Privacy Policy — FlexWage Earned Wage Access

Updated May 8, 2026

This Privacy Policy describes how FlexWage Solutions, LLC (“FlexWage,” “we,” “our,” or “us”) collects, uses, stores, discloses, and protects personal information in connection with FlexWage websites, mobile applications, employer-sponsored OnDemand Pay services, integrations, and related products and services (collectively, the “Services”).

This Privacy Policy applies when you access or use our Services, communicate with us, or otherwise interact with FlexWage in connection with the Services. Please read this Privacy Policy carefully before using the Services.

FlexWage may update this Privacy Policy from time to time to reflect operational, legal, regulatory, or service-related changes. When updates are made, the “Last Updated” date above will be revised accordingly.

By enrolling in, accessing, or using the Services, you acknowledge this Privacy Policy and consent to the collection, use, and disclosure of information as described herein, subject to applicable law.

What Is Personal Information?

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Depending on the Services used, Personal Information may include:

– name,
– postal address,
– email address,
– telephone number,
– date of birth,
– employer-related information,
– payroll or account-related information,
– government-issued identifiers,
– device or online identifiers,
– Internet Protocol (IP) address,
– login credentials, and
– other information provided to FlexWage in connection with the Services.

Personal Information does not include information that has been aggregated or deidentified in a manner that cannot reasonably be used to identify an individual.

How Is Information Collected, Used, And Disclosed?

FlexWage collects Personal Information from:

– individuals who use the Services,
– employer clients and their authorized representatives,
– payroll, workforce management, or related integrations connected to the Services,
– service providers supporting the operation of the Services, and
– information voluntarily submitted through websites, mobile applications, customer support interactions, or other communications with FlexWage.

Depending on the Services used, Personal Information may be used to:

– provide and maintain the Services,
– establish and manage user accounts,
– process OnDemand Pay transactions,
– support payroll reconciliation and reporting,
– authenticate users and maintain account security,
– respond to customer support inquiries,
– improve system functionality and service performance,
– detect, investigate, or prevent fraud, misuse, security incidents, or other unauthorized activity,
– comply with applicable legal, regulatory, audit, and operational requirements, and
– communicate with users regarding the Services.

FlexWage may disclose Personal Information to service providers, payment processors, infrastructure providers, employer clients, professional advisors, and other third parties that support operation of the Services or perform services on FlexWage’s behalf, subject to applicable contractual, legal, or confidentiality obligations.

FlexWage does not sell Personal Information or share Personal Information for cross-context behavioral advertising purposes.

FlexWage may also disclose Personal Information when reasonably necessary to:

– comply with applicable law, regulation, legal process, or governmental request;
– enforce contractual rights, policies, or agreements;
– protect the rights, property, security, or operations of FlexWage, its clients, or users; or
– investigate or respond to suspected fraud, security incidents, or unauthorized activity.

In connection with a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, Personal Information may be transferred as permitted by applicable law.

What Are Cookies And Similar Technologies And How Are They Used?

FlexWage websites, mobile applications, and online services may use cookies, local storage, software development kits (“SDKs”), and similar technologies to support operation, security, and functionality of the Services.

These technologies may be used to:

– authenticate users and maintain secure sessions;
– remember user settings and preferences;
– support navigation and functionality within the Services;
– help diagnose technical issues and improve system performance;
– analyze usage patterns and service utilization; and
– support fraud prevention, security monitoring, and operational integrity.

Cookies are small text files stored on a user’s browser or device. Certain cookies may remain only for the duration of a browser session, while others may persist for a longer period in order to recognize returning users or retain preferences.

Most web browsers allow users to control cookies through browser settings, including the ability to block or delete cookies. However, certain portions of the Services may not function properly if cookies or similar technologies are disabled.

FlexWage may also use service providers that utilize analytics or operational support technologies in connection with the Services, subject to applicable contractual and confidentiality obligations.

What Are Your Choices Regarding Collection, Use, And Distribution Of Your Information?

You may choose whether to provide certain Personal Information to FlexWage. However, some Personal Information may be required for FlexWage to provide the Services, establish accounts, authenticate users, process transactions, or comply with legal and operational requirements.

FlexWage may send administrative, transactional, operational, security, or service-related communications in connection with the Services, including account notifications, authentication messages, support responses, transaction confirmations, service updates, and policy notices. These communications may continue as necessary to provide the Services.

Where permitted by applicable law, FlexWage may also send promotional or informational communications regarding products, services, or updates that may be relevant to users or employer clients. Users may opt out of promotional email communications by using the unsubscribe instructions included in those communications. Opting out of promotional communications will not affect transactional or service-related communications necessary to maintain or support the Services.

Depending on applicable law and the nature of the Services provided, users may also have rights to request access to, correction of, deletion of, or limitation of certain uses of Personal Information, subject to legal, regulatory, operational, fraud prevention, audit retention, and security requirements.

How Can You Correct, Access, And Update Your Information?
FlexWage takes reasonable steps to maintain Personal Information in an accurate and current manner consistent with the purposes for which it was collected.

Depending on the Services used, users may access, review, update, or correct certain account or profile information through available account settings, employer-managed account administration processes, or by contacting FlexWage using the contact methods provided through the Services.

FlexWage may take reasonable steps to verify the identity and authority of individuals requesting access to, correction of, or updates to Personal Information before processing such requests.

Certain information may not be modified or deleted where retention is necessary to:

– comply with legal, regulatory, tax, audit, accounting, or reporting obligations;

– maintain security, fraud prevention, or operational integrity;

– complete transactions or provide requested Services; or

– protect the rights, safety, and operations of FlexWage, users, employer clients, or third parties.

Additional consumer privacy rights and request methods may be described elsewhere in this Privacy Policy where required by applicable law.

How Long Do We Retain Information?

FlexWage retains Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to:

– provide and support the Services;
– maintain account records and transaction history;
– comply with legal, regulatory, tax, accounting, audit, and reporting obligations;
– support fraud prevention, security monitoring, investigations, and dispute resolution;
– enforce contractual obligations and policies; and
– maintain operational and business records.

Retention periods may vary depending on the nature of the information, the Services provided, applicable legal requirements, and operational necessity.

When Personal Information is no longer required for applicable operational, legal, regulatory, or security purposes, FlexWage will take reasonable steps to securely delete, deidentify, or otherwise dispose of such information in accordance with applicable policies and procedures.

How Do We Protect Your Information?

FlexWage maintains administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, disclosure, alteration, or destruction. These safeguards may include, among other things, access controls, authentication mechanisms, encryption technologies, network security controls, intrusion detection, logging, monitoring, and other operational security measures.

Access to Personal Information is restricted to authorized employees, contractors, service providers, and support personnel who require access to perform legitimate business, operational, security, or support functions and who are subject to applicable confidentiality and security obligations.

FlexWage maintains policies and operational procedures intended to support secure system administration, access management, change management, vendor oversight, and risk management activities.

Unfortunately, no method of transmission over the Internet, electronic storage system, or method of data processing can be guaranteed to be 100% secure. As a result, while FlexWage uses reasonable measures designed to protect Personal Information, FlexWage cannot guarantee the absolute security of information transmitted to, from, or through the Services, including information transmitted by email or other electronic communications.

FlexWage reviews and updates its security practices and operational safeguards periodically in light of operational, legal, regulatory, and technology changes.

How Can You Help Protect Your Information?
Users are responsible for maintaining the confidentiality of account credentials, authentication codes, devices, and account access methods associated with the Services.

FlexWage recommends that users:

– do not share passwords, authentication codes, or account credentials with others;
– use strong and unique passwords;
– sign out of accounts after completing sessions on shared or public devices;
– maintain appropriate security protections on personal devices and email accounts; and
– promptly notify FlexWage of suspected unauthorized account access, credential compromise, fraud, or suspicious activity.

FlexWage will not request passwords through unsolicited email communications or unsolicited telephone calls.

Links to Third-Party Websites
The Services may contain links to, integrations with, or connections to third-party websites, applications, payroll systems, workforce management platforms, payment providers, financial institutions, or other third-party services that are not owned or controlled by FlexWage.

FlexWage may also utilize third-party service providers and infrastructure providers in connection with hosting, payment processing, customer support, identity verification, security, analytics, operational support, and related service functions.

These third-party services operate independently from FlexWage and may maintain their own privacy notices, terms of use, and information handling practices. FlexWage is not responsible for the availability, content, security, or privacy practices of third-party services.

Users should review applicable privacy notices and terms associated with third-party services before providing information or interacting with such services.

References or links to third-party services do not constitute an endorsement, certification, or representation by FlexWage regarding such third-party services or their practices.

Location Of Servers And Transfer Of Information
FlexWage systems, infrastructure, service providers, and operational support functions are primarily located in the United States. Personal Information collected in connection with the Services may be stored, processed, transmitted, or accessed within the United States or other jurisdictions where FlexWage or its authorized service providers operate.

By using the Services or providing Personal Information to FlexWage, users acknowledge that Personal Information may be transferred to, processed in, and stored in jurisdictions that may have different data protection laws than the jurisdiction in which the user resides.

FlexWage takes reasonable steps designed to require authorized service providers and third parties supporting the Services to protect Personal Information in accordance with applicable contractual, legal, operational, and security requirements.

Children’s Privacy

The Services are not directed to children under the age of 13, and FlexWage does not knowingly collect Personal Information directly from children under 13 years of age.

If FlexWage becomes aware that Personal Information has been collected directly from a child under 13 in a manner inconsistent with applicable law, FlexWage will take reasonable steps to delete such information as required by applicable law.

Changes To This Privacy Policy

FlexWage may update or modify this Privacy Policy from time to time to reflect changes in operational practices, legal requirements, technologies, Services, or regulatory obligations.

When material changes are made, FlexWage will update the “Last Updated” date at the top of this Privacy Policy and may provide additional notice through the Services or other appropriate communication methods where required by applicable law.

Contact Information

If you have questions regarding this Privacy Policy or FlexWage’s privacy practices, you may contact FlexWage at: privacy@flexwage.com