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Clasp Privacy Policy

Last updated: April 1, 2026

I. Purpose

This Privacy Policy (the “Policy”) describes how Clasp Group Inc., along with its subsidiaries and affiliates (collectively, “Clasp”) collects, receives and shares information about users and visitors to our services (“you”) from our website and any online communications we may have with you. This Privacy Policy, together with our Terms of Use govern your use of our website and our collection and use of your information.

BY USING THE SITE, YOU AGREE TO THE COLLECTION AND USE OF INFORMATION IN ACCORDANCE WITH THIS POLICY.

II. Clasp’s business

Clasp provides employer-sponsored student loan repayment and education finance services. We operate as a technology platform connecting employers, employees, and educational institutions to facilitate education benefit programs and related financial services.

Clasp uses Dwolla, Inc. (“Dwolla”) to provide payment processing services, including ACH transfers. By creating an account and using our payment features, you agree to Dwolla’s Privacy Policy and Terms of Service. Clasp shares limited personal information with Dwolla as necessary to process payments, verify identity, and meet applicable compliance obligations (including AML/KYC requirements).

III. How we collect your information on this website

Clasp collects the following information from students and other visitors to our website:

  • Information you provide on our website such as contact information, school affiliation or feedback.
  • Basic traffic information about your visit such as IP address, host name and pages on our site visited.
  • Application information such as name, contact information, requested funding amount, social security number, income, and credit history.
  • Existing loan information such as existing balances and loan servicer information.
  • Identity verification information, including date of birth and government-issued identification, collected as necessary for KYC/AML compliance.
  • Payment information necessary to facilitate ACH transfers, including bank account and routing numbers, which are processed through Dwolla. See Section VI (Payments) below.

We may use third-party financial data aggregation services to collect information from financial institutions on your behalf, as necessary to provide our services. Your use of any such service is subject to that provider’s privacy policy, which will be disclosed to you at the point of connection.

We do not collect personally identifiable information from website visitors who do not voluntarily submit such information. However, information collected from prior visits could be associated with personally identifiable information if you later submit such information to us.

If you create an account on our website, we will collect information from you, including:

  • Name
  • Email Address
  • Phone Number
  • Educational Institution
  • Program of Study or Major
  • Graduation Date
  • Requested Funding Amount

By using our site and voluntarily submitting such information, you consent to Clasp sharing your information as described in this Policy, including with service providers, banking partners, and other third parties necessary to provide our services.

We use data security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.

IV. Our use of cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our site.

Some browsers transmit Do Not Track (“DNT”) signals. Our services do not currently respond to DNT signals. If our practices change, we will update this Policy accordingly.

V. Our use of Log Data

Like many site operators, we collect information that your browser sends whenever you visit our site (“Log Data”).

This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this log data.

VI. Payments

Clasp uses Dwolla to facilitate ACH-based payment processing. To use our payment features, you must create a Dwolla account and agree to Dwolla’s Terms of Service and Privacy Policy. Any personal information you provide in connection with payment processing is subject to Dwolla’s Privacy Policy in addition to this Policy.

We share the following categories of information with Dwolla as necessary to provide payment services:

  • Identity information (name, date of birth, address, government ID) for identity verification and KYC/AML compliance;
  • Bank account and routing numbers to initiate and settle ACH transfers;
  • Transaction information (payment amounts, dates, and status) for payment execution and reconciliation.

For ACH authorization terms, timing, return policies, and E-SIGN disclosures, please review our Terms of Service.

VII. How we use information collected from visitors to this website

We use information collected from website visitors to improve the content and browsing experience of our website, to provide information regarding our products to you, and respond to you. We do not sell your personal information. Clasp may disclose information collected from website visitors to:

  • Trusted services providers who work on our behalf, who do not have independent use of the information we disclose to them, and who have agreed to adhere to the rules set forth in the privacy statement.
  • Third party service providers and/or joint marketing partners to allow us to make other marketing offers that we think may be of interest to you.
  • Third parties as required by law, such as to comply with a subpoena or similar legal process. Third parties as we deem necessary, based on our good faith belief, (i) to protect our rights, your safety or the safety of others, (ii) to investigate fraud, or (iii) to respond to a government request.
  • Third parties in conjunction with a merger, acquisition or sale of Clasp.
  • Our banking partner(s) who facilitate loan origination and servicing, to the extent necessary to provide those services to you.

We may use third-party analytics services that collect information about your visits to our website using cookies and similar tracking technologies. You may opt out of such tracking through your browser settings or industry opt-out tools such as the Network Advertising Initiative opt-out page.

VIII. Children and Privacy

This website is not intended for use by children. If you are under 18, you may use this website only with the involvement of a parent or guardian. If you are a parent or guardian and believe that we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to support@clasp.com.

IX. Opt-out

You may choose to opt-out of receiving unrequested communications by clicking “unsubscribe” on a given communication or by emailing support@clasp.com.

X. Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, administrative, and technical safeguards to protect the information we collect and maintain. If you notice a vulnerability, please let us know by emailing support@clasp.com.

In the event of a data security incident that may affect your personal information, we will notify you and take steps consistent with applicable law.

XI. Your Consent

By using our website, you consent to the collection, processing and storage of information as described in this Policy. Processing activities may take place in the United States. If you reside outside of the United States, your information may be transferred to, and processed and stored in, the United States or other jurisdictions in accordance with applicable law in that jurisdiction. If you do not agree to these terms, do not use this website.

XII. Your Choices

Some jurisdictions may give you a right to make choices regarding your personal information, such as deletion of your personal information. Clasp will comply with applicable law. We will not discriminate against individuals who exercise their privacy rights under applicable law.

To submit a privacy inquiry or request, please contact us at privacy@clasp.com. We will respond consistent with our legal obligations and the nature of your request.

XIII. Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@clasp.com.

XIV. Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy or as required by law. Our general retention practices are as follows:

  • Account and profile data: retained for the life of your account plus a limited period thereafter to allow for account reactivation and to resolve any post-closure disputes.
  • Payment, transaction, and identity verification (KYC) records: retained for approximately 5–7 years, or as required under applicable law including NACHA rules and applicable anti-money laundering requirements. Proof of ACH authorizations is retained for a minimum of 2 years in accordance with NACHA rules.
  • Diagnostic and analytics data: retained for shorter periods, after which it is deleted or de-identified.

When retention periods end, we delete or de-identify personal information consistent with our internal policies and applicable law.

XV. Third-Party Sites and Services

Our website and services may contain links to third-party websites, applications, or services. Those third-party sites and services are governed by their own privacy policies; we do not control and are not responsible for their privacy practices or content. When you connect a financial account through our services, you authorize our account aggregation provider to access and transmit certain account information to us to provide the service; your use of that provider is also subject to its own privacy policy, which will be made available to you at the point of connection.

XVI. Adjustments to the Policy

This Privacy Policy is effective as of April 1, 2026, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. If we make updates to this Privacy Policy, we will update the Policy with the changes and revise the “Last Updated” date posted at the top of this Privacy Policy.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the website after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.