Privacy policy

Effective Date: June 1, 2026

Our Commitment To Privacy

This website is developed and maintained by ModernFi, Inc., together with its subsidiaries and affiliates, including ModernFi Deposit Services LLC and ModernFi CUSO LLC (collectively, “ModernFi,” “we,” or “us”). For purposes of this Privacy Policy, the data controller is ModernFi Deposit Services LLC and can be contacted as explained below in the “How to Contact Us” section.

When you visit our websites, official social media sites, or other online properties, (collectively “Sites”), ModernFi may collect and use certain information about you. ModernFi recognizes that you care about how your information is used, and your privacy is important to us. This Privacy Policy explains how we may collect and use your information, particularly your personal information, and the choices you can make about what information you share.

We store and process personal information we collect through the Sites in the United States, and we maintain administrative, technical, and physical safeguards designed to protect that information from unauthorized access, use, or disclosure.

This Privacy Policy applies to all Sites offered by ModernFi to U.S. visitors, except where a product or service has a separate privacy notice that does not incorporate this Privacy Policy. Certain individuals also may be provided with additional privacy notices as described below.

• Depositors at Participating Financial Institutions: ModernFi does not maintain direct customer relationships with depositors. If you are a depositor at a financial institution that participates in a ModernFi network, your depositor relationship is with that financial institution, and the financial institution's own privacy notice governs how it collects, uses, and shares your information. ModernFi may receive information about depositors from participating financial institutions solely to facilitate deposit placement and recordkeeping requirements. ModernFi is not responsible for any participating financial institution's information practices or privacy notices, and we strongly suggest you review them.
• Participating Financial Institutions: If you are an authorized representative of a financial institution participating in a ModernFi deposit placement network and are accessing ModernFi's administrative portal or other secure, members-only areas of the Sites, confidentiality and security of information accessed through such portal are governed by the applicable participation agreement, custodial agreement, or other agreement between your institution and ModernFi. In connection with the establishment of a user account, ModernFi may collect certain information, including the name, email address, and contact information of the user. ModernFi is committed to protecting the confidentiality and security of information collected through such portals and uses a variety of security technologies and procedures to help protect personally identifying information from unauthorized access, use, or disclosure.
• Notice to California Residents: If you are a resident of California, please see our California Consumer Privacy Statement below.
• Notice to Residents of Certain Other U.S. States: If you are a resident of a U.S. state that provides privacy rights to consumers (including, for example, Colorado or Virginia), please see the Your Privacy Rights section below for information on your rights and how to exercise them.

Updates to our Privacy Policy

We ask that you read this Privacy Policy from time to time. ModernFi may modify this Privacy Policy at any time at its sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal information we have previously collected about you, we will obtain your consent where required by law. We will indicate at the top of this Privacy Policy the date it was last updated. If ModernFi intends to further process collected personal data for a purpose other than that for which the personal data was collected, prior to that further processing, we shall provide you with information on that other purpose with additional information necessary to ensure fair and transparent processing.

Information We Collect

ModernFi collects information about you when you interact with our Sites. When you use our Sites, we collect information about one or more devices associated with you that you use to access the Sites, such as a computer, mobile phone, or tablet. We collect, store, and use information you provide to us from one or more devices associated with you when you use our Sites, including when you log into the Sites from one or more of your devices, register for an account, complete a web form, add or update your account information, apply for a job at ModernFi, or otherwise correspond with us regarding the Sites. Information that we collect may include:

• Identifiers such as name, physical address, and social security number, when you create an account to log in to our Sites;
• Login credentials, including username and password, for your ModernFi account;
• Biometric information (such as a facial image collected for identity verification);
• Social media handles;
• Voice recordings (such as when you call ModernFi's Customer Service);
• If you use our application on your mobile device, we also may collect mobile device information such as operating system and hardware type, numbers or codes that are unique to your particular device, device information, default device language, the location of your device, and app usage information;
• Information you provide through customer service interactions and that you provide about your experience with ModernFi, including responses to surveys offered by ModernFi;
• If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply;
• If you tell us where you are by allowing your mobile device to send us your location (geolocation data), we may store and use that information for fraud prevention purposes;
• Your subscriptions to our newsletters;
• In addition to the above, we may need to verify your identity in order for you to use some aspects of the Sites. For purposes of verification, we may also collect the following personal information from you. If requested for compliance reasons, providing this information is mandatory to use our Sites:
  • Valid government issued identification such as a passport or driver's license;
  • Other identification documents as deemed appropriate;
  • Tax-related information such as a tax identification number (“TIN”) or social security number (“SSN”); and/or
  • Any other information as may be required to verify your identity in accordance with applicable laws and regulations.
• We may also collect information at other points in our Sites where it is clear we are collecting such information; and/or
• Other information you choose to provide, such as through our “Contact Us” feature, emails, or other communications (such as with customer service), referrals, on social media pages, or in registrations and sign-up forms.

Information Collected Via Technology

Information We Automatically Collect

We automatically collect information about the devices you use to interact with our Sites. We automatically collect your device identifier, web browser type and version, IP address, approximate geolocation (derived from IP address), and browsing information collected through cookies and similar technologies. We also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal information you have provided.

We collect certain information by automated means when you visit our Sites, such as how many users visited our Sites and the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors. We collect this information through various means such as “cookies,” “web beacons,” and similar technologies.

Cookies

Like many companies, we use “cookies” on our Sites. Cookies are pieces of code placed on your devices when you visit certain websites. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor, and to help us identify features of the Sites in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website.

Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of the functionality of our Sites.

Web Beacons

Certain pages on our Sites contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information, such as the IP address of the computer that downloaded the page on which the beacon appears; the URL of the page on which the beacon appears; the time the page containing the beacon was viewed; the type of browser used to view the page; and the information in cookies set by the third party.

IP Addresses

An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our Sites, we view the IP address of the device you use to connect to the Internet. We then use this information to determine the general physical location of the device and understand the general locations of our Sites visitors. We also use this information to enhance our Sites.

Collection Of Data In Connection With Advertising

ModernFi does not currently serve third-party advertising on the Sites and does not sell personal information or share personal information for cross-context behavioral advertising.

Information Collected From Other Sources

We may also collect information about you from third parties, such as marketing partners, identity verification services, anti-fraud services, and other service providers. We may also supplement the information we have about you with information received from other sources such as commercially available sources (e.g., data brokers and public databases). The information we receive may include demographic data such as professional role and employer, your interests and other information that is necessary or useful to assist our marketing efforts or for user verification, authentication, fraud detection or to comply with regulatory requirements.

How We Use The Information We Collect About You

We may use your information for the following purposes:

To Manage And Improve Our Business Operations

• To provide you with access to the Sites;
• To serve the functions of the Sites;
• To manage everyday business needs, such as administering and improving the Sites;
• To analyze the performance and functioning of the Sites;
• To analyze how you use the Sites and to perform other market research;
• For internal operations, including troubleshooting, testing, and analytics; and
• To assist us in developing new products and improving our products and services.

To Ensure A Secure Online Environment And Comply With Legal Obligations

• Protect against and detect fraud, abuse, or other unlawful activity;
• Enforce our Terms and Conditions, other corporate policies, and industry standards; and
• Comply with all applicable laws and reporting obligations.

Third-Party Analytics Services

We use Google Analytics and may use other industry-standard analytics services to monitor website traffic and to help analyze how users use our services. These services use cookies to collect information such as how often users visit our Sites, the pages they visit, and what other sites they used prior to coming to our Services. We use the information we get from these analytics services to improve our Sites, Application(s), and Services.

Do Not Track

Our Sites do not respond to “do not track” signals transmitted from web browsers. At this time, we do not alter our data collection and use practices upon receipt of such a signal. Where required by applicable law, we will honor Global Privacy Control (GPC) signals as opt-out preferences for sale or sharing or personal information.

Business Structure Changes

We reserve the right to disclose and transfer all information related to our Sites, including personal data:

• To a subsequent owner, co-owner, or operator of one or more of the Sites; or
• In connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our assets, or other corporate change, including, without limitation, during the course of any due diligence process.

Information We Share

We share your information with third-party service providers who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services or communicating with you. These third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. These third parties have no independent rights to the data.

We may also share information with participating financial institutions in our deposit placement network as necessary to facilitate the provision of deposit placement services, subject to applicable confidentiality obligations. We may also share information with our custodial agent and with other service providers as necessary to operate the networks.

In addition, we will disclose information about you:

• If we are required to do so by law or legal process;
• To law enforcement authorities or other government officials, as necessary;
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or suspected or actual illegal activity;
• If necessary to protect the vital interests of a person; to enforce our Terms and Conditions;
• To protect our property, services, and legal rights;
• To prevent fraud against ModernFi, our affiliates, business partners, or participating financial institutions;
• To support auditing, compliance, and corporate governance functions; or to comply with any and all applicable laws.

In certain situations, ModernFi may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Links To Other Websites

Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from our Sites. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of our Sites, we are not responsible for their content, any use of the websites, or the privacy practices of any of those websites.

How We Protect Your Information

We maintain administrative, technical, and physical safeguards designed to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using our Sites. Sensitive and private data exchange between the Sites and their users happens over an encrypted communication channel using industry-standard transport-layer security. However, no method of transmission over the Internet or electronic storage is fully secure, and we cannot guarantee absolute security.

Retention Of Information

ModernFi retains all personal information for the duration of the relevant business relationship or, where required, in accordance with its information management policies and schedules, subject to applicable laws. The criteria used to determine our retention periods include the nature and sensitivity of the information, the purposes for which we process it, our legal and regulatory obligations, and applicable statutes of limitation. When deleting personal information based on a request from the individual to whom the information relates, ModernFi will make reasonable efforts to ensure that all instances of the information are deleted in their entirety.

Children's Privacy

Our Sites are not directed to children under 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will delete that information.

How To Contact Us

If you have any questions or comments about this Privacy Policy, please contact: privacy-info@modernfi.com.

If you would like to update your contact information or preferences, have your information removed from our mailing lists, or no longer want to receive marketing e-mails, you may do so by:

• Adjusting the settings in the account you created through our Sites; or
• Unsubscribing via the links contained in emails from us.

California Consumer Privacy Statement

LAST UPDATED: February 2, 2026

This California Consumer Privacy Statement (“Statement”) supplements the ModernFi Online Privacy Policy and applies solely to California residents. This Statement does not apply to ModernFi personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”).

Notice Of Collection And Use Of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver's license number, passport number, and other similar identifiers.
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information.
• Protected Classifications: characteristics of protected classifications under California or Federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status.
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Biometric Information.
• Online Activity: internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements.
• Geolocation Data.
• Sensory Information: audio, electronic, visual, and similar information.
• Employment Information: professional or employment-related information.
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use your personal information for the purposes described in our ModernFi Privacy Policy and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sale And Sharing Of Personal Information

We do not sell or share personal information for cross-context behavioral advertising purposes.

California Consumer Privacy Rights

You have certain rights regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.
• Correction: You have the right to request that we correct inaccurate personal information that we maintain about you.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and, (2) the identity of those third parties.

If your request relates to personal information that you have provided to a financial institution that uses one of ModernFi's deposit placement services, and not directly to ModernFi, you should submit the request directly to that financial institution.

How To Submit A Request

To submit an access, correction, or deletion request, please email us at privacy-info@modernfi.com or submit a request through our webform. To submit a Shine the Light request, email us at privacy-info@modernfi.com. If you designate an authorized agent to make an access, correction, or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in the “How to Contact Us” section of our Privacy Policy.

Verifying Request

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, and the email and physical addresses associated with your ModernFi account, one or more recent transactions, and the last four digits of one or more ModernFi-branded cards associated with your account. If you have never had an account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that ModernFi does not maintain information about non-accountholders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Your Privacy Rights

For residents of certain U.S. states, you have the following additional privacy rights regarding your personal information:

• Access and Data Portability: You can request confirmation of whether we process your personal information and obtain access to the data we maintain about you, including a copy of that information in a portable and readily usable format.
• Correction: You can request that we correct inaccuracies in your personal information.
• Deletion: You can request that we delete personal information that we have collected from you, subject to certain exceptions (for example, information we must retain for legal compliance).
• Opt-Out of Sale, Sharing, or Targeted Advertising: You have the right to direct us not to sell your personal data to third parties, or share it for cross-context behavioral or targeted advertising purposes. ModernFi does not sell personal data or disclose it for targeted advertising, and we will honor any opt-out preferences you express (including through supported browser signals such as the Global Privacy Control). If we ever use your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects, you will also have the right to opt out of such processing.
• Sensitive Personal Data: We will not process your sensitive personal data (e.g. information about your racial or ethnic origin, health, biometrics or other information defined as “sensitive” under applicable law) without first obtaining your consent, where required by law. We will only use or disclose sensitive personal information for purposes necessary to provide our services or as otherwise permitted by law. You may also have the right to limit or opt out of certain uses or disclosures of your sensitive personal data, which we will accommodate as required by applicable laws.
• Submitting Requests: To exercise the rights described above, you (or an authorized agent acting on your behalf) may submit a request to us via email at privacy-info@modernfi.com or through our online web form. We will take steps to verify your identity (and, if applicable, the authority of your agent) before fulfilling your request, for your security.
• Appeals: If we decline to take action on a request you have submitted, you may appeal our decision. To appeal a decision, please reply to our response or contact us at privacy-info@modernfi.com with the subject “Privacy Request Appeal,” and we will review and respond within the time period required by law. If you are unsatisfied with our appeal response, you may contact the Attorney General in your state of residence.
• Non-Discrimination: We will not discriminate against you for exercising any of these privacy rights. This means, for example, we will not deny you goods or services, charge you a different price, or provide a different level of quality for services if you choose to exercise your privacy rights.