Cogni Prepaid Debit Visa Cardholder Agreement


Effective as of September 5, 2019.
[Last Updated: February 14, 2020]

1. Introduction

This Cogni Prepaid Debit Visa Cardholder Agreement ("Agreement") outlines the terms and conditions under which the Cogni Prepaid Debit Visa Card (the "Card") has been issued to you by Community Federal Savings Bank (the "Bank"). The Bank has retained Cogni, Inc. to provide certain services on the Bank's behalf (the "Servicer"). "Account" means the records we maintain to account for the value of transactions associated with the Card. "You" and "your" means the person or persons who have received the Card and who are authorized to use the Card as provided for in this Agreement. "We," "us," and "our" means the Bank, and its successors, affiliates, assignees and our third-party service providers, including Servicer. The Card will remain the property of the Bank and must be surrendered upon demand. The Card is nontransferable, and it may be canceled, repossessed, or revoked at any time without prior notice, subject to applicable law. Please read this Agreement carefully and keep it for future reference.

As described in this Agreement, you can contact Servicer through the Servicer's mobile application, by sending an email to or by calling the Member Services telephone number, Toll free: 833-264-6447 or the toll-free telephone number on the back of your Card. Please keep for future reference the Member Services telephone number or the toll-free telephone number on the back of your Card in case the Card is lost, stolen or destroyed.

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions and their third parties to obtain, verify, and record information that identifies each person who obtains a Card. What this means for you: when you apply for a Card, we will ask for your name, address, date of birth, social security number or country identification number, and other information that will allow us to identify you. We also may ask to see your driver's license or other documentation bearing your photo as verification of your identity. By participating in the Card program, or applying for a Card, you certify that all information you have provided to us, including, but not limited to, your real name, valid U.S. mailing address and residential address (if different), social security number or identification documentation, date of birth, telephone number and other information provided at our request, is true, accurate and complete. If you falsify, misrepresent, or fail to provide requested information, we may cancel your Card and Account. In addition, funds tied to suspected illicit or illegal activity may be subject to both internal and potentially federal investigation. We reserve the right to restrict or delay your access to any such funds, subject to applicable law. We may share any of the information collected and any results of any investigation with the Servicer, which may be used pursuant to its Privacy Policy [].


2. Your Agreement.

This Agreement is provided to you in electronic format pursuant to the E-Signature and Electronic Disclosure Agreement that you accepted and agreed to when you opened your Account. By activating the Card or by retaining, using or authorizing the use of it, you represent and warrant to us that: (i) you are at least 18 years of age (or older if you reside in a jurisdiction where the majority age is older); (ii) you are a U.S. citizen or legal alien residing in the fifty (50) states of the United States ("U.S.") or the District of Columbia; (iii) you have provided us with a verifiable U.S. street address (not a P.O. Box); (iv) the personal information you provide to us in connection with the Card is true, correct and complete; (v) you received a copy of this Agreement and agree to be bound by and to comply with its terms; and (vi) you accept the Card.

3. The Card.

The Card is a prepaid debit card. The Card allows you to access funds loaded or deposited to your Account by you or on your behalf. The funds in your Account will be insured up to the limit established by the Federal Deposit Insurance Corporation ("FDIC")) once the Servicer has been able to verify your identity. You may access the funds in your Account by using your Card, Card Number, or by automated clearinghouse (ACH) debit using an account number provided to you by us. The Card is neither a credit card nor a gift card, and is not intended for gifting purposes. You will not receive any interest on your funds on the Card or in the Account. The funds in your Account will not expire, regardless of the expiration date on the front of your Card.

You agree that the Card will be used primarily for personal, family and household purposes only and not for business use. You may not use the Card for illegal gambling or any other illegal transaction. We reserve the right to cancel, close or restrict use of the Card and Account, including by refusing the processing of any transaction, if we believe you have violated this Agreement or any applicable law.

You should activate the Card and complete the activation process, including setting a Personal Identification Number ("PIN"), before using the card. You should memorize your PIN and not write down your PIN or keep your PIN with your Card. If you believe that anyone has gained unauthorized access to your PIN, you should advise the Servicer immediately, following the procedures in Section XV (Your Liability for Unauthorized Transactions) below. You may need to provide personal information in order for your identity to be verified and for completion of the activation process. You agree to sign the back of the Card immediately upon activation.

4. Fees.

The fees relating to the use (including misuse) of your Card or Account are set forth in this Agreement in the attached fees appendix (Appendix 1) (the "Fees"). Appendix 1 is incorporated herein by reference. Fees incurred pursuant to the terms of this Agreement will be withdrawn from your Account and will be assessed even if there is no remaining balance in your Account, unless prohibited by law. You agree to pay all Fees associated with the Card. We may from time to time amend the Fees, at our sole discretion, as set forth in this Agreement. If you request a service that is not included in Appendix 1 and there is a fee for such service, such fee will be disclosed at the time you request the service and you agree that any such fee may be deducted from your Account.

5. Authorized Users.

You are responsible for all authorized transactions initiated and fees incurred by use of the Card. If you permit another person to have access to the Card or Account, this will be treated as if you authorized such use and you will be liable for all transactions and fees incurred by those persons. You are wholly responsible for the use of each Card according to the terms and conditions of this Agreement, subject to Section XV (Your Liability for Unauthorized Transactions) below, and applicable laws.

6. Using the Card and Account and Limits

Subject to the limitations set forth in this Agreement, you may use your Card, as applicable, to access funds in your Account, including to purchase goods or services wherever your Card is honored as long as you do not exceed the value available in your Account and aggregate purchases do not exceed the limits set forth in Appendix 2, which is incorporated herein by reference. There may be Fees associated with some of these transactions. For fee information, see Appendix 1 attached to this Agreement.

You will be provided with the Bank's routing number and assigned an account number (the "Account Number") once your identity has been verified. The Bank's routing number and your assigned Account Number are for the purpose of initiating direct deposits to your Account and authorized ACH debit & credit transactions. You may only directly deposit funds into your Account through the Servicer's mobile application or as otherwise permitted by this Agreement. You are not authorized to use the Bank's routing number and Account Number to make a debit transaction with a paper check, check-by-phone or other item processed as a check outside of the Servicer's mobile application. These debits will be declined and your payment will not be processed. If you do not have sufficient funds in your Account, debits to your Account may be declined and your payment will not be processed. You also may be assessed an ACH decline fee (see Appendix 1).

With your PIN, the Card may be used to obtain cash at any Automated Teller Machine ("ATM") displaying the Visa or Maestro acceptance marks, subject to your applicable daily cash withdrawal limit set forth in Appendix 2. Fees may apply (see Appendix 1 for details). ATM owner-operators may impose their own fees and lower limits on cash withdrawals. You may use your PIN at supported Point of Sale ("POS") devices, as permitted by a merchant that bears the Visa or Maestro acceptance marks, and subject to your daily purchase limit (if applicable). Each time you use the Card, you authorize the Bank to reduce the value available in your Account balance by the amount of the transaction and any applicable fees.

Foreign Transactions. The Card may only be used to conduct transactions within the 50 United States, District of Columbia and U.S. Territories (Puerto Rico, Guam, Northern Marianas, the U.S. Virgin Islands, and American Samoa). The Card may be used to conduct international transactions, including, without limitation, transactions conducted on international merchant websites or mobile applications accessible within the United States; provided the merchant accepts Visa or Maestro. All debits to your Account will be posted in U.S. dollars. Transactions made in a foreign currency are converted into U.S. dollar amounts by Visa or Maestro using its then current currency conversion procedure and rate. The currency conversion rate used on the processing date may differ from the rate in effect on the transaction date or periodic statement posting date. Foreign transactions are subject to foreign transaction fees, as set forth in Appendix 1, and will be included in the amount charged to your Account.

Card Not Present Transactions. If you initiate a transaction without presenting your Card (such as for a mail order, internet or telephone purchase or a card-based ACH debit), the legal effect will be the same as if you used the Card itself. For security reasons, the amount or quantity of such transactions you may make may be limited.

The total amount of purchases, transfers, reloads and cash withdrawals that you can perform in any single day or over any other period is limited to the amounts set forth in the enclosed Appendix 2. For security reasons, you may be further limited as to the number or dollar amount of transactions you can make with your Card. We may, at our discretion, modify the limits from time to time. You will be notified of any change in the manner provided by applicable law prior to the effective date. Card limits are subject to periodic review and may be changed based on your Account history, activity, and other factors, including but not limited to your Card activity. We retain sole discretion to apply and change limits.

You may add funds to your Account at any time. The maximum deposit amount is set forth in Appendix 2. You agree to present the Card and meet identification requirements to complete deposit transactions as may be required from time to time. Deposit locations may have their own deposit limits that may be less than our allowable amount. Deposit locations also may assess a fee to deposit funds to your Account. You also may direct deposit funds to your Account by providing the Bank's routing number and your assigned Account Number to your employer or other direct deposit payor. You cannot deposit funds into your Account by money order.

7. Split Transactions and Authorization Holds

Split Transactions. If you do not have sufficient funds in your Account, you can instruct the merchant to charge a part of the purchase to the Card and pay the remaining amount with cash or another card. These are called "split transactions." Some merchants do not allow cardholders to conduct split transactions. Some merchants will only allow you to do a split transaction if you pay the remaining amount in cash. If you fail to inform the merchant that you would like to complete a split transaction before swiping your Card, your Card is likely to be declined.

Authorization Holds. When you use your Card to purchase goods or services or to make a cash back withdrawal transaction, the merchant may attempt to obtain preauthorization for the transaction. If the merchant makes such a request, a "hold" is placed on your Account balance for the amount of the preauthorization request (which may vary in some cases from the amount of the actual purchase, depending on the merchant or purchase type), until the merchant sends the final payment amount of your purchase, or for up to sixty (60) days, even if you fail to make the purchase. During the hold period, you may not have access to the preauthorized amount in your Account. We will not be responsible if any transactions are not completed because of the hold. If the preauthorization request varies from the amount of the actual transaction, the actual transaction amount will be debited from your Account, even if this results in your Account balance becoming negative. You remain responsible for any negative balances in your Account. If you use the Card at an automated fuel dispenser ("pay at the pump"), the transaction may be preauthorized for an amount up to $125.00. If the Card is declined, but you have sufficient funds available in your Account, you should use the Card to pay for the purchase inside with the cashier. If you use the Card at a restaurant, a hotel, for a car rental purchase, or for similar purchases, the transaction may be preauthorized for the purchase amount plus up to 20% to ensure there are sufficient funds available to cover tips or incidental expenses incurred. You do not have the right to stop payment on any purchase or payment transaction originated by use of the Card.

8. Obligation for Negative Balances

You acknowledge that Account balances and available funds reported on the Servicer's mobile application are only approximations of real time balances and available funds rather than the settled balances or funds in your Account. A reported balance may not take into account pending debits and credits or recurring payments that you have scheduled. Servicer will provide you with information on pending debits and credits as soon as we have that information. Each time you initiate a Card transaction, you authorize the Bank to reduce the funds available in your Account by the amount of the transaction and all associated fees. You are not allowed to exceed the available amount in your Account through an individual transaction or a series of transactions (creating a "negative balance"). Nevertheless, if any transaction causes the balance in your Account to go negative, including any purchase transactions where the retailer or merchant does not request authorization, you shall remain fully liable to us for the amount of any negative balance and any corresponding transaction fees and agree to immediately load the required amount to correct the negative balance, which will be due without the need for notifying you, and you shall remain fully liable to us for the amount of any negative balance and any corresponding transaction fees. You may also be liable for any related Insufficient Funds/NSF Fee(s) as set forth in Appendix 1. We reserve the right to bill you for any negative balance or to recoup such negative balance from any other Card issued to you by Bank. You agree to pay us promptly for the negative balance and any related fees. We also reserve the right to cancel your Card if you create one or more negative balances with your Card. Additionally, if any transactions cause the balance in your Account to become negative: (a) we may exercise our right to collect the negative balance from you in accordance with this Agreement; (b) we may initiate a chargeback procedure for any specific transaction which led to your Account having a negative balance; (c) we may take debt collection measures, including, but not limited to, mandating a debt collection agency or attorneys to pursue the claim in court, and we reserve the right to charge you the expenses we reasonably incur in connection with any debt collection or enforcement efforts; or (d) you authorize us to initiate a payment transaction for the amount of the negative balance from one of your external accounts linked to your Account if we request that you load your Account with funds in order to correct a negative balance and you fail to do so within seven (7) Business Days, for which you remain liable if funds are insufficient to cover the negative balance.

9. Recurring Transactions and Preauthorized Credits

If you intend to use your Card for recurring transactions, you should monitor your balance and ensure you have funds available in your Account to cover the transactions. "Recurring transactions" are transactions that are authorized in advance by you to be charged to your Card at substantially regular intervals. We are not responsible if a recurring transaction is declined because you have not maintained a sufficient balance in your Account to cover the transaction. If these recurring transactions vary in amount, the recipient of the recurring transaction should inform you, ten (10) days before each payment, when it will be made and how much it will be. You may choose instead to get this notice only when the payment would differ by more than a certain amount from the previous payment. If you have provided instructions for recurring transactions from your Account, you can stop the payment by notifying us orally at Toll free: 833-264-6447 or in writing to Cogni at 175 Varick, New York, New York 10014 at least three (3) business days before the scheduled date of the transfer. If you call, we also may require you to put your request in writing and get it to us within fourteen (14) days after you call. If you order us to stop one of these payments three (3) business days or more before the transfer is scheduled, we will be liable for your direct losses or damages. There may be Fees associated with a stop payment request. For fee information, see Appendix 1 attached to this Agreement. If you have authorized a merchant to make the recurring transaction, you also should contact the applicable merchant in order to stop the recurring transaction. If you have arranged to have direct deposits made to your Account at least once every sixty (60) days from the same person or company and you do not receive a receipt/statement (paystub), you can call us Toll free at: 833-264-6447 or login to the Servicer's mobile app to find out whether or not the deposit was made.

10. Statements

You should keep track of the amount of funds available in your Account. You may obtain information about the amount of funds you have remaining in your Account by looking on the Servicer's mobile application. This information, along with a 12-month history of account transactions, is also available on the Servicer's mobile application. You also have the right to obtain a 24-month written history of account transactions by contacting the Servicer via their mobile application or by calling us Toll free at: 833-264-6447. The Servicer may assess a fee for each paper statement provided to you based on your request, as set forth in Appendix 1. Pursuant to the E-Signature and Electronic Disclosure Agreement, we will deliver any requested Account statements or other statements required by law to you in electronic form. Merchants generally will not be able to determine your available balance. It is important to know your available Account balance before making any transaction.

11. Return and Refunds

If you are entitled to a refund for any reason for goods or services obtained with the Card, you agree to accept credits to your Account for refunds and agree to the refund policy of the merchant. Neither the Bank nor Servicer is responsible for the delivery, quality, safety, legality or any other aspects of the goods or services you purchase from others with the Card. If you have a problem with the delivery, quality, safety, legality or any other aspects of the goods or services you purchased with the Card, you must handle it directly with the merchant. The amounts credited to your Card for refunds may not be available for up to five (5) days from the date the refund transaction occurs.

You should get or request a receipt at the time you make a transaction or obtain cash using your Card. You agree to retain your receipts to verify your transactions. You can get a receipt at the time you make a withdrawal from your Account using an ATM terminal (if available).

12. Card Cancellation, Suspension and Limits and Card Replacement

We reserve the right, at any time and in our sole discretion, to limit your use of the Card, including limiting or prohibiting specific types of transactions. The Bank or Servicer may refuse to issue a Card, revoke Card privileges or cancel your Card with or without cause or notice, other than as required by applicable law. If you would like to cancel the use of your Card, you may do so by calling Toll free: 833-264-6447 or the number on the back of your Card. You agree not to use or allow others to use an expired, revoked, cancelled, suspended or otherwise invalid Card. The cancellation of Card privileges will not otherwise affect your rights and obligations under this Agreement. Not all services described in this Agreement are available to all persons or at all locations. We reserve the right to limit, at our sole discretion, the provision of any such services to any person or in any location. Any offer of a service in this Agreement shall be deemed void where prohibited. We can waive or delay enforcement of any of their rights under this Agreement without losing them.

If you need to replace a damaged Card, call Toll free: 833-264-6447 to request a replacement Card. You will be required to provide personal information which may include the last four digits of your Card number, your full name and knowledge of the Card transaction history. We may cancel any Card that has been disabled for sixty (60) calendar days or longer.

13. Lost or Stolen Card

If you believe your Card or PIN has been lost, stolen or compromised, you may report a Card lost or stolen through the Servicer's mobile application, and this should trigger a new replacement card to automatically be issued. You may also call Toll free: 833-264-6447 or write us at Cogni at 175 Varick, New York, New York 10014. You should also contact us through the means set forth in this section if you believe an electronic transfer has been made using the information from your Card or Account without your permission.

14. Your Right to Dispute Errors

When an unauthorized transaction or other error occurs in the Account, including unauthorized transactions that occur because the Card has been lost or stolen, we will cover you for the full amount of every eligible unauthorized transaction or other error as long as you follow the procedures discussed in this Section. We must hear from you no later than sixty (60) days after the date you electronically access your Account, if the error could be viewed in your electronic history.

1. Describe the error or transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information.

2. Tell us the dollar amount of the suspected error.

If you tell us verbally, we may require that you send us your complaint or question in writing within ten (10) business days.

We will determine whether an error occurred within ten (10) business days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to forty-five (45) days (ninety (90) days for those transactions at merchant POS terminals, processed on a new account, or initiated outside the United States) to investigate your complaint or question. If we decide to do this, we will credit your account within ten (10) business days for the amount you think is in error so that you will have full use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it within ten (10) business days, we may not credit your account.

For errors involving new accounts (an account where the first deposit to the account occurs less than 30 days before the error), we may take up to twenty (20) business days to credit your account for the amount you think is in error.

We will tell you the results within three (3) business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation. If your Card does not receive wages, salary, or other employee compensation that are made on a recurring basis or does not receive electronic deposits of federal payments, all of this Section applies, except the Bank will not credit your Account until our investigation is complete and we have determined an error occurred.

15. Your Liability for Unauthorized Transactions

You agree to exercise reasonable control over your PIN(s); user ID(s); and password(s) and any other access code related to your Card Account (each, an "Access Code") and your Card. If you believe the Card or Access Code has been lost, compromised or stolen, immediately contact us at Toll free: 833-264-6447 or contact us through the Servicer's mobile application. If you believe that someone has transferred money or may transfer money from your Account without your permission, call Toll free: 833-264-6447 or contact us through the Servicer's mobile application. We may suspend or cancel your Card and/or corresponding Account in the event of excessive reports of Card loss or theft. Under Visa Rules, you will not be held responsible for unauthorized transactions if you have used reasonable care in protecting your Card from loss or theft and you have promptly reported to us when you knew that your Card was lost or stolen. If you notify us within two (2) business days after you learn of any unauthorized transactions, you can lose no more than $50.00 if someone used your Card without your permission. If you do not notify us within two (2) business days after you learn of the loss or theft of your Card and we can prove that we could have stopped someone from using your Card without your permission if you had promptly notified us, you could lose as much as $500.00.

Also, if you become aware of, or your electronic history shows, a transaction you did not make, notify us at once following the procedures stated in Section XIV (Your Right to Dispute Errors). If you do not notify us within sixty (60) days after you become aware of the transaction, after you could view your electronic history, you may not get back any value you lost after the sixty (60) days if we can prove that we could have stopped someone from taking the value if you had notified us in time.

You will not be liable for unauthorized use that occurs after you notify us of the loss, theft or unauthorized use of your Card or Access Code(s). You also agree to cooperate completely with the Bank and Servicer in attempts to recover funds from unauthorized users and to assist in their prosecution. The Bank may issue replacement Card(s) or Access Code(s), but only after you have provided such proof and security or indemnification as the Bank may require. In addition, you acknowledge that the Bank or Servicer may have to deactivate your Card(s) and/or Account to prevent future losses. If you share your Card(s) or Access Code(s) with another person, use of your Account by that person may be considered as authorized. If you authorize another person to use your Card or Access Code(s), you agree that you will be liable for all transactions arising from use of the Card or Access Code(s) by such person except as otherwise set forth in this Agreement. In all cases, our liability for an unauthorized transaction is limited to reimbursing you for the face amount of the unauthorized transaction and any corresponding fees, except as otherwise required by applicable law. A transaction is unauthorized if it is not initiated by you, you did not give permission to make the transaction or you do not benefit from the transaction in any way.

16. Our Liability for Failure to Complete Transactions

In no event will Bank or Servicer be liable for consequential damages (including lost profits), extraordinary damages, special or punitive damages. Neither Bank nor Servicer will be liable, for instance: (1) if, through no fault of Servicer or of the Bank, you do not have enough funds available in your Account to complete the transaction; (2) if a merchant refuses to accept your Card or provide cash back; (3) if an ATM where you are making a cash withdrawal does not have enough cash; (4) if an electronic terminal where you are making a transaction does not operate properly, and you knew about the problem when you initiated the transaction; (5) if access to your Card has been blocked after you reported your Card lost or stolen; (6) if there is a hold or your funds are subject to legal process or other encumbrance restricting their use; (7) if Servicer or the Bank has reason to believe the requested transaction is unauthorized; (8) if circumstances beyond Servicer or the Bank's control (such as fire, flood or computer or communication failure) prevent the completion of the transaction, despite reasonable precautions that Servicer or the Bank has taken; or (9) any other exception stated in this Agreement with you.

17. Arbitration

This Section 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.

Definitions: As used in this Arbitration Section, the term "Claim" means any claim, dispute or controversy between you and Bank, Servicer or any of their agents or retailers, arising from or relating to the Card or this Agreement as well as any related or prior agreement that you may have had with us or the relationships resulting from this Agreement, including the validity, enforceability or scope of this Arbitration Section or the 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 Card, or the Cards of any additional cardholders designated by you; (ii) the amount of available funds on the Cards; (iii) advertisements, promotions or oral or written statements related to the Cards, goods or services purchased with the Cards; (iv) the benefits and services related to the Cards; and/or (v) your enrollment for any Card. 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; any appeals from that court shall be pursued only in arbitration. As used in this Arbitration Section, the terms "we" and "us" shall for all purposes mean the Bank, Servicer, their respective wholly or majority owned subsidiaries, affiliates, licensees, predecessors, successors, and assigns, and all of their agents, employees, directors and representatives. In addition, "we" or "us" shall include any third party using or providing any product, service or benefit in connection with any Cards (including, but not limited to merchants who accept the Card, third parties who use or provide services, debt collectors and all of their agents, employees, directors and representatives) if, and only if, such third party is named as a co-party with us (or files a Claim with or against us) in connection with a Claim asserted by you. As solely used in this Arbitration Section, the terms "you" or "yours" shall mean all persons or entities approved by us to have and/or use a Card, including but not limited to all persons or entities contractually obligated under any of the Agreements and all additional cardholders.

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 at; and (ii) AAA at 335 Madison Avenue, New York, NY 10017; website at


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.

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.

Arbitration Procedures: This Arbitration Section 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 Section 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 fifteen (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 twenty (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 thirty (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 one hundred twenty (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.

Continuation: This Arbitration Section shall survive termination of your Card as well as voluntary payment of the debt in full by you, any legal proceeding by us to collect a debt owed by you, and any bankruptcy by you or us. If any portion of this Arbitration Section 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 Section, the Agreement or any prior agreement you may have had with us, each of which shall be enforceable regardless of such invalidity.

18. User Information and Feedback

We may permit you to submit information related to you in order for us and our partners to provide you with the services contemplated herein (“User Content”). By submitting to us User Content, you grant us, our affiliates and financial partners a perpetual, irrevocable, royalty-free, worldwide, sublicensable and transferable license to copy, publish, translate, modify, reformat, create derivative works from, distribute, reproduce, sell, display, transmit, publish, broadcast, host, archive, store, cache, use or otherwise exploit all or any portion of the User Content, in any commercial or noncommercial manner whatsoever, for any purposes that complies with applicable law with or without attribution and without further notice to you. Neither you, nor any other person or entity, will have the right to (i) receive any royalty or consideration of any kind for the use of the User Content pursuant to the terms herein or (ii) inspect or approve the editorial copy or other material that may be used in connection with the User Content.

You may choose to or we may invite you to submit comments or ideas about our services or the services we may make available to you, including without limitation about how to improve the such services or our products (“Ideas”). By submitting any Idea, you agree that your disclosure is gratuitous, unsolicited and without restriction and will not place us under any fiduciary or other obligation, and that we are free to use the Idea without any compensation to you, use the Idea without providing you consideration of any kind for the use of the Idea, and/or to disclose the Idea on a non-confidential basis or otherwise to anyone. You further acknowledge that, by acceptance of your submission, we do not waive any rights to use similar or related ideas previously known to us, or developed by its employees, or obtained from sources other than you.

19. Miscellaneous

The Bank may disclose information to third parties about your Card or the transactions you make using your Card: (1) where it is necessary for completing transactions; (2) in order to verify the existence and condition of your Card for a third party, such as a merchant; (3) in order to comply with government agency, court order, or other legal reporting requirements; (4) if you give the Bank your written permission; (5) to our and the Bank's employees, auditors, affiliates, service providers, or attorneys as needed; (6) in order to collect funds you may owe us; and (7) as otherwise provided in the Bank's Privacy Policy Notice [].

The Card and your obligations under this Agreement may not be assigned. The Bank may transfer its rights under this Agreement. Use of the Card is subject to all applicable rules and customs of any clearinghouse or other association involved in transactions. The Bank does not waive its rights by delaying or failing to exercise them at any time. If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law, or regulation of any governmental agency, local, state, or federal, the validity or enforceability of any other provision of this Agreement shall not be affected. This Agreement will be governed by the law of the State of New York except to the extent governed by federal law.

The terms and conditions of this Agreement may be revised by posting a revised version here You will be notified of any change in the manner provided by applicable law prior to the effective date of the change. However, if the change is made for security purposes, the Bank or Servicer can implement such change without prior notice. We may cancel or suspend the Card or this Agreement at any time. You may cancel this Agreement by returning the Card to the Bank or Servicer. Your termination of this Agreement will not affect any of the Bank's or Servicer's rights or your obligations arising under this Agreement prior to termination. In the event your Card is cancelled, closed or terminated for any reason, any remaining available funds associated with the Account will be returned to you, subject to any contrary provision in this Agreement and applicable law.

By providing us with a telephone number for a mobile phone or other wireless device, including a number that you later convert to a cellular number, you are expressly consenting to receiving communications, including but not limited to prerecorded or artificial voice message calls, text messages, and calls made by an automatic telephone dialing system, from us and our affiliates and agents at that number. This express consent applies to each such telephone number that you provide to us now or in the future and permits such calls for non-marketing purposes. Calls and messages may incur access fees from your cellular provider.

Appendix 1


Cogni Prepaid Debit Visa Card Fee Schedule

This Fee schedule is being provided in connection with the Cogni Prepaid Debit Visa Card issued by Community Federal Savings Bank and managed by Cogni Inc., and contains a list of all fees known to these entities that may be charged for your Account or Card. We reserve the right to change the following Fee schedule in our sole discretion and we will provide written notification to you of such change to the extent required by applicable law.

List of all fees for Cogni Prepaid Debit Card

Get started
All feesAmountDetails
Card purchase fee$0
Monthly usage
All feesAmountDetails
Monthly fee$0
Add money
All feesAmountDetails
Direct deposit$0
ACH transfer$0It is free to add money via the ACH network into your Cogni account from one of your accounts held at another Financial Institution within the US.
Check scan$0It is free to add money to your Cogni account using the remote deposit capture feature within the Cogni mobile app.
Cash reloadVaries from
$2.00 to $6.00
When reloading your card at Visa ReadyLink locations, fees vary by retailer. These fees, set by retailers, are subject to change without notice. We do not charge fees for this. Visa ReadyLink locations may be found here: Visa ReadyLink Locator.
Spend money
All feesAmountDetails
ACH transfer$0It is free to send money via the ACH network from your Cogni account to an account held at another Financial Institution within the US.
Check payment$0A check payment request is only supported from within the Cogni mobile app. Each check payment request is fulfilled through our processor. There is no fee for this service.
Get cash
All feesAmountDetails
ATM withdrawal (in-network)$0“In-network” refers to the Allpoint ATM Network. Locations can be found here:Allpoint ATM Locator.
ATM withdrawal (out-of-network)$2.50“Out-of-network” refers to all the ATMs outside of the Allpoint ATM Network. This is our fee. You may also be charged a fee by the ATM operator, even if you do not complete a transaction.
All feesAmountDetails
Customer service (automated)$0There is no fee for calling our automated Member Services automated system, including for balance inquiries.
Customer service (live agent)$0There is no fee for calling our Member Services team.
ATM balance inquiry (in-network)$0“In-network” refers to the Allpoint ATM Network. Locations can be found here:Allpoint ATM Locator.
ATM balance inquiry (out-of-network)$0“Out-of-network” refers to all the ATMs outside of the Allpoint ATM Network. You may be charged a fee by the ATM operator.
Using your card outside the U.S.
All feesAmountDetails
International transaction$0There are no fees when using your card for purchases outside of the U.S.
International ATM withdrawal (in-network)$0“In-network” refers to the Allpoint ATM Network. Locations can be found here:Allpoint ATM Locator.
International ATM withdrawal (out-of-network)$2.50“Out-of-network” refers to all the ATMs outside of the Allpoint ATM Network. This is our fee. You may also be charged a fee by the ATM operator, even if you do not complete a transaction.
International ATM balance inquiry (in-network)$0“In-network” refers to the Allpoint ATM Network. Locations can be found here:Allpoint ATM Locator.
International ATM balance inquiry (out-of-network)$0“Out-of-network” refers to all the ATMs outside of the Allpoint ATM Network. This is our fee. You may be charged a fee by the ATM operator.
All feesAmountDetails
Inactivity$0There is no fee for inactivity. However, as per the cardholder agreement, Cogni has the right to close an account due to inactivity after a predetermined length of time.
Paper Statement$5.00This fee is per statement. This fee includes the printing and secure mailing of the paper statement.
Replacement Card$5.00This applies to replacement of damaged cards. The first two card replacements are free; the 3rd replacement card begins incurring the fee.
Returned Deposited Check fee$25.00This fee is per returned check that was attempted to be deposited into Cogni. This is incurred if the check is rejected. This may be due to an invalid check, insufficient funds, etc.

Register your card for FDIC insurance eligibility and other protections. Your funds will be held at or transferred to Community Federal Savings Bank, an FDIC-insured institution. Once there, your funds are insured up to $250,000 by the FDIC in the event Community Federal Savings Bank fails, if specific deposit insurance requirements are met and your card is registered. See for details.

No overdraft/credit feature.

Contact Cogni by calling 1-833-264-6447, or visit

For general information about prepaid accounts, visit
If you have a complaint about a prepaid account, call the Consumer Financial Protection Bureau at 1-855-411-2372 or visit

Appendix 2

Transaction Limits

Maximum Amount / Limit
Funds OUTMinimum AmountPer transactionDailyRolling 30-day
Send a Check$0.01$2,500.00NoneNone
Cogni-to-Cogni Transfer (Sender)$0.01$3,000.00$3,000.00$3,000.00
Point-of-Sale Purchases$0.01$5,000.00$5,000.00$10,000.00
ATM Withdrawal$5.00$500.00$500.00$5,000.00
Wire Transfer (FedWire)Transaction Type Not Supported
Maximum Amount / Limit
Funds INMinimum AmountPer transactionDailyRolling 30-day
Cogni-to-Cogni Transfer (Recipient)$0.01$3,000.00$3,000.00$3,000.00
Visa ReadyLink (Cash Load)$20.00$1,000.00$1,000.00$5,000.00
Mobile Check Deposit$0.01$2,500.00$2,500.00$5,000.00
Wire Transfer (FedWire)Transaction Type Not Supported
ATM DepositTransaction Type Not Supported
Minimum AmountMaximum Amount / Limit
Total Account Value$0.00$100,000.00

Privacy Policy

Last Updated: [November 4, 2019]

Who we are:

Cogni, Inc. ("Cogni," "we", "our", or "us") is a financial services company. When you use our services, you'll share some information with us that could be used to identify you or that is associated with information that identifies you ("Personal Information"). Our goal is to clearly inform you about the information we collect, how we use it, and whom we share it with. This Privacy Policy applies to Personal Information that we gather or collect via our website or our app (collectively, the "Services"). It does not apply to any Personal Information collected by third party websites not operated by us.

You may also email us at with any privacy-related questions you have.

The information we collect:

There are three basic categories of information we collect:

Personal Information you provide to us

We may collect Personal Information that you choose to share with us. For example, when you set up an account, we need to collect important details about you, such as your name, phone number, date of birth, unique username, location, social security number, and email address. We may also collect any communications between you and Company and any other information you provide to Company. To help the government fight the funding of terrorism and money laundering activities, we obtain, verify and record information about beneficial owners, including you, of Clients and other permitted users of Services. This means that when you access or use our Services, we may ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see other identifying documents, such as a driver's license. If, for any reason, you are unable to provide the information necessary to verify your identity, you are not permitted to access or use the Services. Please ensure that you only send us an image of yourself. Do not include any images of others.

Automatically-collected data

We, and our third-party partners, collect certain Personal Information automatically when you visit our online services, read our e-mails, access or use our Services, or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and other technology (collectively, "Tracking Technologies").

We, and our third-party partners, use these Tracking Technologies and other tools to automatically collect usage and device information, such as:

Do Not Track Signals. We are unable to respond to Do Not Track signals set by your browser at this time. If you would prefer not to accept cookies, most browsers will allow you to (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies and these browser settings that block cookies may have no effect on such techniques. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about - including how to manage privacy and storage settings for Flash cookies - on Adobe's website. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.

Information we get from third parties

We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.

How we use your information:

To provide the Services, we may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

For internal business purposes, we may use Personal Information for its internal business purposes, including to:

For marketing purposes, we may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:

Non-personal Information

We may also use non-personally identifiable information that does not personally identify you, including by aggregating and/or de-identifying Personal Information, in order to understand better how our visitors use the Services, research our visitors' demographics, interests, and behavior, improve the Services, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use non-personally identifiable information in any manner permitted by law. When any non-personally identifiable information is combined with other information that identifies you, it will be treated as Personal Information in accordance with this Privacy Policy.

Sharing of your Personal Information:

We may share your Personal Information in the instances described below.

Third party tracking and online advertising:

We may participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history or other information. We may share or we may permit third-party services to collect information about your use of our website over time so that they may play or display ads on our website, online platform or in connection with our Service, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

We may use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We may share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site "How Google uses data when you use our partners' sites or apps" located at You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Ad-On here

Please review the section title 'Your choices' below to understanding your choices regarding third party tacking and online advertising.

How long we keep your information:

We will retain your information for as long as you use our Services, to resolve disputes, establish legal defenses, conduct audits, enforce our agreements, comply with applicable laws or as long as we otherwise deem appropriate. We also maintain your Personal Information as part of our standard backup procedures.

Links to Other's Sites and Services:

Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them, we do not endorse, approve or make any representations about third-party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.

Social Media:

Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.

How we store and protect your Personal Information:

Data storage and transfer: Your information collected through our Service may be stored and processed in the United States or any other country in which Company or its parent, subsidiaries, affiliates, or service providers maintain facilities or otherwise stores information. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. In addition, information collected about you may be stored on the block chain or using cloud-based services. Information recorded on the block chain or information stored in the cloud may be maintained by third-party networks in locations in which such third-party networks operate or maintain data storage or processing facilities.

Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Your choices:

If you no longer want to receive email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. You will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding us and you will not be able to opt out of those communications (e.g., communications regarding updates to our Privacy Policy).

We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.

Cookies and Flash cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.

Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services on our Service may not work properly.

Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe's website. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.

Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative's online resources at and/or the DAA's resources at

Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI's and DAA's online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). You may also be able to opt-out of some - but not all - interest-based ads served by mobile ad networks by visiting and downloading the mobile AppChoices app.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Changes to this Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the 'last updated' date at the top of this page. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.

Other Rights and Important Information:

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, please let us know by contacting us at If we learn that we have collected any personal information from children under 13, we will use commercially-reasonable efforts to delete such information.

California "Shine the Light" Law

If you are a user of the Services and a California resident, California's "Shine the Light" law (California Civil Code §1798.83) permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your personal information (if any) to third parties for direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing in compliance with the below section (Contact Us).

Contact Us:

If you have any questions about this Privacy Policy or the Service, please contact us at

California Privacy Notice

Last Updated: [November 6, 2019]

Scope of Disclosures

This California Privacy Notice (the "CA Disclosures") supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ("consumers" or "you").

These CA Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined the CCPA.

Personal Information Disclosures

When we use the term "personal information" in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, personal information does not include:

Collection and Use of Personal Information

We collect various categories of Personal Information in connection with our Services. Please review the Privacy Policy, including the 'Information we collect' section, to learn more about the personal information we collect.

In the last 12 months, we have collected the following categories of personal information:

Category of Personal Information CollectedCollectedCategories of Sources
Identifiers, such as your name, address, phone number, email address, date of birth or other similar identifiers.
  • Directly from you
  • Your browser or device
California Customer Records (Cal. Civ. Code § 1798.80(e))
  • Directly from you
  • Your browser or device
Protected Classification Characteristics
Commercial Information
Biometric Information
Internet/Network Information
  • Your browser or device
Geolocation Data
  • Your browser
Sensory Information
Profession/Employment Information
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information

Purposes for Collecting Personal Information

We collect personal information from and about you for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to 'How we use your information' and 'The information we collect' in our Privacy Statement.

Disclosure of Personal Information and Recipients of Personal Information

We do not sell personal information and will not sell personal information unless we provide proper notice to consumers and, in the case of personal information collected prior to that notice, we obtain explicit consent for the sale of personal information relating to those individuals we previously interacted with.

As described in our Privacy Policy, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;

  • The categories of personal information we have collected about you;

  • The categories of sources of the personal information;

  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and

  • The business or commercial purposes for collecting or selling the personal information.

The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

How to Exercise Your California Consumer Rights

To exercise your Right to Know and/or your Right to Deletion, please submit a request by:

We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Right to Opt Out of Personal Information Sales

Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at

At this time, we do not sell your Personal Information.

Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [insert email] to inform us if you, or your minor child, are under the age of 16.

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to

Alternatively, inquiries may be addressed to:

Cogni, Inc.
175 Varick Street,
New York, New York 10014

E-Sign Disclosure and Consent


This E-Sign Disclosure and Consent (the "Consent") allows Cogni, Inc. and Community Federal Savings Bank (collectively, "our," "us" or "we") to provide each applicant, account owner and anyone else with access to the account (individually and collectively with any other account owner, "you" or "your") with communications electronically. "Communication" means each application, agreement, disclosure, notice, fee schedule, response to claims, statement, privacy policy, record, document and other information related to your account or to any Service, or that you sign, submit or agree to at our request.

Certain laws and regulations require us to provide communications, including notices and disclosures, to you "in writing," which means you may be entitled to receive the information on paper. With your consent, the E-SIGN Act allows us to provide you communications electronically and to conduct transactions with you electronically.

Please read this Consent carefully prior to providing us with your consent. This Consent describes how we deliver and receive communications to and from you electronically, and asks you to consent to use electronic records and signatures in our relationship with you. If you do not agree to this Consent or you later withdraw your consent provided herein, you may not be able to continue to use our services or Services, including, but not limited to, the Cogni Prepaid Visa Card and any associated account (collectively, the "Service").

Scope of this Consent.

This Consent applies to all Communications and Services. By applying for or using a Service, you agree that any Communications will be provided in electronic format, to the extent allowed by law, and that paper Communications will not be sent. Your consent to receive electronic Communications and transactions includes, but is not limited to, all legal and regulatory disclosures and communications associated with the Service; any Service terms, including any amendments thereto, and any and all agreements by and between you and us that relate to a Service; privacy policies and notices; responses to claims filed in connection with a Service; account statements; and all other communications between us and your concerning the Service and any related transactions, Services or services.

This Consent will remain effective until expressly withdrawn by you or terminated by us. We reserve the right, at our sole discretion, to discontinue the provision of electronic Communications, or to terminate or change the terms and conditions upon which electronic Communications are provided. We will provide you with notice of any such termination or change as required by law.

Electronic Delivery of Communications.

All Communications that we provide in electronic form will be provided either by e-mail, by access to our website designated in a notice from us, through the any mobile application we may make available to you, to the extent permitted by law, by access to a website generally designated in advance for such purpose, or in the manner specified in any other agreement we or our affiliates have with you.

All Communications in electronic format from us to you will be considered "in writing." You should print or download a copy of this Consent and any other Communications for your records.

This Consent will apply to any new service or account you may seek to procure or obtain from us. We may remind you that you have already consented to receiving electronic Communications and using electronic signatures in your relationship with us. Continuing to use our Services after receiving updates to our system requirements signifies your acceptance of the change and reaffirmation of your consent.

Keeping your Records Current.

It is your responsibility to provide us with a true, accurate and complete e-mail address, street address, and other information related to this Consent and a Service, and to maintain and update promptly any changes in this information. You can update information (such as your e-mail address) by using the mobile application we may make available to you. We are not responsible for any delay or failure in the receipt of the Communications due to you not providing us with true, accurate or complete information.

System Requirements for Accessing Communications.

In order to access, view, and retain electronic Communications that we make available, you must have:

Requesting Paper Copies.

We will not send paper copies 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 or by requesting that we mail a paper copy. To request a paper copy, call us at 1-833-264-6447 during normal business hours, except for national holidays. There may be a fee associated with the request for the delivery of paper copies of any Communication provided electronically pursuant to this Consent.

Withdrawing Your Consent.

You may withdraw your consent to receive Communications in electronic form at any time by contacting us using the mobile application we make available to you. If you do withdraw your consent, we will terminate access to any Product and close your card account, except where prohibited by law. We will not impose any fee to process the withdrawal of your consent to receive electronic Communications. Any withdrawal of your consent to receive electronic Communications will be effective only after we have a reasonable period of time to process your request for withdrawal. In the meantime, you will continue to receive Communications in electronic form. If you withdraw your consent, the legal validity and enforceability of prior Communications delivered in electronic form will not be affected.


By applying for or using a Service or by checking any call to action (including "Submit" or similar language), you: (i) are agreeing to all terms and conditions set forth in this Consent, (ii) are voluntarily and affirmatively authorizing Communications in electronic form as set forth herein, (iii) are confirming that you meet the system requirements described above, (iv) have demonstrated your ability to receive, retain, and view electronic documents on your mobile device, and (v) have an active and valid email address.

* By tapping Accept, I confirm that I have read and agree to the Cogni Terms and Conditions and the Cogni Privacy Policy, and give my consent to the Electronic delivery of all Cogni related documents, disclosures and notifications.