Icalia, Inc. Privacy Policy Effective as of January 23, 2025 Icalia, Inc.
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(“Icalia” or “we” or “us” or “Company”)  At Icalia, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By navigating our website, using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Privacy Policy Table of Contents

What this Privacy Policy Covers Personal Data
‍− Categories of Personal Data We Collect
‍‍− Categories of Sources of Personal Data
‍− Our Commercial or Business Purposes for Collecting Personal Data

How We Share Your Personal Data Tracking Tools and Opt-Out

Data Security and Retention Personal Data of Children Other State Law Privacy Rights Changes to this Privacy Policy Contact Information

How We Share Your Personal Data Tracking Tools and Opt-Out

It is the policy of Icalia to protect consumer and customer Personally Identifiable Information (PII), or any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Examples of PII could include, but are not limited to full name, social security number, passport number, bank account information, credit card number, or driver’s license number. PII is also known as Non-Personal Public Information (NPI). This Policy outlines the regulatory requirements and provides guidelines on Icalia’s privacy practices, including how Icalia collects, uses, and discloses your information. Icalia takes all necessary steps to safeguard private information that has been provided by its consumers. This Policy outlines Icalia’s practice regarding use of PII for consumers, those consumers who become our customers, and former customers.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

In addition, we may collect the following information about individuals or businesses (“Data”):

Individuals’ Information: name or aliases, physical address, work address, phone number, email address, IP address, date of birth, gender, local tax identification number, result of sanctions screenings, government ID, photo identification, selfie, or video authorization, images of your face on your identification document (e.g., government-issued identification card) and/or video, your biometric facial identifiers, and other additional information you may provide, or additional information we may additionally request you to provide (collectively the “Individual’s Information”);

We collect Personal Data about you from the following categories of sources:

You

• When you provide such information directly to us.
• When you use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically.

• Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
• If you use a location-enabled browser, we may receive information about your location.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Public Records

• From the government or other sources.

Affiliates

• From our affiliates in countries other than the United States. Those affiliates may share all Personal Information they have about you with us.

Third Parties

• Payors: When we interact with third parties that intend to send money to you or receive money from you.
• Vendors: we may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. We may use vendors to obtain information to generate leads and create user profiles.
• Advertising: We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications

Our Commercial or Business Purposes for Collecting Personal Data

1. Providing, Customizing and Improving the Services

• Providing you with the products, services or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

2. Marketing the Services

• Marketing and selling the Services.

3. Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Icalia or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

4. Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Icalia or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We do share your information with third parties as described in this Policy. We may share some of your information:

• With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, credit bureaus, or collection agencies;
• To financial institutions and payment processors to receive or send payments.
• With other parties to transactions when you use the Services, such as other users, merchants, and their service providers.
• To information technology providers or other service providers around the world that act under our instructions regarding the processing of certain data ("Vendors"). Vendors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the information, and to process information only as instructed;
• To independent external auditors or other service providers around the world. Such service providers will be subject to any necessary contractual obligations regarding the protection and processing of such Data;
• In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
• To support our audit, compliance, and corporate governance functions;
• To service providers to prepare, deploy and analyze advertising content;
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention and risk management;
• To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
• With your consent or direction.

In addition, we disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Governmental entities. Various governmental entities may request or demand that we deliver your Personal Data to them or we may do so in compliance with applicable law.
• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  
  

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  

  • Hosting, technology and communication providers.
  • Security, identification verification, and fraud prevention consultants and service providers.
  • Support and customer service vendors.

• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
  

  • Ad networks.
  • Data brokers.
  • Marketing providers.

• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  

  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.
• Affiliates. We may share all Personal Information we have about you with our affiliates in other countries.

• Business Partners. These parties' partner with us in offering various services. They include:
  

  • Auditors, examiners, and consultants.
  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities.

• Parties You Authorize, Access or Authenticate
  

  • Third parties you access through the services.
  • Social media services.
  • Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data That is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools and “Do Not Track”

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Service and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
• You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
• To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
• Data Security, Retention and Control Over Your Information
• We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
• You have the right to request Icalia to correct, or to request data deletion, which we process within 30 days, unless retention is required for legal or contractual obligations

Applicable State Laws

Applicable state laws must be taken into consideration when marketing to customers via a third party. For example, Vermont and California state laws prohibit financial institutions from sharing customer PII unless the customer takes affirmative action authorizing the institution to do so. Therefore, customers with Vermont or California addresses must be removed from campaigns that involve information sharing with unaffiliated third parties under the Regulation P joint marketing agreement exception.

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

Icalia has developed and implemented privacy and security controls to protect your personal information and comply with United States federal law, including but not limited to the Gramm-Leach-Bliley Act and the Fair Credit Reporting Act. As such, most of the personal information about you that we may collect and use is exempt from the CCPA. California Privacy Rights Under the California Consumer Privacy Act, California residents, subject to certain limitations and exceptions, have the right to:some text

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

  • The specific pieces of personal information we have collected about you
  • The categories of personal information that we have collected about you
  • The categories of sources from which your personal information was collected
  • The business or commercial purpose for collecting or selling your personal information
  • The categories of third parties with whom we may share personal information

• Right to Delete - You have the right to request the deletion of your personal information that is collected or maintained by us.
• Right to Opt-Out of Sale - You have the right to opt-out of the sale of your personal information by us. We do not sell personal information.
• Right to Non-Discrimination - You have the right to not receive discriminatory treatment by us for the exercise of the privacy rights described above.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information that we maintain about you is not subject to your rights under the CCPA.

We will advise you in our response if we are unable to honor your request. Additionally, if you request access to the specific pieces of personal information we have collected about you, we will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, account passwords or security questions and answers, or any other specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft, fraud, or unreasonable risk to data, systems, and network security.

How to Exercise Your Rights under the CCPA If you are a California resident, you may make a request to exercise your rights under the CCPA by either of the following methods:

Submitting a request via email to weare@icalialabs.com

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

• Vermont State Law - Icalia does not share information of customers with a Vermont address with affiliated companies.
• Privacy and Opt-Out Notice - Our customers provide private information to Icalia during daily business, and we are committed to treating such information responsibly. Our customers expect privacy and security for their banking and financial affairs. To that end, we provide the Privacy and Opt-Out Notice (Notice) to all consumers at account opening, enrollment for a new service, if there are changes to our privacy practices, and annually thereafter, if required by law.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Icalia website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Reporting Unauthorized Disclosure of Personal Information

When an unauthorized disclosure of PII occurs, how Icalia responds and communicates to customers and regulatory agencies can be the difference between a potential compliance penalty or action lawsuit and an opportunity to reinforce our commitment to care.

The negative impact of an information breach can create reputational risk and cause noncompliance with laws and regulations. Incidents may include any situation in which

customer personal, financial or health information or records (whether in paper, electronic, or other form that is maintained by or on behalf of Icalia) may potentially be lost, misdirected, or in any way accessed by unauthorized individuals or parties. Any incidents or suspected incidents involving data security and disclosure of customer information should be reported immediately to the IT Department and/or Senior Management in accordance with the Information Security Policy’s standards and associated procedures. Icalia’s unaffiliated third-party service providers are instructed to report all unauthorized access to, and disclosure of, any customer information.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Phone: +1 832-336-7786

www.icalialabs.com

weare@icalialabs.com

1606 Headway Cir STE 9094, Austin, TX 78754