At Ezra Financial Inc. (“Ezra”), we exist to help people like you build wealth one step at a time, starting with employer-sponsored emergency savings.  Before you provide any information to us, we encourage you to read this Privacy Policy (the “Policy”) carefully.  

When you access our website tryezra.com (the “Site”) or interact with us through other means (for example, making a purchase, signing up for a newsletter, or submitting a contact form), you are agreeing to our Terms of Use and consenting to the Policy below.

This Policy describes how Ezra collects, uses, discloses, processes, and deletes personal information; what rights and choices you may have with respect to your personal information; how you may contact us, and how we protect your personal information when you visit the Site or access or use products, services, and related applications offered by Ezra (collectively, the “Services”).  

The Services may contain features or links to websites and services provided by third parties and other products and services that may be made available to you through a third-party website (“Third-Party Service”). Any information you provide to a Third-Party Service is subject to the policies, if any, of their respective operators governing privacy and security, even if accessed through or used by our Services. We have no control over, and assume no responsibility for or about any Third-Party Service, no matter how you got there (even if it was through our Service). And, this Privacy Policy does not cover Third-Party Services—even ones we use—so we encourage you to learn about third parties’ privacy and security policies before providing them with information.

1. What We Collect and How We Use It

The information that Ezra collects about you depends on the context of your interactions with us and the choices that you make, your location, and applicable law, and might include:

• Non-identifying information, like anonymous usage data

• Identifying information, like your email or date of birth

We may collect information from you directly (e.g., via an online form) or from third party systems with your consent (e.g., a link to your employer or bank). 

Below, we describe the types of information we may collect about you, and how we collect it:

• Personal information: we may collect personal information in order to identify you, customize your experience, provide our Service to you, to make our Service better and develop new products and functionality, to support you if you reach out and if we need to reach out to you for any reason.

• Third party services: we may collect personal information from you directly or from a Third Party Service. We’ll use this information to provide our Service to you and to operate our business. This information may include but isn’t limited to your full name, email address, physical address, phone number, Social Security number, employee ID number, drivers license image or number, date of birth, and any other relevant information.

• Automatically collected: like most other sites you visit, our Services may automatically collect your IP address, geographic information, details about your computer (like operating system or browser type and version), and other information - including a history of the pages you view. We may use many methods to collect this information, including cookies, web beacons, and other trackers. We’ll use the information to provide you with our Services - for example, saving you from re-entering data or customizing content - as well as to monitor the performance of our services and any associated marketing. 

• Phone calls: we record all outreach to our customer service lines, including phone calls and SMS messages.

• Aggregated data: we’ll collect and aggregate data continually, in an effort to build and provide a better Service. We may share this data with our affiliates and partners. Any shared information will not identify you. 

2. When and How We Share Information with Others

We don’t share, sell, trade, rent, or use your information in any way other than to deliver the best service we can to you. This may include sending you information about the Services. And, in order to provide you the Services, we may need to share your information with certain third parties such as employers, financial institutions, software vendors, contractors, and their affiliates.  Generally, we’ll only share your information if:

You consent to us doing so.

• We need to share to provide you our Service, including via  a third party. If we share with a third party, we generally limit both sharing and use to only what’s necessary for the third party to complete their work.

• Required to do so by law, in a good-faith belief that such sharing is necessary to comply with the law, or in order to cooperate with law enforcement or other governmental agencies - for example, in response to a court order.

• Only in de-identified forms, with third parties like universities for research to understand the impact of Ezra’s programs.

• Ezra is acquired, sold, merged, restructured, sells assets, takes on debt financing, becomes insolvent, bankrupt, or enters receivership, and the information is transferred as a business asset. 

3. Your Choices About Your Information

We offer you choices regarding the collection, use, and sharing of your personal information and we’ll respect the choices you make. But, if you decide not to provide us with the personal information that we request, you may not be able to access all of the features of the Services.

You may:

• Update or amend any information you have provided to us

• Opt out of marketing communications

By using our Service (or associated Third Party Service), contacting us at care@tryezra.com, or writing to us at the address listed on our website. 

While any changes you make will be reflected in active databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Even if you opt out from receiving marketing messages from us, you may continue to receive administrative and transactional messages from us regarding the Services.

4. Security of Your Information

We maintain physical, technical and administrative safeguards to protect your personal information. Our servers are located in the United States and to provide you with the Services, we may store, process and transmit information in the United States. Personal information may also be stored locally on the device you use to access the Services.  When we collect sensitive information, that information is encrypted,transmitted, and stored in a secure way.

5. Data Retention

We only retain personal information for as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required or authorized by law.  A customer may request deletion of their data at any time, but certain identity and transaction information must be retained for legal purposes.

6. Children

This site is only intended for adults of legal working age, and especially not children under the age of 13. If you believe a child has signed up for our services, please contact us so we can remove their information: care@tryezra.com. 

7. Changes to the Privacy Policy

We may update this policy at any time. You can determine when this Policy was last revised by referring to the “Effective date” at the top of this Policy.  If we make significant changes to this Policy, we will notify you through a prominent notice on our Site or Services.  We don’t need to let you know about any such changes in advance, and you agree to the latest version of the policy by continuing to use this site and our services. 

8. Additional Disclosures for California Residents

The following disclosures pertain specifically to California residents.

1. California Privacy Rights

If you are a California resident, you may have the following rights under the California Consumer Privacy Act (“CCPA”) with respect to your personal information.

• Right to Know/Access. You have the right to request (subject to certain exemptions):

  • The categories of personal information we collected about you;

  • The sources from which we have collected that personal information;

  • Our business or commercial purpose for collecting, selling, or sharing that Personal Information;

  • The categories of third parties to whom we have disclosed that personal information; and

  • A copy of the specific pieces of personal information we have collected.

• Right to Correct. You have the right to request that we correct inaccuracies in your personal information.

• Right to Delete. Subject to certain exceptions, you have the right to request deletion of personal information that we have collected from you. Please note, Ezra is not obligated to delete personal information that is necessary to provide services that you request or required to comply with applicable laws.

• Right to Opt-Out. Under the CCPA, California residents may have the right to opt-out of the “sale,” or “sharing,” of personal information. California CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA), the following categories of personal information: Identifiers, and Internet or Other Electric Network Activity Information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old. 

• Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you may have the right to limit the use and disclosure of “sensitive personal information,” as defined under the CPRA. However, we do not engage in activities triggering this right.

• Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

2. How To Exercise Your Privacy Rights

To exercise any of these rights, California residents may email us at care@tryezra.com. 

In the request, please include “California Privacy Rights Request” in the first line of the description and specify which right you are seeking to exercise. We will confirm receipt of your request within 5 business days. 

Ezra will need to confirm your identity before fulfilling the request, so please provide us with your name, street address, city, state, and ZIP code. We may require additional information from you to help us verify your identity and process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.

If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

3. Notice of The Right to Opt-Out of Sale or Sharing

To the extent Ezra sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by emailing us at care@tryezra.com. 

Effective date: October 22, 2024