Privacy Policy

1. Information We Collect

Information You Provide

• Registration Information: When you create an account, we collect your email address, password, and other information needed to set up your account.
• Identification Information: We may ask for your first and last name, zip code, and phone number to confirm your identity and provide our Services.
• Payment Information: When you subscribe to Carlos Plus or initiate a payout, we collect payment-related information. Payment transactions are processed by Stripe, Inc. We do not store full payment card numbers on our servers.
• Loan and Financial Marketplace Information: If you choose to explore loan offers through our financial marketplace, we may collect additional information needed to match you with a lender, including your Social Security number, date of birth, driver’s license, employment, income, and bank account and routing numbers. This information is transmitted through our servers directly to our third-party lending partners in real time to generate offers and is not retained in our databases.
• Communications and Preferences: If you contact us for support or otherwise communicate with us, we collect the contents of those communications. We also record your consent preferences if you opt in to receive text messages or push notifications from us.

Information We Collect Automatically

• Device and Technical Information: We collect your browser type, internet protocol (IP) address, device type, operating system, pages visited, and average time spent on our Site.
• Device Identifiers: When you use our mobile application, we may collect the unique device identifier (Device ID) assigned to your device to store application preferences and other data, and a push notification token if you enable push notifications.
• Usage Data: We collect information about how you interact with our Services, including offers viewed, earnings activity, and features used.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to support the integrity of our registration process, retain your preferences, and evaluate user activity. You may control cookie settings through your browser, though disabling cookies may affect the functionality of our Services.

Financial Account Information

If you choose to use certain features, such as cash advances, you may be asked to securely connect a bank account through a third-party financial data aggregation service. Through that connection, we may receive information about your linked account, including account and routing numbers, balances, and transaction history, which we use to evaluate your eligibility for the feature and to facilitate any resulting transactions. We do not receive or store your bank login credentials — those are handled directly by our aggregation partner under its own security and privacy practices.

Information from Third Parties

• Advertising and Offer Partners: When you complete offers through our offerwall partners (such as AdGem), we receive information about completed transactions including offer name, reward amount, and transaction identifiers.
• Cashback Partners: When you activate a cash-back deal and shop with a participating merchant, our cashback network partner (CartLinks) may share transaction and click-tracking information with us to credit your account.
• Referrals: If another user refers you to Carlos, we receive limited information necessary to credit the referral.

2. How We Use Your Information

We use the information we collect to:

• Create and manage your account and provide our Services
• Process transactions, payouts, and subscription payments
• Match you with relevant loan, cash-back, or other financial product offers through our partners
• Evaluate your eligibility for cash advances or other credit-related features, including through automated decision-making (see Section 3)
• Verify your identity and prevent fraud
• Communicate with you about your account, earnings, and our Services
• Send transactional emails, texts, or push notifications such as account alerts, payout confirmations, and earnings updates
• Send promotional emails and newsletters, where you have opted in
• Improve, personalize, and develop our Services
• Monitor and analyze usage trends and activity
• Comply with legal obligations and enforce our Terms of Service
• Protect the security and integrity of our Services and users
• Respond to legal process, subpoenas, or government requests

3. Automated Decision-Making and Profiling

If you apply for a Carlos cash advance or a similar credit-related feature, we may use automated tools — including a third-party decision engine — to evaluate information about your linked bank account activity and other factors in order to determine your eligibility and the terms of any advance offered to you. This evaluation may occur without individualized human review of every application. Where required by applicable law, we will provide notice if a decision was based in whole or in part on automated processing, and you may contact us at contact@getcarlos.com to request more information about the decision or to request human review of the decision.

4. How We Share Your Information

We do not sell your personal information for money. Depending on how “sale” and “share” are defined under applicable state law (including the CCPA, as amended), some of our advertising or analytics integrations could be considered a “share” of personal information for cross-context behavioral advertising. Where applicable, you may opt out of this sharing as described in Section 6. We may otherwise share your information in the following circumstances:

• Service Providers: With third-party vendors and service providers who perform services on our behalf, including payment processing (Stripe), offer fulfillment (AdGem), cash-back tracking (CartLinks), payout processing (Tremendous), hosting and infrastructure (Vercel, Supabase), financial account aggregation and underwriting decision-engine providers used to evaluate cash advance eligibility, and analytics. These providers are contractually obligated to use your information only as necessary to provide services to us.
• Business Transfers: In connection with a merger, acquisition, sale of assets, financing, or dissolution of all or part of our business, your information may be transferred as a business asset.
• Legal Compliance: To respond to subpoenas, court orders, or other legal process, or as otherwise required by applicable law.
• Protection of Rights: To investigate, prevent, or take action regarding violations of our Terms of Service, illegal activity, suspected fraud, or threats to the safety of any person or the security of our Services.
• With Your Consent: We may share your information for any other purpose with your explicit consent.

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our Services. If you deactivate your account, we may retain archived copies of your information for a period consistent with applicable law, including for fraud prevention, dispute resolution, and legal compliance purposes.

6. Your Privacy Rights

Depending on where you reside, you may have certain rights regarding your personal information, including:

• Access: The right to request a copy of the personal information we hold about you.
• Correction: The right to request correction of inaccurate or incomplete information.
• Deletion: The right to request deletion of your personal information, subject to certain legal exceptions.
• Opt-Out of Marketing: The right to opt out of receiving promotional emails, texts, or push notifications at any time by following the unsubscribe instructions in those messages or contacting us directly. Opting out will not affect transactional or service-related communications.
• Appeal: If we deny your request, you may have the right to appeal that decision. To submit an appeal, contact us at the email below; we will respond within the time period required by applicable law.
• Authorized Agent: You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of authorization and may still require you to verify your own identity directly with us.
• Non-Discrimination: We will not discriminate against you for exercising any of these privacy rights.

California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, including the right to know what personal information is collected, the right to delete personal information, the right to correct inaccurate personal information, and the right to opt out of the sale or sharing of personal information. To exercise these rights, contact us at contact@getcarlos.com.

Other State Privacy Rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, or another state with a comprehensive consumer privacy law, you may have similar rights to access, correct, delete, and port your personal information, to opt out of targeted advertising, the sale of personal information, and profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, and to appeal a denied request. To exercise these rights or appeal a decision, contact us at contact@getcarlos.com.

To exercise any of the above rights, please email us at contact@getcarlos.com with your verifiable contact information and the nature of your request. We will respond within 30 days.

7. Security

We take reasonable administrative, technical, and physical measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include firewall barriers, SSL/TLS encryption, and authentication procedures. However, no system is perfectly secure, and we cannot guarantee absolute security of your information.

8. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we may have inadvertently collected information from a minor, please contact us at contact@getcarlos.com.

9. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services, including offer, cash-back, lending, and financial account aggregation partners. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through our platform.

10. Do Not Track

Some browsers offer a “Do Not Track” signal. Because there is currently no accepted industry standard for how to respond to these signals, our Services do not respond to Do Not Track browser signals at this time.

11. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will notify you by updating the “Last updated” date at the top of this policy and, where appropriate, by sending you an email or in-app notification. Your continued use of our Services after any changes constitutes your acceptance of the updated policy. We encourage you to review this policy periodically.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Red Technology Ventures LLC d/b/a Carlos
contact@getcarlos.com