Privacy Policy — CLS Money Y iOS Application

CLS Money Y LLC ("CLS Money Y," "we," "our," or "us") respects your privacy and is committed to protecting the information collected through the CLS Money Y mobile application for iOS devices (the "App").

This Privacy Policy explains how the App collects, uses, stores, discloses, and safeguards personal information when you download, install, register for, or otherwise use the CLS Money Y iOS application.

This Privacy Policy applies specifically to the CLS Money Y iOS application distributed through the Apple App Store.

Use of clsmoneyy.com is governed separately by our Privacy Notice available on our website.

If you are redirected to, linked to, or otherwise continue to a third-party lender, financial marketplace, or service provider after leaving the App, that third party's own privacy practices and policies govern those interactions.

1. Scope of This Policy

This Privacy Policy applies to:

• the CLS Money Y iOS application;
• in-app account creation and management;
• in-app financial matching services;
• communications and support interactions initiated through the App.

This Privacy Policy does not apply to:

• third-party websites or services;
• lender or marketplace application portals;
• external websites opened after referral or redirection.

Users are encouraged to review third-party privacy policies before submitting information to external providers.

2. Information We Collect

The App may collect the following categories of information depending on how you interact with the service.

Identity and Contact Information

Users may voluntarily provide:

• full legal name;
• date of birth;
• email address;
• phone number;
• mailing address;
• ZIP code;
• state of residence.

Date of birth is collected to verify eligibility requirements, including age restrictions.

Financial and Eligibility Information

To provide financial matching services, the App may collect:

• desired loan amount;
• requested borrowing range;
• loan or borrowing purpose;
• employment status;
• employer name;
• occupation;
• income source;
• monthly income range;
• pay frequency;
• housing status;
• bank name and account type (for example, checking or savings) and whether you primarily receive income by direct deposit, if you choose to provide that information; we do not collect full bank account numbers, routing numbers, or online banking login credentials through the App for this purpose.

Where required during partner application flows, partner providers may request:

• Social Security number;
• bank account details;
• identity verification documentation;
• additional underwriting information.

Such information may be collected directly by or transmitted to the relevant partner provider.

Device and Technical Information

The App may automatically collect:

• device model;
• device type;
• iOS version;
• app build and version;
• device language;
• device region;
• IP address;
• unique device identifiers where applicable;
• authentication token metadata.

Usage and Analytics Information

We may collect:

• app launch activity;
• screen views;
• feature usage;
• session duration;
• interaction events;
• navigation flow;
• referral selections;
• conversion metrics.

Diagnostic and Performance Information

We may collect:

• crash logs;
• error logs;
• performance diagnostics;
• latency and load metrics;
• technical troubleshooting information.

3. Information We Do Not Collect

The App does not request or intentionally collect:

• GPS or precise location data;
• access to device contacts;
• photo library access;
• camera access;
• microphone access;
• health or fitness information;
• biometric identifiers;
• motion or sensor data unrelated to basic device functionality.

The App does not continuously track user location.

State eligibility may instead be inferred from ZIP code or state information voluntarily entered by the user.

4. How We Use Information

We use information collected through the App for the following purposes.

Service Delivery

To:

• operate financial matching services;
• identify relevant partner offers;
• filter providers based on eligibility information;
• display available financial products.

Account Management

To:

• create and maintain user accounts;
• authenticate returning users;
• preserve application progress;
• personalize app experience.

Communications

To:

• send transactional emails;
• deliver service notifications;
• communicate match results;
• respond to support requests;
• send account-related notices.

Where appropriate consent is obtained, communications may include SMS notifications.

TCPA and text messages. Where we send marketing or promotional text messages that may be subject to the Telephone Consumer Protection Act (TCPA), we obtain prior express written consent (which may include electronic consent) before sending autodialed or prerecorded marketing texts to your number, where required by law. Consent to marketing texts is not required as a condition of using the App core matching features, to the extent prohibited by applicable law. Message frequency varies. You may opt out of marketing SMS by following instructions in the messages (for example, replying STOP) or by contacting us at [email protected].

Analytics and Improvement

To:

• improve app usability;
• analyze app performance;
• optimize onboarding and matching flows;
• diagnose technical issues;
• improve feature reliability.

Security and Fraud Prevention

To:

• monitor suspicious activity;
• detect abuse or malicious behavior;
• investigate fraud;
• protect service integrity.

Legal Compliance

To:

• comply with laws and regulations;
• maintain required business records;
• respond to lawful requests or disputes.

5. How We Share Information

We do not sell personal information collected through the App for monetary compensation.

We may share information only as described below.

Partner Providers

If you choose to proceed with a lender or marketplace, relevant information may be transmitted to that provider.

This may include:

• contact information;
• financial profile details;
• eligibility information;
• application-related information.

Information is shared only in connection with requested services or application flows.

Service Providers

We may disclose information to vendors supporting App operations, including:

• cloud hosting providers;
• analytics providers;
• push notification services;
• authentication vendors;
• fraud prevention services;
• customer support infrastructure.

These vendors are contractually restricted from using data beyond providing services to us.

Legal Disclosures

We may disclose information:

• in response to subpoenas;
• court orders;
• lawful government requests;
• regulatory investigations;
• fraud investigations;
• public safety matters.

Business Transfers

Information may transfer in connection with:

• mergers;
• acquisitions;
• financing transactions;
• reorganizations;
• bankruptcy proceedings;
• asset sales.

6. Apple App Tracking Transparency

The CLS Money Y App does not currently engage in cross-app or cross-site tracking for targeted advertising purposes.

Because the App does not perform tracking activities requiring authorization under Apple's App Tracking Transparency framework, the App does not currently request ATT permission.

If our practices change in the future, we will update this policy and implement any required permission flows.

7. Data Security

We implement commercially reasonable security measures designed to protect information.

These measures may include:

• TLS encryption for data in transit;
• encryption at rest where applicable;
• secure API communication;
• role-based access controls;
• authentication protections;
• monitoring and logging systems.

Authentication tokens stored locally on iOS devices may be stored securely using Apple Keychain services.

No transmission or storage method is completely secure.

8. Data Retention

We retain information only as long as reasonably necessary.

Retention considerations include:

• account maintenance;
• user support;
• fraud prevention;
• legal compliance;
• dispute resolution.

User account profiles and match history are generally retained while accounts remain active and for a reasonable period afterward, typically up to 36 months after last activity unless longer retention is required.

Aggregated or de-identified analytics data may be retained indefinitely.

9. Your Rights and Choices

Depending on applicable law, users may have rights including:

• access rights;
• correction rights;
• deletion rights;
• portability rights;
• opt-out rights.

Delete Account

Users may request deletion by:
Menu → Account → Delete Account

or by contacting: [email protected]

Access or Correction Requests

Users may submit requests to: [email protected]
Subject Line: Privacy Request

Notifications

Push notifications may be disabled through:
iOS Settings → Notifications → CLS Money Y

10. California Privacy Rights

California residents may have additional rights under:

• CCPA;
• CPRA.

California residents may review: Do Not Sell or Share My Personal Information.

California residents may submit verifiable consumer requests under the CCPA or CPRA using the contact information in Section 16 (Contact Information).

11. Colorado Privacy Rights

If you are a Colorado resident, the Colorado Privacy Act (CPA) may provide you with rights to access, correct, delete, obtain a portable copy of, and opt out of the processing of your personal data for purposes of sale, targeted advertising, or profiling in certain circumstances. Colorado residents may exercise these rights, where applicable, by contacting us at [email protected] with the subject line "Colorado Privacy Request." We will respond in accordance with applicable law.

Residents of other states with applicable comprehensive privacy laws (including, without limitation, Virginia, Texas, Connecticut, and other states with similar consumer privacy statutes) may submit privacy requests using the same email contact.

12. Children's Privacy

The App is intended only for adults age 18 or older residing in the United States.

We do not knowingly collect personal information from minors under 18.

Users may be required to provide date of birth for eligibility verification.

If we become aware of information submitted by a minor, we will take reasonable steps to delete it.

13. State Availability

CLS Money Y services are currently intended for eligible residents in supported US states.

Services are not currently available in New York.

Partner provider availability may vary by jurisdiction.

Users may only see providers available in their state or region.

14. International Users

The App is intended for users located in the United States.

If accessed outside the United States, information may be transferred to and processed in the United States.

15. Changes to This Policy

We may revise this Privacy Policy from time to time.

Updated versions will be posted within the App or otherwise made available to users.

Material changes may be communicated through:

• in-app notices;
• email notifications;
• updated effective dates.

16. Contact Information

CLS Money Y LLC
728 Bennett Ave, Colorado Springs, CO 80909-4910
United States

Email: [email protected]