Privacy
Policy.

1. About This Policy

This Privacy Policy (the “Policy” ) are a legal agreement between you, the user (“customer”, “users”, “clients”) and Capura Tech, Inc., its subsidiaries, affiliates, agents and assigns ("Capura,", “Capura Tech”, the "Company," “management”, "we," "us," or "our"), collect, use, share and protect information in connection with your use of our website, our mobile application, and offered products and services from us and/or our bank partners (collectively the “Services”)

State-specific notices or a separate financial privacy notice may also apply. When another notice applies to a particular bank account, payment card, consumer report, biometric process, or partner service, that notice supplements this policy and controls for the subject it covers.

When we say “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly. Personal Information does not include information that cannot be reasonably linked to you. When data is deidentified (as defined under applicable U.S. privacy laws), we maintain it in deidentified form and do not attempt to reidentify the information.

The term "Site" includes (1) all websites and all devices or mobile applications operated and owned by Capura Tech Inc, that collect personal information from you and that link to this Privacy Policy; (2) pages within each such website, device, or mobile application, any equivalent, mirror, replacement, substitute, or backup website, device, or mobile application; and (3) all pages within each such website, device, or mobile application.

2. Scope and Relationship to Financial Privacy Notices and Related Parties

This Privacy Policy applies to personal information that Capura Tech Inc controls or processes for its own business purposes through the Services. It does not apply to an employer, payroll processor, bank, payment network, identity-verification vendor, consumer reporting agency, or other third party when that third party independently determines how it processes information. Those parties may provide their own privacy notices.

Capura Tech Inc is not a financial institution which are covered by the Gramm-Leach-Bliley Act (GLBA), though nonpublic personal information will be handled under the applicable GLBA privacy notice for enhanced due diligence. Information, entities, or processing activities governed by GLBA, the Fair Credit Reporting Act (FCRA), or another law may be exempt from some state privacy-law provisions. We will provide rights and notices required by the law that applies to the information and activity at issue.

3. Information We Collect

Additional Collected Information

• Directly from you when you create an account, connect payroll or bank information, request EWA, enroll in premium services, contact support, exercise a privacy right, or provide documents.
• From your employer, payroll processor, timekeeping system, or employment-data provider when you authorize access or when the employer participates in the program.
• From banks, payment processors, payment networks, ACH providers, and financial-data connectivity providers when you authorize account access or when they process a transaction.
• From identity, fraud, security, sanctions, and account-ownership vendors.
• From consumer reporting agencies only when a separate, legally valid authorization or other permissible purpose applies.
• From public records, government sources, professional advisers, bank partners, regulators, law enforcement, and other parties as permitted by law.

4. Information Collected by Cookies and Web Beacons

We use various technologies to collect information, which may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage, and determine whether an email has been opened and acted upon.

Our mobile application may also include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your use of these applications. In addition, some mobile devices come with a resettable identifier that allows us and our service providers to identify your device over time for marketing purposes.

5. Technical and Navigation Information

We may collect your computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.

6. Device Data Information

When you use our mobile applications or the mobile versions of our Site, we may collect the following device information:

Locale Data: This includes specifics about the user’s regional settings and preferences, such as the type of calendar, the language of the keyboard, and other cultural and linguistic details relevant for data formatting.

Accessibility Settings: Information regarding the accessibility features that are activated on the device, enhancing user interaction based on their needs.

Motion and Orientation Data

• Device Motion: Includes details on the device’s movement, captured through sensors like accelerometers and gyroscopes, to track acceleration and orientation.
• Accelerometer: Detects the device’s acceleration and direction, indicating how fast and in what direction the device is moving.
• Magnetometer: Used to measure magnetic fields, aiding in navigation applications to determine directional heading like where "North" is.
• Communication Data: Information gathered from SMS and Short Code Messaging services, focusing on how these communication tools are utilized.
• Device Performance Metrics: Data related to the device’s operational performance, such as battery level, available storage space, and memory utilization.
• Network Details: Includes information about the internet connection, such as the IP address, and whether the device is connected to a Wi-Fi or cellular network.

7. How We Use Information

Subject to the limitations we describe in our privacy policies, we may disclose your Personal Information for business purposes, with strict restrictions on how our partners can use and disclose the data we provide. We may also disclose it at your direction or in other ways that are in accordance with applicable U.S. privacy laws.

We may use automated tools for fraud prevention, identity verification, security, payroll verification, and EWA eligibility. We do not use profiling based on a credit report or credit score for the ordinary EWA model. If we later engage in targeted advertising, a legally defined sale, or profiling that produces a legally significant decision, we will update this policy and provide required notices and opt-out mechanisms as on the appropriated time .

The information we collect, use and disclose about you will vary depending on how you interact with our Services. For the products covered by this Notice, here’s a summary of:

• Create, authenticate, secure, maintain, and support your account.
• Verify identity, age, state of residence, employment, employer, payroll source, account ownership, and eligibility.
• Calculate accrued wages and available EWA amounts; prevent access beyond verified earned wages; detect duplicate access across providers or pay periods where lawful and technically available.
• Show transaction terms, deliver funds, process separately authorized fees or tips, schedule and process ACH entries, reconcile payments, issue refunds, and maintain transaction records.
• Operate optional subscriptions, alerts, budgeting tools, and other financial-wellness features.
• Prevent, detect, investigate, and respond to fraud, identity theft, unauthorized activity, security incidents, sanctions concerns, abuse, and violations of our agreements.
• Provide customer support, respond to complaints and disputes, correct errors, process privacy requests, and provide accessible or translated support where offered.
• Maintain, debug, test, secure, analyze, and improve the Services and develop new features consistent with this policy.
• Comply with laws, licenses, court orders, regulatory requests, bank-partner duties, payment rules, audit requirements, record-retention obligations, and legal holds.
• Create aggregated or de-identified information and use it for lawful analytics, risk management, product improvement, and reporting, subject to controls designed to prevent reidentification.
• Send service-related communications and, only with any required consent, send marketing communications.
• Work to prevent harmful behavior and keep people safe on our Service.
• The information we use for these purposes may be automatically processed by our systems. But in some cases, we also use manual review to access and review your information.
• Seeing if our Services are working correctly, such as troubleshooting, and fixing it when it’s not working.
• We do not use payroll or bank-account data for unrelated behavioral advertising, resale, or general-purpose model training unless we first revise this policy, obtain any required consent, and confirm that the use is lawful and consistent with partner contracts.

8. How We Share Your Information

We may share any of the information collected, except Communication Data, with third parties when it is permitted by law. For example:   Vendors

We work with third parties to provide, maintain, service and improve our Services; to improve app functionality, fraud prevention, security and compliance.

We may also share information to process transactions that you authorize or to fulfill your requests, such as communicating with participating merchants to determine if you are eligible to receive rewards or promotions.

Legal reasons

To respond to subpoenas, court orders, or legal process.

In order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Use, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites, or Services.

With our Bank Partners as required to support their products and services available through Wage Lift.

As otherwise required or allowed by law.

With your consent

We may also share your Personal Information with other third parties, with your consent.

Providers and Third-Parties that we may disclose information

9. Sensitive Data and Consent

Before the use of our Service, we are required to verify your identity. You authorize us and our service providers to:

Collect and verify identifying information, including your full legal name, date of birth, residential address, phone number, and Social Security number or other government identifiers, and, where needed, documentary evidence such as a government-issued ID;

Screen your information against sanctions and watch lists, including lists maintained by the U.S. Office of Foreign Assets Control (OFAC);

Use identity-verification and fraud-prevention services. Where a verification vendor is acting as a consumer reporting agency, we will comply with the Fair Credit Reporting Act, including providing any required adverse-action notice. We do not obtain or use credit scores or traditional credit reports to decide whether to offer you Advances.

We may suspend the Service or decline transactions where identity cannot be verified or where we identify sanctions, fraud, or security concerns, and we may be required by law to report certain activity without notifying you.

10. How to Update Your Information

If you wish to access personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information through our Site. Alternatively, you can send an email that includes your contact information to contact@capuratech.com to request any corrections to your personal information. You may also email us if you wish to deactivate your Services, but even after you deactivate your Services, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

11. How long do we keep your Personal Information

We keep Personal Information, including sensitive Personal Information, as long as we need it to provide our services, comply with legal obligations or protect our or other’s interests. We decide how long we need information on a case-by-case basis.

Here’s what we consider when we decide

• If we need it to operate or provide our services.
• The feature we use it for, and how that feature works.
• How long we need to retain the information to comply with certain legal obligations.
• If we need it for other legitimate purposes, such as to prevent harm; investigate possible violations of our terms or policies; promote safety, security and integrity; or protect ourselves, including our rights, property or service.

12. How We Secure Your Information

We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information.

Examples of measures we have taken to protect your information include, but are not limited to:

• The use of industry-standard encryption while transmitting and storing information.
• Mobile application session timeouts to ensure your information is protected when you put down your device without logging out.
• Passwords are only known by you. No employee, contractor or Third-Party Site has access to your Capura password. We will never ask for your password through our customer service teams.
• Two-factor authentication is provided to ensure your account can only be accessed by the device you register with.
• Our systems are periodically audited for security flaws.

13. How can you exercise your rights provided under applicable U.S. privacy laws?

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:

• Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices. For residents of certain states, this may include a list of third parties (as defined by applicable law) to whom we have disclosed your Personal Information.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
• Right to Opt Out of Targeted Advertising: The right to opt out of the processing of your Personal Information for purposes that may be considered “targeted advertising” under applicable U.S. privacy laws, including information obtained from your activities on nonaffiliated websites or online applications.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

To submit a request to exercise your rights, and as applicable, to appeal a consumer rights action, please contact us at contact@capuratech.com.

Please note that to protect your information and the integrity of our products, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID and related information to verify identity.

14. How We Update Our Privacy Policy

We reserve the right, at our discretion, to make changes to this Policy from time to time, so please review it frequently. You may review updates to our Privacy Policy at any time via links on www.capuratech.com/privacy.

By using our Services, you agree to accept electronic communications and/or postings of revised versions of this Policy on www.capuratech.com/privacy and agree that such electronic communications or postings constitute notice to you of the revised version of this Policy. Changes take effect immediately upon posting.

If you have questions or concerns regarding this Policy or other Services, please contact contact@capuratech.com.

15. Contact for more information

If you have additional questions about this Policy or how to exercise your rights under applicable U.S. privacy laws, please contact us: contact@capuratech.com; If you have questions regarding the Policy or the practices of Capura or by regular mail at Capura Tech Inc., 4 PEDDLERS ROW #138, NEWARK, DE 19702, UNITED STATES