Terms of Service Agreement

For purposes of this Agreement, "Earned Wage Access" or "EWA" means a financial product that permits an eligible worker to receive a portion of wages or income that the worker has already earned but has not yet been paid, prior to the worker's scheduled payday, subject to verification and product rules. "Advance" means a fixed-dollar disbursement of funds made available to You through ZivoAdvance® against verified earned income, in an amount of fifty dollars ($50.00), seventy-five dollars ($75.00), or one hundred dollars ($100.00), as selected by You and permitted by the Application. "Flat Service Fee" means the single, fixed dollar charge disclosed to You in the Application before You confirm an Advance, which does not vary based on the length of time the Advance remains outstanding and does not constitute interest or a time-based finance charge. "Linked Account" means the deposit account at a U.S. financial institution that You authorize Us to connect through open banking integrations for purposes of verification, funding, and repayment. "Pay Cycle" means the recurring interval at which Your employer or income source pays You, as determined from open banking and, where available, open payroll data. "Open Banking" and "Open Payroll" refer to data connectivity services, including without limitation Plaid and Pinwheel and such other partners as Rise may engage from time to time, through which You authorize access to account, income, employment, or payroll information for eligibility and scheduling purposes.

Headings in this Agreement are for convenience only and shall not affect interpretation. Unless the context requires otherwise, singular terms include the plural and vice versa. References to statutes or regulations include amendments and successor provisions. The word "including" means "including without limitation." This Agreement incorporates by reference the Privacy Policy published at /privacy and any advance-specific disclosures presented in the Application at the time You confirm a transaction.

Rise operates as a fintech software company and product operator. Rise is not a bank, not a lender within the traditional depository or consumer-lending sense, not a money transmitter within the meaning of Section 560.103, Florida Statutes, and not a deferred presentment provider within the meaning of Section 560.402, Florida Statutes. Rise does not hold a bank charter, does not accept deposits, and is not insured by the Federal Deposit Insurance Corporation or the National Credit Union Administration.

Rise affirmatively states that ZivoAdvance® is an Earned Wage Access product. ZivoAdvance® is not a payday loan, personal loan, line of credit, or deferred presentment transaction. Rise does not extend "credit" within the meaning of the Truth in Lending Act (TILA), Regulation Z (12 C.F.R. Part 1026), or comparable state consumer lending statutes, because ZivoAdvance® provides access to wages or income You have already earned rather than a right to defer payment of borrowed principal on credit terms. This position is consistent with the Consumer Financial Protection Bureau Advisory Opinion published at 90 Fed. Reg. 60070 (December 23, 2025), which confirms that properly structured earned wage access products, including direct-to-consumer models, are not "credit" within the meaning of TILA and Regulation Z. Accordingly, TILA credit disclosures such as "Amount Financed," "Finance Charge," and annual percentage rate do not apply to ZivoAdvance® as currently structured.

The material specifications of ZivoAdvance® are as follows: the product type is earned wage access; advance amounts are fixed at fifty dollars ($50.00), seventy-five dollars ($75.00), or one hundred dollars ($100.00); the fee structure is a flat fixed fee only with no interest and no time-based charges; only one advance may be outstanding at a time per consumer; repayment is aligned with Your paycheck and Pay Cycle as scheduled from Open Banking and Open Payroll data rather than a fixed calendar offset from advance; repayment occurs by automated clearing house debit from Your Linked Account on pay-cycle-aligned dates or, where You choose a supported Open Payroll option and employer or payroll APIs permit, via employer or payroll-processor repayment on payday; no traditional credit check is performed; credit bureau reporting is expressly prohibited; recourse against You beyond withholding future advances is expressly prohibited; and underwriting is limited to income and cash-flow verification rather than credit scoring.

ZivoAdvance® does not involve a consumer check, a check-holding agreement, or a fee tied to deferring presentment of a payment instrument. In each Advance, Rise transfers its own operating funds to Your Linked Account and later collects repayment owed to itself. Rise does not receive Your funds for the purpose of transmitting them to a third party and does not act as an intermediary between a sender and recipient within the meaning of money transmission statutes. Rise characterizes ZivoAdvance® as non-recourse: Rise does not sell debt, assign receivables to third-party collectors, report Advances to consumer reporting agencies, or pursue consumers through court action or wage garnishment for non-repayment. If repayment is not received, Rise's principal contractual remedy is to suspend or withhold future Advances, subject to Application rules and applicable law. Consumer protections embedded in the Product include the one-at-a-time limit, non-recourse structure, prohibition on collections, and prohibition on credit reporting.

To enroll in and use ZivoAdvance®, You must be at least eighteen (18) years of age and possess legal capacity to enter into a binding contract under Florida Statutes Section 743.07. You must be a legal resident of the United States with valid work authorization. You must maintain an active checking account at a U.S. financial institution capable of receiving automated clearing house credits and debits, in good standing, and not subject to legal encumbrances or restrictions that would prevent verification, funding, or scheduled repayment. You must provide accurate, complete, and verifiable personal information, including government-issued identification and employment or payroll information, as requested in the Application and as required by applicable law.

ZivoAdvance® is presently offered to eligible consumers located in the State of Florida. Rise may expand or restrict geographic availability in its discretion and as permitted or required by applicable law, including prospective earned wage access registration frameworks. Rise may decline enrollment, suspend access, or terminate this Agreement if You fail to satisfy eligibility criteria, if verification cannot be completed, if Rise detects fraud or misrepresentation, or if continued access would present legal, regulatory, or operational risk. Eligibility for any particular Advance is determined at the time of request based on then-current product rules and verified information; prior approval does not guarantee future approval.

ZivoAdvance® permits eligible Users to receive a small, fixed-dollar Advance against income they have already earned but may not yet have been paid. You are accessing a portion of Your own earned income early; You are not obtaining a traditional loan tied to future borrowing capacity or creditworthiness scoring. Advance amounts are fixed at fifty dollars ($50.00), seventy-five dollars ($75.00), or one hundred dollars ($100.00). Only one outstanding Advance may be active at any time; this limitation is enforced by the Application and is a material product rule designed to prevent stacking of obligations.

Before You confirm any Advance, the Application will disclose the Advance amount You selected, the Flat Service Fee applicable to that transaction, the scheduled repayment date aligned with Your Pay Cycle, and the total amount to be collected on repayment (Advance plus Flat Service Fee). There is no interest, no annual percentage rate, and no time-based finance charge that accrues based on the principal amount or duration of the Advance. You must review these transaction-specific disclosures each time before confirming an Advance; marketing materials on Rise's public website do not state dollar amounts because fees and limits may vary and may change over time.

If a change in applicable law requires Rise to modify product structure, provide additional disclosures, or re-characterize ZivoAdvance®, Rise will comply with such requirements and will provide notice to affected Users as required by law before material changes take effect. Rise reserves the right to modify product rules, fee schedules, verification requirements, and partner integrations in accordance with this Agreement and applicable law.

Your use of ZivoAdvance® requires verification of earned income, account status, and Pay Cycle timing. You authorize Rise and its service providers to access information through Open Banking and Open Payroll integrations You select in the Application, including without limitation Plaid and Pinwheel, for purposes of confirming eligibility, determining Advance amounts permitted, scheduling repayment, detecting fraud, and complying with legal obligations. You represent that You have authority to link the accounts You connect and that all credentials and authorizations You provide are valid.

Rise may also use identity verification services, including photographic verification, to confirm that You are the authorized User of the Application and Linked Account. Rise's collection, use, retention, and disclosure of personal information are described in the Privacy Policy. By using the Application, You consent to such processing to the extent described therein and as necessary to operate ZivoAdvance®.

You agree to maintain the security of Your device, login credentials, and verification codes. You must notify Rise promptly if You believe Your account has been compromised or if any information You provided has changed in a manner material to eligibility or repayment. Rise is not responsible for losses arising from unauthorized access resulting from Your failure to safeguard credentials, except to the extent liability cannot be disclaimed under applicable law.

Rise provides pre-transactional disclosure of all fees before You confirm an Advance, in compliance with applicable Florida and federal consumer protection laws, including the Florida Deceptive and Unfair Trade Practices Act (Florida Statutes Section 501.201 et seq.). Fees applicable to Your account may include a Flat Service Fee for the selected Advance and delivery method (standard automated clearing house transfer or expedited transfer where offered), account verification or onboarding fees if disclosed at enrollment, and reasonable cost-based administrative or retry fees if disclosed in the Application and permitted by law. Rise does not charge interest or annual percentage rate, and fees do not increase based on how long an Advance remains outstanding.

You agree that all fees disclosed in the Application at the time of Your confirmation constitute the complete fee arrangement for that Advance, subject only to adjustments expressly permitted by this Agreement and applicable law. Rise will not impose undisclosed, unauthorized, or voluntary "tip" charges. If Rise determines that an erroneous charge occurred, Rise will investigate and, where appropriate, correct or refund the charge in accordance with applicable law and payment network rules.

Upon Your confirmation of an Advance in the Application, Rise will initiate disbursement of funds from Rise's operating accounts to Your Linked Account, typically by automated clearing house credit. Advances may be processed through sponsor-bank arrangements, including Bank of America, N.A., where applicable. Disbursement timing depends on banking networks, verification status, and operational factors; Rise does not guarantee instantaneous availability of funds.

You authorize Rise to initiate automated clearing house credits and debits with Your Linked Account as necessary to fund Advances and collect scheduled repayment. Where You provide a debit or credit card, You authorize Rise to charge that card only for amounts expressly disclosed in the Application and authorized by You, including where applicable onboarding or verification charges and repayment amounts You authorize when automated clearing house debit from Your Linked Account is unavailable, in each case subject to notice requirements in the Application and applicable law. This authorization remains in effect until all obligations arising under confirmed Advances are satisfied or until revoked in accordance with applicable payment network and legal requirements.

Repayment of each Advance is scheduled on a date aligned with Your Pay Cycle, derived from Open Banking and Open Payroll data subject to partner availability. The specific repayment date and total collection amount (Advance plus Flat Service Fee) are disclosed in the Application before You confirm the Advance. The primary repayment method is automated clearing house debit from Your Linked Account on the scheduled date. Where You elect a supported Open Payroll repayment option and employer or payroll application programming interfaces permit, repayment may instead be satisfied through employer or payroll-processor handling on payday.

You agree to maintain sufficient funds in Your Linked Account on the scheduled repayment date or to use another authorized payment method offered in the Application. If an automated clearing house debit fails, Rise may retry collection in accordance with product rules and applicable law, providing notice where required. Availability of retries, partial debits, or alternative payment paths may vary based on banking rules and Application settings at the time of failure.

If repayment is not received after permitted retries and notice, Rise will not engage in traditional debt collection, sell the obligation to third parties, report the Advance to consumer reporting agencies, or pursue legal enforcement or wage garnishment against You for non-repayment. Rise may suspend or withhold Your eligibility for future ZivoAdvance® transactions until any outstanding balance disclosed in the Application is satisfied under then-current product rules. This non-recourse structure is a material term of ZivoAdvance® and reflects Rise's regulatory and consumer-protection design for the Product.

You agree not to use the Application for any unlawful purpose or in violation of applicable regulations. You shall not provide false, misleading, or incomplete information; attempt unauthorized access to systems, accounts, or data; interfere with the operation or security of the Application; circumvent eligibility or one-Advance limits through multiple identities or accounts; or reverse engineer or scrape the Application except as permitted by law. Rise may suspend or terminate access immediately upon detection of fraud, abuse, or legal risk, and may refer matters to law enforcement where appropriate.

If Rise determines that You engaged in fraudulent conduct, Rise may pursue remedies permitted by law for fraud after providing notice where required. Fraud determinations do not convert ZivoAdvance® into a recourse lending product for ordinary non-repayment; they address misrepresentation and intentional abuse distinct from failure to repay on Pay Cycle timing.

Rise does not use traditional credit scores to approve ZivoAdvance® and does not report Advances to Equifax, Experian, TransUnion, or other consumer reporting agencies. Such reporting is expressly prohibited under this Agreement. You may dispute unauthorized or erroneous charges by contacting Rise at hello@risedfc.com or by mail at Rise Digital Financial Corp, Legal Notices Department, 323 Sunny Isles Boulevard, 7th Floor, Sunny Isles Beach, FL, 33160, USA. Rise will investigate disputes and respond in accordance with applicable law, payment network rules, and internal procedures.

For unresolved complaints regarding Rise or ZivoAdvance®, You may contact the Florida Office of Financial Regulation, Division of Consumer Finance, 200 E. Gaines Street, Tallahassee, Florida 32399-0376, telephone 1-800-848-3792 or 850-487-9687, or visit www.flofr.gov. You may also contact the Consumer Financial Protection Bureau at www.consumerfinance.gov where applicable.

Except for claims that may not be arbitrated under applicable law, including qualifying actions in Florida small claims court under Florida Statute Section 34.01, any dispute, claim, or controversy arising out of or relating to this Agreement or ZivoAdvance® shall be resolved by binding arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules. The arbitrator shall apply Florida substantive law and federal law where applicable. Arbitration hearings shall be held in the Florida county of Your residence, or in Miami-Dade County, Florida if You are not a Florida resident, unless the parties agree otherwise or the AAA rules provide differently.

You and Rise waive the right to a jury trial and to participate in a class action, class arbitration, or representative proceeding to the fullest extent permitted by law. You may opt out of arbitration within thirty (30) days of first accepting this Agreement by sending written notice to Rise at 323 Sunny Isles Boulevard, 7th Floor, Sunny Isles Beach, FL, 33160, USA or hello@risedfc.com, including Your name, account identifier, and a clear statement that You opt out of arbitration.

This Agreement is governed by the laws of the State of Florida, without regard to conflict-of-law principles, except where federal law applies. Subject to the arbitration provisions above, exclusive jurisdiction for any permitted court proceeding shall reside in the state or federal courts located in Miami-Dade County, Florida, and You consent to personal jurisdiction therein.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE APPLICATION AND ZIVOADVANCE® ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. RISE DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, EXCEPT WHERE SUCH DISCLAIMERS ARE PROHIBITED BY LAW. RISE DOES NOT WARRANT UNINTERRUPTED OR ERROR-FREE OPERATION, TIMELY DISBURSEMENT, OR CONTINUED AVAILABILITY IN ANY PARTICULAR GEOGRAPHIC MARKET.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, RISE'S TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS AGREEMENT SHALL NOT EXCEED THE GREATER OF (A) THE TOTAL FEES PAID BY YOU TO RISE IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) FIVE HUNDRED DOLLARS ($500.00). NEITHER PARTY SHALL BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR LOST PROFITS, LOST DATA, OR BUSINESS INTERRUPTION, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, EXCEPT WHERE LIABILITY CANNOT BE LIMITED BY LAW. THE FOREGOING LIMITATIONS APPLY SEPARATELY TO EACH CLAIM AND SURVIVE TERMINATION OF THIS AGREEMENT.

Rise collects, uses, retains, and discloses information necessary to operate ZivoAdvance®, verify eligibility, process Advances and repayments, prevent fraud, and comply with applicable law, including the Florida Information Protection Act and the Gramm-Leach-Bliley Act where applicable. Rise employs administrative, technical, and physical safeguards designed to protect information in its possession. Details regarding categories of information, retention periods, third-party service providers, and Your rights are set forth in the Privacy Policy available at /privacy, which is incorporated by reference.

Rise maintains records of Advance confirmations, fee disclosures, repayment schedules, and acceptance timestamps as required by applicable law and internal compliance policies. You may request a copy of this Agreement or transaction records by contacting Rise; Rise will respond within timeframes required by applicable law.

Rise may deliver notices, disclosures, and account communications through the Application, push notification where enabled, email to Your registered address, or other electronic means permitted by the Florida Electronic Signature Act (Florida Statutes Section 668.001 et seq.) and applicable federal law. You consent to electronic delivery and agree that electronic records satisfy any legal requirement that communications be in writing, to the extent permitted by law. You must maintain a valid email address and monitor the Application for time-sensitive repayment and security notices.

Formal legal notices to Rise must be sent to Rise Digital Financial Corp, Legal Notices Department, 323 Sunny Isles Boulevard, 7th Floor, Sunny Isles Beach, FL, 33160, USA, with a copy to hello@risedfc.com. Notices are deemed received when delivered by confirmed electronic transmission during business hours, or three (3) business days after mailing by recognized courier to the address above.

You agree to provide and maintain accurate, complete, and current account, employment, payroll, and banking information throughout Your use of ZivoAdvance®. You agree to review all fee and repayment disclosures in the Application before confirming each Advance. You agree to maintain a Linked Account capable of receiving automated clearing house credits and debits and to ensure sufficient funds are available on scheduled repayment dates or to use another authorized payment method offered in the Application. You agree to notify Rise promptly if You anticipate inability to meet scheduled repayment so Rise may address the matter within product rules and applicable law.

By accepting this Agreement, You represent and warrant that all information You provide is true and complete, that You are the authorized holder of any payment credentials You supply, that You will not permit others to use Your account, and that You will not dispute properly authorized charges except as permitted by law and payment network rules.

This Agreement becomes effective upon Your first acceptance in the Application and continues until terminated as provided herein. Rise may suspend or terminate Your access immediately for violation of this Agreement, suspected fraud, legal or regulatory requirement, or operational necessity. You may cease using the Application at any time; termination of access does not relieve You of repayment obligations for any Advance already disbursed and disclosed in the Application at the time of confirmation.

Upon termination, provisions that by their nature should survive—including regulatory classification acknowledgments, repayment obligations for confirmed Advances, arbitration, governing law, limitation of liability, and dispute resolution—shall survive.

Zivo: Cash Advance is the consumer rebrand and App Store successor of Blink: Cash Advance. Zivo is not a separate financial product. Both applications are operated by Rise Digital Financial Corp. on the same earned-wage-access infrastructure, with the same legal operator, compliance posture, product structure, and regulatory classification. The underlying earned wage access product was previously distributed as BlinkAdvance® through Blink: Cash Advance (Bundle ID com.rise.blinkfinances.blinkApp). Zivo: Cash Advance is distributed under Bundle ID com.risedigital.zivo. Blink has been removed from sale in the Apple App Store; Zivo is the actively distributed consumer listing.

The regulatory exhibit materials submitted in connection with App Store review for Zivo are Zivo-branded counterparts of Rise's existing Florida Office of Financial Regulation Chapter 560 filing package for Blink: Cash Advance and BlinkAdvance®. Legal structure, non-recourse design, flat-fee economics, income-based verification, and operator identity are identical. Only the consumer-facing brand, application name, and App Store identity differ. Users who previously accessed BlinkAdvance® should understand that ZivoAdvance® is the same product category—earned wage access, not credit, not deferred presentment—under a new consumer brand operated by the same entity.

The ZivoAdvance® transaction follows a defined sequence designed for transparency and verification at each stage. You download Zivo: Cash Advance from the Apple App Store and create an account subject to eligibility screening. You connect Your Linked Account and, where offered and authorized by You, payroll-linked data through approved Open Banking and Open Payroll integrations, including Plaid for account and income verification and Pinwheel for payroll connectivity, together with such other data partners as Rise may engage from time to time. You select a fixed Advance amount of fifty dollars ($50.00), seventy-five dollars ($75.00), or one hundred dollars ($100.00). Rise reviews income and cash-flow data to confirm that You have earned or accrued income sufficient to support the requested Advance before any funds are disbursed.

Upon Your confirmation of the transaction-specific disclosures in the Application, Rise initiates disbursement of Advance funds from Rise's operating accounts to Your Linked Account, typically by automated clearing house credit. On the repayment date aligned with Your anticipated paycheck and informed by Open Banking and Open Payroll data subject to partner availability and data quality, Rise collects the Advance amount plus the Flat Service Fee either by automated clearing house debit from Your Linked Account or, where You have elected a supported Open Payroll repayment option and employer or payroll application programming interfaces permit, via employer or payroll-processor settlement on payday. If repayment through the selected path is unsuccessful, Rise does not pursue alternative collection through debt buyers, collection agencies, credit bureau reporting, or court enforcement; the Advance is treated as a non-recourse loss under product rules, and Your eligibility for future Advances may be suspended until any outstanding balance is resolved within the Application.

Regulatory classification of ZivoAdvance® turns on Rise's product structure and the repayment path You actually use for each transaction, not on the identity of any particular third-party data vendor. Plaid, Pinwheel, and other partners supply data infrastructure and, where applicable, payroll connectivity; they are not Rise and do not replace Rise's role as the earned wage access provider responsible for product rules, disclosures, and consumer relationship management.

Rise's regulatory position, as set forth in its Regulatory Position Memorandum and incorporated into this Agreement by reference for classification purposes, is that ZivoAdvance® does not constitute a "deferred presentment transaction" under Section 560.402, Florida Statutes, and that Section 560.125 is accordingly not applicable to Rise's ZivoAdvance® activity as currently structured. Florida's deferred presentment regime governs businesses that exchange currency for a consumer's check and agree to hold that check for a deferment period before deposit or presentment. Section 560.402(3) defines a deferred presentment transaction as providing currency or a payment instrument in exchange for a drawer's check and agreeing to hold the check for a deferment period.

ZivoAdvance® fails each element of that statutory definition. Rise does not accept, receive, or hold a check from You at any point in the transaction. No payment instrument is tendered by You to Rise in exchange for the Advance. Rise does not agree to hold any instrument for a deferment period, and the Flat Service Fee is not a fee charged for deferring presentment of a check—it is a fixed service fee for earned wage access disclosed before You confirm the Advance. You are not a "drawer" in the statutory sense because You do not write or deliver a personal check to Rise. Because no deferred presentment transaction exists, Rise's position is that licensing under Chapter 560, Part II or Part III for deferred presentment is not required for this activity as structured.

ZivoAdvance® is further distinguished from check-based deferred presentment by its non-recourse design and prohibition on credit bureau reporting. Traditional deferred presentment involves recourse when a check is dishonored and may involve database verification of outstanding check-based agreements under Section 560.4041, Florida Statutes. ZivoAdvance® uses in-application electronic acceptance rather than a check-and-signature model, prohibits recourse collection and credit reporting in this Agreement, and does not create a deferred presentment agreement subject to those requirements. Rise's conclusion, which You acknowledge by using the Product, is that a product cannot be a deferred presentment transaction without a check: no check, no deferred presentment.

At the federal level, the Consumer Financial Protection Bureau Advisory Opinion published at 90 Fed. Reg. 60070 (December 23, 2025) (the "2025 AO") establishes an interpretive framework for earned wage access products. While the 2025 AO is not binding on states, it is persuasive authority on whether properly structured EWA products resemble credit subject to the Truth in Lending Act and Regulation Z. The 2025 AO confirms that covered earned wage access products—including direct-to-consumer models—can be categorically different from consumer lending when they provide access to wages or income already earned, do not perform traditional credit risk assessment, prohibit credit bureau reporting, and limit recourse to withholding future advances.

ZivoAdvance® is designed to align with these principles. Advances are limited to income You have already earned, as confirmed through Open Banking and Open Payroll data rather than unsupported estimates. Rise does not use credit scores or traditional credit underwriting. Credit bureau reporting is expressly prohibited. Recourse is limited to suspension of future Advances. The 2025 AO expanded prior guidance by explicitly addressing direct-to-consumer EWA, which encompasses Rise's model of offering ZivoAdvance® through the Application without requiring an employer-sponsored program.

You acknowledge that repayment mechanics may vary by transaction. Where You elect a supported Open Payroll repayment option and employer or payroll processor capabilities permit settlement on payday, repayment may follow a payroll-process path closer to the 2025 AO's payroll deduction model. Where that path is unavailable or not selected, repayment more commonly occurs by automated clearing house debit from Your Linked Account on a date aligned with Your Pay Cycle. Covered EWA and federal credit classification may depend on the actual repayment path in use for each transaction. Regardless of repayment rail, Rise's position is that ZivoAdvance® is not a deferred presentment transaction under Florida Chapter 560 because no consumer check is involved, and the 2025 AO supports the broader principle that non-recourse, income-based EWA is categorically distinct from payday lending and traditional consumer credit.

Rise may implement product enhancements over time, including fee structures for premium users or expedited delivery options, subject to applicable law and disclosure in the Application. Any such enhancement will be presented with pre-transaction disclosures before You confirm an Advance. Rise monitors federal and state regulatory developments affecting EWA and will adjust product rules and disclosures as required to maintain compliance.

Earned wage access is a developing product category in Florida and nationally. Florida's 2025 legislative session saw introduction of Senate Bill 422 and House Bill 1391, cited as the Florida Earned Wage Access Services Act, which would have created Chapter 437, Florida Statutes, requiring EWA providers to register with the Florida Financial Services Commission. Those bills included construction language providing that EWA services offered in compliance with the Act would not be considered a loan or other form of credit, that the provider would not be considered a creditor, debt collector, or lender, that EWA would not be considered money transmission under Section 560.103, Florida Statutes, and that fees paid in accordance with the chapter would not be considered interest or finance charges. The bills did not become law in the 2025 session. Florida also introduced Senate Bill 1146 in the 2024 session as an earlier iteration of a distinct EWA registration framework; that bill likewise did not become law.

The successive introduction of purpose-built EWA legislation in consecutive sessions is legislative recognition that earned wage access is a distinct category from deferred presentment, money transmission, and traditional consumer lending. Rise supports enactment of a Florida EWA registration framework and will register under any such law upon enactment. Pending such a framework, Rise operates ZivoAdvance® in accordance with this Agreement, applicable consumer protection laws, and Rise's documented regulatory position that the Product is earned wage access and not deferred presentment under Chapter 560 as currently structured.

Rise engages constructively with regulators, App Store review processes, and supervisory authorities on product facts and disclosures. When the Florida Office of Financial Regulation or other authorities raise questions about earned wage access products, Rise responds promptly with written submissions explaining product structure and legal classification. The same product previously marketed as BlinkAdvance® is now distributed as ZivoAdvance® through Zivo: Cash Advance. Rise welcomes continued dialogue consistent with its position that ZivoAdvance® is not deferred presentment under Chapter 560 and is not credit under TILA as currently structured.

Rise relies on third-party data partners to operate verification and scheduling functions essential to ZivoAdvance®. Open Banking integrations, principally Plaid, enable secure connection to Your Linked Account for income verification, account status confirmation, and automated clearing house funding and collection. Open Payroll integrations, principally Pinwheel, enable access to employment and payroll data where You authorize such connection, supporting pay-cycle timing and, where available, employer- or payroll-processor-led repayment on payday. Rise may engage additional data partners and suppliers as the Product evolves, subject to disclosure in the Application and the Privacy Policy.

You acknowledge that third-party providers operate under their own terms and privacy policies when You connect accounts or authorize data access. Rise does not control third-party system availability, data accuracy, or API capabilities. Verification outcomes, repayment scheduling, and availability of payroll-linked repayment options may therefore depend on factors outside Rise's direct control, including employer participation, payroll processor support, banking holidays, and network interruptions. Rise uses partner data for income and cash-flow verification and paycheck timing—not as a substitute for credit underwriting or as a workaround for data You have not authorized.

By authorizing connections in the Application, You direct Rise and its partners to access information necessary to determine eligibility, deliver Advances, schedule repayment, detect fraud, and comply with law. You may revoke certain authorizations through partner portals or by contacting Rise, understanding that revocation may limit or terminate Your ability to use ZivoAdvance® if verification and repayment cannot be completed without such access.

This Agreement constitutes the entire agreement between You and Rise regarding ZivoAdvance® and supersedes prior oral or written understandings on that subject, except for transaction-specific disclosures presented in the Application at the time You confirm an Advance, which supplement this Agreement for that transaction. If any provision is held invalid or unenforceable, the remaining provisions remain in full force and effect. Rise's failure to enforce any provision shall not constitute a waiver. You may not assign this Agreement without Rise's prior written consent; Rise may assign this Agreement in connection with a merger, acquisition, corporate reorganization, or sale of assets upon notice where required by law.

By clicking "I Agree," completing identity verification, entering a one-time verification code, or otherwise accepting in the Application, You confirm that You have received and read this Agreement and the transaction disclosures applicable to Your enrollment or Advance, and You consent to electronic records and signatures under applicable law, including the Florida Electronic Signature Act.