Privacy Policy

This Privacy Policy describes how 2147M Equity LLC DBA PayBridger ("PayBridger," "we," "us," or "our") collects, uses, shares, and protects your personal information in connection with our website, mobile application, and related services. This Policy applies to information we collect both online and offline.

By accessing or using PayBridger's website (paybridger.com), Mobile App, or Services, you agree to this Privacy Policy and consent to our collection and use of your information as described herein. Our Terms and Conditions govern any conflicts between those terms and this Privacy Policy.

Changes to This Privacy Policy

We may update this Privacy Policy at any time.

Updates become effective immediately upon posting on paybridger.com, unless otherwise stated.

1. INFORMATION WE COLLECT

1.1 Personal Information

"Personal information" means information that identifies, relates to, or can reasonably be linked to you.

We may collect the following personal information:

• Name
• Address
• Email address
• Telephone number
• Employment information
• Income information
• Pay schedule information
• Transaction history
• Bank account information (via Plaid)
• Device and usage data

We do not knowingly collect personal information from individuals under 18. If we discover information from a person under 18, we will close the account and delete all associated data. To report concerns, email us at support@paybridger.com.

1.2 Information You Provide Directly

You provide personal information when you:

• Create an account
• Verify employment and bank information
• Request an Earned Wage Access transfer
• Contact customer support
• Respond to surveys or submit feedback

If you communicate with us by phone, the call may be recorded for quality assurance and security.

1.3 Information We Collect Automatically

When you use the Mobile App or website, we may automatically collect:

• Device type
• Operating system
• App interactions (page views, session events, navigation)
• IP address
• Browser type
• Performance and diagnostic data

We use this information to enhance functionality, improve user experience, prevent fraud, and ensure service reliability.

1.4 Information We Receive From Third Parties

To provide services, we use third-party data providers such as Plaid. Through these services, we may collect:

• Bank transaction history
• Balance information
• Deposit and withdrawal patterns
• Identity verification data
• Payroll and employment information

Access is authorized by you when you link your bank account or employment data source.

1.5 Cookies and Tracking Tools

PayBridger may use cookies and similar technologies to:

• Maintain session integrity
• Improve website functionality
• Measure marketing performance
• Personalize user experience

You may adjust cookie preferences through your browser settings.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your information to:

• Create, manage, and maintain your PayBridger account
• Verify employment, income, and pay schedule
• Facilitate Earned Wage Access advances
• Process repayments
• Prevent fraud and unauthorized activity
• Provide customer support
• Improve our Services
• Communicate updates, alerts, or important notices
• Offer relevant PayBridger products or features

We may also use aggregated or de-identified data for analytics, research, and service improvement. Aggregated data contains no personal identifiers.

3. HOW WE SHARE YOUR INFORMATION

We may share your personal information with:

3.1 Named Third-Party Service Processors

We share your information with the following named third-party service processors who assist in operating the PayBridger platform:

• Plaid Technologies, Inc.: Used for bank account verification, identity verification, income verification, and transaction history analysis under the Consumer Reporting Agency (CRA) framework. Plaid's privacy policy is available at plaid.com/legal.
• Increase: Used for bank payment processing (ACH/RTP) for membership billing, advance disbursement, and repayment collection.
• Twilio Inc.: Used for SMS-based phone number verification (Twilio Verify) and transactional SMS notifications including transfer confirmations and repayment reminders. Twilio's privacy policy is available at twilio.com/legal/privacy.

Each processor is contractually required to handle your data only as directed by PayBridger and in compliance with applicable law, including the Gramm-Leach-Bliley Act (GLBA) and, for California residents, the California Consumer Privacy Act (CCPA).

3.2 Legal Purposes

We may disclose information when required to:

• Comply with applicable laws
• Respond to subpoenas or lawful requests
• Protect our rights, users, or the public
• Prevent fraud or security breaches

3.3 With Your Consent

We may share information for specific purposes you authorize.

3.4 We Do Not:

• Sell your personal information
• Share your information for cross-context behavioral advertising
• Share your information with third parties for their own marketing

4. HOW WE PROTECT YOUR INFORMATION

PayBridger implements administrative, technical, and physical safeguards to protect your information, including:

• Encrypted data transmission
• Encrypted data at rest
• Firewalls and network protections
• Multi-factor authentication
• Access controls and auditing
• Secure data centers

Your account is protected by a password and other security features. Never share your password with anyone.

Email is not secure. Do not send sensitive information to us via email.

4.1 Your Responsibilities

To help keep your data secure:

• Use a strong, unique password
• Never log into your PayBridger account on public or shared devices
• Avoid clicking suspicious links
• Notify us immediately if you suspect unauthorized access

Report suspicious contacts at support@paybridger.com.

5. CHANGING OR UPDATING YOUR INFORMATION

You can update your personal information within the PayBridger app or by contacting us at:

support@paybridger.com

6. DATA DELETION AND RETENTION

You may request deletion of your personal information by emailing support@paybridger.com with subject line "Data Deletion Request."

PayBridger will delete your personal information within 30 days of a verified request, except where retention is required by law or necessary to:

• Complete pending transactions
• Comply with legal obligations
• Resolve disputes or enforce agreements
• Prevent fraud

Retention schedule:

• Account data: deleted 90 days after account closure
• Transaction records: retained 5 years per financial regulations
• Identity verification data: retained 3 years or 1 year after account closure, whichever comes first
• Fraud flags: retained indefinitely for security purposes

7. COMPLAINTS OR CONCERNS

We take privacy seriously. If you have questions or concerns about your personal information, contact us:

Email: support@paybridger.com

Mail:

2147M Equity LLC DBA PayBridger
1178 Broadway, 3rd Floor #489
New York, NY 10001

8. SUMMARY OF PERSONAL INFORMATION SHARING (GLBA NOTICE)

Why?

Federal law gives consumers rights regarding how financial companies handle personal information. This section explains what we collect, how we share it, and how federal law applies.

What We Collect:

Examples include:

• Social Security number
• Checking account and routing information
• Employment and income
• Transaction history
• Payment history

We continue to share information as described even after your account is closed, unless you request deletion.

Reasons We Share Personal Information

Who We Are

2147M Equity LLC DBA PayBridger

How We Protect Your Information

We use security measures that comply with federal law, including:

• Secure systems
• Limited access
• Encryption

How We Collect Information

We collect information when you:

• Open an account
• Provide income or employment information
• Connect your bank account
• Request a wage advance

We may also collect information from:

• Employers
• Payroll providers
• Financial institutions
• Fraud prevention services

State Considerations

California & Vermont: We will not share personal information with nonaffiliates except as permitted by law.

9. CALIFORNIA PRIVACY NOTICE (CCPA)

California residents have the following rights under the CCPA:

Right to Know: You may request disclosure of the personal information we have collected about you, the sources, the business purpose, and the third parties we share it with.

Right to Delete: You may request deletion of your personal information subject to certain exceptions. See Section 6.

Right to Opt-Out: PayBridger does not sell personal information. There is nothing to opt out of.

Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your rights contact:

Email: support@paybridger.com

Subject line: "California Privacy Request"

Note: Because PayBridger provides financial services regulated by the Gramm-Leach-Bliley Act (GLBA), some information may be exempt from CCPA. We will honor all requests to the fullest extent permitted by law.

Advertising Measurement

We use the Meta Pixel, a measurement tool from Meta Platforms, Inc., to understand how people reach PayBridger from our ads on Facebook and Instagram and to measure whether they sign up. The pixel collects information about your visit (such as pages viewed and actions taken, like creating an account) and shares it with Meta for ad measurement and ad delivery optimization.

Where required by law, we ask for your consent before this tracking runs, and you can accept or reject it. You can change your choice at any time from the "Cookie settings" link in the footer of our website. Rejecting this tracking does not affect your ability to use PayBridger.

Contact Us

Email: support@paybridger.com

Mail:

2147M Equity LLC DBA PayBridger
1178 Broadway, 3rd Floor #489
New York, NY 10001