Privacy Policy

Effective Date: April 30, 2026

1. Introduction

SOLVY Ecosystem™ ("SOLVY," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how SA Nathan LLC collects, uses, shares, and safeguards your personal information when you use the SOLVY Card™, website, mobile applications, and related services (collectively, the "Services").

2. Information We Collect

We collect the following types of information:

• Personal Information: Name, address, date of birth, Social Security number, phone number, email address
• Financial Information: Bank account details, transaction history, card usage data
• Identity Verification: Government-issued ID, selfie verification for KYC compliance
• Device Information: IP address, device type, operating system, browser type
• Usage Data: How you interact with our apps and website

3. How We Use Your Information

We use your information to:

• Provide banking and card services through our partner Unit.co and Thread Bank
• Verify your identity and comply with federal KYC/AML regulations
• Process transactions and maintain account records
• Communicate with you about your account and services
• Detect and prevent fraud, unauthorized access, and illegal activity
• Improve our Services and develop new features

4. Information Sharing

We share your information only with:

• Unit.co and Thread Bank: Our banking-as-a-service partner required to provide deposit accounts and card services
• Service Providers: Companies that help us operate our Services (e.g., identity verification, fraud prevention, customer support)
• Legal Compliance: When required by law, court order, or government request
• Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties.

5. Data Security

We implement industry-standard security measures including:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Restricted access to sensitive data (need-to-know basis)

6. Your Rights

Depending on your state of residence, you may have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion of your personal information
• Opt out of certain data sharing
• Receive a copy of your data in a portable format

To exercise these rights, contact us at hello@ebl.beauty.

7. Data Retention

We retain your personal information for as long as your account is active and as required by law. Federal banking regulations typically require retention for 5 years after account closure.

8. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children.

9. Cookies and Tracking

We use cookies and similar technologies to enhance your experience, analyze usage, and deliver personalized content. You can manage cookie preferences through your browser settings.

10. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via email or through the Services. Continued use after changes constitutes acceptance.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us:

• Email: hello@ebl.beauty
• Support: support@ebl.beauty
• Business: SA Nathan LLC