This Privacy Policy provides a description of how Rain collects, uses, and shares information about you as well as your rights and choices regarding such information. "Rain", "we", "our", and "us" refers to Signify Holdings, Inc., including its affiliates, successors, assigns, and subsidiaries, and "you" or "your" refers to the natural person interacting with us.  

By accessing the Site or by applying for or using the Services, you represent that you have read and agree to be bound by this Privacy Policy, including consenting to our collection, use, and sharing of Personal Information. If you do not agree, please notify us in writing, close your Rain Account, delete any cookies you may have on your devices, and cease all use of the Services.  

This Privacy Policy applies to the Rain website at https://www.raincards.xyz/ (including any subdomains or mobile applications of such sites) (the “Sites”) or use of any Services (as defined in the Platform Agreement). Any capitalized terms not defined herein will have the meaning assigned to them in the Platform Agreement or accompanying agreements including but not limited to the Card Terms, the Authorized User Agreement, the Privacy Policy, and the Bill Pay Agreement.  

We reserve the right to amend this Privacy Policy at any time. We will use commercially reasonable efforts to notify you in advance of any changes that impose material obligations on you. Notwithstanding the foregoing, by continuing to use the Services, you agree to be bound by such amendments, additional obligations or restrictions. The date on the top of this page shows when the Privacy Policy was last updated.

If you are a California, Colorado, Connecticut, Nevada, Virginia, or Brazilian resident, please see the additional disclosures at the end of this Privacy Policy.

1. Introduction
In general, this Privacy Policy explains:

1. What information we collect, and how we use it

2. Choices you can make about the way your information is collected and used

3. How we protect information electronically and physically.  

2. Information We Collect

A. Information you provide to us

We collect information when you use or interact with our Services. This may include:  

1. “Personal Information” which means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device, or household. Examples include:  

• First name, last name
• Email address

• Phone number
• Date of Birth
• Email address
  

2. “Company Information” which means any information related to, or identifying, the Company which is using the Services. Examples include:

• Company name

• Company address
• Formation or other incorporation documents
• Company jurisdiction
• Company tax identification number
• Company registration number

• Beneficial owners
• Wallet Address  

B. Information we collect automatically from you

We or our vendors or service providers may also automatically collect information when you use the Sites or the Services to, for example, protect against fraud or to improve our products, Services, and user experience.

This information can include:

• Your browser type;
• Your device type or operating system;
• Your device’s location and other information sent by your device;
• Your device’s IP address;

• Your interaction with the Site or the Services, such as number of clicks, landing pages and pages viewed.

C. Information we collect from you with respect to your use of the Services.  

We may collect or have access to transactional information about your use of the Services. This information can include:

• Amount, type, and size of transactions or purchase details

• Date and time of transactions  
• Merchants where you have transacted using a Rain Card
• Repayment history
• Financial data

D. Tracking and Cookie Data

Like many online services, we may use cookies or other tracking technologies to collect information about you. In addition, third parties may place cookies on your device to enable the collection of certain device identifier information, IP address, and information about your interactions with the Site and the Services. Cookies are small pieces of data placed on your computer, phone, or similar device when you use that device to visit the Sites or use our Services.

Examples of cookies we may use:

• Session cookies: Session cookies help us recognize users who visit our Sites.

• Tracking cookies: Tracking cookies help us remember preferences and other settings.
• Security cookies: Security cookies help us prevent fraud.

You can decide whether to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies. If you do not accept cookies, however, you may not be able to use some or all portions of our Sites.

E. Information that we may collect from third parties

We may also supplement any of the information that you provide to us or that we obtain with information that we receive from third parties, such as credit bureaus, data providers, fraud detection services and data analytics providers. Some of these third parties may obtain your Personal Information through your use of the Sites or the Services, and other third parties may already have your Personal Information that they then share with us.

We may use this information for marketing, identity verification, fraud prevention, to help us provide our Services to you, including determining whether you are eligible for the Services, and for other business purposes.

3. How We Use Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

• Helping us assess your eligibility to use the Services. Examples include verifying your identity or underwriting you for a Rain account through Rain.
• Supporting our internal business operations. Examples include maintaining your Rain account with us or improving our Services or products or building new products or services.

• Contacting or communicating with you. Examples include providing customer services to you or marketing our products and services.
• Complying with our own policies and procedures. Examples include complying with our obligations under applicable law, regulation, or other legal process or complying with our contractual or audit obligations.
• Preventing and detecting potentially fraudulent or unauthorized transactions, breach of policies or terms, and threats of harm.  

As described above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address (either directly or through the Company), we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve the Services.

4. Sharing Information

We share information we collect, including information that identifies you, in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

• ​​Service providers, vendors, and advisors. For example, we may share your Personal Information or Company Information with third parties who provide services or products to us and/or who help us provide the Services to you, including our Banking Partners, the Issuer, or Third Party Providers. Such service providers may further require your consent to obtain your Personal Information.
• Our affiliates for everyday business purposes.
• Our financing partners such as sources of debt or equity capital.
• Issuers of your Rain Card.

• Merchants and businesses with whom you transact or use your Rain Card.  
• A third party as part of any due diligence process in relation to a partnership, financing arrangement, or potential purchase of Rain or its assets provided such party agrees to use such information only for such particular purpose.
• Federal or state regulatory bodies, government agencies, courts, law enforcement officials, courts, or any other judicial body as required by law or to protect our legal rights.

In the event of a merger, acquisition, or other sale or transfer of any or all of our assets, your Personal Information may be transferred to a buyer or other successor of our business. If that happens, we may not be able to limit how such other party may use or further transfer your information.

5. Aggregated or Anonymized Information

​​We may share aggregated and/or anonymized information with any third parties at any time to the extent such information cannot be linked back to any identifiable person.

6. Analytics and Advertising

We may use analytics services, such as Google Analytics, to help us understand how users access and use the Services. As part of this process, we may incorporate tracking technologies into our own Services (including our Sites and emails) as well as into our ads displayed on other Sites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you.  

Vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

7. Safeguarding Information

We maintain reasonable safeguards to ensure the protection of your information from unauthorized access or use. Such safeguards may include physical, technical, or administrative security measures.

However, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to our Sites.

Please notify us immediately if you believe your information with Rain has been compromised in any way.

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8. Retention of Information

We will retain your Personal Information as long as permitted by our internal data retention policies, or applicable law, and as long as necessary in order to:  

• Provide the Services to you.
• Use for any of the purposes permitted by this Privacy Policy.
• To comply with any legal or regulatory requirements.

9. Children’s online privacy

Protecting children on the Internet is very important to Rain. For that reason, we do not knowingly solicit or collect Personal Information from anyone under the age of thirteen (13), and no part of the Sites is intended to attract anyone under the age of thirteen (13).

If you believe that a child under the age of thirteen (13) may have provided us Personal Information to us, please contact us immediately at support@raincards.xyz.  

10. Do Not Track Signals

At this time, our Sites do not support Do Not Track (“DNT”). DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across the Sites. For more details, including how to turn on Do Not Track, visit https://www.donottrack.us/.

11. Company Account

The information in your Rain Account is governed by our agreements with the Company. You may access, update, or delete certain information within your Rain Account, provided that the Company will make the ultimate decision around the processing. The Company Administrator is responsible for your Account and Rain Cards associated with the Company. The Company Administrator has the ability to grant, restrict, suspend, or terminate your access to or use of the Rain Card or the Account. The Company and Company Administrator can also access information about you, access and retain information we have stored on its behalf, and limit your ability to edit, modify, delete, or use information associated with your use of the Services. Please note that if you delete information through your Account, we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12. Data Transfer to the United States.

If you are outside of the United States and submit your Personal Information to us, please be advised that your information will be transferred to, stored, and processed in the United States. Please be advised that U.S. law may not offer the same privacy protections as the law of your jurisdiction. If you visit our Sites and use our Services, or contact us from outside of the United States, please be advised that (i) any Personal Information you provide to us or that we automatically collect will be transferred to the United States; and (ii) by using our Sites or submitting Personal Information, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.  

13. Contact Us

If you have any questions about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us: support@raincards.xyz  

Additional Disclosures for Nevada Residents

If you are a resident of Nevada, you may submit requests directing us not to sell Personal Information, pursuant to Nev. Rev. Stat. 603A.340, that the business has collected or will collect about you.  Nevada residents may submit a request relating to our compliance with Nevada law by contacting us at support@raincards.xyz.

Additional Disclosures for California, Colorado, Connecticut, and Virginia Residents

If you are a resident of California, Colorado, Connecticut, or Virginia, you may have certain privacy rights and choices regarding how we collect, share, use, and protect your Personal Information pursuant to the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”). Depending on your state of residence, you have the right under State Privacy Laws over the past 12 months to:

• Know which categories and sources of Personal Information were collected, disclosed or sold over the past 12 months, the business or commercial purpose for such collection, and the categories of third parties with whom we share Personal Information;  
• Access a copy of any Personal Information that we have collect about you;
• Correct any inaccuracies regarding Personal Information about you either in your settings, by contacting your Rain Account administrator, or by contacting us at the email address provided below;
• Delete any Personal Information we have about you, subject to our legal or contractual obligations to keep the information or a need for the information to carry out a legitimate business function, such as to complete a transaction;
• Request that a copy of the Personal Information that we collect and maintain about you be transferred to another party;

• Opt out of the sale or sharing of Personal Information or direct us not to process your Personal Information for targeted advertising or profiling purposes;  
• Not to be subject to automated decision-making; and  
• Not be discriminated against for exercising your privacy rights

To exercise any of these rights, please submit a request by sending an email to support@raincards.xyz with "Privacy Rights Request" in the subject line, and specify your state of residence and the right you are seeking to exercise. We will confirm receipt of your request within 10 days. Please be advised that you can designate an authorized agent to submit requests on your behalf. However, we will require signed certification of the authorized agent's permission to do so. When you exercise your privacy rights and submit a privacy rights request to us, we will verify your identity by asking you for specific information such as your [name, email address, or telephone number]. We also may use a third-party verification provider to verify your identity. If we are unable to verify your identity, we may deny your privacy rights request. If you are a resident of Colorado, Connecticut, or Virginia, you have the right to appeal the denial of a privacy request and may do so by contacting us at the email address provided above. If you have concerns about your appeal, you may contact the attorney general in your state of residence.

If Personal Information about you has been processed by us as a service provider on behalf of a business customer, and you wish to exercise any rights you have regarding such Personal Information, we will instruct you to exercise your rights with the service provider directly. If you wish to make your request directly to us, please provide the name of the Company on whose behalf we processed your Personal Information. We will refer your request to that Company, and will support them to the extent required by applicable law in responding to your request.

Shine the Light.

If you are a resident of California, pursuant to California Civil Code 1798.83, you may request (i) a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write to us at support@raincards.xyz and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Additional Disclosures for Brazilian Residents

If you are a resident of Brazil, you have certain rights regarding the processing of your Personal Information under Brazilian General Data Protection Law (“LGPD”).

Subject to certain conditions, you have the right to obtain the following from us regarding the Personal Information that we collect and maintain about you: · confirmation of processing; · access to information; · correction of incomplete; · inaccurate or out-of-date information; · the anonymization, blocking or deletion of unnecessary or excessive data processed in noncompliance with the LGPD; · the portability to another provider; · the deletion of information  processed; · information on the entities to whom we have disclosed the data and the consequences of not providing consent for the processing; and · the review of decisions made exclusively on the basis of the automated processing of your Personal Information.

You have the right to withdraw consent for processing of your Personal Information. Please be advised that if you withdraw consent to the processing of your Personal Information for the purposes described in this Privacy Policy, we may not be able to provide you with some, or all, of our Services. In certain situations, we may continue to process your Personal Information after you withdraw your consent where may be required to do so, such as to comply with legal obligation to which we are subject.

We rely on the following lawful bases to process your Personal Information: · valid consent; · to fulfill our legitimate interests or those of a third party, such as a contractual arrangement with you, unless your fundamental rights outweigh those interests; · when we are required to comply with a regulatory or legal obligations or exercise our rights in legal, administrative, or arbitration proceedings.  

If you are a resident of Brazil and have a concern about the processing of your Personal Information, you have the right to lodge a complaint with the National Data Protection Authority (ANPD). You may exercise your data subject rights or the withdrawal of your consent for processing by emailing us at support@rain.xyz.

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