Panda Pay Privacy Policy

1. Overview

Panda Pay, a product of Radiant Union LLC, is a financial technology company that offers tools, including Financial Insights (budgeting and spending analysis) and Cash Flex™ (temporary cash flow support). To provide these Services, we need to collect and process certain information about you, including financial and device data. Panda Pay is not a bank, lender, or credit provider.

We are committed to handling your information responsibly, using it only for legitimate purposes, and explaining our practices in clear language. This Privacy Policy describes the categories of information we collect, how we use and share it, and the choices you have about your data.

We only collect the information reasonably necessary to provide the Services and to meet our legal, accounting, and compliance obligations. Your use of the Services is also governed by our Terms & Conditions, which include provisions on arbitration and dispute resolution. For more information, please review the dispute resolution section of our Terms.

2. Information We Collect

In this Policy, "personal information" refers to any data that identifies or can reasonably be linked to an individual user.

2.1 Information You Provide

We collect information that you provide directly to us, including when you:

• Create or update an account in the Panda Pay app (such as your name, email address, mobile phone number, and password).
• Provide financial information when you link accounts or request Cash Flex™ (for example, bank account details routed through a secure third-party connection).
• Provide subscription and billing information (such as subscription status, renewal dates, and transaction identifiers).
• Communicate with us by email, through in-app chat, or by other channels (including the content of messages and attachments you send).

2.2 Information From Connected Financial Accounts

When you choose to link a bank account or other financial account to Panda Pay, we use third-party integration partners to securely connect to your institution. Depending on what you authorize, we may receive:

• Account identifiers (such as account type, last four digits, and institution name).
• Account balances and available funds.
• Transaction information (such as dates, descriptions, amounts, and merchant categories).
• Identity or verification information returned by the connection partner to confirm your ownership of the account.

These partners may include financial data aggregation services, payment processors, or banking institutions.

We do not see or store your bank username or password. Those credentials are processed directly by our third-party connection partners using bank-grade encryption.

Your bank connection is provided by third-party service providers and is subject to their terms and privacy policies. You can revoke access at any time by unlinking your account in the app.

We currently use Plaid Inc. ("Plaid") to help connect to your financial institution. When you connect your bank, Plaid receives your bank login credentials (processed directly by Plaid, never stored by Panda Pay), account numbers, balances, transaction history, and identity information. Plaid may retain data about your account even after you disconnect from Panda Pay. You can manage your Plaid connections and delete your data at my.plaid.com. Plaid may use your data in accordance with its own privacy policy, which we encourage you to review at plaid.com/legal.

Financial account and transaction information may be considered sensitive personal information under some laws. We use this information to assess eligibility for Services, operate features you request, and manage risk. Panda Pay does not report to or pull information from any consumer credit bureau.

2.3 Information Collected Automatically

When you use the Services, we and our service providers may automatically collect certain information about your device and usage, such as:

• Device information (for example, IP address, device model, operating system and version, language, and app version).
• Usage information (for example, pages or screens viewed, links clicked, features used, and the time and date of your interactions).

2.4 Information From Third Parties

We may receive information about you from third parties, including:

• Bank connection and financial data aggregators that help us securely access your financial accounts.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, operate, and maintain the Services, including Financial Insights and Cash Flex™.
• To manage subscriptions, billing status, free trials, and access to the Services.
• To verify your identity, protect against fraud or abuse, and maintain the security and integrity of the Services.
• To analyze usage and performance, develop new features, and improve the design and reliability of Panda Pay.
• To communicate with you about your account, transactions, security alerts, and support issues.
• To send you optional updates, product announcements, and promotional messages (you can opt out of marketing communications at any time).
• To comply with law, regulatory obligations, and our contractual requirements, including recordkeeping and reporting.
• To enforce our Terms and protect Panda Pay, our users, and the public from fraud, misuse of the Services, or other unlawful activity.

We may send transactional communications by email or SMS (for example, verification codes, security alerts, and account notices). You can opt out of marketing messages at any time (for example, by using unsubscribe links in emails or following instructions in SMS messages); standard messaging rates may apply.

4. How We Share Information

4.1 Service Providers

We share information with service providers that perform services on our behalf, such as cloud hosting, data storage, customer support tools, email and notification services, and security or fraud detection providers. These service providers are contractually obligated to protect your information and use it only to provide services to Panda Pay.

Our service providers may include artificial-intelligence services that help us respond to your support messages on our behalf.

4.2 Financial and Banking Partners

When you link a financial account or use features that depend on external financial data, we share information with third-party connection partners, payment processors, or banks as necessary to provide the Services you request. For example, we may share identifiers that allow those partners to route transfers, confirm account ownership, or verify that a transaction has been completed.

4.3 Legal and Compliance

We may share information when we believe it is reasonably necessary to:

• Comply with applicable law, regulation, legal process, or government request.
• Protect the rights, property, or safety of Panda Pay, our users, or others.
• Detect, investigate, and prevent fraud, security incidents, or other harmful activity.

4.4 Business Transfers

If Panda Pay is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will continue to protect your information as described in this policy and notify you of any material changes.

4.5 With Your Consent

We may share information with third parties when you direct us to do so or provide your explicit consent—for example, when you choose to share certain data with another app or service.

Except as described in this section, we do not disclose your personal information — including nonpublic personal information about current or former customers — to nonaffiliated third parties, other than as permitted or required by law. This applies both while you have an account and after your account is closed.

5. Cookies, Analytics, and Device Technologies

The Panda Pay app uses software development kits (SDKs) and similar technologies to support core functionality and security.

Our website uses cookies and similar technologies, including Google Analytics, to understand how visitors use the site and to improve it. You can limit cookies through your browser settings.

Panda Pay does not sell personal information and does not share personal information for cross-context behavioral advertising.

6. How We Protect Your Information

We use a combination of technical, administrative, and organizational safeguards to help protect your information, including:

• Encrypting data in transit using industry-standard protocols.
• Relying on partners that use bank-grade security for financial connections.
• Limiting access to personal information to employees and contractors who need it to do their jobs.
• Monitoring for suspicious activity and taking steps to prevent fraud and abuse.

No system can be guaranteed to be completely secure. We cannot promise or guarantee that your information will always remain secure, but we work hard to protect it.

Data Breach Notification

In the event of a data breach affecting your personal information, we will notify affected users as required by applicable state and federal law, typically via email or in-app notification.

7. Your Choices and Rights

You may have certain choices and rights regarding your information, including:

To submit a request, email support@pandapay.money with the subject line "Privacy Request." To protect your information, we may verify your identity and account ownership before fulfilling a request. We will respond within the time required by applicable law. We may retain certain information as required for compliance, dispute resolution, and fraud prevention, even if you request deletion.

• Updating or correcting your account information within the app or by contacting us.
• Unlinking a bank or financial account at any time from within the app, which stops future data sharing from that account.
• Opting out of marketing emails by using the unsubscribe link in those messages or contacting us directly.
• Requesting that we delete your account or certain stored information, subject to our legal and contractual obligations.

Depending on your state of residence, you may have rights to request access to, correction of, deletion of, or a copy of personal information we hold about you. To make a request, contact us using the information in the "Contact Information" section below, and we will respond as required by applicable law.

8. Data Retention

We retain personal information for as long as your account is active and thereafter for as long as reasonably necessary to comply with our legal, regulatory, tax, accounting, and recordkeeping obligations (which for financial records is generally at least five years), to resolve disputes, prevent fraud, and enforce our agreements. Because Panda Pay provides financial services, we are generally required to retain transaction and account records after account closure.

If you unlink a bank or financial account from Panda Pay, we stop receiving new data from that account, though we may retain existing records as needed for legal, accounting, or risk management purposes.

When we no longer need to retain data, we may delete it, anonymize it, or aggregate it so that it can no longer reasonably be linked to an individual.

9. Third-Party Links & External Services

The Services may contain links to third-party websites, apps, or services that are not owned or controlled by Panda Pay. We are not responsible for the privacy practices of those third parties, and this Privacy Policy does not apply to them.

We encourage you to review the privacy policies of any third-party services you use in connection with Panda Pay to understand how they handle your information.

10. Children's Privacy

Panda Pay is not directed to children, and we do not knowingly collect personal information from individuals under the age of 13. Financial features are intended for adults and are not designed for users under 18.

If we learn that we have collected personal information from a child in violation of this policy, we will take reasonable steps to delete that information as soon as possible. If you believe a child has provided us with personal information, please contact us using the details below.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date below and, where appropriate, provide additional notice (for example, by email or in-app notification).

Your continued use of the Services after any changes become effective means you accept the updated Privacy Policy.

12. Contact Information

If you have questions about this Privacy Policy, our data practices, or your rights, you can contact us at:

Email:support@pandapay.money

Mail:Radiant Union LLC, 7901 4th St N, Ste 300, St. Petersburg, FL 33702

When you contact us, please do not include sensitive personal information such as full account numbers or passwords. We may ask you for additional details as needed to verify your identity and respond to your request.