Cottonwood Privacy Notice

Effective Date: January 2026

FACTS:

What Does FinWise Bank d/b/a Cottonwood Payments Do with Your Personal Information?


WHY?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice

carefully to understand what we do.

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WHAT?

The types of personal information we collect, and share depend on the product or service you have with us.

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This information can include:
• Social Security number and income
• Account balances, payment and transaction history
• Credit history and credit scores

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When you are no longer our customer, we continue to share your information as described in this notice.

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HOW?‍

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons FinWise Bank d/b/a Cottonwood Payments chooses to share; and whether you can limit this sharing.

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QUESTIONS‍

Call 833-346-9473 or go to www.cottonwoodpayments.com

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WHO WE ARE

Who is providing this notice?
FinWise Bank d/b/a Cottonwood Payments

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WHAT WE DO

How does FinWise Bank d/b/a Cottonwood Payments protect my personal information?

‍To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

FinWise Bank d/b/a Cottonwood Payment’s policy is such that access to confidential information is provided only to those employees who need to know such information to administer your account(s).

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How does FinWise Bank d/b/a Cottonwood Payments collect my personal information?

We collect your personal information, for example, when you:
• Open an account, make deposits or withdrawals from your account

• Apply for a loan or pay your bills

• Give us your contact information, employment history or income information

• Make a wire transfer or use your credit or debit card

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

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Why can’t I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for affiliates' everyday business purposes - information about your credit worthiness

• Affiliates from using your information to market to you

• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. (See below for more on your rights under state law.)

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DEFINITIONS

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include companies with a Holding Company interest in the Bank, our Holding Company is “FinWise Bancorp”.

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Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• FinWise Bank d/b/a Cottonwood Payments does not share with nonaffiliates so they can market to you.

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Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Our joint marketing partners include financial service providers, such as online lending platforms.

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OTHER IMPORTANT INFORMATION

Nevada Residents

We are providing this notice pursuant to state law. You may be placed on our internal Do Not Call List by contacting us at 833-346-9473, getintouch@finwisebank.com, or FinWise Bank d/b/a Cottonwood Payments, 756 E Winchester Street: Suite 100, Murray, UT 84107. For more information, visit www.cottonwoodpayments.com or call 833-346-9473. If you would like more information regarding this Nevada law, contact: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St. Suite 3900, Las Vegas, NV 89101; 702-486-3132; AgInfo@ag.nv.gov

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State Laws

Depending upon where you live, you may have additional privacy protections under some state laws. We comply with applicable state laws before sharing non-public information about you.