CABICASH SOLUTIONS, INC
(DBA UALETT)

Privacy Policy

This Cabicash Solutions, INC. doing business as Ualett (“UALETT”) Online Privacy Policy describes our practices in connection with information that we collect through UALETT or any of our Third party Software Providers, including DWOLLA, Astra, Twilio and PLAID which enables secure bank account verification, transaction history, and balance checks, which are essential for financial transactions and user authentication through the APP, any other websites other than http://www.ualett.com that may be operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “App”), through our social media pages and apps used by us collectively, (our “Social Media Pages” ) as well as through text messages, and HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including the Websites, the Apps and our Social Media Pages, the “Services”). As used in this Privacy Policy, The Trademarks UALETT, UALETT App, or Cabicash Solutions, INC., the licensor” or “we” or “us” or “our” refers to Cabicash Solutions, INC. (Doing Business As/DBA UALETT).
This Online Privacy Policy supplements other applicable policies, practices and privacy notices that may relate to specific business relationships you have with Cabicash Solutions, INC. (DBA UALETT) and our trusted partners, or to certain products or services, as described in the particular privacy notice. We will use and share any information that we collect from or about our U.S. account holders and visitors to the Services in accordance with our Terms of Service and Conditions.

With your consent, we may share your personal data with business partners that request it in order to provide you with a better experience when using our Services or the services of the business partner (including their independent marketing purposes subject to their privacy policies), to determine your financial information, or to assist customers in onboarding. Those trusted business partners and Third Party providers include, but are not limited to: Dwolla, Twilio, Pave, Astra, Credolab, TrueLoyal , Argyle, Plaid, TrueAccord, Foundever, OneSignal, Seon, Taktile, Runa, Insurify, inter alia.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the text message services.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared or sold with any third parties for promotional or marketing purposes, excluding aggregators and providers of the text message services.

You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to you or your service provider for the duration of your business relationship with Ualett, solely to help them identify you or your wireless device and to prevent fraud. Please refer below regarding how Ualett handles your data.

By providing Personal Information to us through the Services, you agree to the terms and conditions (T&C) of this Online Privacy Policy.

Personal Information

Personal Information We May Collect Online
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, such as information you provide via forms, downloads, surveys, applications or other online fields, including:

Full Legal Name (First Name, Last Name) (as on government issued ID).
Driver’s License information.
Physical, residential address (No P.O. Box).
Email address.
Telephone number.
Banking Account number.
Routing number.
Debit Card.
Date of birth.
Username and password.
Profile picture (optional).
Business profile or company you are affiliated (Lyft, Uber, Via, Juno, Curb, inter alia).
IP address.
Current billing address.
Mobile/cellular phone Number.

If you share with us any Personal Information relating to other people or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Online Privacy Policy.

authority to do so and to permit us to use the information in accordance with this Online Privacy Policy.

How We May Collect Your Personal Data

We and our Third Party Software Providers, may collect Personal Information in a variety of ways, including:

• Through the Services: We may collect Personal Information through the Services, for example, when you sign up for our Cash Advance product, newsletter, or request information about one of the services and products, such as Cash Advance or any other receivable you may apply for.
• From Other Sources: We may receive your Personal Information from other sources, such as financial institutions, publicly available information, public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties such as banks and other financial institutions.

We Use Personal Information as following:

We may use Personal Information or data:

• To respond to your inquiries and process your requests, and provide you with the best customer service.
• To send administrative information to you, such as information regarding the Services and changes to our terms, conditions, or remittance reminders and requests.
• To allow you to apply for products and services, evaluate your eligibility for such products and services, communicate with you regarding your application and provide you with related customer service.
• To send you targeted marketing communications that may be of interest to you.
• To personalize your experience regarding the Services by presenting products and offers tailored to you.
• To send you emails through Third Party Providers for remittance in or if you are unable to make the relevant remittance for your Cash Advance.
• For our business purposes, such as data analysis, audits, risk controls, fraud detection, monitoring and prevention, developing new products, enhancing, improving or modifying our products and services, identifying usage trends, determining the effectiveness of our promotional campaigns and for the purpose of expanding our business activities.
• As we deem to be necessary or appropriate: (i) under applicable law; (ii) to comply with laws and regulations and to comply with legal and compliance processes and law enforcement requirements and inquiries; (iii) to respond to requests from public and government authorities; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates or partners, including but not limited to Dwolla, Twilio, Foundever, TrueLoyal, Credolab, Seon, OneSignal, Astra and Plaid; (vi) to protect our rights, privacy, security, safety or property, and/or that of our affiliates, Third Party Software Provider, Dwolla, Astra, you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

This is How Cabicash Solutions, INC. dba Ualett (UALETT), May lawfully disclose your Personal Data

Your Personal Information will be shared consistent with the regulations, guidelines and mandates of the U.S. Consumer Financial Protection Bureau, the Gramm-Leach-Bliley Act of 1999, the Fair Credit Reporting Act, the Electronic Fund Transfer Act, The Right to Financial Privacy Act, the Telephone Consumer Protection Act and all other applicable U.S. regulations and industry best practices. For example, Personal Information may be shared: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (vii) to allow us to pursue available remedies or limit the damages that we may sustain; and (viii) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other users of the Services and the general public

Please be reminded that any information you post or disclose on or through our profile pages and blogs and other services to which you are able to post information and materials (including our Social Media Pages) will become public information, and may be available to users of the Services and to the general public. We urge you to use discretion when deciding to disclose your Personal Information, or any other information, on the Services.

Other Information

Other or Additional Personal Data We May Collect

“Other Information or Additional” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser and device information including, but not limited to: keystroke dynamics, user interface interactions and similar information.
• Device information including, but not limited to: device hardware type, operating system, language, inter alia.
• App usage data
• Information collected through cookies, pixel tags, mobile software development kits (SDKs) and other technologies
• Demographic information and other information provided by you
• Aggregated information

How We May Collect Other Information

We and one of our Third Party Software Providers, Dwolla, Astra as Ualett’s payment processor, may lawfully collect Other Information in a variety of ways, including:

• Through your browser or device: Certain identifying information is collected by most browsers or automatically through your device. We use this information to ensure that the Services function properly.
• Through your use of the UALETT App: When you download and use the UALETT App, we and our Third Party Software Provider, Dwolla, Astra may track and collect UALETT App usage data.
• Please be aware you will need to agree to additional terms and conditions when downloading the UALETT App. Especially those from Third Party Software Provider, Dwolla and Astra, in order to successfully complete your request or any other operation through our platform.
• Please note that in most instances, a download of the UALETT application alone will NOT be enough to determine your eligibility to access our services. We urge you to carefully review our T&C and this Privacy Policy for a complete list of all the information and documentation you are required to submit online to apply, and determine your eligibility for a Merchant Cash Advance.
• Using cookies: We may use cookies and similar technology on our Application and in our emails. Cookies are very small text files that may be stored on your computer or handheld device when you visit a website or view images or click on a link in an email. This technology works to allow for your ability to navigate between web pages efficiently and remember your preferences. In emails, cookies help us to understand whether you have opened the email and how you have interacted with it.
• Our platform provides you with more information on this technology, how and where we use the technology, and how you can select your preferences or opt out. UALETT, as a mobile application, functions with cookies. Cookies help us give you a better service e.g. showing relevant tailored advertisements to you across all UALETT services and platforms. By using the UALETT mobile application, you agree to our use of cookies.
• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure and compile statistics about usage of the Services and obtain analysis on response rates.
• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. We use IP Addresses for purposes such as calculating usage levels of the Services, preventing fraud, helping diagnose server problems and administering the Services.
• Physical Location & Time Zone (s): We may collect the physical location of your device to provide you with personalized location-based services and content and to ensure that you are in our required footprint.
• From you: Other personal data or information, such as your location or your preferred means of communication, is collected when you voluntarily provide this information.
• Application Version Installed
• Mobile Phone Model (IOS, Android, etc.)
• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

Metadata

Uallet collects metadata from Installed Applications (and in the case of Credolab, this metadata does not include any Personal Information).  Ualett also collects financial data about your Installed Applications to better evaluate your cash advance application and calculate a more accurate risk score. The data is only accessed once and collected in the form of metadata.

We tell you How We May Use and Disclose Other Information collected or provided by you

Please note that we may use and disclose Other Information for any purpose we and our Trusted Business Partners deem appropriate, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and protect it for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location, your name and company you are affiliated with, telephone number and/or e-mail address). If we combine any Other Information with Personal Information, we will treat the combined information as Personal Information.

Our Third Party Software Provider(s)

In order to guarantee a satisfactory experience, Cabicash Solutions, INC. dba Ualett, interacts with several Third Party Providers that are listed in this Online Privacy Policy.

This Online Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any Third Parties, including any third party operating any site or service. For instance, Dwolla, Pave, Astra, Twilio, Credolab, TrueLoyal, OneSignal, Seon, Argyle, Plaid, Foundever, TrueAccord, inter alia.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Instagram, Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

Tailored Advertising

Online Behavioral Advertising (OBA) helps us serve you marketing messages that are relevant to you, based on your behavior on the web and the usage of UALETT. If You don’t want to receive targeted advertising, you can opt out of OBA. This would remove your information from collection across UALETT, our affiliates, and Third Party Software Providers.

If you choose to opt out of advertisements or sharing any personal data with us, you will still see ads, but they will not be targeted to you, specifically.

Your Security Comes First

We seek to use reasonable organizational, technical and administrative measures designed to protect Personal Data within our platform. However, if you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account or someone you have referred to use our services, has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

If you reasonably believe that the information you have shared with us is at risk, you are entitled:

• To request access to, or erasure of, the personal data we have.
• To request us to restrict the processing of the personal data we collect and have.
• To object to us processing any personal data relating to you.
• To obtain certain personal data from us in a format that can be transferred electronically to a third party.

Your Choice Based on our Advertising Strategies

If you no longer want to receive marketing-related texts or emails from us on a going-forward basis, you may opt out by following the instructions contained in such email. We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages, especially those in connection to your Ualett App account.

Keeping your Ualett App account and information up-to-date is very important. If you believe your account information is incomplete or not current, please contact us by email contact@ualett.com or calling the following number +1 (844) 844 2488.

Use of our Services by MINORS

The Services are not directed to individuals under the age of twenty-one (21), and we request that these individuals do not provide Personal Data through the UALETT App. The Services that we provide are only eligible for those who are 21 and older, in accordance with the Credit Card Accountability, Responsibility and Disclosure Act of 2009.

Governing Law

The Services are controlled and operated by Cabicash Solutions, INC., dba Ualett (UALETT), and Third Party Software Providers and other trusted business partners, in the United States, and are not subject to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services you consent to the transfer of information to countries outside of your state or country of residence.

Online Updates of Our Privacy Policy and APP Version

From time to time and as needed, we may change this Online Privacy Policy. Please take a look at the “Last Updated” legend at the top of this page to see when this Online Privacy Policy was last revised and updated. Any changes to this Privacy Policy will become effective when we post the revised Online Privacy Policy on the Services.

Notice that UALETT may change or cancel the availability of any services at any time with or without previous notice. You are not entitled to use the App or any other services provided by Cabicash, INC., dba Ualett in any way that could harm them or impair anyone else’s use of the Services. You may not use the platform to try to gain unauthorized access to any service, data, account or network by any means. Your use of the Services following these changes means that you accept the revised Online Privacy Policy.

Getting in Touch with Us

If you have any questions about this Online Privacy Policy, please contact us by email contact@ualett.com or dialing the following number +1 (844) 844 2488.