RAI Partners Inc dba Groundwork Card DIGITAL PRIVACY POLICY

Last Revised: January 2025

This digital privacy policy (“Digital Privacy Policy”) describes how RAI Partners Inc, dba Groundwork Card (referred to herein as “we,” “us,” and “our”) uses the information that we process in connection with your use of our website, mobile application, and any other online services we operate that links to this Digital Privacy Policy (collectively, our “Sites”) and any services provided through our Sites or in the course of doing business online or offline (collectively, our “Services”). If you provide information in connection with a credit card application, such information will also be subject to the Privacy Notice of the issuing bank. If you opt-out of disclosing information to us through your issuing bank’s Privacy Notice, we will process and use your information solely as a service provider to your issuing bank subject to the Privacy Notice. Both the Digital Privacy Policy and the Privacy Notice are written in accordance with Federal and State law requirements, and your issuing bank is not responsible for the terms of this Digital Privacy Policy.

Please read this Digital Privacy Policy carefully to better understand how we collect, use, and disclose information about you as you use our Services. Any changes to this Digital Privacy Policy will appear on this page, so we encourage you to review it periodically. By using our Services, you consent to the terms of this Digital Privacy Policy. If you do not agree with this Digital Privacy Policy, you must discontinue using our Services; provided, however, that credit card applicants who opt-out of sharing with non-affiliates through the issuing bank’s Privacy Notice will not be required to discontinue using our Services.

INFORMATION WE COLLECT

In the past 12 months, we have collected various categories of personal information. The types of information we collect include:

• Identifiers including your name, alias, phone number, postal address, residence, email address, and other contact details;
• date of birth, Social Security number, and other account information we use to verify your identity;
• your employer’s identity, income, expenses, date of paycheck(s), and other sources of professional or other employment related information;
• the name and date of birth of any additional cardholder(s) that you authorize;
• the web browser you employ, your internet protocol address, operating device and/or system type, IMEI, device identifiers (including cookies), other online identifiers, clickstream data, tracking codes provided by third-party marketers, choice of settings such as Wi-Fi and Bluetooth settings, and other information relating to internet activity or other electronic network activity; geolocation data, which may include Global Positioning System (“GPS”) data, locational information based upon your IP address, cell network data, and similar location data;
• payment, banking, and account information you provide;
• any other information you may provide to us voluntarily through your use of our Services;
• audio, electronic, or visual information, which may include audio recordings and similar information;
• inferences, such as predispositions, behavior, preferences, and characteristics;
• information not listed above but related to characteristics protected under state or federal law; and sensitive personal information, such as Social Security number, driver’s license number, passport number, account log-in, citizenship, or immigration status.

We collect this information directly from you, service providers, business partners, government entities, operating systems and platforms, social networks, and data brokers.

If you choose to use your mobile device’s and operating system’s finger scan or facial image recognition features, your biometric information, identifiers or data will be maintained under your custody on your device in accordance with your device’s and your operating system’s features, and we will not collect, capture, purchase, receive through trade, otherwise process, obtain, or have access to them.

INFORMATION COLLECTED AUTOMATICALLY

Certain information is collected automatically when you use our Services by means of various software tools. We have a legitimate interest in using such information for our business or commercial purposes, such as to assist in systems administration, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our Services.

Log Files

Log files refers to the information that is automatically sent by your web browser or device (or otherwise automatically collected) each time you view our Sites or interact with our Services. The information inside the log files may include IP addresses, type of browser, internet service provider, date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

Device and Online Usage

We may collect information about your computer, browser, mobile or other device that you use to access our Services. We may use cookies, pixels, log files and other techniques to collect such information, including IP address, time zone, device identifiers and other unique identifiers, browser type, browser language, operating system name and version, device name and model, version, referring and exit pages, dates and times of Services access, links clicked, features uses, crash reports and session identification information.

Location Information

When you use our Services on your mobile phone or device, we may collect information on your physical location through satellite, cell phone tower, Wi-Fi signal, beacons, Bluetooth, and near field communication protocols. For example, when you opt-in to allowing us to collect this information, it may allow us to recognize the location of your mobile device.

Cookies

We use cookies to make interactions with our Services easy and meaningful. When you visit our Services, our servers may send a cookie to your computer. We may use cookies that are session-based or persistent. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. We use cookies that enable you to navigate our Services and use its features, such as accessing secure areas of our Services. Because required cookies are essential to operate our Services, there is no option to opt out of these cookies. We use cookies to provide features and services such as:

Remembering your preferences and allowing you to enter your information less frequently; and

Providing other services and features that are only available through the use of cookies.

The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable such technologies. You can disable our cookies or all cookies through your browser settings, but please note that disabling cookies may impact some of our Services features and prevent the Services from operating properly.

We may use or engage a third party that uses Local Stored Objects (LSOs), sometimes referred to as “Flash Cookies”, and other technologies to collect and store information about your use of our Services. A flash cookie is a small data file placed on your device using Adobe Flash technology. Flash cookies are different from the cookies described above because cookie management tools provided in your browser will not remove them. 

We may use or engage a third party that uses session replay technology (with or without cookies) to record and analyze interactions with our Services. This technology captures your interactions with our application, including but not limited to, mouse movements, key strokes, clicks, and scrolling. It helps us gain insights into how users interact with our Services, identify usability issues, mitigate security threats, and improve the overall user experience.

The online advertising industry also provides websites from which you may opt out of receiving certain targeted ads from data partners and other advertising partners that participate in self-regulatory programs.

Do Not Track Signals

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of information about an individual consumer’s online activities over time and across third party websites or online services.

Analytics Services

We work with service providers (including, without limitation, Google Analytics) who conduct analytics to help us track and understand how visitors use our Sites. Google Analytics is a web analytics service provided by Google that uses cookies to help us analyze how users use our Sites. The information generated by the cookies about your use of the Services will be transmitted to and stored by Google on servers in the United States. If you access the Sites through different devices, Google may associate your devices with one another. Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). 

Web Beacons and Similar Tracking Technologies

When you visit our Services, we may collect your IP address for certain purposes such as, for example, to monitor the regions from which you navigate our Services. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Services and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular site tied to the web beacon. We may use web beacons to operate and improve our Services. We may use other tracking technologies to collect other information, such as session replay information or recordings of communications, relating to you and your online activities.

HOW WE USE YOUR INFORMATION

If you submit or we collect information, then such information may be used for the following business or commercial purposes:

Provision and Monitoring of the Services: We may use your information to: (i) determine whether you are qualified for our Services; (ii) provide you with access to our Services;; (iii) support our Services and your use of our Services; (iv) monitor your use of the Services; (v) fulfill any requests you make of us; and (vi) enable you to make payments.

Questions and Requests: We will use the information you provide to answer your questions or resolve your problems.

Research and Data Analysis: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on users’ demographics, interests and behavior based on usage data and other information provided to us. This data may be compiled and analyzed on an aggregate basis, and we may use this aggregated data for its own purposes and disclose this aggregated data to advertisers, researchers, business partners, publications, and other third parties, who will use the data for their own purposes

Services Improvement: We may use your information to help us improve the content and functionality of the Services, to better understand our users, and to improve the Services.

Fraud Monitoring, Prevention, and Detection: We may use your information as necessary to confirm your identity and to prevent and detect fraud.

Compliance: We may use your information to protect our rights or our property and to ensure the technical functionality and security of the Services. We may also use your information to comply with applicable law, assist law enforcement, and to respond to regulatory or other legal inquiries.

Business and Commercial Purposes: We may use your information for auditing our Sites, such as counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with applicable law; helping to ensure security and integrity of our Services; debugging to identify and repair errors that impair existing intended functionality; performing services on behalf of the business such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, undertaking internal research for technological development and demonstration, undertaking activities to verify or maintain the quality of a service provided; and for advertising and marketing.

SMS Alerts: When you provide your mobile telephone number to us in connection with your use of our website, mobile application, and any other online services, you expressly agree that we (and our affiliates, agents and contractors) may contact you at this number via SMS (text message). Compatible carriers include: AT&T, Virgin Mobile, T-Mobile, MetroPCS, US Cellular, and Verizon Wireless. Mobile carriers are not liable for any delayed or undelivered messages. Message and data rates may apply. To opt out of text messages, respond “STOP” to any text message. To request support, text “HELP” in reply to any text message we send you. If you have any difficulty unsubscribing, please contact us at (877) 290-2905. Mobile information will not be shared with any third parties for marketing or promotional purposes.

HOW WE DISCLOSE YOUR INFORMATION

We may disclose any of the above categories of personal information for any of the above business purposes with third parties, including service providers, business partners, government entities, operating systems and platforms, social networks, and data brokers as well as the following third parties:

Our Business Partners

We transfer and disclose information to our business partners to perform tasks on our behalf and to assist us in providing our Services. For example, we may disclose your information to the issuing bank or the entity servicing your account. If you opt-in to certain supplemental services (e.g., credit protection or debt cancellation), we may share your information with third party business partners who service and administer such offerings.

Our Third Party Service Providers

We transfer information to our third-party service providers to perform tasks on our behalf and to assist us in providing our Services. For example, we may disclose your information to service providers who assist us in performing core functions (such as payment processing, hosting, data storage, and security) related to our operation of the Services and/or by making certain interactive tools available to you as a user. We also use third parties for technical and customer support, application development, marketing, analytics, tracking and reporting functions, quality assurance, and other services. In the performance of our Services, we may disclose information from or about you to these third parties so that we can deliver a quality user experience.

Aggregated or Deidentified Information

To better serve our users, business partners, and to improve our Services, we may conduct research on user demographics, interests and behavior or engage in other activities based on identifiable personal information and/or information that we aggregate or de-identify. Aggregated or de-identified information is not considered personal information and does not identify a user personally. We may disclose this aggregated or de-identified information to our affiliates, agents, business partners, and/or other third parties.

Across our Organization

We may share your information with our parent company and affiliates.

In the Event of Merger, Sale, or Change of Control

We may transfer or assign your information in the course of (or in the evaluation of) a merger, acquisition, sale, or other change of control.

With Your Consent

At your direction or request, or when you otherwise consent, we may disclose your information.

Other Disclosures

We may disclose information about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms of Use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of our company, our users, or the public.

RETENTION

We reserve the right to retain any information as long as it is needed to: (i) fulfill the purposes for which we collected the information, and (ii) comply with applicable law. Please note that in many situations we must retain all, or a portion, of your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes. We will not retain information for longer than is reasonably necessary for any of the disclosed purposes in this Digital Privacy Policy.

DATA SECURITY

We take the protection of your information seriously and use physical, administrative, and technical measures that are designed to protect the information collected through the Services. However, please keep in mind that the Internet is not a 100% secure medium for communication. We also cannot guarantee that the information collected about you will always remain private when using our Services. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

CHILDREN’S PRIVACY

Our Services are not intended for or directed to individuals under 13 years of age, and we do not knowingly collect any personal information from children under the age of 13. When a user discloses personal information on our Services, the user is representing to us that he or she is at least eighteen (18) years of age.

LINKS TO OTHER SITES AND SERVICES

Our Sites may include links or provide access to other third party websites as a convenience to you. If you click on one of those links you will be taken to websites we do not control, and this Digital Privacy Policy does not apply to those third- party websites. The inclusion of any link does not imply our endorsement of any other company, its site(s), or its product(s) and/or service(s). We are not responsible for the privacy practices or content of any other site.

LOCATION-BASED SERVICES

Where you have opted in to sharing your location information, we may use various technologies to collect your information as described in this Digital Privacy Policy to provide you with location-based services and content, including, without limitation, for marketing purposes. You can opt-out from further allowing us to access your location data, by adjusting the permissions in your mobile device.

CHANGES TO THIS PRIVACY POLICY

As our organization changes over time, this Digital Privacy Policy may change as well. We reserve the right to amend the Digital Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Digital Privacy Policy or as otherwise required by applicable law. We will provide you notice of material changes by indicating that the Digital Privacy Policy has been updated on our homepage and will indicate the date we made the update above. Your continued use of any of the Services after the changes have been made will constitute your acceptance of the changes. Please, therefore, make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of the policy, please cease using the Services. The terms of this Digital Privacy Policy are effective as of the Last Updated date posted above.

CONTACTING US

Any comments, concerns, complaints, or questions regarding our Digital Privacy Policy may be addressed to us by calling us toll-free at (877) 290-2905.

ADDITIONAL STATE RIGHTS

California Privacy Policy (CCPA)

California Residents:.  If you are a California resident you may have certain rights under the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq.)(“CCPA”). Under the CCPA, covered businesses that collect the personal information of California residents must provide notice regarding their data collection and sharing practices. In addition, the CCPA provides California residents the right to make certain requests with respect to their data.

In the following CCPA Disclosure, the words “us,” “we,” or “our” means RAI Partners Inc dba Groundword Card and the terms “you” and “your” refer to California residents who are customers of RAI Partners Inc Inc. The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Disclosure does not apply with respect to personal information that we collect about California residents in connection with providing our financial products and services for personal, family, or household purposes (i.e., information subject to the Gramm-Leach-Bliley Act (GLBA)). 

California Privacy Rights

Personal Information We Collect.

We collect the following categories of personal information:

1. Identifiers such as your name, address, telephone number, Internet Protocol address, email address, driver’s license number, social security number or government issued ID, employment history, signatures, or other similar identifies.
2. Certain personal characteristics, such as your gender, age, race, color, national origin and marital status.
3. Internet activity information, such as your browsing history, search history, or your interactions with our website or mobile application.
4. Geolocation data.
5. Professional or employment-related information.

As disclosed in our Privacy Policy, we may share your personal information for our everyday business purposes (such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus) and for our marketing purposes to offer our products and services to you. We may also share information about your transactions and experiences with us with our affiliates for their everyday business purposes. 

Our Sources of Personal Information

Category of Sources from which we Collect Personal Information

• We obtain your personal information when you provide it to us (e.g., where you contact us via email or telephone, or by any other means)
• We receive your personal information from third parties who provide it to us (e.g., our customers; credit reference agencies; and law enforcement authorities)We collect your personal information using various sources, including your interactions with our website, the information you provide to apply for a product or service from us, and information obtained from cookies, pixel tags, web beacons, server logs, or other similar technologies. We collect your personal information to provide the products or services requested by you, to contact you regarding our products and services, and to otherwise enhance your experience with us.   When you visit a digital site we make available for use, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a digital channel or  other technical communications information), some of which may constitute Personal Data.

Use of Information

Business and Commercial Purposes for Use of Personal Information

• Marketing/Prospecting: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate
• Servicing: to verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts, conduct online transactions, and to maintain measures aimed at preventing fraud and protecting the security of account and Personal Information
• Operation of our Sites: operation and management of our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites
• IT operations: management of our communications systems; operation of IT security; and IT security audits
• Financial management: sales; finance; corporate audit; and vendor management
• Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services
• Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems)
• Investigations: detecting, investigating and preventing breaches of policy, and criminal offenses, in accordance with applicable law
• Legal compliance: compliance with our legal and regulatory obligations under applicable law
• Legal proceedings: establishing, exercising and defending legal rights
• Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services
• Risk Management: Audit, compliance, controls and other risk management
• Fraud prevention: Detecting, preventing and investigating fraud

Disclosure of Information

Categories of Third Parties to Whom Personal Information is Disclosed

• You and, where appropriate, your family
• With your consent
• Anti-fraud service
• Accountants, auditors, financial advisors, lawyers and other outside professional advisors to us subject to confidentiality
• Consumer reporting agencies
• Accreditation bodies
• Third party service providers (such as payment services providers; shipping companies; etc.)
• Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
• Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties

Note: We do not sell your Personal Information. We also do not sell the personal information of minors under 16 years of age without affirmative authorization.  Please see the Privacy Notice for information on how Personal Information about our customers may be shared and how you may be able to limit certain types of sharing.

Changes to this Disclosure

We may change this disclosure from time to time. When we do, we will let you know by appropriate means such as by posting the revised disclosure on our CCPA web site with a new “Last Updated” date. Any changes to this disclosure will become effective when posted unless otherwise indicated. 

Your Right to Make Requests

California law permits residents of California to request certain details about how their information is collected, disclosed, and sold to third parties. 

Under the CCPA, California residents have the right to:

• Request that a business delete any personal information about the consumer which the business has collected from the consumer.
• Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
  • The categories of personal information that it has collected about that consumer.
    The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom the business shares personal information.
  • The specific pieces of personal information it has collected about that consumer.
• Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to the consumer, free of charge, the following:
  • The categories of personal information that the business collected about the consumer.
  • The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
  • The categories of personal information that the business disclosed about the consumer for a business purpose.
• Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

We do not sell your personal information to third parties or disclose your personal information to third parties for a business purpose. To exercise any of your other rights above, you may contact us by calling us toll-free at (877) 290-2905. We may request up to three pieces of personal information about you when you make a request to verify your identity. Only you, or an authorized agent acting on your behalf, may make a verifiable consumer request related to your personal information. To use an authorized agent to submit a request to us, you must (i) provide the authorized agent signed permission to make a request on your behalf; (ii) verify your identity with us; and (iii) directly confirm with us that you provided the authorized agent permission to submit the request.

We will verify your consumer request by comparing the information you provide to us against our records, which may include requesting that you provide us with your name, address, and phone number.

You have the right not to be discriminated against for your exercise of the privacy rights conferred by the CCPA. We will not discriminate against a consumer because the consumer exercises any of the consumer’s rights as described in this CCPA Disclosure. However, we reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified, to the extent your rights adversely affect the rights and freedoms of others, or where the CCPA allows us an exemption, such as when we are required to comply with federal, state, or local laws.

Contact Us.

If you have any questions or concerns about this CCPA Disclosure or our privacy practices, you may contact us by calling us toll-free at (877) 290-2905.