Privacy Policy


  1. EFFECTIVE DATE

    September 30, 2025

  2. OUR COMMITMENT TO PRIVACY

    Privacy Promise

    Palla Financial Inc. ("Palla", "we", "us", or "our") takes privacy very seriously and knows that you care about how your non-public personal information ("NPI") is used and shared. Federal and certain state laws require us to tell you how we collect, share, and protect your nonpublic personal information. Federal and certain state laws also give consumers the right to limit some but not all sharing. This Privacy Statement explains how Palla may collect, process, retain, share, treat, disclose, and transfer the NPI that we collect when you visit or use the website owned, published, or operated by Palla. It also covers personal information that is disclosed to us via mail, our website, or telemarketing. This Policy explains what NPI is collected and the manner in which Palla may use and share such NPI. It also sets forth the options available to consumers if they seek to limit the use and sharing of their NPI.

    Palla shares information for its own marketing purposes and for joint marketing with other financial companies such as the partner bank and third-party vendors used to manage Palla's platform. Palla shares consumer NPI with nonaffiliates for their own marketing purposes. Currently, Palla does not sell information for marketing purposes to affiliates or non-affiliates.

    This Privacy Statement does not describe privacy policies and practices of other websites and platforms that we do not provide, including those linked to, or integrated with, our website. It also does not cover NPI you may choose to share with other users of our website.

    Security is Paramount

    At Palla, we recognize that the trust of our customers is one of our most important assets. As such, it is our goal to ensure the privacy of our customers' nonpublic personal information that we collect. No data is disclosed except for everyday business purposes and what is permitted by law.

    The following outlines some of the steps we take on a daily basis to ensure that our customers' information is secure, private, and used only in a manner consistent with our customers' wishes. We will safeguard, according to our strict standards of security and confidentiality, any and all information our customers share with us. We use administrative, physical, and technological security techniques and processes designed to protect the integrity and privacy of our customers' information.

  3. REQUIRED PRIVACY NOTICES

    This Privacy Statement applies to all information collected by Palla through Palla websites and the Services. This Privacy Statement applies to information related and retrieved in connection to the Service. You should read this Privacy Statement in its entirety as certain sections may apply differently to residents of different jurisdictions.

    This Privacy Statement applies to you and information collected from you if you are an individual who resides in the United States and uses our Sites or Services for your own personal, family or household purposes.


    FACTS

    WHAT DOES PALLA DO WITH YOUR PERSONAL INFORMATION?

    WHY?

    Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all, sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

    WHAT?

    The types of personal information we collect, and share depend on the product or service you have with us. This information may include, but is not limited to, the following:

    • Domestic and foreign government issued identification numbers such as driver's license, passport, visa, social security number or tax identification number;

    • Date of birth, address, email address, occupation, employer, mobile number, nationality, country of birth, gender;

      • Debit card information, such as the card number, issuer, expiration date, security code, and any bank account and account balances information used to debit outgoing transfers funds and credit incoming transfers funds.

    • Transaction history

    • Transactional profile, monthly transaction amount, frequency of transfers, parties to transactions

    • Phone conversations and email communications

    • Internet protocol (IP) address, geo-location information, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data

    You consent to our collection, transfer, and storage of information by computers or other transfer or storage devices in the United States and elsewhere.

    • When you are no longer our customer, we continue to share your information as described in this notice.

    HOW?

    All financial companies need to share consumers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers' personal information; the reasons Palla chooses to share; and whether you can limit this sharing.

    WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

    We may share your personal information with the following categories of third-parties for one or more purposes such as contacting and corresponding with you, responding to your inquiries, improving our website, targeted advertising, offering media products you request, or for other purposes and if there is a legal basis:

    • Service Providers (or Processors) subject to written agreement to process your personal information consistent with our instructions, including:

      • Email alert providers

      • Know Your Customer service providers

      • Website and application analytics providers

      • Website hosting providers

      • Website testing and optimization providers

      • Customer Service and Support providers

    • Where permitted by law, and this Privacy Statement, we may share your personal information with commercial or banking partners

    • In addition, where permitted by law, and this Privacy Statement, we may share your personal information with the following types of Marketing and Advertising Partners:

      • Advertising, direct marketing, and lead generation providers

      • Social media site advertising providers

      • Targeted advertising platforms

    • SMS Originator Opt-In Data and Consent. The website does not sell or share mobile phone information with third-parties for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

    • Where we believe it necessary or appropriate to do so, we may share your personal information with: law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive. In those circumstances, we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible.

    • We may share or transfer your information in connection with, or during negotiations of, any merger, sale or company assets, financing, or acquisition of all or a portion of our business to another company.

    WHEN?

    This privacy statement was last revised on August 1, 2025.



    Reasons we share your personal information

    Does Palla Share?

    Can you limit this sharing?

    For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

    Yes

    No

    For our marketing purposes - to offer our products and services to you or send you marketing and promotional messages

    Yes

    No

    For joint marketing with other financial companies - to offer jointly marketed products and services to you or send you marketing and promotional messages.

    Yes

    No

    For our affiliates' everyday business purposes -information about your transactions and experiences

    No

    No

    For our affiliates' everyday business purposes -information about your creditworthiness

    No

    Yes

    For our affiliates to market to you

    No

    Yes

    For nonaffiliates to market to you

    No

    Yes



    To limit our sharing

    • Call 786-652-6048 —our menu will prompt you through your choice(s)

    • Visit us online: www.palla.app or

    • Send us an email at support@palla.app or mail us at the following address:

      8950 SW 74th Court, Suite 2201 PMB A132, Miami, FL 33156


    Please note:

    If you are a new consumer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.


    However, you can contact us at any time to limit our sharing.

    Questions?

    Call us at (786) 625-6048

    Email us at: support@palla.app

    Or visit our website,www.palla.app for more information.



    Who we are

    Who is providing this Privacy Policy?

    Palla Financial Inc. ("Palla")

    What we do

    How does Palla protect my personal information?

    To protect your personal information from unauthorized access and use, we use the appropriate technical and organizational security measures that comply with federal law.

    These measures can include physical, electronic, procedural, and computer safeguards and secured files and buildings. These measures are designed to protect the security of any personal information we collect, receive, use, or store. We will do our best to protect your personal information taking into account the state of art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing. You should however access the website within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at support@palla.app. Palla also limits the sharing of personal information to only those employees that need access to it.

    How does Palla protect my personal information?

    We collect your personal information, for example, when you:

    • Register online

    • Provide account information or otherwise provide contact information

    • Conduct a transaction, complete a payment or use or request other products or services from us

    • Use your credit or debit card or provide bank account information

    • Use Palla online services to conduct a prepaid card transaction or to send or receive funds

    • Provide your government issued ID or tax identification number

    • Use or visit our online sites or navigate through mobile apps providing our services (for example, to complete a transaction or manage your account)

    • Communicate with our customer representatives via phone, online, or email

    We also collect your personal information from others, such as credit bureaus, affiliates, non-affiliates, or other companies, all in compliance with and subject to the limitations of applicable law.

    Why can't I limit all sharing?

    Federal law gives you the right to limit only:

    • sharing for affiliates' everyday business purposes - information about your creditworthiness

    • sharing for affiliates to market to you

    • sharing for nonaffiliates to market to you


    State laws and individual companies may give you additional rights to limit sharing.



    Definitions

    Affiliates

    Companies related by common ownership or control. They can be financial and nonfinancial companies.

    Nonaffiliates

    Companies that are not related by common ownership or control. These can be financial and nonfinancial companies.

    Joint marketing

    A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

    Other Important Information

    CHILDREN'S POLICY

    Our website is not directed at children under the age of 14. Palla does not knowingly collect or maintain any personal information concerning or from children under the age of 14, except when consent is provided by a parent or guardian. If we become aware that we have collected personal information from a child under the age of 14 without parental consent, we will promptly delete it, unless we are legally obligated to retain such data. We recommend that parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal information without parental consent. Contact us at support@palla.app if you believe that we have inadvertently collected personal information from a child under the age of 14.


    DE-IDENTIFIED (ANONYMIZED) AND AGGREGATE DATA

    The website may de-identify (also referred to as "anonymize") and aggregate data for its business purposes, including but not limited to, improving the products and features of its services, maintaining the security and integrity of its systems, for analytics, and other legitimate business purposes. "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. De-identified Data includes anonymized data and is no longer "personal data" under applicable data protection laws. Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to re-identify the information, except where permitted by law. The website may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in anonymized form and not attempt to re-identify the data for any business purpose.


    LINKS TO SOCIAL MEDIA AND THIRD-PARTY WEBSITES

    Our website may be linked to or from third-party websites. These third-party sites have their own privacy policies and terms of use. Palla is not responsible for the content or privacy practices of websites that are linked to or from our website. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any personal information. If you follow a link to any third-party site, any information you provide that site will be governed by its own terms of use and privacy policy and not this Privacy Statement.


    We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including links to any third-party site from the websites. We make no representations, express or implied, concerning the accuracy, privacy, safety, security, or the information practices of any third-party site. The inclusion of a link to a third-party site on our website does not constitute any type of endorsement of the linked site by us. We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third party website.


    COOKIES

    Palla and third-party service providers use cookies, pixel tags, web beacons, clear GIFs, or similar technologies to track the actions of website users and email recipients across non-affiliate websites over time, in order to personalize your experience on the website by presenting advertisements that are more relevant to you. For example, we use third party service providers, to present products and offers tailored to the preferences and interests demonstrated by your online activity over time. If you would like to opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiate (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising, you may visit the opt-out pages on the NAI website and DAA website. You understand that these opt-out mechanisms are maintained by third parties, not Palla. Palla is not responsible for, nor does it control these mechanisms of the third parties who choose to participate in these opt-out programs.


    This section describes how the website uses cookies and similar technologies to collect and store information when you visit the website. Like many companies, the website uses certain technologies – cookies, web beacons, clear GIFs, tracking pixels, and similar technologies (collectively, "cookies") – to collect information when you interact with the website and email communications.


    1. How Do Cookies Work?


      To understand how tracking technologies work, it is helpful to describe the types of technologies we use and what they are used for:

      • Cookies - a "cookie" is a small text file that websites send to your computer, device, or other internet-connected tool you are using that contains data used by the website for its business purposes. Cookies enable us to store individual information related to your computer or other device used to access our website. Cookies help us, e.g., to determine the frequency of use and the number of people visiting our website and to create our services to be as comfortable and efficient as possible for you.

      • Web Beacons - a "web beacon" or "pixel" is a tag used on a web browser or HTML email that records your activities when viewing the web page or email where it is placed.


      Classes of Cookies. There are two types of cookies: session cookies and persistent cookies.

      • Session cookiesmake it easier for you to navigate the websites and expire and disappear from your device when you close your browser.

      • Persistent cookies remain longer and help in understanding how you use the websites, and enhance your user experience, and they stay on your device even after you close your device's browser or end your session. Session cookies may remain on your hard drive for an extended period of time.


      Types of Cookies. Cookies are classified by their purpose:

      • Essential -These cookies are required for the website to function. You cannot disable these. They also do not require your consent. In particular:

        • Strictly Necessary cookies are cookies that are required for the operation of our website, such as to ensure security. Other necessary cookies allow us to provide features or services that you expressly request. These cookies do not require your consent and cannot be switched off (although in some cases you can change your requests). You can set your browser to block or alert you about these cookies, but some parts of our website may not work if you block these types of cookies.

        • Functional cookies are used to provide certain functionalities to you by recording your choices and settings regarding our Services, maintaining your preferences over time and recognizing you when you return to our website so that we can offer you a better experience on this website. We will only store and access functional cookies on your device if you consent to such storage and access. If you do not consent to these types of cookies, we will not be able to provide certain functionalities to you.

      • Non-Essential cookies:We use these cookies only for internal research on how we can improve our website for our users. These cookies simply assess how you interact with our website as an anonymous user (meaning the data gathered does not identify you personally). Also, this data is not shared with any third parties or used for any other purpose. The anonymized statistics may be shared with contractors working on communication projects under a contract with Palla. However, you are free to refuse these types of cookies, either via the cookie banner you see when you first visit the site or by visiting the cookie preference page.

        • Performance - These cookies are used to improve the performance of our website and to enhance your experience. The information these cookies collect is aggregated and anonymous information, and we are never provided with your personal information from these cookies.

        • Personalization - Allow the website to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personal features. For example, a website may provide you with local weather reports or traffic news by storing data about your general location.

        • Analytics - Help us understand how the websites perform, how visitors interact with the websites, and whether there may be technical issues. This helps us to improve the way our website works, for example, by ensuring that visitors are easily finding what they are looking for. We will only store and access analytics cookies on your device if you consent to such storage and access. If you do not consent to these types of cookies, we will not be able to improve our website based on information from your visit.

        • Targeted Advertising - Used to deliver advertising that is more relevant to you and your interest. May be also used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the Websites operator's permission. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.


      The website uses first party cookies and third party cookies. The difference between first party cookies and third party cookies relates to the control of the party who serves the tracking technology. First party cookies are cookies that are specific to the website that created them. Their use enables us to operate an efficient service and to track the patterns of behavior of visitors to the website. Third party cookies, on the other hand, are placed on your device or served by a third party (i.e., not by us). While we may allow third parties to access the website to place these cookies on users' devices, we do not retain control over the information supplied by the cookies, nor do we retain access to that data. This information is controlled wholly by that third party in accordance with their respective privacy policy. To learn more about the tracking technologies delivered on our website, please visit our Cookie Preferences Center and select "View Cookies" under each category's heading.


    2. How Does Palla Use Cookies?


      We use cookies consistent with this Privacy Statement. For example, a cookie may be used to determine your preferred language, maintain the security of our website and your account, measure website analytics, measure the effectiveness of our advertising and promotional communications, and gain information for marketing and advertising purposes, including by identifying the website from which a person was referred to the website and to track other websites visited by an individual.


      Information gathered through usage of a cookies is not linked to any direct personal identifiers (e.g., your name or email address), unless you become a customer of Palla. Once you submit personal information on our website (e.g., by signing up to receive information from us) we may link such personal information with data associated with your visit(s) to the website.


      Third-Party Analytics. Our websites use third-party web analytics services that use cookies to help the website analyze how users use the website. The information that is collected about your use of the website will be de-identified or pseudonymized by the third-party analytics provider ([www.posthog.com]) for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. The third-party analytics providers that we use will not link your IP address with any other data held by them about you. Information collected by us through use of third-party analytics includes: website interaction, number of visitors, where they visit the website, and the pages visited.


    3. Managing Cookies and Withdrawing Consent


      We will obtain your opt-in consent to the use of the non-essential cookies and other tracking technologies on this website when you first access the website and if we introduce any new cookies to the website, unless they are essential cookies, in which case your consent is not required. When you visit this website, a pop up will appear to inform you about our use of such cookies. You can then consent by clicking on "Accept", or you may refuse cookies (except necessary cookies) by clicking on "Deny". You may alternatively click on the link to the cookie manager to visit our Consent Management Platform and decide the categories of cookies that you wish to accept, and the cookies you wish to reject.


      You may withdraw your consent at any time with effect for the future.


      If you deny cookies, we will not set those cookies on your device, except essential cookies and a cookie to remember that you don't want any cookies set when you visit this website.


      If you do not want to have cookies on your device, many of them offer ways to opt out, and most web browsers allow at least some control of most cookies through browser settings. You may refuse the use of cookies by selecting the appropriate settings on your browser to decline cookies. You may also delete existing cookies through your browser and the cookies window including the link to the cookie manager appears again.


      Cookie and Browser Settings. You can disable cookies by changing your website browser settings to reject cookies. How to do this will depend on the browser you use. Rejecting cookies 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. Please visit the following websites to learn more (depending on the browser you use):



      Please note, if you disable cookies, you may not be able to use the full functionality of our website. In particular, you may have limited access to some areas or be transitioned to a different experience.


      You may also disable JavaScript at any time. Please remember, some features of our website may not function properly unless cookies and JavaScript are enabled, and some areas of our website may not function at all.


      You may choose to delete cookies placed on your device and to block new third-party cookies from being placed by using your internet browser's privacy and security settings. In addition, you may opt out of our sharing your personal information for targeted advertising purposes by submitting a request through the "Your Privacy Choices" link in our footer of our website. If you do this, however, you may have to manually adjust some preferences every time you visit this website. All modern browsers allow you to change your cookie settings, typically by going to the 'options' or 'preferences' menu of your browser. Use the 'Help' option in your browser for more details.


      Blocking all cookies (including necessary cookies) will have a negative impact upon the usability of many websites, including ours. If you block necessary cookies, you may not be able to use all the features on this website. You can also delete cookies already stored on your computer. However, deleting cookies might have a negative impact on the usability of many websites, including ours.


      To find out more about cookies, www.aboutcookies.org or www.allaboutcookies.org.


    4. Do-Not Track Features


      Many web browsers and some mobile operating systems and mobile applications include a "do-not-track" 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 do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will update this Privacy Statement if that changes in the future.


    CHANGES

    Palla reserves the right to modify this Privacy Statement. To the extent required by applicable law, we will notify you and give you the opportunity to opt out of any material change in the way we use or disclose personal information you previously have provided. You can get an updated Privacy Statement by calling us at or (786) 625-6048 by visiting our website at www.palla.app.

    WEBSITE TERMS OF USE

    The Website Terms of Use governing your use of the website contains important provisions disclaiming and excluding our liability and the liability of others regarding your use of the website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding your use of the website. Each of those provisions also applies to any disputes that may arise in relation to this Privacy Statement and the collection, use and disclosure of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Statement.

    MARKETING PREFERENCES

    If you do not want us to use your email address or contact information to receive marketing related emails or text messages from us going forward, you can opt-out by communicating such request to us by sending us an email at support@palla.app , calling us at (786) 625-6048, or by following the opt-out instructions at the bottom of any emails or replying STOP to any messages you receive from us. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.


We are passionate about building products that people love.
Reach out with any questions:


partners@palla.app
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