Customer Identification Program (CIP) Notice

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This requirement is part of the USA PATRIOT Act and is administered by the Financial Crimes Enforcement Network (FinCEN). Refundo, Inc. is subject to customer identification requirements under applicable FinCEN regulations.

Refundo, Inc. maintains a Customer Identification Program (CIP) as required by federal law. When you open an account or request a financial product, we are required to verify your identity. This notice is provided at or before account opening.

Information We Will Collect

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

●      Your full legal name

●      Your residential or business address (P.O. Boxes alone are not sufficient)

●      For individuals: Your date of birth

●      For business entities: Formation documents and beneficial ownership information as required by law

●      Your Taxpayer Identification Number (Social Security Number or Employer Identification Number)

The information and documentation we require may vary based on the type of account and assessed risk level.

How We Verify Your Identity

To verify your identity, Refundo may use one or more of the following methods:

●      Documentary methods, such as agovernment-issued photo ID (e.g., driver’s license, passport, or state ID), orbusiness formation documents for entity accounts.

●      Non-documentary methods, such aschecking third-party databases, credit header information, public records, orcontacting you directly.

●      Verification against government lists for sanctions screening and compliance purposes.

Record Retention

We will retain records of the information and methods used to verify your identity for five years after the account is closed, or as required by applicable law.

Additional Requirements and Account Delays

Refundo may request additional documentation or information as needed to complete identity verification. We reserve the right to delay or refuse to open an account if we are unable to verify your identity or if required by applicable law or regulation.

Privacy and Data Protection

Your information will be used and protected in accordance with Refundo’s Privacy Policy.

Questions or Concerns

If you have any questions or complaints regarding this notice, please contact us at 908-445-5544 or email us at hello@refundo.com.

This notice is provided in compliance with federal regulations and law.

CIP Notice Version 1.1 | Effective 2/2/2026