LUCKY MONEY, INC.
PRIVACY POLICY
Last updated: April 28, 2014


Protecting consumer privacy is a priority at Lucky Money. Currently, this information concerning your privacy is only applicable to online transactions initiated by U.S. customers and visitors to our website. This online privacy statement is written in accordance with the financial privacy provisions of the Gramm-Leach-Bliley Financial Modernization Act of 1999, 15 U.S.C. § 6801-6809 ("GLB Act") and the California Financial Information Privacy Act of 2004, Cal. Fin Code §§ 4050-4060 ("California Financial Information Privacy Act"). This reflects the Lucky Money policies covering personal and non-personal information collected by us on and after the effective date shown above, so that you can make informed choices about how your own information is collected and used.

Lucky Money is a "financial institution" within the meaning of the GLB Act, and falls under the jurisdiction of the Federal Trade Commission ("FTC") and the California Department of Financial Institutions ("DFI") for purposes of the GLB Act and the California Financial Information Privacy Act, respectively.

Lucky Money limits access to your personal information to only those employees of Lucky Money and its affiliates who need it to fulfill their business responsibilities. Employees must adhere to Lucky Money privacy policies. Employees violating these policies will be subject to disciplinary action, up to and including dismissal. Vendors and other outside contractors we engage are subject to our strict contractual requirements to ensure that your sensitive personal information is safeguarded. We employ appropriate measures to protect your information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. Lucky Money continually reviews and enhances its security systems as necessary.

COLLECTION OF INFORMATION:

Lucky Money collects personal and non-personal information in order to offer or provide our Services to you. This information may include the following: your name, address, telephone number, date of birth, social security number, government-issued identification (i.e. driver's license or passport) number, bank account number, and debit/credit card number. We also collect information regarding your recipients, including, but not limited to their name, address, phone number, bank account and routing numbers. We may obtain this information from a variety of sources including, but not limited to the following: (a) directly from customer applications, questionnaires and other materials submitted to us by the Sender; (b) from transactions in which Lucky Money and Sender are involved; (c) from clickstream activity on our website (including the use of "cookies" and or "web beacons," as described below); and (d) from a variety of third-party sources, such as government repositories, consumer reporting agencies and other financial institutions.

Lucky Money allows you to connect to your Facebook account through the Lucky Money website. If you so connect to Facebook, Facebook will ask your permission to share certain information from your Facebook account with Lucky Money, including your first name, last name, public profile, friend list, email address, birthday, hometown and current city and friends' hometown and current cities, and whether you "like" the Lucky Money page on Facebook. This information is collected by Facebook and is provided to us under the terms of Facebook's privacy policy. You may control the information that we receive from Facebook using the privacy settings in your Facebook account.

USE OF COOKIES AND WEB BEACONS:

A "cookie" is a small text file placed on your computer's hard drive by a web server you visit and which is acknowledged by your web browser. A cookie contains information on you that your browser saves and sends back to a web site when you visit it again. "Web beacons" are transparent electronic images placed in the web code, also called "clear GIFs" or "Web bugs." We use cookies and/or web beacons for a variety of purposes, including, but not limited to, the following:

(a) to assist us in providing our services to you;

(b) to allow you to change pages during your visit to our website without repeatedly having to re-enter your password;

(c) to track activity on our website;

(d) to determine whether you came to our site from a banner ad or an affiliate website;

(e) To display our ads to you when you visit other websites; or

(f) To allow third-party vendors including Google, to show our ads to you on sites across the internet based on your past visits to our website luckymoney.com.

You can adjust settings in your browser that allow you to elect to accept cookies or to have your browser notify you each time a cookie is offered. You can also delete cookies from your hard drive. Instructions on how to accept cookies, on how to be notified that a cookie is being offered and on how to delete cookies are available through your Internet Browser. You can also visit the Google Ads Preference Manager, and Network Advertising Initiative opt-out page to opt-out of third-party cookies.

DISCLOSURE OF INFORMATION:

Lucky Money does not sell, distribute, or otherwise disclose your information to third parties without first obtaining your express written consent and giving you an opportunity to opt-out of such disclosure, except as expressly specified in this Privacy Policy. There are some disclosures to third parties that are not subject to the opt-out, such as the following: disclosures necessary to affect, administer or enforce a transaction requested by you; to companies that perform services for us; and/or to prevent fraud. If you participate in any referral programs, your information may be disclosed as specified in the terms of the program. Additionally, Lucky Money may disclose information about former consumers or customers to third parties and companies with which Lucky Money is affiliated. Those disclosures may consist of the following:

(a) financial background information describing financial status;

(b) identification information, such as name and address data;

(c) transaction information, such as account activity, debit activity or credit activity; and

(d) other information relating to financial matters.

RECIPIENTS OF INFORMATION:

Lucky Money may disclose your information to companies affiliated with us. These recipients include: (a) financial institutions such as banks, credit card companies, brokerage houses, and consumer reporting agencies pursuant to the Fair Credit Reporting Act (15 U.S.C. §1681 et seq.); (b) companies that process transactions or provide other services for us including, but not limited to, attorneys, accountants, and auditors; and (c) government and law enforcement agencies in general and where specifically required or permitted under the Right to Financial Privacy Act of 1978 (12 U.S.C. §3401, et seq.), to comply with federal, state, or local laws, rules, and other applicable legal requirements, as required by Title III of the federal United and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA Patriot Act; P.L. 107-56).

LINKS TO OTHER WEBSITES:

Lucky Money may create links to third party websites. Lucky Money is not responsible for the content or privacy practices employed by websites that are linked from our website.

If you have any questions or comments about Lucky Money's Online Privacy Statement, or if, for some reason, you believe we have not met our commitment to safeguard your privacy, please contact us at the customer service number listed below.

As stated above, this Lucky Money Online Privacy Statement is currently only applicable to our website customers and visitors in the United States. As we develop websites for international customers, we may adopt additional rules and practices consistent with this statement to confirm to the policies or requirements of those countries. We may alter this statement as needed for certain products and services and to abide by local laws or regulations around the world. Lucky Money reserves the right to amend or modify this statement from time to time. We urge you to review this statement whenever you visit in order to obtain the most current statement.

If you have questions or concerns regarding this Privacy Policy, please contact Lucky Money, Inc. at:

LUCKY MONEY, INC.
Attn: Attn: Compliance Department
1028 Mission Street
San Francisco, CA 94103
1-800-SUWERTE
P: 415-864-8367
F: 415-864-2606
Email: compliance@luckymoney.com

For more information about your online and financial privacy as it relates to both federal and state law, please visit http://www.ftc.gov/privacy/index.html and http://www.privacyprotection.ca.gov/.