1. About This Policy

This Privacy Policy (the “Policy”) describes the information GoDo Inc. (“GoDo”) collects about you, how we use and share that information, and the privacy choices we offer. This Policy applies to information we collect when you open an account through GoDo, access or use our website, mobile application, products, and services (collectively, the "Services"), or when you otherwise interact with us. This includes information we collect when you apply for an Advance from GoDo through the GoDo Wage Advance Service, as well as when you apply for a GoDo Prepaid Account from Sutton Bank through our website or mobile application.

The terms “GoDo,” “we,” “us,” or “our” mean GoDo, Inc. “You” or “your” means an individual who visits our website or uses our mobile applications or Services. The term "Platform" includes (1) all websites and mobile applications operated by GoDo that collect personal information from you and that link to this Privacy Policy, and (2) all pages within each such website, device, or mobile application, any equivalent, mirror, replacement, substitute, or backup website, device, or mobile application. By using our Services or our Platform, you acknowledge and agree to the terms of this Policy.

2. Personal Information We Collect and Disclose

GoDo collects personal information about you for a variety of purposes. We collect information about you (1) directly from you, (2) from third parties such as our bank partners or your employer, and (3) automatically when you use the Platform.

Information you provide to us. Personal information you may provide us includes:

• Contact details, such as your first and last name, email, and phone number.
• Platform account data, such as the username and password that you may use to establish an online account with us.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Our Services may use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Data brokers that provide us with basic information to allow us to better tailor our Services to you or qualify you for Services, such as your payroll information for purposes of evaluating you for participation in the GoDo Wage Advance Service.
• Financial institutions that operate any financial accounts or products that you connect to your GoDo Platform account, including Sutton Bank and its service providers that issue and administer the GoDo Prepaid Card and any other financial account that you link to your GoDo Platform account. 
• We may also collect information about you from mailing list providers, publicly available sources, identification verification services, and other third parties.

3. How We Use Your Information 

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

• Provide, operate, and improve our Services and our business, including personalizing the Services for your use;
• Process payments and complete transactions;
• Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
• Understand your needs and interests, and personalize your experience with the Services and our communications; and
• Provide support for our Services, and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you GoDo-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in Section 5 below.

Compliance and protection. We may use your personal information to:

• Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern our Services; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

Comply with law. We may use your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

4. How We Share Your Information

We share your personal information with the following third parties or as otherwise described at the time of collection:

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). Our service providers include companies that assist us in accessing your payroll data, evaluating whether we will provide you with access to the GoDo Advance Service, and informing us of your financial account transaction histories. Our service providers also include professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Our financial partners. Companies with whom we partner to offer you financial products and services that you request, including prepaid card accounts and the GoDo Advance Service. These companies’ privacy and information sharing practices are set forth in their respective privacy policies.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, GoDo (including, in connection with a bankruptcy or similar proceedings).

Advertising partners. Third-party advertising companies, including for the interest-based advertising purposes described above, that may collect information on our website through cookies and other automated technologies. We do not share your financial information with advertising partners. 

Although we share your personal information as described above, we do not sell your personal information to any third parties. We also may share your personal information with additional third parties as you direct us to in writing. 

5. How We Protect Your Information 

We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information. Examples of measures we have taken to protect your information include, but are not limited to:

• The use of encryption while transmitting and storing information.
• Mobile application session timeouts to ensure your information is protected when you put down your device without logging out.
• Passwords and personal identification numbers (“PINs”) are only known by you. No employee, contractor or Third-Party Site has access to your GoDo password or PIN. We will never ask for your password or PIN through our customer service teams.
• Two-factor authentication is provided to ensure your account can only be accessed by the device you register with.
• Our systems are periodically audited for security flaws.

Please take note that no security measures are failsafe, and we cannot guarantee the security of your personal information.

6. Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you.  To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in Section 10 below. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you have a GoDo Platform account, you may update some of your account details and settings by logging into your account on our Platform, calling 1-844-226-1413 (from within the United States) or 1-832-344-3665 (from outside the United States), or by writing us at support@godolife.com. Please note that even if you close your GoDo Platform account, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

7. Children’s Privacy

Our Services are not intended for use by individuals under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

8. Links to Third-Party Services and Features

For your convenience and information, our Platform may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by GoDo, we are not responsible for these third parties’ information practices.

If you have a GoDo Platform account and elect to use the GoDo Advance Service, you will need to create an account with Argyle and authorize them to collect your payroll information from your employer.  By using the Argyle services, you acknowledge and agree that Argyle will collect and use your personal information in accordance with Argyle’s privacy policy, which is available at https://argyle.com/legal/privacy-notice.

9. Changes to This Privacy Policy

We reserve the right, at our discretion, to make changes to this Policy from time to time, so please review it frequently. You may review updates to our Terms of Use and Privacy Policy at any time via links on www.godolife.com. You agree to accept electronic communications and/or postings of revised versions of this Policy on https://godolife.com/privacy-policy/ and agree that such electronic communications or postings constitute notice to you of the revised version of this Policy. Changes take effect immediately upon posting.

10. How to Contact Us

If you have questions or concerns regarding this Policy, you may contact us through email at support@godolife.com. You may also contact us through our website at https://godolife.com/support/ or by calling us at 1-844-226-1413 (from within the United States) or 1-832-344-3665 (from outside the United States).

11. California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the GoDo Privacy Policy and applies solely to California consumers. This Statement does not apply to GoDo personnel or job applicants. 

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as age
• Commercial Information: commercial information, including 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
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information
• Inferences: 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 may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our GoDo Privacy Policy and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Debugging to identify and repair errors that impair existing intended functionality
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you sign up for a GoDo Platform account, use the GoDo Platform, or contact customer support
• Our Bank Partners and their service providers, including Sutton Bank
• Your devices, when you use our Platform
• Payment processors
• External banks (i.e., banks other than our Bank Partners) if you link a bank account to the GoDo Platform, such as to qualify for an Advance
• Vendors who provide services on our behalf
• Our joint marketing partners
• Our business partners (such as referring websites)
• Online advertising services and advertising networks
• Data analytics providers
• Government entities
• Operating systems and platforms
• Data brokers

Sale of Personal Information

We do not sell personal information.

Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below. When we share personal information with our Bank Partners, we do so as their service provider. The privacy practices of our Bank Partners are subject to their privacy notices (see the Sutton Bank Privacy Notice, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-Privacy-Disclosure-1218.pdf), which we strongly suggest you review. GoDo is not responsible for our Bank Partners’ information practices or privacy notices.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: government entities; other persons to whom we have a legal obligation to disclose personal information (including, for example, in response to a duly issued subpoena or search warrant); and other persons to whom you authorize GoDo to disclose your personal information.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access or deletion request, please submit a request through our webform at https://godolife.com/support/, or call us at 1-844-226-1413 (from within the United States) or 1-832-344-3665 (from outside the United States). To submit a Shine the Light request, submit a request through our webform at https://godolife.com/support/. Be sure not to transmit your Account Number or other sensitive information in your initial request; if we need additional information to identify you for the purpose of responding to your request, we will contact you.

If you designate an authorized agent to make an access or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in Section 10.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your GoDo Platform account, one or more recent transactions, and the last four digits of your GoDo Prepaid Card. If you have never had a GoDo Platform account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that GoDo does not maintain information about non-accountholders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.