Policies

Grab a cup of coffee, get comfortable, and check out our policies to make sure you understand all the terms and conditions for your BrightFi account.

Cardholder Agreement
+ BrightFi Prepaid Visa Debit Cardholder Agreement
IMPORTANT – PLEASE READ CAREFULLY

1.  Terms and Conditions for the BrightFi PrepaidVisa® Debit Card.  Thisdocument is an agreement (“Agreement”) containing the terms and conditions thatapply to the BrightFi Visa Debit Card that has been issued to you by MetropolitanCommercial Bank (Member FDIC) pursuant to a license from Visa U.S.A. Inc.“Metropolitan Commercial Bank” and “Metropolitan” are registered trademarks ofMetropolitan Commercial Bank © 2014. By accepting and/or using this Card, youagree to be bound by the terms and conditions contained in this Agreement.  The Program Manager for the BrightFi Visa Cardis Karrikin, Inc. d/b/a Karrikin Technologies (the “Program Manager”) and theCustomer Service telephone number is +1 (888)627-5407 or the toll-free telephone number onthe back of your Card.  In thisAgreement, “Card” means the BrightFi Prepaid Visa Debit Card issued to you by theBank, including any Physical Card or Virtual Card, (each as defined below) aspermitted under this Agreement. “BrightFi Account” means the records we maintainto account for the value of transactions associated with Card. “You” and “your”means the person or persons who have received the Card and who are authorizedto use the Card as provided for in this Agreement. “We,” “us,” “our,” and“Bank” mean Metropolitan Commercial Bank, together with its successors andassigns. “Program Manager” means Karrikin, Inc. d/b/a Karrikin Technologies, together with its successors andassigns. The Card will remain the property of the Bank and must be surrenderedupon demand. The Card is nontransferable, and it may be canceled, repossessed,or revoked at any time without prior notice subject to applicable law. Pleaseread this Agreement carefully and keep it for future reference.  To help thegovernment fight the funding of terrorism and money laundering activities,federal law requires all financial institutions and their third parties toobtain, verify, and record information that identifies each person who obtainsa Card. What this means for you: When you apply for a Card, we will ask foryour name, address, social security number or country identification number,and other information that will allow us to identify you. We also may ask tosee your driver's license or other documentation bearing your photo asverification of your identity. You will also be required to complete a simplevideo-based identity verification using your mobile phone or computer camera. Byparticipating in the Card program, you agree that the information andstatements you provide to us are accurate, including, but not limited to, yourreal name, valid U.S. mailing address and residential address (if different),social security number or other identification documentation and telephonenumber. If you fail to provide accurate information that we request, we maycancel your Card. In addition, funds tied to suspected illicit or illegalactivity may be subject to both internal and potentially federalinvestigation.  We reserve the right torestrict or delay your access to any such funds.
+ Your Card
The Card is a Debit card. The Cardallows you to access funds deposited into your BrightFi Account by you or onyour behalf. The funds in your BrightFi Account will be FDIC-insured once wehave verified your identity.  Funds canbe loaded or deposited into your Brightfi Account by direct deposit, electronictransfer, mobile check deposit or cash via ATM as fully described below is thesection titled “Adding Funds to Your BrightFi Account.” You may access thefunds in your BrightFi Account by using (1) your Card, (2) the number inscribedor printed on the front of your Physical Card or the number provided to you inconnection with your Virtual Card, as applicable (the “Card Number” or “CardNumbers”), (3) by automated clearinghouse (“ACH”) debit using your AccountNumber. The Card is not a creditcard.  The Card is not a gift card, nor is it intended for gifting purposes. You will not receive any interest on your fundson the Card.  The funds in your BrightFi Accountwill not expire, regardless of theexpiration date on the front of your Card. You will be issuedand may use a physical plastic card (a “Physical Card”) or a virtualrepresentation of the card (a “Virtual Card”). If you have and use a PhysicalCard and a Virtual Card at the same time, both forms of your Card areassociated to one Primary Access Number (“PAN”), which allows you to access thefunds available in your BrightFi Account. Except as otherwise stated in thisAgreement, you have the same rights and responsibilities under this Agreementwhether you use a Physical Card or Virtual Card. a.     Virtual Card.  Your Virtual Card can be obtained and used throughuse of the Brightfi mobile application (the “Mobile App”) or the website www.mybrightfi.comat the time of enrollment.  Your VirtualCard will be displayed either in the Mobile App or the website after thesuccessful verification of your identity as described above and will beactivated and ready for full use after the first successful deposit of funds toyour BrightFi Account. You may access the funds in your BrightFi Account byusing your Virtual Card Number for transactions or purchases initiated over thephone or online. You will not receive a PIN for your Virtual Card. b.     Physical Card.  Your Physical Card will be mailed to theaddress you provide to us during the registration process. When you receiveyour Physical Card, you can activate it using the Mobile App in the “ManageCard” section. You can also call Customer Service at +1 (888) 627-5407 to activate the Card and receive your PIN(as set forth in the Section of this Agreement titled “Personal IdentificationNumber (“PIN”) ”). Upon receipt and activation of your Physical Card, yourVirtual Card will not be automatically disabled and you can use both thePhysical Card and the Virtual Card.
+ Fees
The fees relating tothe use (and misuse) of your Card are set forth in the “Schedule of Fees andCharges (Schedule A)” ATTACHED TO THIS AGREEMENT AND INCORPORATED HEREIN BYREFERENCE. FEES INCURRED PURSUANT TO THE TERMS OF THIS AGREEMENT will be withdrawnfrom your BrightFi Account and will be assessed so long as there is a remainingbalance in your BrightFi Account, unless prohibited by law.  You agree to pay all feesassociated with the Card. We may from time to time amend the Fee Schedule atour sole discretion as set forth in the Section of this Agreement titled“Amendment and Cancellation.”
+ Authorized Users
If you permit another person to have access to your Card or Card Number,you are liable for all transactions made with the Card, Card Number or AccountNumber, and all related fees incurred, by those persons.
+ BrightFi Account Use and Purpose
Subject to the limitations set forth in this Agreement, you may use yourCard, Card Number, or Account Number, as applicable, to (1) deposit funds toyour BrightFi Account (as described in the section below titled “Adding Fundsto Your BrightFi Account,” (2) purchase goods or services wherever your Card ishonored as long as you do not exceed the value available in your Brightfi Accountor the Daily Purchase Limit (as defined in the table below), (4) withdraw cashfrom your BrightFi Account (as described in the Section below titled “UsingYour Card to Get Cash,”) and (5) make payments to third parties directly fromyour BrightFi Account.  Your monthly feeprovides the ability to do all of these transactions subject to the limitationsdescribed in the table below. For fee information, see the “Schedule of Feesand Charges (Schedule A)” attached to this Agreement.   You agree not to use your Card for illegalgambling or any other illegal purpose.  You will be provided with our routing number and assigneda 13 digit Account Number onceyour identity has been verified.  Ourrouting number and your assigned Account Number are for the purpose ofinitiating direct deposits to your BrightFi Account, receiving electronictransfers from others, and authorized automated clearinghouse (“ACH”) debittransactions only. The 16-digit Card Number embossed or printed on your Cardshould not be used for these types of transactions or they will be rejected.You are not authorized to use our routing number and Account Number if you donot have sufficient funds in your BrightFi Account. These debits will bedeclined and your payment will not be processed.    
+ Limitations on Frequency and Dollar Amounts of Transactions
The total amount ofpurchases that you can perform in any single day is limited to the DailyPurchase Limit and the total amount of cash withdrawals (including withdrawals froma teller inside a bank office) that you can perform in any single day islimited to the Daily Withdrawal Limit (as defined in the table below).  The maximum aggregate value of your CardAccount(s) may not exceed $10,000.00 atany time.  For security reasons, we mayfurther limit the number or dollar amount of transactions you can make withyour Card. The following grid is provided in order to highlight the frequencyand limitations of cardholder transactions in a single day or additional timeframe if warranted:
+ Personal Identification Number (“PIN”)
When you activateyour Physical Card and after your identity has been verified, we will give youa PIN that you may use with your Physical Card.  Only one PIN will be issued for each BrightFiAccount.  You will need a PIN to obtaincash at an ATM or to make a PIN purchase or obtain cash back at a point-of-sale(“POS”) terminal. You should not write or keep your PIN with your Card. If youbelieve that anyone has gained unauthorized access to your PIN, you should immediatelycall the number on the back of your Card, +1 (888) 627-5407 or send notice byemailing service@mybrightfi.com, or through www.mybrightfi.com or write to the BrightFi - Virtual Branch at 4250 N Drinkwater Blvd #300 Scottsdale, AZ85251
+ Adding Funds to Your BrightFi Account
1.You may add funds to your Accountby depositing funds using direct deposit, electronic transfer, mobilecheck deposit or cash via ATM. You cannot add funds by sending checks or cashthrough the mail. All forms of deposit are subject to the limits identified inthe table above. (a)    Direct Deposit: Your employercan arrange to directly deposit your paycheck into your BrightFi Account.(b)    ACH Transfer: Third partiescan make ACH transfers into your BrighFi Account using your Account Number andBrightFi routing number, which are available to you under “Account Details” inthe Mobile App. (c)    Cash via ATM: You can make acash deposit to your BrightFi Account at any ATM in the MoneyPass network thatsupports deposits. You can find a directory of MoneyPass network ATMs at www.moneypass.com.(d)    Mobile CheckDeposit:Paper checks can be deposited to your BrightFi Account using the mobile depositfeature in the Mobile App. You can only deposit checks that are made payable toyou. You must (i) endorse the check  inthe same manner in which it was made payable to you and (ii) include arestrictive endorsement: “For Mobile Deposit Only” indicating that the checkwas deposited using Mobile Deposit. We may reject any attempted mobile depositthat does not comply with these conditions, or for any reason within our solediscretion. After we have accepted a check through mobile deposit, you may notpresent the check in any  form (paper ordigital) to any other financial institution. You must retain the original papercheck in your possession for 60 days to facilitate the clearing and depositprocess, to address third-party claims regarding the check or for our ownauditing purposes. If you fail to make the original check available forBrightFi’s review during the 60 days following mobile deposit, we reserve theright to deduct the funds in question from your BrightFi Account. When yousubmit a check for mobile deposit, you represent and warrant that (i) eachcheck image is a true and accurate rendition of the front and back of theoriginal check, without alteration, and that the drawer of the check has nodefense against payment of the check, (ii) all signatures and endorsements are authenticand authorized, (iii) the amount and payee are accurately identified and havenot been altered, (iv) you are entitled to enforce the check, (v) the checkcomplies with all requirements for mobile deposit set forth in this Agreementor that we have otherwise communicated to you, (vi) you have possession of theoriginal paper check, (vii) other than the digital image of an original checkthat you submit through our Mobile App, you have not created any otherduplicate images, (viii) no other party will submit the original check forpayment. After your mobile deposit is complete and accepted for deposit, thefunds will be applied to your BrightFi Account and will automatically load theCard for transactions, subject to our funds availability policy set forth inthe section below titled “Funds Availability.”
+ Is there overdraft protection?
At BrightFi, you spend what you have. We don’t charge overdraft fees because we don’t let you overspend. So no, we don’t offer overdraft protection because you won’t over spend. You can easily check your balance in the app before making a purchase.
+ I don’t have credit history. Can I still get an account?
Yes! We don’t run credit checks and you don’t need any prior credit history to join BrightFi. A BrightFi account will help you save time and keep more of your hard-earned money. You can manage and keep track of your money and work toward your financial goals.
+ I’m in the CHEX system. Can I still get an account?
Yes! We know how difficult it is to get a bank account once you’re in the CHEX system. We also know your past shouldn’t define your future. Our industry-leading verification tools mean we don’t have to rely on the CHEX system for our account sign-up process.
+ How does BrightFi make money?
A BrightFi account costs a flat fee of $7.95 each month. That’s it. There are no hidden fees, no overdraft charges and we don’t try to sell you things you don’t need, like credit cards or loans. The account fee covers some of our operations. We also get a small percentage from the store when you use your debit card to make a purchase.
+ What are your fees?
One flat fee: $7.95 a month. That’s it! To see more about what’s included, checkout this list below.
Feature
Pricing
Digital banking  tools (mobile & web)
View transaction history and balance anytime, anywhere
Included
In-app product tutorials
Included
Savings jars
Included
(open up to  three)
$0 opening and minimum balance
Included
No overdraft (spend only what you have!)
Included
(no need to opt in)
Direct deposit
Included
(we’ll walk you through the easy process)
Mobile check deposit
Included; up to $2,000 available immediately/ per day; $10,000 limit of checks cashed/month
ATMs to deposit and withdraw cash
Included for the MoneyPass and Visa PLUS Alliance networks. Out-of-network ATMs may charge an additional fee; check with provider.
Debit card
Included
Replacement card
First one included
($10 each additional card)
Person to person transfers (U.S.)
Included; up to $4,000 in transfers per day; 8 external transfers per month; unlimited transfers to other BrightFi customers
User Agreement
+ User Agreement
LAST UPDATED: SEPTEMBER 2020

Please read this User Agreement (the “User Agreement”) carefully. This User Agreement sets forth a legal agreement between you (“you”or “your”) and Karrikin, Inc. d/b/a Karrikin Technologies (“Karrikin”) and its affiliates (collectively, “we”, “us” and/or “our”), the provider of the BrightFi Account, regarding your use of the mobile application (the “Mobile App”), the Website (“Website”) and/or technology platform (collectively, the Services”) offered, operated or made available by us in connection with your BrightFi Account. This User Agreement applies when you access, interact with, sign up for or use any of the Services and is binding as of the first date you access,use, interact with or sign up for any Services. THIS USER AGREEMENT ALSO INCLUDES, AMONG OTHER THINGS, A BINDING ARBITRATION PROVISION THAT CONTAINS A CLASS ACTION WAIVER. PLEASE REFER TO THE SECTION BELOW TITLED “DISPUTE RESOLUTION” FOR MORE INFORMATION.
+ Acceptance of User Agreement
By accessing and/or using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms and conditions set forth in this User Agreement. If you do not agree with these terms and conditions, you may not access or use the Services.
+ Privacy Policy
Please read the Karrikin BrightFi Privacy Policy carefully for information relating to our collection, use, and disclosure of your personal information. By accessing or using the Services you agree to the Karrikin BrightFi Privacy Policy. The policy describes what personal information we collect from you, how we protect that data, and explains that we do not share the data with third parties for any marketing purposes. We do share data with third-party vendors that we rely on to provide services to you.
+ Use of Karrikin Services
You may not use the Services in any manner that may impair, overburden, damage, disable or otherwise compromise (i) Karrikin’s Services; (ii) any other party’s use and enjoyment of the Services; or (iii) the services and products of any third parties including, without limitation, any device through which you access the Mobile App (the “Authorized Device”) or our website. You agree to comply with all applicable laws and regulations governing the downloading, installation and/or use of the Mobile App, including, without limitation, any usage rules set forth in the online application store terms of service.
+ Updates to Mobile App
From time to time, Karrikin may automatically check the version of the Mobile App installed on the Authorized Device and, if applicable, provide updates for the BrightFi Mobile App(“Updates”). Updates may contain, without limitation, bug fixes, patches, enhanced functionality, plug-ins and new versions of the Mobile App. By installing the Mobile App, you authorize the automatic download and installation of Updates and agree to download and install Updates manually if you do not receive automatic Updates. Your use of the Mobile App and Updates will be governed by this User Agreement (as amended by any terms and conditions that may be provided with Updates). Karrikin reserves the right to temporarily disable or permanently discontinue any and all functionality of the BrightFi Mobile App at any time without notice and with no liability to you.
+ Eligibility
You must be at least eighteen (18) years old to use the Services. By agreeing to this User Agreement you represent and warrant to us: (i) that you are at least eighteen (18) years old; (ii) that you have not previously been suspended, removed or deactivated from the Services; (iii) that you are a legal resident of the United States; and (iv) that your registration and your use of the Services is in compliance with any and all applicable laws and regulations.
+ Accounts
a.  Account Creation. In order to use the Services, you must create an account (a “BrightFi Account”)with Karrikin. You agree that the information you provide with registration and at all other times, will be true, accurate, current, and complete, and that you will always keep this information accurate and up to date.  You agree not to disclose your BrightFi Account username or password to anyone else.  Your responsibility for unauthorized transactions as set forth in the BrightFi Prepaid Visa Debit Cardholder Agreement. You must notify us immediately if you believe your password has been compromised. Please refer to the BrightFi Prepaid Visa Debit Cardholder Agreement, section labeled “Your Liability for Unauthorized Transfers” for further information.

‍b.  Identity Verification.You hereby authorize Karrikin, directly or through third parties, to make anyinquiries we consider necessary to validate your identity and/or authenticateyour identity and Account information.

c.  Limitations on User Accounts. You may not create more than one (1) BrightFi Account. Please read the BrightFi Prepaid Visa Debit Cardholder Agreement for more details about our products and services. Your use of the Services is subject to the terms of the BrightFi Prepaid Visa Debit Cardholder Agreement.
+ Third Party Websites
The Services, including our website, may contain links to third-party websites. The linked sites are not under our control, and we are not responsible for the contents of any linked site. We provide these links as a convenience only, and a link does not imply our endorsement of, sponsorship of, or affiliation with the linked site. You should make whatever investigation you feel necessary or appropriate before proceeding with any transaction with any of these third parties’ services or websites.
+ User Content
Karrikin does not claim ownership of the content that you provide, upload, submit or send to Karrikin through the Services or otherwise. You understand and agree that you are responsible for all material you provide, upload, submit or send to or through the Services.When you provide content to Karrikin through the Services or otherwise, you grant Karrikin (and parties that we work with) a non-exclusive, irrevocable,royalty-free, transferable, and worldwide license to use your content and associated intellectual property and publicity rights in any manner and for any purpose, including to improve the Services and create other products and services. Karrikin will not compensate you for any of your content. You acknowledge that Karrikin’s use of your content will not infringe any intellectual property or publicity rights. Further, you acknowledge and warrant that you own or otherwise control all the rights of the content you provide, and you agree to waive your moral rights and promise not to assert such rights against Karrikin.
+ Feedback
If you choose to provide input and suggestions regarding problems with or proposed modifications or improvements to the Services (“Feedback”), then you hereby grant Karrikin and its affiliates an unrestricted, perpetual, irrevocable, non-exclusive, fully paid, royalty-free right to use the Feedback in any manner and for any purpose, including to improve the Services and create other products and services.
+ Prohibited Conduct
BY USING THE SERVICES, YOU AGREE NOT TO:
(a)  breach this User Agreement or any other agreement between you and Karrikin or violate any Karrikin policy related to your BrightFi Account;
(b)  access or use any part of the Services for any non-personal, commercial purpose;
(c)  access or use the Services for any illegal purpose or violate any law, statute, ordinance, or regulation;
(d)  attempt to gain unauthorized access to any other user’s Account;
(e)  modify or attempt to modify or in any way tamper with, circumvent, disable, damage or otherwise interfere with the Services;
(f)  access or use the Services in a way that may infringe upon the intellectual property or other rights of any third party, including, without limitation, trademark, copyright, privacy, or publicity rights;
(g)  provide false, inaccurate or misleading information;
(h)  reverse engineer, decompile, disassemble or otherwise attempt to discover the source code of the Services or any part thereof (including any Mobile App), except and only to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation;
(i)  modify, adapt, translate or create derivative works based upon the Services or any part thereof, except and only to the extent the foregoing restriction is expressly prohibited by applicable law;
(j)  copy, distribute, transfer, sell or license all or part of the Services;
(k)  transfer the Mobile App to, or use the Mobile App on, a device other than the Authorized Device;
(l)  intentionally interfere with or damage operation of the Services or any user’s enjoyment of it, by any means, including uploading or otherwise disseminating viruses, adware, spyware, worms, or other malicious code;
(m)  take any action to circumvent, compromise or defeat any security measures implemented in the Services;
(n)  use the Services to access, copy, transfer, retransmit or transcode information, Karrikin or BrightFi logos, marks, names or designs or any other content in violation of any law or third party rights; or
(o)  remove, obscure, or alter Karrikin or BrightFi (or any third party’s) copyright notices, trademarks, or other proprietary rights notices affixed to or contained within or accessed through the Services.
+ Modification of User Agreement
Karrikin reserves the right, in its sole discretion, at any time to modify, augment, limit, suspend, discontinue or terminate any or all Services without advance notice. Karrikin may, from time to time, modify the User Agreement. Please check this User Agreement periodically for changes. Your continued use of the Services after the changes become effective constitutes your binding acceptance of such changes. In the event that a change to this User Agreement materially modifies your rights or obligations, we will make an effort to notify you of the change, such as by sending you an email to the address we have on file for you, or presenting a pop-up window or other notification to you through the Services when you login,  a message or notification through the Mobile App to your registered device,  and we may require that you accept the modified User Agreement in order to continue to use the Services. Immaterial modifications are effective upon publication, and material changes will be effective upon the earlier of (a) continued use of the Services with actual knowledge of the modification, or (b) thirty (30) days following the change. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the User Agreement in effect that the time the dispute arose. You can determine when this User Agreement was last revised by referring to the“LAST UPDATED” legend at the top of then-current version of this User Agreement.
+ Term
This User Agreement is effective beginning when you accept the User Agreement or first download, install, access, or use the Services, and ends when terminated as described in Termination Section.
+ Termination
(a)  Termination by Karrikin. Without limiting other remedies, Karrikin may immediately terminate or suspend your access to and/or use of the Services and remove, subject to any regulatory retention requirements, any material from the Services or our servers, if you breach or attempt to breach this User Agreement. Notwithstanding the foregoing,we also reserve the right to terminate, limit or suspend your access to or use of the Services at any time and for any reason or no reason, including: (i) where we determine in our sole discretion that such action is reasonable in order to comply with legal requirements or to protect the rights or interests of Karrikin or any third party; or (ii) in connection with any general discontinuation of the Services. We also reserve the right to modify the Services at any time without notice to you. We will have no liability whatsoever on account of any change to the Services or any suspension or revocation of your access to or use of the Services.

(b)  Termination by You. You may terminate acceptance of this User Agreement at any time by closing your BrightFi Account whereupon (and without additional notice from Karrikin) any rights granted to you herein will automatically terminate.
+ Effect of Termination
Upon termination of this User Agreement, you understand and acknowledge that we will have no further obligation to provide or allow access to the Services. Upon termination, all licenses and other rights granted to you by this User Agreement will immediately cease. Karrikin is not liable to you or any third party for termination of the Services or termination of your use of the Services. UPON ANY TERMINATION OR SUSPENSION, ANY INFORMATION THAT YOU HAVE SUBMITTED, UPLOADED OR OTHERWISE MADE AVAILABLE ON, TO OR THROUGH THE SERVICES OR THAT WHICH IS RELATED TO YOUR BRIGHTFI ACCOUNT MAY NO LONGER BE ACCESSED BY YOU. Furthermore, except as may be required by applicable law or as provided in our Privacy Policy, Karrikin will have no obligation to store or maintain (or delete or destroy) any information stored in our database or to forward any information to you or any third party.
+ Intellectual Property Rights
You hereby acknowledge that Karrikin owns all rights, title and interest in and to the Services and to any and all proprietary and confidential information contained therein (“Karrikin Information”). The Services and Karrikin Information, including visual interfaces, graphics,design, compilation, information, computer code (including source code or object code), products, software, services, look-and-feel, and all other elements of the Services, are protected by applicable intellectual property and other laws, including patent law, copyright law, trade secret law, trademark law, unfair competition law, and any and all other proprietary rights, and any and all applications, renewals, extensions and restorations thereof, now or hereafter in force and effect worldwide.
+ Copyright Policy
(a) Karrikin respects the intellectual property rights of others and expects you to do the same. Accordingly, we will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or through the Services infringe your copyright, you may request removal of those materials(or access to them) from the Services by submitting written notification to our Copyright Agent (designated below).

(b) In accordance with the Digital Millennium Copyright Act of 1998, (17 U.S.C. §512) (“DMCA”) the text of which may be found on the U.S. Copyright Office website at http://www.copyright.gov/legislation/dmca.pdf, the written notice (the “DMCA Notice”) must include substantially the following:

(i)  your full legal name, telephone number, and email address
(ii)  and physical or electronic signature
(iii)  identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the Services, a representative list of such works
(iv)  identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material
(v)  a statement by that you have a good faith belief that the disputed use has not been authorized by the copyright owner, its agent, or the law
(vi)  a statement by you made under penalty of perjury, that the information in your notice is accurate, that you are the copyright owner or authorized to act on the copyright owner’s behalf, and
(vii)  your electronic or physical signature or the electronic or physical signature of the person authorized to act on your behalf.

(c) Our designated Copyright Agent to receive DMCA Notice is customerservice@verdigrisholdings.com.

(d) If you fail to comply with all the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective. Please be aware that if you knowingly materially misrepresent that material or activity on the Services is infringing your copyright, you may be held liable for damages (including costs and attorneys’ fees) under Section 512(f) of the DMCA.
+ Indemnification
To the fullest extent permitted by law, you agree to indemnify, defend and hold Karrikin and all of its successors, parents, subsidiaries, affiliates, officers, directors, stockholders, investors, employees, agents, representatives and attorneys and their respective heirs, successors and assigns (collectively, the “Indemnified Parties”), harmless from and against any and all claims, liabilities, losses, damages, costs and expenses, including, without limitation, reasonable attorneys’ fees, incurred by the Indemnified Parties arising out of or relating to (i) your access to, use of or alleged use of the Services; (ii) your violation of this User Agreement or any representation, warranty, or agreements referenced herein, or any applicable law or regulation; (iii) your violation of any third party right, including without limitation any intellectual property right, publicity, confidentiality, property or privacy right; or (iv) any disputes or issues between you and any third party. We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and in such case, you agree to cooperate with our defense of such claim. You shall cooperate as fully as reasonably required in the defense of any such claim. Karrikin reserves the right, at its own expense, to assume the exclusive defense and control of any matter subject to indemnification by you. You agree not to settle any matter subject to indemnification by you without our prior written consent.
+ Disclaimers: No Warranties
THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE”. EXCEPT AS REQUIRED BY LAW, Karrikin DISCLAIMS ALL WARRANTIES AND REPRESENTATIONS OF ANY KIND REGARDING THE SERVICES, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTIES OF MERCHANTABILITY, ACCURACY, QUIET ENJOYMENT, NON-INFRINGEMENT OF THIRD PARTY RIGHTS, FREEDOM FROM VIRUSES OR OTHER HARMFUL CODE, FITNESS FOR ANY PARTICULAR PURPOSE, OR ANY WARRANTY ARISING OUT OF COURSE OF DEALING, USAGE OR TRADE. Specifically, but without limitation, Karrikin does not warrant that: (1) the information provided in, or that may be obtained from use of, the services will meet your requirements or be correct, accurate, up-to-date, or reliable; (2) the services will be uninterrupted or error-free; (3) the quality of any products, services,information or other material purchased by or obtained by you through the services will meet your expectations; or (4) any errors in the technology will be corrected. You assume all risk for all damages, including damage to your computer system, mobile device or loss of data that may result from your use of or access to the service. You hereby acknowledge that use of the services is at your sole risk.
+ Limitation of Liability
To the maximum extent permitted by applicable law, neither the indemnified parties nor any other party involved in creating, producing, operating or delivering the services will be liable for any incidental, special, consequential or punitive damages, whether based on warranty, contract, tort (including negligence), statute or any other legal theory, whether or not the indemnified parties have been informed of the possibility of such damage where such damages result from: (i) your access to or use of, or inability to access or use, the services, or (ii) any purchase of a third party product or service based on information contained in the  Services, including the availability of a coupon. You specifically acknowledge that the indemnified parties are not liable for the defamatory, offensive or illegal conduct of other users or third parties and that the risk of injury from the foregoing rests entirely with you. Further, the indemnified parties will have no liability to you or to any third party for any third-party content uploaded onto or downloaded from the site or through the service.

Some jurisdictions do not allow the limitation or exclusion of liability in certain circumstances. Accordingly, some of the above limitations may not apply to you.

Each provision of this user agreement that provides for a limitation of liability, disclaimer of warranties, or exclusion of damages is intended to and does allocate the risks between the parties under this user agreement. This allocation is an essential element of the basis of the bargain between the parties. Each provision providing for limitation of liability, disclaimer of warranties, or exclusion of damages is severable and independent of all other provisions of this user agreement. The limitations in this section entitled “limitation of liability” will apply even if any limited remedy fails of its essential purpose.
+ Dispute Resolution - Arbitration
This Arbitration Provision sets forth the circumstances and procedures under which claims (as defined below) shall be arbitrated instead of litigated in court upon the election of either party.

(a) Definitions: As used in this Arbitration Provision, the term “Claim” means any claim, dispute or controversy between you and us, or any of our agents, arising from or relating to this User Agreement as well as any related or prior agreement that you may have had with us or the relationships resulting from this User Agreement, including the validity, enforceability or scope of this Arbitration Provision or the User Agreement. “Claim” includes claims of every kind and nature, including but not limited to initial claims, counterclaims, cross-claims and third-party claims and claims based upon contract, tort, fraud and other intentional torts, statutes, regulations, common law and equity. The term “Claim” is to be given the broadest possible meaning that will be enforced and includes, by way of example and without limitation, any claim, dispute or controversy that arises from or relates to (i) your BrightFi Account, (ii) this User Agreement or (iii) your use of the Services. We shall not elect to use arbitration under the Arbitration Provision for any Claim that you properly file and pursue in a small claims court of your state or municipality so long as the Claim is individual and pending only in that court.              

(b) Initiation of Arbitration Proceeding/Selection of Administrator: Any Claim shall be resolved, upon the election by you or us, by arbitration pursuant to this Arbitration Provision and the code of procedures of the national arbitration organization to which the Claim is referred in effect at the time the Claim is filed. Claims shall be referred to either Judicial Arbitration and Mediation Services (“JAMS”) or the American Arbitration Association (“AAA”), as selected by the party electing to use arbitration. If a selection by us of one of these organizations is unacceptable to you, you shall have the right within thirty (30) days after you receive notice of our election to select the other organization listed to serve as arbitrator administrator. For a copy of the procedures, to file a Claim or for other information about these organizations, contact them as follows: (i) JAMS at 1920 Main Street, Suite 300, Los Angeles, CA 92614; website atwww.jamsadr.com; and (ii) AAA at 335 Madison Avenue, New York, NY 10017; website at www.adr.org.

(c) Significance of Arbitration: IF ARBITRATION IS CHOSEN BY ANY PARTY WITH RESPECT TO A CLAIM, NEITHER YOU NOR WE WILL HAVE THE RIGHT TO LITIGATE THAT CLAIM IN COURT OR HAVE A JURY TRIAL ON THAT CLAIM, OR TO ENGAGE IN DISCOVERY EXCEPT AS PROVIDED FOR IN THE CODE OF PROCEDURES OF JAMS OR AAA, AS APPLICABLE (THE“CODE”). FURTHER, YOU WILL NOT HAVE THE RIGHT TO PARTICIPATE IN A REPRESENTATIVE CAPACITY OR AS A MEMBER OF ANY CLASS OF CLAIMANTS PERTAINING TO ANY CLAIM SUBJECT TO ARBITRATION. THE ARBITRATOR SHALL NOT CONDUCT A CLASS ARBITRATION OR A JOINT ARBITRATION, EXCEPT AS SET FORTH BELOW. THE ARBITRATOR’S DECISION WILL BE FINAL AND BINDING. NOTE THAT OTHER RIGHTS THAT YOU WOULD HAVE IF YOU WENT TO COURT ALSO MAY NOT BE AVAILABLE IN ARBITRATION.

(d) Restrictions on Arbitration: If either party elects to resolve a Claim by arbitration, that Claim shall be arbitrated on an individual basis. There shall be no right or authority for any Claims to be arbitrated on a class action basis or on bases involving Claims brought in a purported representative capacity on behalf of the general public, other Cardholders or other persons similarly situated. The arbitrator’s authority to resolve Claims is limited to Claims between you and us alone, and the arbitrator’s authority to make awards is limited to you and us alone. Furthermore, Claims brought by you against us or by us against you may not be joined or consolidated in arbitration with Claims brought by or against someone other than you, unless otherwise agreed to in writing by all parties.  This section of this Arbitration Provision is the “Class Action Waiver.”

(e) Location of Arbitration/Payment of Fees: Any arbitration hearing that you attend shall take place in the federal judicial district of your residence. At your written request, we will consider in good faith making a temporary advance of all or part of the filing administrative and/or hearing fees for any Claim you initiate as to which you or we seek arbitration. At the conclusion of the arbitration (or any appeal thereof), the arbitrator (or panel) will decide who will ultimately be responsible for paying the filing, administrative and/or hearing fees in connection with the arbitration (or appeal). If and to the extent you incur filing, administrative and/or hearing fees in arbitration, including for any appeal, exceeding the amount they would have been if the Claim had been brought in the state or federal court which is closest to your billing address and would have had jurisdiction over the Claim, we will reimburse you to that extent unless the arbitrator (or panel) determines that the fees were incurred without any substantial justification.

(f) Arbitration Procedures: This Arbitration Provision is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act, 9 U.S.C. Sections 1-16, as it may be amended (the “FAA”). The arbitration shall be governed by the applicable Code, except that (to the extent enforceable under the FAA) this arbitration Provision shall control if it is inconsistent with the applicable Code. The arbitrator shall apply applicable substantive law consistent with the FAA and applicable statutes of limitations and shall honor claims of privilege recognized at law and, at the timely request of either party, shall provide a brief written explanation of the basis for the decision. In conducting the arbitration proceeding, the arbitrator shall not apply the Federal or any state rules of civil procedure or rules of evidence. Either party may submit a request to the arbitrator to expand the scope of discovery allowable under the applicable Code. The party submitting such a request must provide a copy to the other party, who may submit objections to the arbitrator with a copy of the objections provided to the request party, within 15 days of receiving the requesting party’s notice. The granting or denial of such request will be in the sole discretion of the arbitrator who shall notify the parties of his/her decision within 20 days of the objecting party’s submission. The arbitrator shall take reasonable steps to preserve the privacy of individuals, and of business matters. Judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction. The arbitrator’s decision will be final and binding, except for any right of appeal provided by the FAA. However,any party can appeal that award to a three-arbitrator panel administered by the same arbitration organization, which shall consider anew any aspect of the initial award objected to by the appealing party. The appealing party shall have 30 days from the date of entry of the written arbitration award to notify the arbitration organization that it is exercising the right of appeal. The appeal shall be filed with the arbitration organization in the form of a dated writing. The arbitration organization will then notify the other party that the award has been appealed. The arbitration organization will appoint a three-arbitrator panel which will conduct arbitration pursuant to its Code and issue its decision within 120 days of the date of the appellant’s written notice. The decision of the panel shall be by majority vote and shall be final and binding.

(g) Public Injunctive Relief: If a Claim is brought seeking public injunctive relief and a court determines that the restrictions in the Class Action Waiver and/or elsewhere in this Arbitration Provision prohibiting the arbitrator from awarding relief on behalf of third parties are unenforceable with respect to such Claim (and that determination becomes final after all appeals have been exhausted), the Claim for public injunctive relief will be determined in court and any individual Claims seeking monetary relief will be arbitrated.  In such a case the parties will request that the court stay the Claim for public injunctive relief until the arbitration award pertaining to individual relief has been entered in court.  In no event will a Claim for public injunctive relief be arbitrated.

(h) No Preclusive Effect: No arbitration award involving the parties will have any preclusive effect as to issues or claims in any dispute involving anyone who is not a party to the arbitration, nor will an arbitration award in prior disputes involving other parties have preclusive effect in an arbitration between the parties to this Arbitration Provision.

(i) Continuation: This Arbitration Provision shall survive termination of this User Agreement or any other agreement between you and us (including but not limited to the Deposit Agreement, Electronic Communications Agreement, and Cardholder Agreement). If any portion of this Arbitration Provision is deemed invalid or unenforceable under any principle or provision of law or equity, consistent with the FAA, it shall not invalidate the remaining portions of this Arbitration Provision, the Agreement or any prior agreement you may have had with us, each of which shall be enforceable regardless of such invalidity.
+ General
This User Agreement, together with the Account Agreement, Cardholder Agreement, Electronic Communication Agreement, Privacy Policy and any other agreements expressly incorporated by reference herein,constitute the entire and exclusive understanding and agreement between you and us regarding your use of and access to the Services. You may not assign or transfer this User Agreement or your rights hereunder, in whole or in part, by operation of law or otherwise, without our prior written consent. We may assign this User Agreement or any of our rights or obligations under this User Agreement at any time without notice, subject to applicable law. The failure to require performance of any provision shall not affect our right to require performance at any time thereafter, nor shall a waiver of any breach or default of this User Agreement constitute a waiver of any subsequent breach or default or a waiver of the provision itself. Use of paragraph headers in this User Agreement is for convenience only and shall not have any impact on the interpretation of particular provisions. If any part of this User Agreement is held to be invalid or unenforceable, the unenforceable part shall be given effect to the greatest extent possible and the remaining parts will remain in full force and effect.
+ Survival
In the event of termination of this User Agreement or the Services, the terms in this User Agreement that by their nature are continuing shall survive such termination, including but not limited to the indemnification and hold harmless obligations, disclaimers and limitations of liabilities, and the Arbitration Provision.
+ Contact Information
If you have any questions regarding Karrikin, your BrightFi Account, the Services, or this User Agreement please email us at service@mybrightfi.com.
Electronic Communications Agreement
+ Electronic Communications Agreement
LAST UPDATED: SEPTEMBER, 2020

Please read this information carefully and print or download a copy for your files.

This Electronic Communications Agreement (“ECA”) applies to all communications related to the transaction account (“BrightFi Account”) and accompanying services available through www.mybrightfi.com (the “Website”) and the BrightFi mobile application (“Mobile App”). This ECA supplements and is to be construed in accordance with the terms contained in the BrightFi Account Agreement (“Account Agreement”), the BrightFi User Agreement (“User Agreement”), and Privacy Policy that  you received when you opened your BrightFi Account.

“We”, “us”,“our”, refers to Karrikin, Inc. d/b/a Karrikin Technologies and its affiliates (“Karrikin”), the provider of the BrightFi Account. “Communication(s)” means any customer agreements, including but not limited to this ECA, the Account Agreement, User Agreement and Privacy Policy or amendments thereto, disclosures, notices, responses to claims, transaction histories, and all other information communicated to you in connection with the BrightFi Account(s) or related products and services, including but not limited to information that we are required by law to provide you “in writing.”

The BrightFi Account is intended for use only by persons who are willing and able to receive notices and communications exclusively through the Website, the Mobile App or via electronic means (i.e., E-mail, Chat, SMS). Subject to applicable law, if you do not agree receive all notices,including but not limited to notices that are required by law, in electronic and not paper form, you may not open a BrightFi Account. Similarly, if after providing your consent hereunder, you withdraw such consent, your BrightFi Account will be closed.

+ Scope
When you use a product or service to which this ECA applies, you agree that we may provide you with any Communication in electronic format, to the extent allowed by law,and that we may discontinue sending paper Communications to you.  Your consent to receive electronic communications and transactions includes, but is not limited to:·      

(i) All legal and regulatory disclosures and communications associated with your BrightFi Account;·      
(ii) Agreements related to your BrightFi Account (including the BrightFi Account Agreement, User Agreement, or any other applicable agreement), and all amendments thereto;·      
(iii) Privacy policies and notices;·      
(iv) Responses to claims filed in connection with your BrightFi Account;·      
(v) Notices of resolution of any claimed error in connection with an electronic transfer;·      
(vi) Notices regarding insufficient funds or negative balances; and·      
(vii) All other communications between us and you concerning your BrightFi Account and any related transactions, products or services.
+ Methods of Electronic Communication
Communications that we provide to you in electronic form will be provided either (1) via email,if you elect to receive communications via e-mail from us (2) SMS where available or (3) by notifications delivered through the Mobile App.  
+ How to Withdraw Consent
You may exercise your right to withdraw your consent to receive Communications in electronic form by writing us at 4250 N Drinkwater Blvd, Scottsdale AZ 85251-3981 or by e-mailing us at service@mybrightfi.com.  If you withdraw your consent, we will close your BrightFi Account and mail you a check in the amount of funds remaining in your BrightFi Account at the time of closure, in accordance with the terms of your Account Agreement.Withdrawal of your consent shall not affect the legal validity and enforceability of prior Communications delivered in electronic form.
+ How to Update Your Records
It is your responsibility to provide us with a true, accurate and complete email address, cellular phone number, other contact information related to this ECA and your BrightFi Account, and to maintain the information and keep it current. You must promptly update your profile if there are any changes to this information. You can update information (such as your email address) by emailing service@mybrightfi.com, or by contacting us at  +1 (888) 627-5407. We are not responsible for any delay or failure in your receipt of the Communications if we send the Communications to the last email address or mobile number you have provided to us.
+ Hardware and Software Requirements
In order to access, view, and retain electronic Communications that we make available to you, you must have:

For the mobile application:
1. An Apple iPhone running a current version of iOS
2. Access to a cellular carrier
3. Native browser that supports the iOS operating system that is on most recent version

On desktop computers:
1. Windows (7 or higher) or Mac OS X
2. Microsoft Edge, Internet Explorer 11, Safari 9 (or higher), or the latest available version of Mozilla, Firefox or Google Chrome
+ Requesting Paper Copies
We will not send you a paper copy of any Communication, however, we reserve the right, but assume no obligation, to provide a paper (instead of electronic) copy of any Communication that you have authorized us to provide electronically. You can obtain a paper copy of an electronic Communication by printing it yourself or by requesting that we mail you a paper copy. To request a paper copy, contact us at +1(888) 627-5407 during normal business hours. We may charge you a reasonable service charge for the delivery of paper copies of any Communication that would otherwise be provided to you electronically pursuant to this authorization.
+ Communications in Writing
All Communications in either electronic or paper format from us to you will be considered “in writing”. You should print or download for your records a copy of this ECA and any other Communication that is important to you.
+ Federal Law
You acknowledge and agree that your consent to electronic Communications is being provided in connection with a transaction affecting interstate commerce that is subject to federal Electronic Signatures in Global and National Commerce Act (the “Act”), and that you and we both intend that the Act apply to the fullest extent possible to validate our ability to conduct business with you by electronic means.
+ Termination or Changes
We reserve the right, at our sole discretion, to discontinue the provision of your electronic Communications, or to terminate or change the terms and conditions on which we provide electronic Communications. We will provide you with notice of any such termination or change as required by law.
+ Consent
By indicating“I agree”, you are providing consent to Verdigris to use this agreement as your electronic signature and you give your affirmative consent to provide electronic Communications to you as described herein. You further represent and warrant that your computer and mobile phone satisfy the hardware and software requirements specified above. If you elect to receive communications from us via e-mail, you further represent and warrant that that you have provided us with a current e-mail address at which we may send electronic Communications to you.
Privacy Policy
+ Privacy Policy
LAST UPDATED: SEPTEMBER, 2020

We respect your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the BrightFi Services website (the "Site") and services (including mobile and web-based applications, and any other  tools, products, or services provided by BrightFi LLC that link to or reference this Privacy Policy) (collectively, the “Services”).

This Privacy Policy applies to information BrightFi Services collects through the Services, as well as other information provided to us online or offline by third parties, when we associate that information with customers or users of the Services.  It does not apply  to information that you share with third parties or is collected by third parties through the Services (such as web traffic analytics tools).  You acknowledge and agree that BrightFi Services is not responsible for the data collection or use practices of any other  Services user or third party utilized in providing the Services.
+ Your Consent
By accessing or using the Services, you consent to this Privacy Policy.  If you do not agree with this Privacy Policy, please do not access or use the Services.  Information gathered through the Services may be transferred, used, and stored in the United States  or in other countries where our service providers or we are located.  If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United  States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or BrightFi Services are deemed to occur in the United States, where our servers are located.
+ Collection of Your Personal and Other Information
When you register for, or use our Services, we collect Personal Information.  By “Personal Information” we mean information that can identify an individual, such as:

- Names;
- Personal or business addresses;
- Email addresses;
- Phone numbers;
- Unique identifiers (arbitrary codes or series of characters we create or are provided from a third party to identify unique users or devices) that are connected or may reasonably be connected to your identity.

We also collect non-Personal Information relating to the Services, that is, information that does not personally identify an individual.  

The non-Personal Information we collect includes how you interact with the Services, information generally collected or  “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services. We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes  use cookies and other automatic information gathering technologies to gather non-Personal Information.Information collected by the Services may be collected by us or one of our service providers acting on our behalf, but in either case, this Privacy Policy will govern the collection, use, and sharing of the information.
+ Information Use
We do not sell, rent or exchange your personally identifiable information to any outside party, for any reason, at any time. Any of the information BrightFi Services collects from you may be used or disclosed in one of the following  ways:

- To facilitate customer service interactions
- To process transactions
- To improve customer experience
- For market research, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity
- To third-party contractors that provide services to BrightFi Services and are bound by these same privacy restrictions
- To enforce BrightFi Services’ Terms of Service
- As otherwise set forth in this Privacy and Security Policy

The email address you provide for receiving additional information will only be used to send you information and updates pertaining to BrightFi Services, unless you decide to opt-in to the BrightFi Services email lists.

If you opt-in, BrightFi Services may use this information to notify you of any company updates. If you don’t wish to receive these newsletters or updates then you may unsubscribe.

We do not intentionally collect personally identifiable information from children under the age of thirteen. If we become aware that we have collected personally identifiable information from a user of the Site who is under the age of thirteen, we will remove that child’s personal information from our files.
+ Google Analytics
BrightFi Services uses Google Analytics, and it may record visits to this Site, what website you came from to get here, how long you stay for, what kind of computer you’re using, and other simple pieces of information about your  visit to the Site.

To opt out of Google Analytics reporting on any site, install the browser add-on available from Google here.

BrightFi Services may access data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics. To opt out of demographic and interest-based information in the Google  network, use Google's Ad Settings page here.
+ Your Information Security is Important
BrightFi Services offers the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our provider’s database only to be accessible by those authorized with special  access rights to such systems. All parties are required to keep the information confidential.
+ Tracking
BrightFi Services may anonymously track your browsing activity for advertising and data collection purposes.  BrightFi Services and third-party vendors use first-party cookies or other first-party identifiers.  

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could  affect the availability and functionality of our Services.
+ Sharing of Information
As mentioned above, BrightFi Services does not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted  third parties who assist BrightFi Services in operating its website, conducting its business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your  information when it believes release is appropriate to comply with the law, enforce this Site’s policies, or protect BrightFi Services’ or others rights, property, or safety. However, non-personally identifiable  visitor information may be provided to other parties for marketing, advertising, or other uses.
+ Contests, Surveys and Promotions Fall Under This Policy Too
From time to time, BrightFi Services may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this  Privacy and Security Policy, except as specifically set forth in the rules for those contests, giveaways or promotions. From time to time, BrightFi Services may also ask you to participate in surveys designed to help us improve the Site. Any personal information provided to BrightFi Services in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Policy.
+ Your California Privacy Rights
Because BrightFi Services values your privacy it has taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. BrightFi Services therefore will not distribute your personal information to outside parties without your consent.
+ Privacy Changes
BrightFi Services reserves the right to change the content of this Privacy Policy from time to time, and such changes will become effective immediately. We will always post our most current Privacy Policy at our web site, and we suggest that you periodically consult it, or contact us at hello@mybrightfi.com should you have any concerns.