Legal

Privacy Policy

Last updated: June 25, 2026

Pemford Bank USA, Inc. (“Pemford Bank”, “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our banking services, website, and mobile applications. Please read this policy carefully. If you disagree with its terms, please discontinue use of our services.

Pemford Bank operates under applicable U.S. federal and state banking, consumer protection, and privacy laws, including the Gramm-Leach-Bliley Act where applicable.

1. Information We Collect

We collect information you provide directly to us, such as when you create an account, make a transaction, or contact our support team. This includes: • Identity information: full name, date of birth, Social Security number or Tax Identification Number, government-issued ID • Contact information: email address, phone number, home address • Financial information: account numbers, transaction history, income details • Technical information: IP address, browser type, device identifiers, usage data We may also collect information from third parties, such as credit bureaus and identity verification services, to the extent permitted by applicable law.

2. How We Use Your Information

We use the information we collect to: • Open, maintain, and manage your banking accounts • Process transactions and send related notifications • Verify your identity and prevent fraud • Comply with federal and state legal and regulatory obligations • Improve our products and services • Send account alerts, statements, and marketing communications (with your consent) • Respond to customer support inquiries

3. How We Protect Your Information

Pemford Bank employs industry-standard security measures to protect your personal and financial information: • 256-bit AES encryption for all data in transit and at rest • Multi-factor authentication for account access • Real-time fraud detection and monitoring systems • Regular security audits and penetration testing • Strict access controls — only authorised staff can access your data Despite our best efforts, no security system is impenetrable. We encourage you to protect your account credentials and never share your PIN or password.

4. Sharing Your Information

We do not sell your personal information to third parties. We may share your information with: • Regulatory bodies: federal and state banking regulators, the Federal Deposit Insurance Corporation (FDIC), and relevant law enforcement authorities, as required by law • Service providers: third-party vendors who assist us in operating our platform, subject to strict confidentiality agreements • Financial partners: banks and payment processors necessary to complete your transactions • With your explicit consent for any other purpose

5. Data Retention

We retain your personal information for as long as your account is active and for the period required by applicable U.S. financial regulations, which may extend several years after account closure. You may request deletion of certain non-essential data by contacting our Privacy Officer.

6. Your Rights

Depending on your state of residence and applicable federal law, you may have the right to: • Access the personal data we hold about you • Correct inaccurate personal data • Request deletion of your data (subject to regulatory retention requirements) • Object to processing of your data for direct marketing • Appeal certain decisions or submit a complaint to the appropriate regulator To exercise these rights, contact our Privacy Officer at privacy@pemfordbank.com.

7. Cookies and Tracking

We use cookies and similar technologies to improve your experience on our platform. These include essential cookies (required for the platform to function), analytics cookies (to understand how you use our services), and preference cookies (to remember your settings). You can control cookie settings through your browser, though disabling essential cookies may affect platform functionality.

8. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or a prominent notice on our platform. Your continued use of Pemford Bank services after any changes constitutes acceptance of the updated policy. The date of the most recent revision appears at the top of this page.

Questions About This Policy?

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact our Privacy Officer:

Email: privacy@pemfordbank.com

Address: Privacy Officer, Pemford Bank USA, Inc., 120 Broadway, New York, NY 10271

Phone: +1 (800) 555-0147