to whom we have sold or shared Personal Information 

2. Right to Deletion: You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need to keep certain Personal Information, such as for our legitimate business purposes or as required to comply with retention requirements under applicable laws. 

3. Right to Rectification: You have the right to correct inaccurate Personal Information that we have about you. As stated above, we may provide you with tools to correct your Personal Information yourself.

4. Right to Withdraw Consent: You may have the right to revoke a consent that you previously granted to the collection and sharing of your Personal Information.

5. Right to Opt-Out of Profiling: You may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

6. Right to Limit Use or Disclosure of Sensitive Personal Information: You have the right to limit the use of your sensitive Personal Information, as those terms are defined under respective state privacy laws. Please note that MoneyLion only uses or discloses your sensitive Personal Information as permitted under applicable laws, and that such use or disclosure is reasonably necessary and proportionate for those purposes. As such, our use and disclosure of your sensitive personal information is already limited.  Please note that we do not use your sensitive Personal Information to infer characteristics about you.
   

7. Right to Opt-Out of Sale, Sharing, or Use for Targeted Advertising: Some states allow residents to have the right to opt out of disclosures of Personal Information to third parties for monetary or other valuable consideration (which may be considered a “sale” even if no money is exchanged). You may also have the right to opt out of our “sharing” your Personal Information for the purposes of cross-contextual behavioral advertising. Our use of cookies, pixels, and similar tracking technologies may constitute “sharing” under some state laws.  
   
   To view the categories of Personal Information that we sell or share for advertising and marketing purposes, and the categories of third parties with whom we sell or share this information, please see Appendix A. We do not have any knowledge of the sale or share of Personal Information of those under 18 years of age. 
   
   To opt-out of the sale or sharing of your Personal Information, please visit our Data Rights Request Form.

In addition to these rights, pursuant to California’s “Shine the Light” law, California residents who share Personal Information with us have the right to request and obtain from us, once per year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for direct marketing purposes in the prior 12 months, as well as the type of Personal Information disclosed to those parties. If you would like to exercise this right, please use the contact information listed below to contact us.

We will not discriminate or retaliate against you for any exercise of these rights.

C. HOW TO EXERCISE YOUR PRIVACY RIGHTS

1. Submission 

If you would like to exercise your privacy rights, please fill out our Data Rights Request Form, call 1-888-704-6970, email us at [email protected] or mail your request to the attention of the Legal Department at MoneyLion Technologies Inc., 249 West 17th Street, 4th Floor, New York, NY 10011. You may exercise these rights yourself or via an authorized agent. If you have provided an authorized agent with a power of attorney pursuant to your state’s Probate Code, we will work directly with your authorized agent to complete your request. Where you have not provided an authorized agent with a power of attorney pursuant to your state’s Probate Code, we will reach out to you directly to confirm the authorized agent’s authority and collect the Verification Information (as defined below). 

We do not typically charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

2. Verification and Response 

We are required to verify the requests we receive when you exercise privacy rights. We (or third parties we engage to assist us) may ask you to provide certain information to us in order for us to verify your request, including your name, state of residence, email address, MoneyLion account login, date of birth, and other data points as needed to verify that you are who you say you are (the “Verification Information”). If we are unable to locate you in our records, or we are unable to verify your identity, we will be unable to fulfill your privacy rights request. 

If we are able to successfully verify your request, we will respond within the timeframes prescribed by applicable laws. 

3. Appeals

We make every effort to fulfill your request. However, we reserve the right to deny requests as permitted by applicable state law, such as where your identity cannot be confirmed, where we have a reasonable belief that the request is fraudulent, or where we must retain your information to comply with retention requirements under applicable laws. 

Depending on your state of residence, you may have the right to appeal a decision made in response to your request. 

If you would like to submit an appeal, you may do so via the Data Rights Request Form.   Our response to your appeal will inform you of decisions and actions in response to your appeal, including an explanation of the reasons for the decisions.

CONTACTING US:

If you have questions about this Privacy Policy or our privacy practices generally, feel free to contact us as follows: 

Email: [email protected]

Phone:1-888-704-6970

Postal Mail:

MoneyLion Technologies Inc.

249 West 17^th Street, 4th Floor

New York, NY 10011

Attn: Legal Department 

Appendix A

Collection, Use, and Disclosure of Personal Information

The following table describes how we currently collect, use, disclose, sell, and share your Personal Information, and how we have collected, used, disclosed, sold, and shared your Personal Information over the last 12 months (see next page).

All the below categories exclude text messaging originator opt-in data and consent; this information will not be shared with any non-affiliated third parties.

To the extent that you navigate to the “Products and Offers” tab on our App or page on our Site, please refer to the table in Appendix A of the Engine by MoneyLion Privacy Policy for a summary of  the collection, use, and disclosure, sale and sharing of your Personal Information by our corporate affiliate, ML Enterprise Inc., in connection with that service.

Categories Collected	Categories of Sources	Business Purpose(s)	Categories of Third Parties with Whom Personal Information is Disclosed	Categories of Third Parties with Whom Personal Information is Sold or Shared
Contact and Demographic Identifiers, such as your name, profile name (e.g., RoarTag), date of birth, address, phone number, email address, telephone number, military status, Social Security number, driver’s license number, passport number, or other similar identifiers.	Information you provide when using our Services. Information collected from our affiliates and non-affiliated third-party partners.  Information that you provide when you register for a MoneyLion account or enter a sweepstakes, giveaway, contest or promotion. Information sourced through identity verification and fraud prevention partners. Information from consumer reporting agencies, with your authorization. Information from public databases.	To personalize the services when you visit, access or use the MoneyLion Platform. For identity verification, fraud and information security purposes. To send you emails, subject to applicable laws, to provide you with information, to inform you of new events, product features, services, or content, to solicit your feedback, and to keep you up to date on MoneyLion. To perform “soft” credit inquiries  with your authorization. To respond to inquiries related to customer support or other requests. To build aggregated user profiles and segments. For cross-context behavioral advertising. To manage our relationships.	We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, database maintenance or storage, facilitating mailings, administering promotions, and providing marketing assistance. We may also disclose this information to consumer reporting agencies, either for the purpose of completing a “soft” credit inquiry (with your authorization), or as part of data studies, with the consumer reporting agencies acting in a service provider capacity, which are intended to test the reliability of our internal data and improve the quality of our Services.	We may share this information with our third-party business partners, including companies assisting us with targeted advertising and marketing, who may use this information combined with information collected via the use of cookies or internet activity information to deliver interest-based and personalized marketing to you.  We may share this information with our marketplace partners to improve efforts to target appropriate advertising content to you. This may include our affiliates.
Employment and Income Information, including your income and the frequency of your pay cycles.	Information provided when you connect a bank account that receives income through direct deposits, whether a RoarMoney bank account or an external linked bank account, or when you upload a pay statement.	To determine your eligibility for Instacash, our “earned wage access” product, which provides access to cash advances based on the anticipation that you will receive future, recurring direct deposits into an account that belongs to you. Your direct deposit information helps us to determine: – The amount of Instacash you qualify for.  – The days on which we may schedule repayments to be processed on any advances from your account, based on your pay days.  To personalize the services when you visit, access or use the MoneyLion Platform.To develop, provide, and improve the services. To conduct analytics such as usage trends. To build aggregated user profiles and segments.	We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, database maintenance or storage, facilitating mailings, administering promotions, and providing marketing assistance.	We do not sell or share this information.
Financial Account Information, including, for any MoneyLion account or external linked bank account, account balances, trading activity, account activity, direct deposit information, spending activity, and any other transaction data.	Information provided when you establish a MoneyLion account or connect an external linked account (for example, through Plaid Technologies or other bank verification partners).	To develop, provide, operate, enhance, improve, personalize and market our services and features.  To personalize the services when you visit, access or use the MoneyLion Platform. To conduct analytics, such as spending trends and insights.  To respond to inquiries related to support or other requests. To build aggregated user profiles and segments.	We disclose this information to service providers who help to perform certain business functions, for example, identity verification, fraud detection, trade execution, payment, and securities clearing services, and that prepare and mail account statements and transaction confirmations, and to provide  other services in connection with the operation of our business.	Where we have applicable permissions, we may share this information with our affiliates and marketplace partners to better personalize your offers and to improve efforts to target appropriate advertising content to you.
Consumer Reporting Information, such as your credit score, credit data status (for example, how long you’ve had a credit file or whether your credit is frozen), your credit, payment, and bankruptcy histories, and the type and amount of any outstanding loans.	Information you provide when using our Services. Information collected from our affiliates and non-affiliated third-party partners.  Information from consumer reporting agencies, with your authorization.	To assess your creditworthiness in connection with your application(s) for MoneyLion loan products. To provide features and functionalities requested by you, such as credit monitoring services. To personalize the services when you visit, access or use the MoneyLion Platform. To build aggregated user profiles and segments, which we may use to target “lookalike” audiences on other platforms.  For any other business purpose permitted under the Fair Credit Reporting Act and other applicable laws and regulations.	We disclose this information to service providers who help to perform certain business functions, for example, identity verification, fraud detection, trade execution, payment, and securities clearing services, and that prepare and mail account statements and transaction confirmations, and to provide other services in connection with the operation of our business.	We do not sell or share this information.
In limited circumstances, we may receive identity verification and authentication information, which may include photographic images, such as selfies or images from your government-issued photo identification. We partner with third parties to complete identity verification, some of whom may collect biometric identifiers, such as your faceprint, from these images.	Third-party service providers who facilitate, host, and run MoneyLion identity verification solutions.	For account authentication and identity verification purposes, and for use with fraud prevention technologies.	This information is collected and stored by third-party service providers who facilitate MoneyLion identity verification solutions.	We do not sell or share this information.
Location Information, based on your IP address and the geolocation of your device.	Your IP address and the geolocation of your device are automatically collected digital information.	To personalize the services when you visit, access or use the MoneyLion Platform. To geo-target users in specific Designated Metro Areas (DMAs) for marketing campaigns, as appropriate.	We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, database maintenance or storage, facilitating mailings, administering promotions, and providing marketing assistance.	We may disclose this information to our affiliates and marketplace partners in order to improve efforts to target appropriate advertising content to you.
Precise geolocation information, for consumers that sign up for Driver Score.	Precise location and device motion information is collected by our automobile insurance partner, Zendrive, and passed back to MoneyLion via an application program interface (API) endpoint.	To provide you with the opportunity to receive discounts and savings on automobile insurance with one of the providers in our network, based on your driving habits.	When you opt into our Driver Score feature, you authorize the disclosure of your precise location and device movement information to our third-party business partner, Zendrive, for the purpose of finding you discounts and savings on automobile insurance. Please review Zendrive’s Privacy Policy to ensure that you are comfortable with Zendrive’s privacy practices before enabling this feature.	We do not sell or share this information.
Support Information, including audio, electronic or similar information, or the information collected when you email or call our customer support center, which may include your name, email address, voice recording, and any other content or communications you send to or share with us.	Information you provide when you contact us.	To monitor communications and interactions with you to ensure the quality of our support services and the appropriate training of our people, and to respond to and resolve your inquiries.   To improve our products and services.  To undertake activities to verify or maintain the quality of our services, and to improve, upgrade, or enhance our services.	We may engage service providers to help to provide customer service to our users.   We may disclose certain of the information that you contact us about to our corporate affiliates.	We do not sell or share this information.
Survey Information, if you elect to complete surveys about your user experience.	Information you provide when you volunteer to complete a survey.	To improve and enhance our products and services, and for testing, research, and other product development purposes.	This information is used for internal purposes only, but we may occasionally engage a third-party service provider to help facilitate survey administration.	We do not sell or share this information.
Internet or other Electronic Network Activity Information, including information collected automatically when you interact with our services, such as your IP address, device ID and mobile device ID, mobile carrier, browser type and language, and location data (based on your IP address).	Automatically collected digital information.	To better tailor our services to you and to be able to provide service offerings available in your geographic area. We may also be able to pre-populate certain fields in our forms based on your geographic area, helping to streamline your experience and improve efficiencies.  To detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity, and prosecute the same.  To debug to identify and repair errors in our systems.  To audit by counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance with this specification and other standards.  To determine your general location in order to comply with applicable privacy regulations and serve you necessary notifications and/or consent mechanisms.	We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, database maintenance or storage, identity resolution, facilitating mailings, and providing marketing assistance. We disclose this information to marketing technology service providers who help to perform certain business functions, for example, analytics, identity matching, and providing marketing assistance.	We may share this information with third-party advertisers who help to improve efforts to target appropriate advertising content to you.
Tracking Information collected through cookies, pixels, web beacons, fingerprinting and other tracking technologies, which may include information about how you use our services, such as the types and categories of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities on our websites.	First party and third-party digital tracking technologies.	To keep you logged into your account, and to remember your settings and preferences. To collect website performance and analytics data.   To ensure accurate financial and billing data vis-à-vis our marketplace partners. To personalize and improve your experience while using our products and services.   For cross-context behavioral advertising. To build aggregated user profiles and segments, which we may use to target “lookalike” audiences on other platforms.  To detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity, and prosecute the same.  To debug to identify and repair errors that impair existing intended functionality.  For testing, research, analysis and product development. To audit by counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.	We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, database maintenance or storage, facilitating mailings, and providing marketing assistance.	Although we place many of these tracking technologies on our websites ourselves, these technologies may also be placed by third party service-providers or business partners, including analytics partners and marketing and advertising partners, in order to support certain functionalities and to better target advertising to you on their services.  In these cases, tracking information is shared with those third-party service providers or business partners.
Inferences drawn from any of this Personal Information to create a profile reflecting your preferences.	Information we infer about you based on your inputs when using our Services and based on your engagement with our platform and the platforms of our affiliates.	To provide you with personalized content and information related to financial products and services.  For cross-context behavioral advertising. To communicate with you by email, postal mail, or by text message/phone calls in order to: 1. Provide you with transactional information relevant to your account. 2. Provide you with alerts, opportunities, event registrations, surveys and promotions that we think may be of interest to you. 3. Provide you with content, such as articles or whitepapers, that we believe would be of interest to you.	We disclose this information to service providers who help to perform certain business functions, for example database maintenance or storage, facilitating mailings, and providing marketing assistance. We may disclose this information to our marketplace partners for purposes of their internal analytics.	We may share this information with our marketplace partners to improve efforts to target appropriate advertising content to you. This may include our affiliates.
Sensitive Personal Information, such as your precise location, Social Security number, driver’s license number, passport number, or other similar identifiers, and veteran or military status.	Information you provide when using our Services and information collected from our affiliates.    Information sourced through identity verification and fraud prevention partners. Information from consumer reporting agencies, with your authorization.	To provide you with personalized content and information related to financial products and services, including to provide information relevant to the underwriting models and eligibility criteria of our marketplace partners so that they can provide you with personalized offers.  To communicate with you by email, postal mail, or by text message/phone calls in order to: 1. Provide you with transactional information relevant to your account. 2. Provide you with alerts, opportunities, event registrations, surveys and promotions that we think may be of interest to you. 3. Provide you with content, such as articles or whitepapers, that we believe would be of interest to you.	At your direction, if the information you provide in one of our online forms or tools matches criteria required by our marketplace partners to offer their products or services, we disclose this information to our marketplace partners so that they may provide you with personalized offers.   We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, or database maintenance or storage. We may also disclose some of this information to consumer reporting agencies, either for purpose of completing a “soft” credit inquiry (with your authorization), or as part of data studies, with the consumer reporting agencies acting in a service provider capacity, which are intended to test the reliability of our internal data and improve the quality of our Services.	Please reference relevant rows above.
Any other information that you provide to MoneyLion, including, but not limited to, information posted to any public areas of the MoneyLion Platform when you engage with our content, including by commenting or using chat or messaging features, information volunteered in connection with participation in webinars or other events hosted through the MoneyLion Platform, ideas for new products or for enhancements, improvements, or modifications to our Services, to the extent that any of this “Unsolicited Information” includes Personal Information.	Information you voluntarily provide through use of and engagement with our platform.	To improve and enhance our products and services, and for testing, research, and other product development purposes. To personalize the services when you visit, access, or use the MoneyLion Platform. To conduct analytics, such as usage trends.	We disclose this information to service providers who help to perform certain business functions, for example, fraud detection, database maintenance or storage, facilitating mailings, and providing marketing assistance.	We do not sell or share this information.