Privacy Policy

Effective as of August 27, 2025

Introduction

Cyder Inc. (“we,” “us,” “our,” or “Cyder”) collects data directly from members (“you,” “your,” or the “Users”) through our Loyalty Platform (the “Platform”). This Privacy Policy explains how we collect, use, protect, and disclose your information in connection with your participation in loyalty and rewards programs offered through your credit union.

We are committed to the highest standards of data security, privacy, and transparency. All information collected through the Platform is safeguarded using strict technical, administrative, and organizational controls designed to ensure confidentiality, integrity, and availability of member data. Our practices emphasize accountability, minimize data collection to what is necessary, and ensure that processing is based only on your clear consent or legitimate program needs.

Your data is used exclusively to deliver rewards, verify eligibility, improve program functionality, and meet legal or regulatory obligations. It will never be sold and will only be shared with carefully vetted service providers or your credit union where required to operate the Loyalty Platform.

By participating in the Loyalty Platform, you consent to the collection and use of your data as outlined in this Privacy Policy, with the assurance that Cyder applies rigorous standards to protect your information and uphold your privacy rights at every stage.

What We Do

Loyalty Platform

The Loyalty Platform for Credit Unions enables members to receive rewards based on eligible financial behaviors, while maintaining transparency and control over the use of their personal data.

Through the Platform, members may choose to link their financial accounts and authorize the collection of transactional data. This data is used exclusively to identify and administer rewards tied to specific behaviors such as maintaining a minimum account balance, enrolling in direct deposit, utilizing a debit or credit card, or contributing to a savings goal.

By interacting with the Platform, including but not limited to completing financial milestones, participating in surveys, or enrolling in promotional offers, members allow the Platform to assess eligibility for rewards and distribute benefits accordingly. These benefits may include monetary deposits, points, or other credit union-defined incentives.

Participation in the Loyalty Platform constitutes consent for the credit union and its authorized service providers to collect and process relevant transaction data strictly for the purpose of operating the rewards program. This data is never sold, and is only disclosed to third parties insofar as necessary to fulfill reward obligations and enhance the member experience, in accordance with applicable laws and the Platform’s Terms and Conditions.

The Loyalty Platform is committed to upholding the highest standards of data security and member privacy while providing tangible value in recognition of members’ everyday banking activities

Data Collection

How We Collect Data

Cyder collects data directly from you when you:

Create and maintain a Cyder account with your credit union.
Link financial accounts to the Platform for rewards eligibility.
Complete surveys, enroll in promotions, or participate in offers.
Interact with the Platform to earn, redeem, or track rewards.

What Data Do We Collect?

We collect your data directly through our Platform and Services. Cyder manages and protects your data in accordance with our Privacy Principles and your instructions. We do not collect, store, or use your information without your consent, and we only access the data necessary to operate as a secure, compliant, and feature-rich loyalty platform. We retain your data only while your account remains active or while you are receiving rewards through the Platform.

We collect only the data necessary to provide you with secure, compliant, and feature-rich loyalty services. This may include:

Basic Account Data: Information such as your name and email address used to create and manage your account.
Contact Information: Details including physical address and phone number, necessary for communication and reward delivery.
Device & Access Information: Technical data such as IP address or browser type, used to maintain system integrity and prevent fraud.
Fraud Prevention Information: Data used to detect and prevent unauthorized activity.
Usage Data: Information on how you interact with the Platform, including milestones achieved and rewards redeemed.
Transaction & Reward Data: Data related to eligible financial behaviors (e.g., maintaining a balance, setting up direct deposit, or using a debit/credit card), as well as points or monetary deposits earned.
Other Information You Provide: Communications with Cyder or your credit union, survey responses, and participation in promotional offers.

The Data That We Do Not Collect

Data of Minors Under the Age of Eighteen: You must be at least eighteen (18) years old to use the Services. Our Services are not addressed, directed or intended for individuals under the age of eighteen (18).

Cyder will never knowingly collect personal information about individuals under the age of eighteen (18). By using the Services, you represent that you meet this minimum age requirement. In the event that we discover that an individual under the age of 18 has provided personally identifiable information to us, we will make efforts to delete the individual’s information along with the entire account in accordance with any applicable regulations.

If you are a parent or guardian and you are aware that your child has provided us with their personally identifiably information, please contact us at getcyder@gmail.com.

Keeping your Data Safe

How We Keep Your Data Safe

Cyder is committed to safeguarding the data you collect, manage, and share through our Platform. We have implemented industry-standard security procedures to protect the storage and disclosure of the data we process, including encryption in transit and at rest. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

Third-Party Programs

Our Privacy Policy does not apply to how third parties define and collect personal data or how they use it. Cyder will not be held liable for how third parties collect and use your personal data. We encourage you to read their Privacy Policies and to know your privacy rights before interacting with them.

How We Use Your Data

We process your data only to operate and improve the Loyalty Platform, specifically to:

Verify eligibility for rewards based on financial behaviors.
Deliver rewards such as deposits, points, or incentives defined by your credit union.
Communicate with you about your participation, including confirmations and updates.
Detect, investigate, and prevent fraud or abuse of the Platform.
Comply with applicable legal and regulatory obligations.

How We Share Data

Cyder will never sell your personal data. We may share your information only in the following limited circumstances:

With Your Credit Union: To administer and support your participation in the loyalty program.
With Trusted Service Providers: For secure hosting, payment processing, fraud monitoring, and customer support. These providers are contractually obligated to use your information only for the services provided to Cyder.
For Legal and Regulatory Compliance: To comply with applicable laws, enforce our Terms and Conditions, or respond to valid legal requests.
Corporate Transactions: In the event of a merger, acquisition, or other corporate change, provided your information continues to be protected by this Policy or equivalent safeguards.

Data Security

We use strong technical and organizational measures to protect your data, including encryption in transit and at rest, restricted access controls, continuous monitoring, and regular security audits. While no system can guarantee absolute protection, our controls are designed to minimize risks and prevent unauthorized access, disclosure, or misuse.

Data Retention

Active Accounts: We retain your data for as long as your account is active or you continue to receive rewards.
Account Deletion: You may delete your account at any time. When you do, all personal data associated with your account will be permanently deleted, subject to limited retention required for legal, regulatory, or fraud-prevention purposes.
Automatic Deletion: If your account remains inactive for one (1) year, it may be automatically deleted, along with associated data.

Legitimate Interests

Generally, the remainder of the processing of your data and personal information we perform is necessary for the purposes of our legitimate interest, for example, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of Cyder’s systems, Website, and Services.

If you would like to request deletion of data that we process on the basis of consent, or if you object to our processing of personal information, please email us at getcyder@gmail.com.

Onward Transfer & Sharing

Cyder may share your data with:

Credit Union Partners: To administer your rewards program.
Trusted Service Providers: For functions such as secure hosting, fraud monitoring, or payment processing. These providers are bound by contractual obligations to use your data only for services provided to Cyder.
Regulators or Law Enforcement: When legally required to satisfy compliance, fraud prevention, or security obligations.
Corporate Successors: In the event of a merger, acquisition, or other corporate change, subject to the same protections described here.

Sharing Personal Information and Data

Personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above.

Based on User preferences, data may be shared with third parties for analytical, marketing, and advertising purposes.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or another lawful request for information we receive, or to otherwise protect our rights.

Personal Data

Except as otherwise stated in this Privacy Policy, we do not collect, store, access, use, sell, rent, or share your data without your consent. We may use the Personal Information you provide to us to communicate with you, for example, in response to questions you have asked or to provide technical support.

Your Rights

Through your Cyder account, you can:

Access and review the data you’ve provided.
Correct inaccurate or incomplete information.
Restrict or object to processing of your data.
Withdraw consent at any time.
Request account and data deletion.

Data Deletion and Retention

Account Automatic-Deletion

By default, if you stop using Cyder for at least one (1) year, your account will be deleted along with all your data held on the Cyder network. You can go to your Settings to change the exact period of inactivity, after which your inactive account will automatically be deleted. In some circumstances, such as cases of anti-money laundering or fraud, we may have to keep your data for longer.

Data Retention

We retain your data as long as your account remains active or you are receiving rewards through the Platform.
You may delete your account at any time, and all associated data will be permanently deleted.
If your account is inactive for one (1) year, it may be automatically deleted. Some exceptions may apply where longer retention is required for fraud prevention or regulatory compliance.

Miscellaneous

Changes To This Privacy Policy

We reserve the right to modify this Privacy Policy from time to time. If we make changes to the Policy, we will notify you by revising the “Last Updated” date at the top of the Policy. The most current version of this Privacy Policy will govern our current use of your information and your use of our Services, the Websites, and/or the Platform. We encourage you to review our Privacy Policy regularly to stay informed about our privacy practices. Your continued use of the Website and/or the app and/or any of the Services following a change or changes to this Privacy Policy constitutes your binding acceptance of the change or changes.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at getcyder@gmail.com