Last Rev. Date: 05/07/2021

Ahead Financials, LLC Privacy Policy

Ahead Financials, LLC (“Ahead” or “we, us, ours,”) respects your privacy and is committed to protecting your personally identifiable information (“PII”) that may be collected through your use of our website or mobile application (together, “Site”) or in applying for or receiving any of our products or services (“Services”). This privacy policy (“Privacy Policy”) describes how we collect and use your PII and how you can control that use.

Please read this Privacy Policy carefully.  By using our Site or Services, you agree to our collection, use, and sharing of your PII as described in this Privacy Policy.

California Residents:  Please click here to view the additional Privacy Notice for California Residents.

When you sign of for an Ahead Account, we may collect and use your PII on behalf of the bank responsible for issuing your Account through our Services (“Bank Partner”). Our Bank Partner’s privacy practices are subject to their own privacy notices, which may differ from Ahead’s. We encourage you to review our Bank Partner’s privacy notices found at www.aheadmoney.com/bancorp-privacy-notice.

Information that We Collect

Through your use of our Site and Services, we may collect PII, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific consumer. PII may include, but is not limited to, your first and last name, physical address, Social Security number, phone number, date of birth, and checking account information. We collect the following types of information:

INFORMATION PROVIDED BY YOU

During any application with us or through general inquiries made about our products, we will collect certain PII from you, including, but not limited to, contact information (such as name and email), which we will use to contact you. We may request additional PII that is necessary to process any application submitted by you, such as your physical address, Social Security number, mobile phone number, date of birth, bank account information and numbers, employment and income information. Additionally, we may collect additional PII to verify your identity, for security-related purposes or other administrative purposes, such as bank account information, pay stubs, or other forms of identification. In order to provide Services to you, we may on occasion supplement the PII you submit to us with information from third-party sources, such as information from consumer reports. If you contact us via e-mail or phone, tell us your story by sharing a video related to your Ahead experience, or otherwise provide us with information about yourself, we will maintain records of your correspondence and interactions. This may include any questions, comments, or suggestions you make during these interactions. You may also provide us with the email addresses of your contacts and include a personal message to your contacts if you choose to participate in our referral program.

ACCOUNT AND TRANSACTION INFORMATION

We collect information about your use of our Services. For example, in processing a payment with you, such information would include your name, amount of payment, and your bank account information, including account numbers, routing numbers, debit card numbers and similar information. Further, your use of certain features of the Services requires us to collect account numbers, balances, and other information about your bank accounts unrelated to your relationship with us. We may collect this information through a payment processor that facilitates a transfer to your Ahead Account or through a third-party secure access tool.

Other information that we collect during your use of our Services includes your transaction history, payment history, and account balance. We collect your Ahead account transaction history from our processor and Bank Partner. We collect this information in order to provide you with the Services, in particular preparing your statement, resolving errors and unauthorized transfers, and verifying your identity in certain circumstances. For the security of your information, we also collect tokens from online services and payment systems to help us process your account transactions.

DEVICE AND USAGE INFORMATION

We may automatically collect the following types of information as you use our Site and Services.

COOKIES AND OTHER TRACKING TECHNOLOGIES

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes.

If you reject cookies through your browser’s settings, you may still use our Site, but your ability to use some areas of our Site will be substantially limited. For example, you cannot create an account with us or use our products without accepting cookies.

We use a software technology called tracking pixels (a.k.a. web beacons or clear gifs) that help us better manage content on our Site by informing us what content is most effective. Tracking pixels are tiny graphics files with unique identification codes which are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are included on individual Web pages as part of a website’s content.

We also use technologies such as device fingerprinting to identify your device and keep track of your preferences, prevent fraudulent activity, improve Site security, and assess the performance of the Site.

AGGREGATE INFORMATION

Statistical or aggregated information that we use does not directly identify a specific person, but it may be derived from your PII.

Third Party Data Collection

Some content or applications on the Site may be provided by third parties, including advertisers, ad networks and servers, analytics companies, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your PII or they may collect information, including PII, about your online activities over time and across different websites and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising.

What Does Ahead Do with Your Personal Information?

Why?

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

What?

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

  • Social Security number and income

  • Account balances and payment history

How?

All financial companies need to share customers’ personal information to run their everyday business. Please refer to the information below in which we list the reasons financial companies can share their customers’ personal information; the reasons Ahead chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Ahead share?

Can you limit this sharing?

For our everyday business purposes— such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations

Yes

No

For our marketing purposes — to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We don't share

For our affiliates' everyday business purposes— information about your transactions and experiences

Yes

Yes

For our affiliates to market to you

Yes

Yes

For non-affiliates to market to you

No

We don't share

To Limit our Sharing

Federal law gives you the right to limit some but not all marketing from our affiliates. You may limit our affiliates from marketing their products or services to you based on your personal information that we collect and share with them. This information includes transaction and experience information, but also the type of information found in consumer reports, such as information from third party sources.

Note: For new customers, we may begin sharing your PII no sooner than thirty (30) days from the date we provided this notice. If at some point you no longer use our services, we may continue to share your information only as explained in this notice.

Your choice to limit marketing offers from our affiliates will apply until you tell us to change your choice. To limit marketing offers from our affiliates:

We reserve the right to share information, including PII, with third parties, as described below:

How We Use and Share Information

We use PII we collect in the following ways:


Who we are




Who is providing this notice?

Ahead Financials, LLC and LendUp Global, Inc.



What we do




How does Ahead protect my personal information?

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



How does Ahead collect my personal information?

We collect your personal information, for example, when you:

  • Apply for an Ahead account

  • Use your debit card

  • Give us your contact information or tell us where to send the money

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



Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes

  • Affiliates from using your information to market to you.

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



What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account – unless you tell us otherwise.



Definitions




Affiliates

Our affiliates include financial companies related by common ownership or such as:control. They can be financial and non-financial companies.

  • Ahead Financials, LLC

  • LendUp Global, Inc.



Non-affiliates

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

Ahead does not share with non-affiliates so they can market to you.



Joint marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you.

Ahead doesn’t jointly market.



Other Important Information




California Residents: We will not share your information with non-affiliated third parties except as permitted by California law. For example, we may share certain information with affiliates or third parties that perform services on our behalf. We will limit sharing with our affiliates to the extent required by California law.

Nevada Residents: We are providing you this notice under state law. If you prefer not to receive marketing calls from Ahead, you can be placed on our internal Do Not Call List by calling us at 1-833-33-AHEAD. If you would like more information about our telemarketing practices, you may contact us at Ahead, 1750 Broadway, Suite 300, Oakland CA 94612 or support@aheadmoney.com. For more on this Nevada law, contact Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; call 702-486-3132; or email BCPINFO@ag.state.nv.us.

Correction

If your PII changes, or if you no longer desire our Service, you may correct, update, or request that we delete your PII by contacting us at: 1-833-33-AHEAD or support@aheadmoney.com. If you have an account with us and your account is in good standing, you may also correct or update your PII by logging into your account on our Site and updating your information there.

Security

The security of your PII is important to Ahead. We maintain reasonable physical, technical, and administrative security measures to protect against unauthorized access to our systems including, but not limited to, firewalls and data encryptions. Additionally, we enforce physical access controls to our facilities and your personal information is only available to authorized employees as job responsibility required. If you have any questions about Ahead’s security of PII, please contact 1-833-33-AHEAD.

Other Websites

The Site may contain links to or links from third party sites that are not owned or controlled by Ahead. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to review the privacy policies of these third party sites before you disclose your PII.

Browser Do Not Track

The Site is not currently configured to respond to Do Not Track signals.

Children’s Privacy

Our Site and Services are not intended for use by children. If we learn that PII has been collected from a child under the age of 18, we will promptly take reasonable steps to delete the information from our systems. If you believe that Ahead has mistakenly or unintentionally collected information from a child under the age of 18, please contact 1-833-33-AHEAD.

Applicable Law

This is a United States-based Site that is subject to United States law. This Site is controlled, operated, and administered by Ahead from its offices within the United States of America. This Privacy Policy is provided in accordance with and subject to applicable United States law. If you are accessing this Site from a location outside the United States, you hereby agree that your use of this Site and our collection and use of your PII is subject to this Privacy Policy.

Updates to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we decide to make material changes to this Privacy Policy, we will post those changes to this Site in a manner that we deem is appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You agree to these future updates by continuing to use our Site or Services after they have been posted. You can always obtain a copy of the most updated Privacy Policy by accessing our website at: www.aheadmoney.com/privacy.

Privacy Notice for California Residents

Effective: November 2020

Privacy Policy (“Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. In the event of a conflict between the terms of the Privacy Policy and this Privacy Notice, this Privacy Notice will control with respect to the subject matter contained herein.

Where noted in this Privacy Notice, the CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication ("B2B Personal information") from some of its requirements.  Further, this Privacy Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.  This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Ahead Financials, LLC ("Ahead")

Information that We Collect

The Ahead website (https://www.aheadmoney.com)or mobile application (together, the "Site") collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("Personal Information"). The types of information collected are set forth under the "Information that We Collect" heading in the Privacy Policy and the following section of this Privacy Notice.

The Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Personal Information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Collection, Use, Disclosure, and Sharing of Personal Information

We may collect, use, disclose, and/or share the Personal Information we collect for one or more of the business purposes disclosed in the Privacy Policy.

Ahead will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Ahead may disclose your Personal Information to a third party for a business purpose (see Personal Information Sales Opt-Out and Opt-In Rights) When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

  • Service providers,

  • Affiliates,

  • Data aggregators,

  • Advertisers,

  • Partner,

  • Parent or subsidiary,

  • Internet cookie data recipients

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Although the CCPA covers the rights of California residents, Ahead has extended the CCPA protections to all of our customers regardless of whether they are California residents.

Access to Specific Information and Data Portability Rights (Right to Access)

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Although the CCPA covers the rights of California residents, Ahead has extended the CCPA protections to all of our customers regardless of whether they are California residents.

Ahead does not provide these access and data portability rights for business-to-business (B2B) Personal Information. B2B Personal Information is personal information reflecting a written or verbal communication or a transaction between Ahead and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of Ahead and whose communications or transaction with Ahead occur solely within the context of Ahead conducting due diligence regarding, or providing or receiving a product or service to or from Ahead.

Deletion Request Rights (Right to Request Deletion)

You have the right to request that Ahead delete any of your Personal Information that we collected from you and retained, subject to certain exceptions, including to comply with a legal obligation. See below for a full list of reasons why Ahead may need to deny your deletion request. Ahead will comply with requests to delete Personal Information by either: permanently and completely erasing the Personal Information on its existing systems with the exception of archived or back-up systems; de-identifying the Personal Information; or aggregating the Personal Information. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. For example, Ahead cannot delete your Personal Information if retaining the information is necessary for Ahead to comply with a legal obligation.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

We do not provide these deletion rights for business-to-business (B2B) Personal Information.

Exercising Access Rights (including Data Portability), and Deletion Rights

To exercise the access rights (including data portability) and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

By submitting a request after you’ve logged in, the verifiable consumer request will:

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, if you already have an Ahead account but are not signed in, you will need to enter your email address and password on file with Ahead in order for us to verify your identity.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days to respond), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights (Right to Opt Out)

Ahead does not sell your Personal information. The CCPA does provide California consumers with a right for consumers to direct a business that sells Personal information about the consumer to third parties not to sell the consumer’s Personal information. This CCPA protection is not applicable to Ahead because Ahead does not sell your information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to ConsumerPrivacy@aheadmoney.com.

Changes to Our Privacy Notice

Ahead reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Ahead collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by:

© 2021 Ahead Financials, LLC. All Rights Reserved.
1750 Broadway, Suite 300, Oakland, CA 94612

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