IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING AN ACCOUNT

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To help the government fight the funding of terrorism, money laundering activities and other financial crimes, federal law requires us to obtain, verify and record information that identifies each person who applies for our products and services.

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What this means for you: When you apply for or receive a financial product or service offered by or in connection with our relationship with a financial us or one of our business partners, we may ask for your name, mailing address and other information or documentation, such as a copy of your driver’s license or other identifying documents, to verify your identity and otherwise comply with the applicable federal laws and regulations.

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1. Changes and Updates to this Privacy Policy. VIVA reserves the right to revise or update this Privacy Policy at any time, and you agree to be bound by those revisions or updates. VIVA will notify you of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Last Modified” date on the Website. Your use of the Website thereafter constitutes your agreement to and acceptance of the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. This Privacy Policy is incorporated as part of the Terms of Use or other agreements that apply with respect to your use of the Website. If you do not agree to the terms and conditions of this Privacy Policy, including having your PI used in any of the ways described in the Privacy Policy, do not provide us with your information. If you do not agree to any terms of the Privacy Policy, please do not use the Website.

2. Contact and Electronic Communication. By using our Website or providing your PI to us, you agree that we can communicate with you electronically regarding any legal, regulatory, technical, security, privacy, and any administrative or consumer notification obligations that may be related to your use of the Website or the Products and Services. If you have any questions about this Privacy Policy, you can contact us at:

   Email: info@viva-finance.com

   Phone: +1 (678) 685-8834

   Address: 112 Krog St NE STE D145, Atlanta, GA 30307

3. Summary of Privacy Policy.

   This Privacy Policy notifies you of:

   • What types of non-personally identifiable information (“Non-Personal Information” or “Non-PI”) is collected from you when you use our Website;

   • What PI of yours is collected from you through the Website and the Products and Services;

   • How your PI is used by VIVA;

   • With whom the PI may be shared;

   • What choices are available to you regarding collection, use, and distribution of your PI;

   • The kind of procedures VIVA employs in an effort to hinder the unauthorized access, deletion, alteration, use, or disclosure of information you provide to Viva using the Website;

   • How you can correct any inaccuracies in the PI you provide to use using the Website.

4. Information Collection. We collect two types of information from you when you use our Website or the Products and Services. We collect PI and Non-PI which we describe below.

5. Non-Personally Identifiable Information. VIVA gathers certain broad, Non-PI about the use of the Website and the Products and Services, including, by way of example and without limitation, the number of unique visitors to the Website, the frequency with which you visit the Website. We also combine your information with other information in way that it is no longer associated with you and share that aggregated information. VIVA gathers this Non-PI data so it can learn, for example, which pages of the Website are the most and least viewed by visitors and which third-party websites are referring visitors to the Website. The Non-PI data helps VIVA determine the extent to which visitors use certain parts of the Website or the Products and Services. In connection with these activities, VIVA may use the following standard technologies to collect information:

   • Login Information. When you use our Website, we automatically collect and store certain information in our server logs. This type of information includes details of how you used our Website, IP address information described below, webpages within our website which have been viewed by a visitor, data and time of visits, domain type, device event information such as crashes, system activity, hardware, settings, browser types, browser language, the date and time of your request and referral URL.

   • Cookies. A cookie is a small, removable data file that is stored by your web browser on your computer. VIVA uses cookies to, among other things, identify your computer during a particular visit to the Website and analyzes your behavior during a particular visit. Most web browsers provide you with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent. If you choose to decline cookies, however, you may not be able to take advantage of all aspects of the Website.

   • Pixel Tags. Pixel tags, also known as beacons or clear GIFs, help VIVA better manage content on the Website by informing it of what content is effective. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, pixel tags are embedded invisibly on web pages.

   • IP Addresses. VIVA collects and analyzes traffic on the Website by keeping track of the IP addresses of its visitors. An IP address is the unique numeric identifier assigned to each computer browser accessing the Internet. An IP address, by itself, cannot identify you personally. However, when combined with other information provided by your Internet service provider, your IP address can be used to identify the computer originating a message.

6. Personally Identifiable Information. Certain areas of the Website and functionality of Products and Services allow you to provide PI to VIVA. The PI that VIVA collects may include your name, phone number, e-mail address, physical address, date of birth, Website log-in information, date of log-in, social security number, bank account information, and any other financial information (such as your income, assets, or debts) and other personal information provided by you in connection with your use of the Website or the Products and Services.

   By submitting PI to VIVA, you agree that VIVA may use the information in accordance with this Privacy Policy, including, without limitation: (i) to provide to third party organizations for the purpose of providing you the applicable Products and Services, (ii) to adapt and improve VIVA services to better suit your needs, and (iii) to meet legal, regulatory or contractual requirements relating to the Services and Products provided to you. If you do submit PI to VIVA, VIVA may share that information with third parties, including without limitation, its affiliates, subsidiaries, and partners, in accordance with applicable federal or state law.

   VIVA may also use your PI in other ways, such as to provide you with information about the Products and Services and offers that may be of interest to you, to seek follow-up from you about your experiences with VIVA or as otherwise disclosed to you at the point of collection. You may withdraw your consent for VIVA to use your PI in certain ways by contacting VIVA via email at info@viva-finance.com. In some instances, you may receive certain emails relating to your use of the Products and Services which do not have an unsubscribe option. These emails are generated as an integral part of the Products and Services, and you may choose to discontinue receiving these emails by discontinuing your use of the applicable Products and Services.

   By submitting PI to VIVA, you give VIVA permission to receive it, review it, edit it, store it and use it in appropriate ways and settings.

7. Retention and Storage of PI. VIVA will retain your PI for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid after termination of VIVA's relationship with you.

8. Use of PI and Non-PI: In addition to any of the previously mentioned uses of PI and non-PI, VIVA may use your information collected on the Website, and through the Products and Services for such purposes as:

   • Helping establish and verify your identity;

   • Activating and maintaining your account and general customer services;

   • Contacting you to offer Products and Services updates and notices, promotional notices and other information about Products and Services or other services available from VIVA or its affiliates (you may choose not to allow VIVA to use or disclose your PI for marketing and promotional purposes by contacting VIVA as outlined in the Contact and Electronic Communications section of this Privacy Policy);

   • Providing you with Products and Services or carrying out the transaction(s) you have requested or authorized;

   • Responding to your questions, inquiries, comments and instructions;

   • Improving the Website and Products and Services by solving technical problems, calculating overall usage statistics, internal marketing and promotional purposes, product development and content improvement;

   • Taking good faith steps to enforce Terms of Use or other agreements between you and VIVA;

   • Maintaining the security and integrity of the Website, the Products and Services, and VIVA's systems;

   • Compliance with law, or in the good faith belief that such action is necessary to conform to the requirements of law; and

   • To protect against fraud and potential fraud.

9. Plaid Technologies, Inc (“Plaid”). VIVA may use Plaid to verify your bank account, transaction history, confirm your identity, and confirm your bank account balance prior to approving a transaction. VIVA only shares your information with Plaid in accordance with this Privacy Policy. Information shared with Plaid is treated by Plaid in accordance with its Privacy Policy, available at https://plaid.com/legal/#consumers.

10. Access to and Ability to Correct or Delete Your Information. Upon request via postal mail, e-mail, or telephone, VIVA will provide you a summary of your retained PI. As allowed by law and consistent with our applicable partner agreements, you may modify, correct, change, or request VIVA to delete or update any PI that VIVA has collected through the Website by contacting VIVA via postal mail, e-mail, or telephone, as provided in the Contact and Electronic Communication section of this Privacy Policy.

11. Third Party Sites. The Website and Products and Services, may contain links to other websites, including websites operated by non-affiliated or independent third parties. Please be aware that those sites may collect PI from or about you and Non-PI about your visit. These sites have not necessarily been reviewed by VIVA and are maintained by third parties over which VIVA exercises no control. Accordingly, VIVA expressly disclaims any responsibility for the privacy policies, information collection practices, content, accuracy of the information, and/or quality of products or services provided by or advertised on these third-party websites. Moreover, these links do not imply an endorsement with respect to any third party or any website or the products or services provided by any third party. You should review the privacy policies that are posted on any website that you visit, before using the website and providing PI to the website. VIVA is not responsible for the privacy policies or practices of any websites that may be mentioned on, or is accessible from, the Website.

12. Children under 18. The Products and Services provided by VIVA are not directed to or intended for use by persons under 18. VIVA does not knowingly collect any information from children under 18. If you become aware that your child is accessing the Website, or the Products and Services and providing any information to VIVA, please contact us by emailing info@viva-finance.com. VIVA will take steps to remove any information provided by any child under 18 from its systems and terminate the account associated with such information.

13. Security of Information on the Website. Information submitted via the Internet, including through a web page or e-mail, is subject to interception or incorrect routing, and the Internet is not a fully secure communications channel. Please consider this prior to submitting any information to VIVA via the Site, Products or Services. No method of transmission over the Internet, or method of electronic storage, is 100 percent secure. Therefore, while VIVA strives to use commercially acceptable means to protect your personal information, VIVA cannot guarantee its absolute security. In the event of a data breach, VIVA will do its best to notify you in a timely manner if VIVA knows that your information has been compromised.

14. Obligations Upon Change of Control. If we sell or otherwise transfer part or the whole of Viva or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address and any other information collected through the Website, and/or Products and Services may be among the items sold or transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

15. International Users. This Site, and the Products and Services are intended to be solely for VIVA customers residing in the United States. If you are a non-US resident, please be advised that we may transfer information that we collect about you, including your PI, to subsidiary and affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about you, including PI, to a country and jurisdiction that does not have the same data protection laws as the European Union, and you consent to the transfer of information about you, including your PI, to the U.S.; and the use and disclosure of information about you, including your PI, as described in this Privacy Policy