Information Collection - BFF Prime collects, retains, and uses information for the purpose of providing financial solutions and administering account relationships. We collect information from applications or other forms, which may include but is not limited to surveys and questionnaires. We may also collect information about transactions, information through cookies, and information we receive from consumer reporting agencies.

Use of Information - BFF Prime uses personal information in ways that align with the purposes for which it was originally requested and collected. For example, BFF Prime uses information to process customer requests and transactions, provide additional information about products and services, or to evaluate financial needs. BFF Prime collects and uses information to administer our business and deliver quality service. This may include advising consumers and customers about our products or services, those of our affiliates and our business partners, and other opportunities BFF Prime believes may be of interest to our customers.

Information Sharing - The primary federal regulation governing the collection, use and disclosure of customer information is Regulation P. As required by Regulation P, BFF Prime provides the required Notice to bank customers and consumers. The Notice is provided at account opening and as changes occur.

Sharing with BFF Prime's Third-Party Service Providers and Joint Marketers - BFF Prime uses third-party service providers to assist with providing quality products and services to our customers. We may share the customer information we collect with third parties to facilitate the offering, administration, collection, and delivery of products and services under controlled circumstances designed to protect the privacy of our customers. We require third parties to comply with applicable laws and regulations as well as our requirements regarding security and confidentiality of such information.

Fair Credit Reporting Act (FCRA) permits BFF Prime to share customer transaction information (e.g., number of monthly deposits made) and experience information (such as account balance) as well as information obtained from our customers.

Fair and Accurate Credit Transactions Act (FACTA) Section 214 provides consumers with the ability to limit the circumstances by which an affiliated institution may use certain information received from another affiliate to market to the consumer.

Banks and Financial Institutions: You may choose to link a bank account to add money to an account, receive a direct deposit, or other related services. When you link a bank account, we receive financial information related to that account, including your account balance, and may also receive transaction history and information about the account owner. The amount of information we receive depends on your financial institution's own privacy policy. We use third-party bank account verification providers, such as Plaid Inc. (“Plaid”), to connect your BFF Prime Account with your bank account(s). Plaid’s use of your personal information is governed by Plaid’s Privacy Policy.

Service Providers and Linked Account Data: We use third-party service providers to perform services for us, including to help us process and authorize your payments and to facilitate ownership of account transfers. By using our Services, you are authorizing us and our third-party service provider(s) to take actions on our behalf such as debiting your account using your selected payment method when you initiate such action.

Credit Reference Agencies: We use these services that may provide information related to your credit file, such as your credit score, credit inquiries, and payment history.

Social Media: When you interact with our Services through social media networks, we may receive information about you that you permit the social media network to share. The data we receive is dependent upon your privacy settings within the social media network.

Job Applicant-related Third Parties: we may receive personal information from job applicant-related third parties, such as job application platforms, your current employer, references, background check providers and recruiters.

Publicly Available Sources: We may also collect personal information from publicly available sources to, for example, contact you if we are otherwise unable to reach you, or, to send advertising or promotional materials or to personalize our Services.

Information about you and your computer or mobile device such as your hardware model, operating system information, unique device identifier, mobile network information, device performance information, and information about the device’s interaction with our Services. Note that the BFF Prime App may periodically recollect this information in order to stay up to date. You can review and change permissions for some information the BFF Prime App has access to in your device privacy settings.

Transaction data, when you use our Services, including if you give us access to collect your financial data from your other accounts, for example payments into and out of such accounts including the date, time, amount, merchant or beneficiary details, or ATMs associated with the transaction.

Usage data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your activity information on our Services.

Location information. We use your information to protect against fraud and verify your address without the need of address documents. If you have location services in the BFF Prime App enabled, we may track your geolocation and your IP address. You can withdraw your consent at any time by disabling location permission for the BFF Prime App within your device settings. However, if you disable or do not grant geolocation permissions, we may require you to provide proof of residency through documentary methods, or certain account functionalities may be restricted or disabled. We may use third-party providers to help provide location-based services through mobile systems and we may make information available to such providers to enable them to provide their location-based services, provided that such third-party providers may use the information only in accordance with this Privacy Policy.

Comply with applicable laws, including disclosing information to fraud prevention agencies

Comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements

Enforce our Privacy Policy

Protect the rights, privacy, safety, or property of you, BFF Prime, or others

Advertising - We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the BFF Prime App, Ad ID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Social Media Widgets and Advertising - BFF Prime may use social media platforms like Instagram, Facebook, Twitter, and LinkedIn. We may display targeted advertising to you through these social media platforms. These companies have interest-based advertising programs that allow us to direct advertisements while those users are on the social media platform. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel. These activities are governed by the privacy policies of those social media companies that provide them.

Third Party Partners - We may use third-party analytics on our Services. For example, we use Mixpanel to better understand how you interact with our Services. The information we obtain through our Services may be disclosed to or collected directly by these third parties. To learn more, see Mixpanel.

Cookies - We and our third-party partners may also use cookies and tracking technologies for advertising purposes. BFF Prime uses various technologies to collect information, and this may include sending cookies to your computer or mobile device. “Cookies” are small text files that are stored on your device or hardware by a website. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies, please visit All About Cookies (https://www.allaboutcookies.org/).

Email Pixels - We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Analytics - We may also use analytics tools such as Mixpanel to collect information regarding visitor behavior and visitor demographics on our mobile app. This data is not tied to any Personal Information. For more information on how Mixpanel uses this data, go to https://mixpanel.com/legal/privacy-policy.

Online Tracking and “Do Not Track” Signals - We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of our website and use that information to send targeted advertisements. Our website currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Updating your Information - Once you have registered for an account, you may be able to update or correct your profile information details and preferences by accessing your account settings through the BFF Prime App, or by contacting us at support@ugly.cash, or make a phone call to our number +1 844 735 0769.

Deactivating your Account - We do not delete information about you upon deactivation of your account. Although your deactivated status is reflected promptly in our user databases, we may retain the information you submit for a variety of purposes, including legal compliance, backups and archiving, prevention of fraud and abuse, and analytics. Upon deactivation, you will no longer receive emails from BFF Prime and links to third-party financial accounts and services will automatically terminate. If you have a money transfer transaction pending at the time you deactivate your account, your link to this service from BFF Prime will terminate but your pending transfer will continue to completion and your bank account will remain open.

Opting-Out of Certain Online Ads - To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you can visit the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative’s (“NAI”) at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. Please note: When you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us. It means that the online ads that you see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

GLBA-Covered Data - Our GLBA Privacy Notice provides information about how you can limit your sharing options for our financial services and GLBA-covered data.

California Consumer Privacy Act (“CCPA”) covers California residents about whom BFF Prime has collected PII from and is applicable to any business that collects and stores PII of California residents, regardless of if the business is located in California. For purposes of this section the term “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. Personal information does not include information that has been de-identified or that does not fall within the above definition of personal information.

Right to Know- The right to request the following information from us about our use of your personal information:

Right to Delete - You have the right to request the deletion of your personal information that is collected or maintained by us (subject to exceptions the law provides). Please note that you may no longer be able to use our Services if you delete your personal information.

Right to Opt-Out of Sale - You have the right to opt-out of the sale of your personal information by us. We do not sell personal information.

Right to Non-Discrimination - You have the right to not receive discriminatory treatment by us for the exercise of the privacy rights described above.

Submitting a request via email to support@ugly.cash, or

Calling us at +1 844 735 0769.

Children Online Privacy Protection Act (“COPPA”) is a federal law that imposes specific requirements on operators of websites and online services to protect the privacy of children under 13. It is BFF Prime’s policy NOT to (i) sell any customer or consumer PII to third parties, and (ii) collect PII from individuals under the age of 13, as defined by COPPA (Children Online Privacy Protection Act), and under the age of 16 (per the CCPA). The BFF Prime App is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us.

Vermont State Law - BFF Prime does not share information of customers with a Vermont address with affiliated companies.

Privacy and Opt-Out Notice - Our customers provide private information to BFF Prime during daily business, and we are committed to treating such information responsibly. Our customers expect privacy and security for their banking and financial affairs. To that end, we provide the Privacy and Opt-Out Notice to all consumers at account opening, enrollment for a new service, if there are changes to our privacy practices, and annually thereafter, if required by law.