Privacy Policy

1. Introduction

UBANLC Limited ("UBANLC," "we," "us," or "our") is committed to protecting the privacy and security of your personal and financial information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our banking services, website, and mobile application (collectively, the "Services"). We are a FinCEN-registered Money Services Business operating in compliance with the Gramm-Leach-Bliley Act (GLBA), the Bank Secrecy Act (BSA), and other applicable federal and state regulations.

2. Information We Collect

We collect the following categories of information:

• Personal Identifiers: Name, date of birth, Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN), government-issued ID, and passport information.
• Contact Information: Mailing address, email address, and phone number.
• Financial Information: Account numbers, routing numbers, transaction history, income, employment status, and credit information.
• Device and Usage Information: IP address, device type, browser type, operating system, and usage data collected through cookies and similar technologies.
• KYC/AML Information: Identity verification documents, risk assessment data, and screening results required under BSA/AML and OFAC regulations.

3. How We Use Your Information

We use your information for the following purposes:

• To open, maintain, and service your deposit accounts, cards, and loan products.
• To process transactions, including ACH transfers, wire transfers, instant payments, and internal transfers.
• To verify your identity as required by KYC, CIP, BSA/AML, and OFAC regulations.
• To detect, prevent, and report fraud, money laundering, and other financial crimes.
• To comply with federal, state, and local laws, regulations, and legal processes.
• To provide customer support and respond to your inquiries.
• To improve our Services, develop new products, and conduct business analytics.
• To send you account statements, notifications, alerts, and other required communications.

4. Information Sharing and Disclosure

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• With Partner Banks: To provide deposit account and banking services through our FDIC-insured partner banks.
• With Service Providers: Third parties that perform services on our behalf, such as payment processors, identity verification services, and cloud hosting providers, under contractual obligations of confidentiality.
• For Legal Compliance: To comply with lawful requests from government authorities, law enforcement agencies, and regulators, including FinCEN, OFAC, and the CFPB.
• For Fraud Prevention: To detect and prevent fraud, unauthorized transactions, and other financial crimes.
• With Your Consent: When you authorize us to share your information for a specific purpose.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations.

Under the Gramm-Leach-Bliley Act, you have the right to opt out of certain sharing of your nonpublic personal information with non-affiliated third parties. To exercise this right, contact us at privacy@ubanlc.com.

5. Online Privacy

Our website and mobile application use industry-standard security measures, including 256-bit AES encryption and TLS/SSL protocols, to protect your data in transit and at rest. We employ multi-factor authentication, continuous fraud monitoring, and regular security audits to safeguard your information. We do not knowingly collect personal information from children under 18. If you believe we have collected information from a minor, please contact us immediately.

6. Cookie Policy

We use cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and personalize content. The types of cookies we use include:

• Essential Cookies: Required for the website to function properly, including authentication and security features.
• Analytics Cookies: Help us understand how visitors interact with our website so we can improve our Services.
• Preference Cookies: Remember your settings and preferences, such as language and display options.

You can control cookies through your browser settings. Disabling essential cookies may affect the functionality of our Services. We do not use cookies for targeted advertising.

7. Data Retention

We retain your personal and financial information for as long as your account is active and as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. Records related to BSA/AML compliance, including KYC documentation and transaction records, are retained for a minimum of five (5) years as required by federal regulations.

8. Your Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

• Right to Know: Request information about the categories and specific pieces of personal information we have collected about you.
• Right to Delete: Request deletion of your personal information, subject to legal retention requirements.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out: Opt out of the sale or sharing of your personal information.
• Right to Non-Discrimination: Receive equal service and pricing regardless of whether you exercise your privacy rights.

To exercise any of these rights, contact us at privacy@ubanlc.com or by mail at 600 N Broad St Ste 5, Middletown, DE 19709.

9. Data Security

We implement comprehensive technical, administrative, and physical safeguards to protect your information, including encryption, access controls, employee training, and regular security assessments. Our information security program is designed to comply with the safeguards required under the GLBA and the FTC Safeguards Rule. In the event of a data breach, we will notify affected customers and regulators as required by applicable law.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and, where required, by sending you a direct notification. The "Last updated" date at the top of this page indicates when the policy was last revised.

11. Contact Us

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