Privacy Policies and Terms of Use

FACTS	WHAT DOES NET PAY ADVANCE, INC. (“NPA, Inc.”) 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 can include: Social Security number and bank account information Account balances and income Payment history and credit history
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons NPA, Inc. chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information		Does NPA, Inc. 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		No	We don’t share
For joint marketing with other financial companies		No	We don’t share
For our affiliates’ everyday business purposes – information about your transactions and experiences		No	We don’t share
For our affiliates everyday business purposes – information about your creditworthiness		No	We don’t share
For our affiliates to market to you		No	We don’t share
For nonaffiliates to market to you		No	We don’t share
To limit our sharing	Call (888) 942-3320 – our menu will prompt you through your choice(s); or Visit us online: www.netpayadvance.com Email us at [email protected] Mail in opt-out form Please note: If you are a new customer, 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 (888) 942-3320 or go to www.netpayadvance.com.

Who we are
Who is providing this notice?	Net Pay Advance, Inc. is providing this notice, and it applies to all loans and lines of credit made by Net Pay Advance, Inc. and all products and services offered in connection with such loans and lines of credit.
What We Do
How does NPA, Inc. protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also maintain physical, electronic and procedural safeguards i.e. computer virus protection software, firewalls, 128 bit Secure Socket Layer. Only authorized employees have access.
How does NPA, Inc. collect my personal information?	We collect your personal information, for example, when you Apply for a loan Give us your income information Provide employment information Provide account information Give us your contact information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
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 Affiliates from using your information to market to you Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account
Definitions
Affiliates	Financial and nonfinancial companies related by common ownership or control. Our affiliates include companies with a common corporate identity of NPA, Inc.
Nonaffiliates	Financial and nonfinancial companies not related by common ownership or control. Nonaffiliates we share with can include direct marketing companies for application resell, direct mail and other purposes.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial institutions, credit card companies, partners that promote our products, pre-paid debit card providers and other lending companies.

Net Pay Advance, Inc. SMS Short Code Terms of Service

Please read these terms and conditions carefully as they constitute a legal agreement between you (“you” or “your”) and Net Pay Advance, Inc., referred to as (“Net Pay Advance, Inc.”, “we”, “us” or “our”).

If you do not understand any of these Terms and Conditions, please consult with a legal expert for clarification.

SMS Short Code Program Services

Account Services – By providing your mobile telephone number you expressly consent to receive text notifications from Net Pay Advance, Inc. related to your account including but not limited to:

• Application completion assistance
• Payment due date reminders and notifications

Marketing/Promotional Services – By providing your mobile telephone number you expressly consent to receive text notifications from Net Pay Advance, Inc. for special offers including but not limited to:

• New products and services
• Promotional campaigns and valuable offers

When you opt-in to the service, we will send you an SMS message to confirm your signup.

You can cancel the SMS service at any time. Just text “STOP” to 88571. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.

If at any time you forget what keywords are supported, just text “HELP” to 88571. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe.

Message and data rates may apply for any messages sent to you from us and to us from you. You will receive up to four messages per month. If you have any questions about your text plan or data plan, you should contact your wireless service provider. For all questions about the services provided by this SMS short code, you can send an email to [email protected]

Limitation of Liability

The SMS Short Code Program Services are provided on an “as is” basis. Delivery of content and/or information to a mobile device may fail due to a variety of circumstances or conditions. You understand and acknowledge that network services, including but not limited to mobile network services, are outside of Net Pay Advance, Inc.’s control, and Net Pay Advance, Inc. is not responsible or liable for issues arising from them.

T-Mobile or carriers are not responsible or liable for delayed or undelivered messages.

California Resident’s Privacy Policy Addendum

Your rights

       Under the California Consumer Privacy Act. California residents have a right to:

• Know what categories of personal information is collected.
• Know the purpose for which personal information is collected.
• Request a copy of any personal information collected about you.
• Request that we delete certain personal information.
• Know what categories of personal information we share.
• Request that we not share your personal information. (Note: we do not sell personal information)
• Be free from discrimination for exercising your rights.

Categories of personal Information collected

We collect the following categories of personal information and may have done so in the past 12 months:

• Identifying information such as a real name, alias, postal address, telephone number, email address, social security number, driver’s license Numbers, Internet Protocol address, cookies, beacons, pixel tags, mobile ad identifiers, Geo tag location, signature etc.
• Financial Information such as; bank account numbers, debit card numbers, employment history, salary history, etc.
• Protected Classifications such as race, color, national origin, age, sex, gender, and military and veteran status.
• Commercial Information such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
• Communications: Telephone, email, text, or regular mail communications relating to your account.
• Inferences: any inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• We do not knowingly collect information about or from those under the age of eighteen.

Sources of personal information collected

This information may be collected from various sources including:

• Directly from you.
• From your devices when you visit our websites.
• Other individuals, such as authorized agents or family members.
• Inferred from information collected from you and the other sources listed above.
• Our affiliates, vendors and joint marketing partners.
• Social networks.
• Government entities and public records.
• Consumer data re-sellers.

Reasons we collect personal information

This information is collected for the following reasons:

• For regular business transactions such as: underwriting loan applications and processing your applications for loans or financial services; providing services to our customers; maintaining customer accounts and records; communicating with customers; responding to court orders, investigations and inquiries from investigatory agencies; collecting on accounts receivable; marketing our services etc.; for the regular business purposes of our affiliates so that they can support our operation and assist in determining creditworthiness.
• Detecting and securing against fraud, deception malicious and illegal activity.
• Identifying and repairing bugs in our system.
• Internal research for technological development.

To Request a copy of the personal information we have collected about a specific person please fill out the form below and email it to; [email protected] In the alternative: print form and mail to: Net Pay Advance Inc. Attn: CCPA Records Request 6820 W. Central, Wichita Ks 67212. You may also call 855-790-7834. To make such a request.

Please allow up to 45 days for the processing of your request

Right to Request that we to delete personal data

Pursuant to the California Consumer Protection Act California Residents have a right to request that certain personal information which may have been collected be deleted. However, there are some exceptions and limitations to this right. Specifically, we may be exempt from complying with a request to delete the following:

1. Personal information, the maintenance of which necessary for the business to:
   1. Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
   2. Detect security incidences, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
   3. Debug our systems. ( i.e.to identify and repair errors that impair existing or intended functionality.)
   4. Exercise free speech, ensure the right of another to exercise his or her right of free speech, or exercise another right provided for by law.
   5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
   6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
   7. Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
   8. Comply with a legal obligation.
   9. Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.


2. Information regulated under certain Federal Regulations and sector-specific privacy laws are exempted from this requirement. This includes:
   1. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
   2. personal information covered by the Fair Credit Reporting Act (FCRA),
   3. personal information covered by the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA),
   4. personal information covered by the Driver’s Privacy Protection Act of 1994 (DPPA).

Note: As we collect personal information for the purpose of conducting business with you and processing any loan applications or requests for services which you have submitted, Please be advised that any request to delete your personal information may result in an inability to process any requests for financial services or applications for loans and may result in the denial of any such requests or applications.

To Request deletion of personal information we have collected about a specific person please fill out the form below and email it to; [email protected] In the alternative: print form and mail to: Net Pay Advance Inc. Attn: CCPA Records Request 6820 W. Central, Wichita Ks 67212. You may also call 855-790-7834. To make such a request. (I recommend a voice mail that then get forwarded to specific person for follow up action. The voice mail should say: You have reached the California Consumer Privacy Act Record Request line of Net Pay Advance Inc. please leave your name, telephone number, your email address and the nature of your request and someone will contact you to process your request.)

Please allow up to 45 days for the processing of your request.

Personal Information we share with others

NET PAY ADVANCE INC. DOES NOT SELL PERSONAL INFORMATION. We do however, share and discloses certain personal information. During the past 12 months, we may have disclosed the categories of Personal Data above below for business purposes and subject to the limitations applicable state and federal laws and regulations.

• Identifying information such as a real name, alias, postal address, telephone number, email address, social security number, driver’s license Numbers, Internet Protocol address, cookies, beacons, pixel tags, mobile ad identifiers, Geo tag location, signature etc.
• Financial Information such as; bank account numbers, debit card numbers, employment history, salary history, etc
• Protected Classifications such as race, color, national origin, age, sex, gender, and military and veteran status.
• Commercial Information such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
• Communications: Telephone, email, text, or regular mail communications relating to your account.
• Inferences: any inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

With whom we share personal information

This information may be shared with certain categories of third parties including:

• Authorized agents or family members.
• Our affiliated contractors, and partnering businesses.
• Government entities as required by prevailing legal and regulatory authority.

Reasons we share personal information

This information is shared for the following reasons:

• For regular business transactions such as: underwriting loan applications and processing your applications for loans or financial services; providing services to our customers; maintaining customer accounts and records; communicating with customers; responding to court orders, investigations and inquiries from investigatory and regulatory agencies; collecting on accounts receivable; marketing our services etc.; for the regular business purposes of our affiliates so that they can support our operation and assist in determining creditworthiness.

Right to request that we not share or sell personal information

While NET PAY ADVANCE INC. DOES NOT SELL PERSONAL INFORMATION . pursuant to the California Consumer Protection Act, California Residents have a right to request that we not share, sell or transfer your personal information to others. However, there are some exceptions and limitations to this right. Specifically, we may be exempt from complying with a request to refrain from sharing, transferring or selling your information under the following circumstances:

1. When doing so is necessary to provide the financial service you have requested.
2. When doing so is necessary to process loan applications you may have submitted.
3. When doing so is necessary to Detect security incidences, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
4. When doing so is necessary to comply with lawful orders from law enforcement, courts and government agencies.
5. When doing so is necessary for litigation purposes.
6. When doing so is necessary to complete the transaction for which the personal information was provided, to provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
7. To the extent that State law requiring compliance with a request not to share personal information is pre-empted by prevailing federal legislation a regulations such as the Gramm, Leach, Bliley Act.

Note: From time to time we share personal information with third party partners for the purpose of conducting business with you, processing any loan applications, and processing requests for services which you have submitted, Please be advised that any request that we DO NOT SELL YOUR INFORMATION may result in an inability to process any requests for financial services, or applications for loans and may result in the denial of any such requests or applications.

To Request that personal information not be sold or shared with others fill out the form below and email it to; [email protected] In the alternative: print form and mail to: Net Pay Advance Inc. Attn: CCPA Records Request 6820 W. Central, Wichita Ks 67212. You may also call call 855-790-7834. To make such a request. (I recommend a voice mail that then get forwarded to specific person for follow up action. The voice mail should say: You have reached the California Consumer Privacy Act Record Request line of Net Pay Advance Inc. please leave your name, telephone number, your email address and the nature of your request and someone will contact you to process your request.)

Please allow up to 45 days for the processing of your request.

Right to Non-discrimination

If you chose to exercise any rights under the California Consumer Privacy Act, you will not be discriminated against and the same services and benefits may be obtained at the same price and rate with the same level of quality as those benefits and services obtained by those who chose not to exercise their rights under the California Consumer Privacy Act. However, if you do not allow us to share your data, or if you request that we delete your data, we may not be able to properly ascertain credit worthiness and therefore we may deny any application for a loan or other financial services.

Right to timely response to requests under the California Consumer Privacy Act

We will acknowledge receipt of any request made under the California Consumer Privacy Act within 10 days of its receipt. We will respond to verifiable consumer requests within 45 days of receipt. If we require more time, we will inform you of the reason and extension period in writing. If necessary, we may take a total of 90 days to completely respond to such requests.

This California Consumer Privacy Act Policy is applicable to Net Pay Advance Inc. NPA Tx LLC, NPA Ks LLC, and Acumen Connections Inc.