HAVN Privacy Policy

1. Who This Policy Covers

This Privacy Policy explains how New Haven Group North America INC ("HAVN," "we," "us") collects, uses, and shares information from workers, employers, merchants, and prospective members (waitlist signups) who interact with the HAVN service, including our website, application, and onboarding flows.

2. Information We Collect

Identity and employment verification data — collected via our verification provider (FrankieOne) as part of onboarding and ongoing monitoring:

• Government-issued ID information and biometric data (photo/liveness check)
• Employment status and employer identity, verified through payroll connection
• Screening results against sanctions, watchlist, and adverse media sources

Wage and payroll data — used to determine and process earned wage access:

• Confirmed earned wages for the current pay period
• Pay schedule (payday cadence) and payment history through HAVN
• Wage advance draw history and repayment records

Waitlist and signup data — collected when you register interest before full launch:

• Full name and mobile number
• Industry and approximate weekly take-home pay range
• Payday cadence
• Referral activity (who referred you, and whom you refer)

Business/employer lead data — collected when a business registers interest in offering HAVN to its team:

• Company name, sector, and headcount
• Contact name and work email address

Merchant and discount network data:

• Which discount categories and offers a member views or redeems

Device and usage data — standard technical data collected automatically, such as IP address, browser type, and pages visited.

3. How We Use Information

• To verify your identity and employment, and to determine eligibility for earned wage access
• To calculate available wage access amounts and process draws and repayments
• To detect and prevent fraud, and to meet our AML/KYC/KYB and other legal obligations
• To operate the merchant discount network and match members with relevant offers
• To administer the employer benefit program, including the churn/retention signal shared with employers at an aggregate, non-identifying level
• To follow up with waitlist registrants and business leads about HAVN's launch
• To improve and maintain the security of our services

4. Who We Share Information With

We do not sell personal information to third parties for their own marketing purposes.

• Identity and employment verification providers (currently FrankieOne), to perform the checks described above
• Case management / compliance providers (if engaged, e.g. Hummingbird), to investigate and document flagged activity
• Payroll and employer systems, to confirm employment and earned wages
• Payment processors, to move funds for wage advances and repayments
• Merchant partners, limited to what is necessary to apply a discount or offer — not your full account or wage data
• Service providers who host or process data on our behalf (e.g. our database and hosting providers)
• Regulators and authorities, where required by law (e.g. AUSTRAC, FinCEN, or state regulators, as applicable to where HAVN operates)

6. Your Rights and Choices

Depending on where you live, you may have rights to access, correct, delete, or limit the use of your personal information, and to opt out of certain data uses.

• You may request access to or deletion of your waitlist or account information by contacting us (see Section 10).

7. Security

We use administrative, technical, and physical safeguards designed to protect personal information. No system is completely secure, and we cannot guarantee absolute security.

8. Children's Privacy

HAVN is intended for working adults and is not directed to, or knowingly used to collect information from, anyone under 18.

9. International Data

HAVN operates in the United States, and personal information is primarily collected, processed, and stored in the United States. Some of the service providers we use to operate HAVN maintain offices or infrastructure outside the United States. This includes our identity and employment verification provider, FrankieOne, which maintains operations in both San Francisco, California and Australia. Where personal information is transferred to, processed in, or accessed from a country other than where you reside, we require that provider to protect it consistent with this Privacy Policy and applicable law, through contractual, technical, and organizational safeguards.

10. Contact Us

If you have questions about this Privacy Policy, or want to exercise any of the rights described above, contact us at: info@wearehavn.com

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version with a new effective date, and where required by law, provide additional notice.