Privacy Policy

Effective Date: August 08, 2025

This policy describes how Kiwi Financial Inc., and its parent company KIWI FINANCIAL GROUP INC. (collectively, “Kiwi”, “we”, “us” or “our”) collect, use, and share personal information when you visit our website or mobile application (collectively, “Site”), communicate with us, submit information to a third party that provides it to us (including your employer or client) or that provides services for us. 

If you enroll in our credit program or other financial product offered through Kiwi, our privacy practices with regard to that information are governed by the Kiwi Privacy Notice.

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You can jump to particular topics by going to the headings below:

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Information We Collect

We collect information about you in a variety of ways, depending on how you interact with our website, mobile application, products, and services. This includes:

  • Direct interactions: When you register for and use the Kiwi platform, either as an administrator for one of our business customers or as an end-user employee or contractor.
  • Platform activity: When you engage with features like schedules, auto-scheduler, pay, team, and communication tools.
  • Program enrollment: When you enroll in and use programs such as loans, credit builder, and referral bonuses.
  • Communications: When you sign up for communications from us or contact us by phone, email, or other channels.
  • Authentication and identity verification: When we perform verification procedures, including the use of tools that collect or process biometric information.
  • Automated technologies: When you interact with our websites, mobile applications, advertisements, and emails through cookies, server logs, and similar technologies.
  • Third-party sources: From affiliates, business partners, service providers, financial institutions, social media networks, other third parties, or publicly available sources. For example, we may conduct background checks if you submit a job application or become an employee.
  • External data providers: From outside companies that assist with fraud prevention, identity verification, and marketing, including internet service providers, operating systems and platforms, data brokers, advertising networks, and analytics providers.
  • Human resources support: From outside organizations that provide data to support HR and workforce management activities.

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The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

Context
Types of Data
Primary Purpose for Collection and Use of Data
Business Customer Information
Name, contact information of our business customers and their employees and workforce members.
To manage and communicate with business customers regarding projects, services, billing, and account support. Also used to provide assistance with login credentials and PIN/password resets.
Enrollment in Credit or Financial Products
Information entered during application and enrollment forms, including name, financial information, and identifying information.
Used to process your application. Once submitted, this information is governed by our separate Kiwi Privacy Notice for financial products.
Cookies and First-Party Tracking
Cookies and tracking technologies that identify website usage and preferences.
To ensure website functionality, customize offers, improve user experience, and prevent fraud.
Cookies and Third-Party Tracking
We may place tracking technologies on our website, such as Google Analytics, that collect analytics, record how you interact with our Site, or allow us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our Site so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our Site or other websites.
We collect this information to analyze how our websites are being accessed and used, to improve user experience and the overall quality of our websites, and to customize advertising and content. Please see the Your Choices section below for information on how to disable targeted advertising.

Note: The data collection and use practices of any company with third-party tracking technology on our Site is not covered by this Privacy Policy. 
Demographic Information
Age, gender, and other demographic data.
To understand our users and provide tailored services.
Biometric Information
Facial images or biometric data (e.g., selfie or facial scan).
Used for identity verification.
Location Information
GPS, Wi-Fi, IP address, and approximate device location from web or app usage.
To enhance security, prevent fraud, and comply with legal requirements.
Email Interconnectivity
Information on email open rates, clicks, and interactions.
To understand user engagement with our communications.
Employment
Data collected during the application or employment process, including Social Security Number and other identifying details.
Used for recruitment, onboarding, HR administration, and to comply with legal requirements.
Feedback/Support
Name, email address, and content provided when contacting support.
To respond to feedback and provide assistance.
Mobile Devices
Unique identifiers from your device when using our site or app.
To identify unique visitors, analyze mobile usage, and prevent fraud.
Surveys
Information provided in response to surveys.
To understand customer opinions and improve our products and services.
Sweepstakes or Contests
Contact information and other details provided when entering a contest.
To conduct promotions and comply with legal requirements for contests.
Website Interactions
Data on website use, including clicked links, form inputs, and device/browser details.
To analyze and improve website usability, personalize content, and prevent fraud.
Web Logs
Browser type, operating system, IP address, domain name, click-activity, referring site, and timestamp.
To monitor network security, analyze website usage, and detect fraud.

How We Use Information

We may also use information in the following ways:

  • To identify you when you visit our website and use our services.
  • To provide and deliver our products and services to you.
  • To test, improve, promote, and personalize our offerings.
  • To streamline the onboarding process for end users of our business customers.
  • To facilitate enrollment in our credit program and other products we offer.
  • To process payments and handle transactions securely.
  • To conduct analytics and better understand how our services are used.
  • To respond to inquiries related to customer support, job applications, or other requests.
  • To maintain and manage end user accounts and customer relationships.
  • To coordinate and execute events.
  • To send marketing and promotional communications about our products, services, and offers.
  • To detect and prevent malicious, deceptive, fraudulent, or illegal activity, including violations of our terms and policies, security incidents, and threats to the rights, property, or safety of our users, employees, or others.
  • To identify and fix errors that affect the functionality of our website and services.
  • To comply with legal or regulatory obligations, establish or exercise our rights, and defend against legal claims.
  • For internal administrative purposes and relationship management.
  • For any other purposes that you may consent to from time to time.

While the sections above describe our primary reasons for collecting your information, it is important to note that we may collect and process your information for multiple overlapping purposes. For example, if you submit an employment application with us, we collect your information to make an employment decision, but we also have a legitimate interest in retaining that information to comply with applicable laws, facilitate the employment relationship, and maintain records of our recruitment efforts.

Accordingly, our collection and processing activities are based on a variety of legal grounds, including your consent, the need to perform a contract, compliance with legal obligations, and our legitimate interests in running our business.

To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information except to determine whether our deidentification processes satisfy applicable legal requirements. Additionally, if we are required to share your information in response to a legal process, we will provide you with notice so you may challenge the disclosure—unless we are prohibited by law from doing so or believe that notifying you may put others at risk. We will object to requests for user information that we believe are improper or unjustified.

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How We Share Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

  • Affiliates and Corporate Transactions: We may share your information with our corporate affiliates, such as our parent company, sister companies, subsidiaries, joint ventures, or other companies under common ownership or control. Additionally, if another company acquires, or plans to acquire, our company, business, or assets, we may share information with that company during negotiations and beyond. We may also share information with our investors or potential investors. In the event of a merger, acquisition, bankruptcy, reorganization, or sale of assets that would transfer your information or make it subject to a different privacy policy, we will provide advance notice so that you can opt out of the new policy by deleting your account before the transfer takes place.
  • Legal and Regulatory Disclosures: We may disclose your information as required by law, including in response to subpoenas, warrants, court orders, or similar legal processes. We may also share your information to establish or protect our rights, defend against legal claims, investigate, prevent, or take action against potential illegal activities, suspected fraud, threats to safety, or violations of our policies.
  • Partner Promotions: From time to time, we may offer contests, sweepstakes, or other promotional opportunities with third-party partners. If you choose to participate, your information may be shared with both us and the third-party partner. Their use of your information will not be governed by this Privacy Policy.
  • Service Providers: We may share your information with trusted service providers who help us operate our website, conduct surveys, provide technical support, process payments, and fulfill products and services you have requested.
  • Other Disclosures with Your Consent: We may share your information with third parties whenever you give us your consent or direct us to do so.

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Use of Artificial Intelligence and Automated Decision-Making

At Kiwi Financial, we use advanced technologies, including artificial intelligence (AI) and machine learning (ML) to enhance the speed, accuracy, and fairness of our financial services. These tools support key areas of our operations:

  • Credit Decisioning: AI models help evaluate loan applications by analyzing a broad range of financial and behavioral data. This allows us to provide faster decisions and better align loan products to each applicant’s needs.
  • Fraud Prevention: Real-time AI systems monitor for suspicious patterns and help prevent unauthorized activity, protecting both customers and our infrastructure.
  • Customer Support: Automated systems and virtual assistants are used to respond to common inquiries, improving response times and ensuring consistent service.

While these technologies increase operational efficiency, we recognize the importance of oversight and accountability. Any decision significantly impacting a customer is subject to human review. We maintain safeguards to ensure our use of AI remains fair, transparent, and compliant with all applicable laws.

When you engage with Kiwi, whether through our websites, AI-powered chat assistants, over the phone, or via email, we may collect information such as:

  • Contact details (e.g., phone number or email address),
  • The content of your communications, and
  • Feedback related to your experience.

We may also request feedback through surveys or questionnaires to help us improve our services. Where legally required, we will inform you when calls are recorded.

If you have concerns about a decision influenced by automated tools, you may request further information and ask for a manual review. At Kiwi, we are committed to ensuring that technology complements not replaces our responsibility to serve customers with fairness and care.

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Your Choices

Certain jurisdictions provide you with the right to make specific choices regarding your personal information. Please note that these rights are not absolute and may not apply in every circumstance. In some cases, we may limit or deny your request if the law allows or requires us to do so, or if we cannot adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable laws and accommodate all request including:

  • Access To Your Personal Information. You may request access to your personal information or confirmation that we have and/or process information about you.
  • Changes To Your Personal Information. We rely on you to update and correct your personal information. You can contact us at the address described below in order to request that your information be modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
  • Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes. ‍
  • Opt-out of Targeted Advertising. Although we do not “sell” your personal information for money, we may use some of your personal information for advertising performance analysis, use your information for audience modeling for ongoing advertising, disclose your information to data brokers, and/or participate in data co-ops, which may constitute a “sale” under certain privacy laws. You may opt-out of online tracking-based targeted advertising (e.g., cookies).

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Manage Settings

Please note that if you switch browsers or devices, or clear your browser’s cache, you may need to opt out again to maintain your preferences.

  • Objection to Certain Processing: You have the right to object to our use or disclosure of your personal information by contacting us at the address provided below.
  • Online Tracking: At this time, our systems do not recognize “Do Not Track” signals.
  • Promotional Emails: If you provide us with your email address, we may use it to send you newsletters, surveys, offers, and other promotional materials, including targeted offers from third parties. You can unsubscribe at any time by following the instructions included in the emails. Please note that even if you opt out of promotional emails, you may still receive service-related communications from us. 

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Submitting Requests

You may exercise your rights as described above by contacting us using the details provided in the Contact Information section below. To make a data request via email, please use the same email address you currently use (or most recently used) with Kiwi. If you submit your request by mail, be sure to include the email address you currently use (or most recently used) with Kiwi in your correspondence. As required by law, we will need to verify your identity before fulfilling your request. This verification may occur via phone call or email, and depending on your request, we may ask for information such as your name and your relationship with Kiwi. We may also request a signed declaration to confirm your identity. Once your request is submitted, we will make reasonable efforts, consistent with applicable laws and our policies, to supply, correct, or delete any personal information we have on file about you. In some cases, you may designate an authorized agent to submit a request on your behalf. If you do so, please include a signed permission form confirming the agent’s authority to act for you.

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How We Protect and Retain Information

No method of transmission over the internet or method of electronic storage can be guaranteed to be fully secure. While we take reasonable measures to protect your personal information from unauthorized access, use, or disclosure, we cannot ensure or warrant the absolute security of your information. If we are legally required to notify you of a breach involving your personal information, we may do so electronically, in writing, or by telephone, as permitted by law.

When you create an online end user account with us, you will be asked to choose a password. It is your responsibility to keep this password confidential and to safeguard any access to your account by others who might obtain it, whether or not such access or use was authorized by you. If you become aware of any unauthorized use of your password or account, please notify us as soon as possible.

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to meet any legal, accounting, or reporting obligations, unless a longer retention period is required or permitted by law. In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we collected the information; whether those purposes can be achieved through other means; and applicable legal requirements.

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Transmission of Information to Other Countries

Kiwi primarily collects personal information from residents of the United States. If you are a resident of another country and choose to provide your information to us, you acknowledge and consent to the transfer, storage, and processing of your information in locations outside of your country of residence. This may include transferring your data to foreign countries that may not have the same level of data protection laws as those in your home country. By submitting your information, you understand and agree that your personal information may be transferred to, stored in, and processed in one or more countries where privacy laws and protections may differ from those in your country of residence. While we take reasonable steps to protect your information and comply with applicable laws, the legal protections provided in these foreign countries may not be as comprehensive as those in your home jurisdiction. We will continue to handle your personal information in accordance with this Privacy Policy, regardless of where it is processed.

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Third-Party Content, Applications and Websites

Some of the content you see displayed on the Kiwi site is hosted by third parties, not by Kiwi itself. This includes embedded videos from platforms like YouTube or Vimeo, gifs from Imgur or Giphy, audio files from SoundCloud, tweets from Twitter, code from GitHub, or documents from Scribd that appear within a Kiwi broadcast. These types of content may be embedded on the Kiwi site but actually reside on the servers of those third-party providers.

When you access a Kiwi broadcast that includes this embedded content, data about your activity is transmitted directly to the third-party site, just as if you were visiting that site directly. For example, when you load a broadcast containing a YouTube video, YouTube receives data about your interaction with that video. Kiwi does not control the data collection practices of these third parties or what they do with your information. Therefore, this third-party embedded content is not covered by this Privacy Policy; instead, your activity with respect to this content is governed by the privacy policies of those third-party providers. We encourage you to review their privacy policies carefully to understand how your information may be collected, used, and shared.

For your convenience, we may also provide links to websites or other third-party content or services that we do not own or operate. These websites and third-party services may have their own privacy notices or policies, and we do not control their privacy practices or the content on those websites. We recommend that you review the privacy policies of any third-party website or application you visit to understand their privacy practices.

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Use of Facial Recognition and Biometric Technologies

We may use facial recognition or other biometric technologies to verify your identity, enhance security, or prevent fraud. These technologies analyze unique features (such as facial geometry) to assist in authenticating your account. If we use biometric technologies, we will comply with applicable laws and ensure appropriate consent and data protection measures are in place. We may update this section with the specific providers and technologies we use once finalized.

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Changes to This Privacy Policy

We may update our Privacy Policy and our privacy practices from time to time to reflect changes in our services, technology, legal requirements, or business practices. Each version of our Privacy Policy includes an “effective” date to help you understand the timeline of any changes. The effective date is the date that the current version of the Privacy Policy took effect. We are committed to keeping you informed about material changes to this Privacy Policy that may affect how we handle your personal information. When we make significant changes, we will provide you with appropriate notice as required by applicable law, which may include posting a notice on our website, sending you an email, or using other means of communication. By continuing to use Kiwi services after any such changes become effective, you are agreeing to the terms of the revised Privacy Policy. We encourage you to review the Privacy Policy periodically so that you are always aware of how we collect, use, and share your information.

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Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

Email: support@kiwicredito.com

Correspondence Address: 151 San Francisco Street Ste 200 PMB 1123 San Juan, PR 00901-1607

Mail/Correspondence:

Kiwi Financial Group Inc.

151 Calle de San Francisco Ste 200 PMB 1123 

San Juan, PR 00901-1607

ATTN: DATA REQUEST

Phone:  (787)-490-2004

Physical Address: 

Kiwi Financial Group Inc. 

33 Calle Resolución, Suite 803-A 

San Juan, PR 00920

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Additional Information for California Residents

Please note that Kiwi does not offer services to residents of California. However, if you are a California resident who has unintentionally or accidentally applied for our services, the following rights apply under California law.

Under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), you have the right to:

  • Know what personal information we collect, its sources, and how we use and share it.
  • Request deletion or correction of your information (subject to certain exceptions).
  • Opt-out of the sale or sharing of your information, if applicable.
  • Limit the use of sensitive personal information if we process it beyond permitted exceptions.
  • Not be discriminated against for exercising your privacy rights.
  • Appeal any response to your requests.

Most information we collect is governed by the federal Gramm-Leach-Bliley Act (GLBA) and not subject to these CCPA rights. However, GLBA-protected information may still be subject to the California Financial Information Privacy Act.

To exercise your rights:

Email: support@kiwicredito.com

We will verify your identity and respond to your request.

You may also designate an Authorized Agent with written permission to act on your behalf.

Sensitive Personal Information includes SSNs, ID numbers, financial account details with credentials, precise geolocation, race or ethnicity, union membership, the contents of certain communications, genetic data, health information, or sex life or sexual orientation. We do not use or disclose Sensitive Personal Information except as permitted by law.

Kiwi does not sell your personal information as described in the CCPA/CPRA.

Kiwi does not sell or share personal information of minors as described in the CCPA/CPRA.

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NOTICE TO ALL U.S. RESIDENTS

In accordance with applicable state laws, we restrict our sharing of your information with affiliated entities, non-affiliated parties, and third parties to situations that are required or permitted by law, or when we have your explicit consent.