Across America Financial

Privacy Policy — Across America Financial

PRE-PUBLICATION REVIEW NOTE — COMPLETE BEFORE PUBLISHING

This Privacy Policy is a working draft. Before publication, complete or confirm the following placeholders and details:

  • [Legal Entity Name], the legal entity operating Across America Financial;
  • [Registered Address];
  • [Effective Date] and [Last Updated Date];
  • the final list of third-party service providers and processors;
  • the actual website, application, cookie, advertising, analytics, financial-product, and data-retention practices; and
  • any bank, lender, payment, credit-reporting, or other regulated-product partners.

This document should be reviewed by a licensed Florida attorney and a qualified privacy professional before launch. It has not been attorney-reviewed and is not legal advice.

Effective Date: [Effective Date] Last Updated: [Last Updated Date]

1. Who We Are and What This Policy Covers

Across America Financial is an online cash flow management platform designed to help people understand and manage everyday money.

This Privacy Policy explains how [Legal Entity Name], doing business as Across America Financial (“Across America Financial,” “we,” “us,” or “our”) collects, uses, shares, protects, and retains personal information.

This Policy applies to personal information collected through:

Some financial products may be provided by a bank, lender, employer, payment provider, credit reporting agency, or other third-party partner. Those partners may provide separate privacy notices that also apply to their collection and use of information.

2. Information We Collect

The information we collect depends on how you use our services, the features you select, and the products available to you.

2.1 Information You Give Us

We may collect information you provide directly, including:

Please do not provide information about another person unless you are authorized to do so. If you add another person to a household or Family plan, you represent that you have permission to provide their information and invite them to the service.

2.2 Information From Connected Bank and Card Accounts

If you choose to connect a bank, card, or other financial account, we may receive information through a third-party account-aggregation provider.

Depending on the account and the permissions you provide, this information may include:

The third-party aggregation provider may collect and process information under its own privacy policy and terms.

We use connected-account information to provide features such as spending tracking, cash-flow views, bill reminders, savings goals, product eligibility, fraud prevention, and other services you request.

We do not move money from your connected bank or card accounts merely because you connect them to our platform. We do not initiate transfers, withdrawals, or payments from a connected account unless you separately authorize that activity and the applicable product terms clearly explain it.

2.3 Payment and Subscription Information

If you purchase a Plus plan, Family/Elevated plan, or another paid service, payment information is processed by a third-party payment processor.

The payment processor may collect:

We do not store full payment card numbers on our own systems unless this Policy is updated to say otherwise. We may receive limited payment information, such as the card type, last four digits, billing ZIP Code, payment status, and processor transaction identifier.

2.4 Information Collected for Financial Products

If you apply for or use Buy Now, Pay Later, Overdraft Protection, Credit Builder, Earned Wage Access, or another regulated product, we or the relevant product partner may collect additional information, including:

The specific information collected, the party making an eligibility decision, and the applicable privacy notice may vary by product. Product-specific terms and notices will be provided before enrollment or use.

2.5 Identity Verification and Fraud Prevention Information

Where required by law, a product partner, or our risk controls, we may collect and use information to verify your identity or prevent fraud.

This may include:

We will use identity-verification and fraud-prevention information only for disclosed purposes, legal compliance, security, and related legitimate business purposes.

2.6 Device, Usage, Log, and Technical Information

When you use our website or services, we may automatically collect:

2.7 Cookies and Similar Technologies

We and our service providers may use cookies, pixels, software development kits, local storage, tags, and similar technologies.

These technologies may collect information about your device, browsing activity, preferences, and use of our services. See Section 9, “Cookies and Tracking Technologies,” for more information.

3. How We Use Information

We may use personal information to:

3.1 Provide and Operate the Services

We use information to:

3.2 Support Financial Product Features

We may use information to:

Eligibility decisions may be made by us, a bank or lender partner, an employer, or another third party. Product-specific terms and notices will explain the relevant process.

3.3 Secure Accounts and Prevent Fraud

We use information to:

We may use information to comply with:

3.5 Communicate With You

We may use information to send:

You may opt out of promotional marketing messages as described in Section 12.

3.6 Improve Our Products and Services

We may use information to:

We will not attempt to re-identify properly de-identified information except as permitted by law.

4. How We Process Information and Applicable Privacy Rights

Privacy laws differ by state and may apply differently depending on the type of information we collect and the product you use.

Depending on where you live and whether a law applies to us, you may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), and similar laws in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states.

4.1 Our Privacy Processing Grounds

Where applicable, we process personal information based on one or more of the following:

4.2 Categories of Information

The categories of personal information we may collect include:

CategoryExamplesTypical SourcesTypical Uses
IdentifiersName, email, phone number, account ID, IP addressYou, your device, service providersAccount creation, authentication, support, security
Customer recordsAddress, contact details, payment-related informationYou, payment providersBilling, support, account administration
Commercial informationSubscription plan, payment history, product useYou, payment providers, product partnersSubscription management, service delivery
Financial informationBalances, transactions, income, bills, account detailsYou, connected institutions, aggregation providersCash-flow tools, reminders, eligibility, servicing
Internet or network informationBrowsing, device, usage, log dataYour device, cookies, analytics toolsSecurity, analytics, improvement
Geolocation informationApproximate location from IP addressYour device or browserSecurity, analytics, regional functionality
Professional or employment informationEmployer and income informationYou, employers, product partnersProduct eligibility and Earned Wage Access
InferencesSpending categories, preferences, account insightsInformation collected from your useDashboard features, personalization, service improvement
Sensitive personal informationGovernment identifiers, precise financial information, identity-verification data, and other information defined as sensitive under applicable lawYou, financial institutions, verification providersIdentity verification, fraud prevention, legal compliance, product administration

We may disclose categories of information to service providers and other recipients as described in Section 7.

4.3 Rights to Know and Access

You may have the right to request information about:

4.4 Right to Correct

You may have the right to request correction of inaccurate personal information.

You can also update certain account information directly through your account settings. We may ask for information needed to verify the requested correction.

4.5 Right to Delete

You may have the right to request deletion of personal information we collected from you.

Deletion is subject to legal exceptions. We may retain information when necessary to:

Deleting your information may limit or terminate your ability to use some services.

4.6 Right to Data Portability

You may have the right to receive certain personal information in a portable and usable format, or to request that it be transmitted to another entity where technically feasible and required by law.

4.7 Right to Opt Out of Sale or Sharing

We do not sell personal information for money.

We may use service providers and business partners to operate our services. We do not sell personal information in exchange for monetary payment.

Some privacy laws may define “sale” or “sharing” broadly. If any of our use of information is treated as a sale or sharing under an applicable law, you may have the right to opt out.

We may also use analytics or advertising technologies that could be considered “sharing” or targeted advertising under certain state laws. The final list of these technologies and our opt-out controls must be confirmed before publication.

4.8 Right to Opt Out of Targeted Advertising

Where required by applicable law, you may opt out of the use of personal information for targeted or cross-context behavioral advertising.

You may exercise this choice through:

4.9 Right to Limit Use of Sensitive Personal Information

California residents and residents of other states with similar rights may have the right to limit certain uses or disclosures of sensitive personal information.

We use sensitive information primarily for purposes such as:

Where applicable, you may submit a request to limit the use or disclosure of sensitive personal information by contacting support@acrossamericafinancial.com or using [Limit the Use of My Sensitive Personal Information].

4.10 Right to Appeal

If we deny a privacy request where applicable law provides an appeal right, you may appeal by replying to our response or emailing support@acrossamericafinancial.com with the subject line “Privacy Appeal.”

Your appeal should include:

We will review the appeal and provide a written response within the time required by applicable law. If we deny an appeal, we will explain the reason where required and tell you how to contact the applicable state privacy regulator.

4.11 Right to Non-Discrimination

We will not unlawfully discriminate against you for exercising a privacy right.

Unless permitted by law, we will not:

because you exercised a privacy right.

Some services may not function if you ask us to delete information or disconnect an account that the service requires.

4.12 Financial Information and the Gramm-Leach-Bliley Act

Some financial information we collect may be subject to the Gramm-Leach-Bliley Act (“GLBA”) and other financial privacy laws.

To the extent information is governed by the GLBA or another sector-specific financial privacy law, it may be handled under the privacy notice and rights applicable to that law rather than under all provisions of a state comprehensive privacy law. State privacy laws may also contain exemptions for information collected, processed, sold, or disclosed under the GLBA.

This Policy does not replace any separate financial privacy notice required for a regulated financial product.

4.13 How to Submit a Privacy Request

To submit a request, email:

support@acrossamericafinancial.com

Please identify the type of request in the subject line, such as:

We may also provide an online request form at [Privacy Request URL].

We will not require you to create an account solely to submit an opt-out request. We may ask you to provide information reasonably necessary to verify your identity and protect your information.

4.14 Verification of Requests

For certain requests, we must verify that you are the person about whom we collected information.

Verification may involve:

We will not request highly sensitive information unless reasonably necessary for verification. If we cannot verify your identity, we may be unable to complete the request.

4.15 Authorized Agents

Where permitted by law, you may designate an authorized agent to submit a privacy request on your behalf.

We may require:

A request made through a recognized opt-out preference signal may be treated as a request directly from the consumer where required by law.

5. Sharing and Disclosure of Information

We may disclose personal information for the purposes described in this Policy.

5.1 Service Providers and Processors

We may disclose information to companies that provide services for us, including:

These providers may use information only as permitted by our agreements and applicable law.

The final list of third-party processors must be completed before publication and may be available at [Third-Party Providers Page].

5.2 Banks, Lenders, Employers, and Financial Partners

Where a regulated product is delivered through a bank, lender, employer, payment provider, credit reporting agency, or other partner, we may disclose information necessary to:

The relevant partner may provide its own privacy policy and legally required financial privacy notices.

We may disclose information when you direct us to do so or consent to the disclosure, including when you:

We may disclose information when reasonably necessary to:

5.5 Corporate Transactions

We may disclose information in connection with:

We will handle personal information in accordance with applicable law and will provide required notices about material changes in ownership or use.

5.6 Aggregated and De-Identified Information

We may share information that has been aggregated or de-identified so that it cannot reasonably be used to identify you.

We may use this information for analytics, research, reporting, product improvement, and other lawful business purposes.

5.7 No Sale of Personal Information

We do not sell your personal information for money.

We do not provide your personal information to third parties to sell it as a standalone data asset. If our practices change, we will update this Policy and provide any notices and choices required by law.

6. Information About Financial Products

Across America Financial currently markets or may offer the following product lines:

These products may involve additional data collection, eligibility requirements, disclosures, underwriting, credit reporting, repayment, servicing, licensing, and regulatory obligations.

The availability, terms, fees, eligibility criteria, and provider for each product may vary by state and customer. A product may be provided by Across America Financial or by a third-party partner.

Before you enroll in a regulated product, we will provide applicable terms, disclosures, consent requests, and product-specific privacy information.

7. Cookies and Tracking Technologies

7.1 Types of Technologies We May Use

We may use the following categories of cookies and similar technologies:

Strictly necessary technologies: These support account login, security, fraud prevention, navigation, accessibility, and core site functions. They generally cannot be disabled through ordinary cookie settings without affecting the service.

Functional technologies: These remember preferences, settings, language, and other choices to improve your experience.

Analytics technologies: These help us understand usage, performance, traffic, errors, and feature effectiveness.

Advertising technologies: These may be used, if implemented, to measure campaigns, display relevant advertising, or understand activity across websites or services. The final advertising technologies must be confirmed before publication.

7.2 Managing Cookies

You may manage cookies through:

Disabling cookies may affect the availability or functionality of certain features.

7.3 Global Privacy Control and Opt-Out Signals

Where required by applicable law, we will honor valid opt-out preference signals, including Global Privacy Control (“GPC”), as a request to opt out of the sale or sharing of personal information or targeted advertising.

The effect of an opt-out signal may depend on the applicable law, the browser or device sending the signal, and whether the signal is associated with a recognized account.

A cookie consent banner and preference-management tool will be implemented before launch. The final banner will describe the technologies used and provide controls required by applicable law.

8. Data Security

We use administrative, technical, and physical safeguards designed to protect personal information.

These safeguards may include:

We describe our security as “bank-level” only to the extent that our actual controls support that statement and the claim has been reviewed before publication.

No method of transmitting or storing information is completely secure. We cannot guarantee that personal information will never be accessed, disclosed, altered, or destroyed through a security incident.

If we discover a legally reportable security incident, we will provide notices required by applicable law.

9. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy.

Retention periods depend on:

When you close your account or request deletion, we may delete, de-identify, or restrict access to personal information, subject to applicable exceptions.

We may retain information for longer periods when required or permitted for:

Information retained for legal or regulatory purposes will be protected and used only for the applicable purpose, unless otherwise permitted by law.

10. Children’s Privacy

Our services are intended for adults and are not directed to anyone under 18.

We do not knowingly collect personal information from children under 18. If you believe that a child has provided personal information to us, contact us at support@acrossamericafinancial.com.

If we learn that we collected personal information from a child under 13 without legally required parental consent, we will take reasonable steps to delete it.

11. Your Choices

11.1 Marketing Communications

You may opt out of promotional emails by using the unsubscribe link in the message or contacting support@acrossamericafinancial.com.

Even if you opt out of marketing communications, we may continue to send non-promotional messages about:

11.2 Closing Your Account

You may request to close your account by contacting support@acrossamericafinancial.com or using the account-closure option available in the service.

Closing your account may not immediately delete all information. We may retain information as described in Section 9.

11.3 Disconnecting a Linked Account

You may disconnect a linked bank or card account through the platform, where available, or by contacting support.

Disconnecting an account may stop future data access but may not delete information previously collected. Information already collected may be retained for service, legal, security, fraud-prevention, or financial-recordkeeping purposes.

You may also need to revoke access directly with the third-party account-aggregation provider or financial institution.

11.4 Deleting Information

To request deletion of your personal information, contact support@acrossamericafinancial.com with the subject line “Privacy Request — Delete.”

We may need to verify your identity before processing the request. Some information may be retained as required or permitted by law.

Our website, application, emails, or services may contain links to third-party websites, applications, products, or services.

Those third parties may have their own privacy policies and practices. We are not responsible for their content, security, or privacy practices.

Review the privacy policy of any third party before providing information or connecting an account.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make a material change, we will provide notice required by applicable law. Notice may be provided by:

Your continued use of the services after the effective date of an updated Policy means that the updated Policy applies to your use of the services, except where applicable law requires your consent.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, contact us at:

Across America Financial Legal Entity: [Legal Entity Name] Registered Address: [Registered Address] Email: support@acrossamericafinancial.com Privacy Request URL: [Privacy Request URL]

We will respond to privacy requests within the time required by applicable law.