Ooblix Privacy Policy

The protection of your Personally Identifiable Information (“PII”) is important to Ooblix , Inc. (“ooblix”, “we”, “us”, or “our”).

When you visit our mobile application and/or website ooblix.com. and use our online or offline offerings or services (“Services”), you provide us with your PII. In this privacy policy (“Privacy Policy”), we explain what information we collect, how we use it, to whom we disclose it, and what rights you have in relation to it. Please thoroughly review this Privacy Policy before you begin to use our Services, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue the use of our Sites (as defined below) and our Services.

This Privacy Policy applies to all information collected through our website (such as ooblix.com), mobile application, and/or any related Services, sales, marketing, or events (collectively referred to as the “Sites”).

If you have any questions or concerns about our policy, or our practices with regards to your PII, please contact us by email at contact@ooblix.com or by US mail to: Ooblix, 5151 California Avenue, Suite 100, Irvine, CA 92617.

WHAT INFORMATION DO WE COLLECT?

The PII that we collect depends on the context of your interactions with us, the Sites, the choices you make and the products, Services and features you elect to use, and requirements of applicable law. We collect information that you voluntarily provide to us, information we obtain automatically when you use our Sites, and information from other sources such as third-party services and organizations (such as your financial institutions), as described below. The PII we collect can include, but is not limited to, the following categories.

PII You Provide To Us Directly

We may collect PII that you provide to us.

• PII Voluntarily Disclosed. We may collect PII you disclose to us, such as first and last name, postal addresses, social security number, phone numbers, contact information, email addresses, and emails.
• Passwords and Security-Related Information. We may collect PII such as passwords, password hints, security questions, and similar security information used for authentication, credentials, and account access.
• Purchases. We may collect PII and details associated with your purchases, including payment information for payment processing
• Your Communications with Us. We may collect PII, such as email addresses, phone numbers, or mailing addresses when you request information about our Sites, request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect PII from you in connection with the surveys.
• Interactive Features. We and others who use our Sites may collect PII that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Sites will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
• Conferences, Trade Shows, and Other Events. We may collect PII from individuals when we attend or host conferences, trade shows, or other events.
• Business Development and Strategic Partnerships. We may collect PII from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job screenings and opportunities on our Sites. If you respond to one of these postings, we may collect your PII, such as your application, CV, cover letter, and/or any other information you provide to us.

PII Collected With Your Consent

With your explicit consent (provided through the Ooblix Use of AI Policy), Ooblix collects transaction and other data from your financial institution or bank(s), approved data from your cell phone and cell carrier, and other public data sources using PII provided by you. This data may include, but is not limited to, the following categories of data:

• PII Related to Applicants. The PII collected from personal loan applicants may include full name, spouse/partner name, relatives name(s), current home address, past home address(es), email addresses, date of birth, social security number, home phone, cell phone, banking relationship, public records, sanctions and watchlist information, identity and background records results, employer’s name, job title, salary, and employment history.
• Banking Information. We may collect PII relating to banking and transaction data, including bank name, bank location and contact information, bank routing number(s), account holder name(s), account holder address, account holder tax ID number or social security number, account holder phone, account holder email(s), retailer(s)’ and depositor(s)’ name and contact information, account number(s), account type(s) (savings, checking, credit, loan, etc.), non-sufficient funds charges, overdraft data, bank fees, interest charges, transaction date(s) and time(s), daily ending balance(s), transaction amounts, transaction currency, transaction type (debit, credit, authorization, etc.), transaction description, transaction rail (ACH, Debit, Visa, Mastercard, other), income details, expenses and other information needed to assess the creditworthiness of loan applicants, employer’s contact information, landlord’s contact information, mortgage company contact information, bill pay information, child support and government assistance data, purchase location(s), merchant name(s), and any other information or bank records.
• Cell Phone Data. We may also collect cell phone data which may include, location history, IP addresses, device ID information, cellular network, device type, device operating system, advertising ID, application usage data, heat maps, biometric data (face, eyes, finger, other) collected by third parties for identity verification purposes, camera information and photos, microphone data, locally stored files, browsing history, accelerometer data, gyroscope data, Bluetooth, Wi-Fi, VPN, security logs, call history, message history, contacts, and social media history.

PII Collected Automatically

We may collect PII automatically when you use our Sites

• Automatic Collection of PII. We may automatically collect certain information when you visit, use, or navigate the Sites. This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your Internet protocol (IP) address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our Sites and other technical information.
  • Location Information. We may collect precise location information which may reveal your identity, such as GPS and location history or otherwise in connection with your use of our Sites.
• Cookie Policy (and other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Sites, may use cookies and similar tracking technologies (like web beacons and pixel tags) (“Technologies”) to automatically collect, access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pix Tags / Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Sites that collects information about engagement on our Sites. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

Our use of these Technologies falls into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Sites, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
• Performance-Related. We may use Technologies to assess the performance of our Sites, including as part of our analytic practices to help us understand how individuals use our Sites (see Analytics below).
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Sites. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed.
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Sites or on third-party digital properties.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Sites. These Technologies allow us to better understand how our digital Sites are used and to continually improve and personalize our Sites. One of our analytic partners includes:
  • Hotjar: We may use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our Services with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the 'about Hotjar' section of Hotjar's support site.
• Social Media Platforms. Our Sites may contain social media buttons, such as Instagram, Meta, X, YouTube, and Reddit, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect PII such as your IP address and which page you are visiting on our Sites and may get a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

PII Collected from Other Sources

We may collect PII from other sources.

• Third-Party Services and Sources. We may obtain PII about you from other sources, including third-party services and organizations and public records. For example, if you access our Sites through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect PII about you from that third-party application that you have made available via your privacy settings. We may collect information from marketing partners, including social media information, marketing leads, search results and links (including paid or sponsored links).
• Referrals and Sharing Features. Our Sites may offer various tools and functionalities that allow you to provide PII about your friends through our referral service. Our referral services also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Sites. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker.)

HOW DO WE USE YOUR PII?

We use your PII for a variety of business purposes, including for our Sites and providing our Services, for administrative purposes, and to market our products and Sites, as described below.

Provide our Sites and Services

We use your information to fulfill our contract with you and provide you our Sites and Services, such as:

• Managing your information and accounts;
• Conducting identity verification for you to use our Sites and Services;
• Providing access to certain areas, functionalities, and features on our Sites;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Sites, and policy changes;
• Processing your financial information and other payment methods for our Sites;
• Processing applications if you apply for a job we post on our Sites; and
• Allowing you to register for events.

Administrative Purposes

We use your PII for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research, and development (including market research), network and information security, and fraud prevention;
• Detecting and mitigating security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Sites;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading, or enhancing our Sites through analyzing aggregated data;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with our Sites;
• Auditing related to interactions, transactions, and other compliance activities;
• Sharing PII with third parties as needed to provide our Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

Marketing and Advertising our Sites

We may use your PII to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, text messages, custom audience advertising, and “internet-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt-out of the use of your PII for marketing purposes, you may contact us at any time set forth in “How Can You Contact Us About This Policy?” below.

With Your Consent

We may use your PII for other purposes that are clearly disclosed to you at the time you provide PII or with your consent.

Other Purposes

We also use your PII for other purposes as requested by you or as permitted by applicable law.

• Automated Decision Making (AI). We may engage in automated decision making, for completing Know Your Customer (“KYC”) requirements and the loan application process . For example, subject to your prior written consent, we may use Artificial Intelligence and Machine Learning (collectively referred to as “AI”) to analyze PII provided during the application process, including but not limited to, consumer permissioned bank transaction details that the applicant authorizes their financial institution(s) to share with us, identity and background record results, residence and employment history, income, and expenses, and other relevant information needed to assess the creditworthiness of loan applicants. Subject to your prior written consent (given in the Use of AI Policy), the AI system will generate final underwriting decisions as well as recommendations to support additional review. It is possible that an applicant’s loan approval or denial will be determined exclusively by AI. After the full payment of your loan or if your loan application is denied, Ooblix will anonymize any PII that is used to train the AI from its systems, unless we need to keep certain data in an identifiable format for historical loan record bookkeeping, fraud detection purposes, or as required by applicable laws and regulations. If you have any questions about our automated decision making or use of AI, please refer to our “Use of AI Policy” or you may contact us as set forth in “How Can You Contact Us About This Policy?” below.
• De-Identified and Aggregated Information. We may use your PII as part of a larger anonymized and/or aggregated dataset to train and increase the knowledgebase of our AI tools and deterministic models, for marketing purposes , and other general data driven business purposes.
• Providing Discounts If you opt-in to receive discounts, we may use your PII to provide you offers from our business partners.
• Train AI We may collect and process your PII to train our AI.
• Assessing Your Qualification. We may use your PII to analyze your financial behavior to determine eligibility for loans or other financial products.
• Fraud Detection and Prevention. We may use your PII to identify and mitigate fraudulent activities to protect you and us.
• Improving Services. We may use your PII to analyze aggregated data to enhance our products and Services.

WILL YOUR PII BE SHARED WITH ANYONE?

We disclose your PII to third parties for a variety of business purposes, including to provide our Sites and Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Disclosure to Provide Our Services

We may share your PII with the following categories of third parties as described below.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your PII with third party vendors, service providers, contractors or agents who perform Services for us or on our behalf and require access to such information to do that work. We may share your data with vendors, consultants, or other third-party service providers, contractors, or agents for the following reasons, including identity verification, payment processing, data analysis, IT management, email delivery, hosting services, customer service and marketing efforts.
• Affiliates. We may share your PII with our company affiliates, for example, for administrative purposes, IT management, or for them to provide Services to you or support and supplement our Sites.
• Business Partners. We may share your PII with our business partners to offer you certain products, services, or promotions requested by you. We may also share your PII with business partners with whom we jointly offer products or Services.
• Advertising Partners. We may share your PII with third-party advertising partners. These third-party advertising partners may set cookies and other tracking technologies on our Sites to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “internet-based advertising” or “personalized advertising.”
• APIs/SDKs We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Sites. For more information about our use of APIs and SDKs, please contact us set forth in “How Can You Contact Us About This Policy?” below.

We may share your PII with third parties if you explicitly consent to such sharing.

Disclosure to Protect Us or Others

We may access, preserve, and disclose any PII we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect you, our, or others’ rights, property or safety; enforce our policies and contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or other Asset or Business Transfer

We may share, sell, or transfer your information as permitted by law and/or contract in connection with, or during negotiations of, any merger, sale of company assets, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or acquisition of all or a portion of our business to another company.

HOW LONG DO WE KEEP YOUR INFORMATION?

We store your PII as described in this Privacy Policy for as long as you use our Sites, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, detect fraud, for historical loan recordkeeping, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws and regulations.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We aim to protect your PII by implementing a system of organizational and technical security measures. However, please also remember that we cannot guarantee that our systems are 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Although we implement practices designed to protect your PII, we do not accept liability for unauthorized access, use, disclosure, or loss of PII. You should only access the Sites and Services within a secure environment.

By using our Sites or providing PII to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to the use of our Sites. If we learn of a security system’s breach, we may attempt to electronically notify you by posting a notice on our Sites, by mail, or by sending an email to you.

DO WE COLLECT PII FROM MINORS?

Protecting children’s privacy online is very important to us. The Sites are not directed to children under 18 years of age. By using the Sites, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that PII from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records, unless we have a legal obligation to keep it. If you are a parent or guardian and believe your child has uploaded PII to our site without your consent, or wish to review the information collected from your child, or have that information modified or deleted, please contact us at contact@ooblix.com.

WHAT ARE YOUR PRIVACY RIGHTS?

The privacy choices you may have about your PII are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Sites and Services, and you will not be able to opt-out of those communications (e.g., communications regarding our Sites and updates to our Terms and Conditions or this Privacy Policy.
• Text Messages. If you receive an unwanted text message from us, you may opt-out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “How Can We Contact You About This Policy?” below.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt-out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt-out of this collection by changing the settings on your mobile device.]
• Phone Calls. If you receive an unwanted phone call from us, you may opt-out of receiving future phone calls from us by following the instructions which may be available on the call or otherwise by contacting us as set forth in “How Can We Contact You About This Policy?” below.
• “Do Not Track” and Opting-Out of “Sharing” and “Selling” PII. Most web browsers and some mobile operating systems and mobile applications include a Do Not Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. You have a right to opt-out of the “sharing” of PII (as “sharing” is defined in applicable laws) for internet-based advertising. retargeting by contacting us, or cross-context behavioral advertising. You may exercise this right by contacting us as set forth in “How Can We Contact You About This Policy?” below.
• Cookies and Personalized Advertising. Most web browsers are set to accept cookies by default. If you prefer, you may set your browser to stop or restrict the placement of cookies and other tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you choose to remove or reject cookies or other tracking technologies, this could affect certain features or Services of our Sites. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Please note that you must separately opt-out in each browser and on each device.
• Right to Data Deletion. You have the right to request the deletion of your PII held by Ooblix unless you are in the process of paying off your loan to us or if we need to keep certain data for historical loan record bookkeeping, fraud detection purposes, and subject to certain exceptions as permitted by applicable laws and regulations. Once your personal data has been deleted, we will provide you with confirmation of the deletion, unless prohibited by law.
• Right to Correct Inaccuracies. You have the right to correct any incorrect PII used in your loan application and the AI-based underwriting decision.
• Right to Appeal an Adverse Consequential Decision. An applicant has the right to appeal an adverse consequential decision regarding the data used in their loan application and the AI-based underwriting decision. In the event of an adverse action, Ooblix will provide clear and concise explanations of the underwriting decision, the degree to which the AI system contributed to the underwriting decision, the type of PII that was processed by the AI system in making the decision and the sources of that data, an opportunity to correct the PII that the AI processed in making the decision. You have the right to dispute any underwriting decision that you believe to be incorrect or unfair. Ooblix will review and address disputes promptly and fairly, with the option for human review of AI-based decisions where technically feasible.
• Right to Opt-Out of Profiling. An applicant has the right to opt-out of the processing of their PII for purposes of profiling in furtherance of decisions that may produce a legal or similarly significant effect.
• Right to Opt-Out of Processing Your PII in connection with our AI System. You have the right to opt-out the processing of your PII in connection with our AI system.
• Right to Opt-In for Discounts. An applicant has the right to opt-in to receive discounts from our business partners.

To exercise any of these consumer rights, please contact us via email at contact@ooblix.com. To protect your privacy, your request should include sufficient information to allow us to verify your identity and locate your data within our systems. Upon receiving a valid and verifiable request to exercise any of these consumer rights, we will review and process your request in accordance with applicable laws and regulations.

While we strive to honor all consumer rights requests, there may be certain exceptions where we are unable to fulfill your request, such as:

• Compliance with legal obligations: We may be required to retain certain data for compliance with legal obligations or regulatory requirements.
• Verification: We are provided insufficient information to allow us to verify your identity and locate your data within our systems.
• Legitimate business purposes: We may need to retain certain data for legitimate business purposes, such as fraud prevention, dispute resolution, or enforcing our terms of service.

BY USING THIS WEBSITE, YOU AFFIRM YOU ARE LOCATED IN AND ARE A RESIDENT OF THE UNITED STATES.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes, if you are a resident of California, you are granted specific rights regarding access to your PII.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of PII (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared PII in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to: Ooblix, 5151 California Avenue, Suite 100, Irvine, CA 92617.

DO NEVADA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of Nevada, you have the right to opt-out of the sale of certain PII to third parties who intend to license or sell that PII. You can exercise this right by contacting us at contact@ooblix.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your PII as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “How Can You Contact Us About This Policy” below.

THIRD-PARTY WEBSITES/APPLICATION

The Sites may contain links to other websites/applications and other websites/applications may reference or link to our Sites. These third-party services are not controlled by us. We encourage users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing PII to third-party websites or applications is at your own risk.

DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time in our sole discretion to stay compliant with relevant laws. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes, by directly sending you a notification, or as required by applicable law. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services and Sites after the new Privacy Policy takes effect.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about our privacy practices or this Privacy Policy, you may email us at contact@ooblix.com or by US Mail to: Ooblix, 5151 California Avenue, Suite 100, Irvine, CA 92617.

CONSUMER PRIVACY NOTICE

The following Consumer Privacy Notice applies to you if you are an individual who resides in the United States and use the Services and Sites for your own personal, family or household purposes.