Straddle Bridge Services

Latest Revision: September 10, 2026

1. Straddle Bridge Services.

These terms (“Straddle Bridge Terms”) supplement the General Terms and govern your use of the Straddle Bridge Services and Bridge Data.

2. Use of the Straddle Bridge Services.

2.1 Usage limitations and restrictions

You may only use Straddle Bridge and Data in conjunction with the Straddle Payment Services

2.2 Express Consents and Record Keeping.

Straddle must clearly and conspicuously disclose to each Bridge End User the data you are receiving, and the Authorized Purpose to which they are consenting in their Consent. During the Term and for at least 24 months after the end of the Term, Straddle shall maintain records of each Bridge End User’s Express Consent.

2.3 Updates to Express Consents.

(a) If you received an Express Consent from an End User and you later materially change your Authorized Purpose, you must obtain a new Express Consent that covers the updated Authorized Purpose.

(b) If your Authorized Purpose includes your receipt of Bridge Data, and you later materially change the scope, purpose, security, sharing or period of storage of that data, you must obtain a new Express Consent before those changes go into effect.

(c) Straddle presents the Express Consent for its own collection, use, retention and disclosure of Bridge Data as an independent controller under Section 3.5 of these Straddle Bridge Terms at the time of each Payment. Where Straddle materially changes the scope, purpose, security, sharing or period of storage of that data, the updated Express Consent and the updated Straddle Privacy Policy apply from the date they are first presented, and apply only to Bridge Data collected on or after that date.

Straddle does not share Bridge End User login credentials with your application. You must not request or obtain Bridge End User login credentials for a Bridge End User’s financial account outside of the Straddle UI.

2.5 Marks Usage.

In addition to the license you grant to Straddle in Section 7.3 of the General Terms, you grant to Straddle and its Affiliates a worldwide, non-exclusive, non-transferable, royalty-free license during the Term to (a) use Marks belonging to you or your Affiliates to identify you to the Bridge End User as a recipient of the Straddle Bridge Services; and (b) sublicense those Marks to Data Sources.

3. Bridge Data.

Your obligations under this Section 3 will continue after the Term, and this Section 3 will survive termination of this Agreement.

3.1 Receiving Bridge Data.

You will not receive Bridge Data outside of available balance and last 4 digits of account number by default.

You may request to receive Bridge Data as part of the Straddle Bridge Services. Access may or not be granted after an Information Security Review.

This default limits the Bridge Data that Straddle provides to you. It does not limit Straddle's own collection, use and retention of Bridge Data as an independent controller under Section 3.5 of these Straddle Bridge Terms, which is described in the Straddle Privacy Policy.

When you stop using Straddle Payments Services, you may request that Straddle provide to you the account and routing number of each Bridge End User’s financial account used to process transactions made via the ACH Network as part of your use of Straddle Payments Services.

3.2 Your Service Providers.

You may only share Bridge Data with your service providers (a) whose agreement with you imposes on that service provider obligations consistent with those contained in these Straddle Bridge Terms and Section 9 of the General Terms; and (b) for the purpose of providing services to you that implement the Authorized Purpose. You are responsible for your service providers’ acts and omissions, including their compliance with this Agreement.

3.3 Using Bridge Data.

You must not, and must not enable or allow any third party to:

(a) use a Bridge End User’s Bridge Data in any way if you have not obtained an appropriate Express Consent from the applicable Bridge End User;

(b) sell any Bridge Data;

(c) share the Bridge Data, including with any third party for use in marketing or for the third party’s marketing purposes; or

(d) use or transfer the Bridge Data for fraudulent purposes or otherwise in violation of Law.

3.4 FCRA Compliance.

Straddle is not a consumer reporting agency as defined in the FCRA. Except as Straddle’s authorized representative approves, you must not use any Bridge Data (a) in any way as a consumer report; or (b) to generate a consumer report under FCRA.

3.5 Straddle as a Service Provider and Independent Controller.

Straddle, and any third party Straddle engages, will act as your processor (e.g., service provider) for the purposes of facilitating your access to Bridge Data. In addition, Straddle will request, through the Straddle Bridge Services, consent from Bridge End Users for Straddle to separately collect, use, retain, disclose and process Bridge Data as an independent controller of that data under the Straddle’s Privacy Policy.

3.6 Data Security Requirements.

You must comply with the Nacha Data Security Requirements with respect to your collection, use or disclosure of any Bridge Data or Bank Account information, and those terms are considered Financial Services Terms for the purposes of this Agreement.

3.7 Bridge End User Notifications.

If Straddle wishes to send a notice to Bridge End Users (e.g., because Straddle believes that Law requires a data subject notification, or because Straddle modifies its legal terms that apply to Bridge End Users, including its Privacy Policy), then upon Straddle’s request, you must promptly provide Bridge End Users’ contact information (including email addresses) to Straddle.

4. Cooperation and Audit.

4.1 End User Rights.

If a Bridge End User informs you that it seeks to exercise its End User Rights related to the Straddle Bridge Services, you must notify Straddle no later than 5 days after you become aware. You must assist Straddle as necessary in addressing the End User request, including by providing the Bridge End User with access to and deleting their Bridge Data in your and your service providers’ possession, or control.

4.2 Providing Records to Straddle and Data Sources.

You must provide information that Straddle requests for the purpose of ensuring that you comply with, and use Bridge Data in compliance with, these Straddle Bridge Terms, the General Terms, Law and any Data Source requirements, including:

(a) Express Consents and other Bridge End User records;

(b) information describing how you process Bridge Data;

(d) information describing your industry, business activities, licensing and regulatory standing; and

(e) information about complaints or issues that Bridge End Users have raised to Straddle or a Data Source.

4.3 Straddle May Provide Data to Data Sources.

To comply with Straddle’s obligations to Data Sources, Straddle may (a) provide the following to Data Sources: (i) your name; (ii) any Bridge End User’s name associated with that Data Source; (iii) all Express Consents and related records; (iv) all other information you provided to Straddle under this Section 4; and (b) with your reasonable cooperation, obtain and verify the information required under this Section 4.3 onsite at your premises. If you control any Bridge End User data covered by rules implementing Section 1033 of the Consumer Financial Protection Act of 2010, then upon Straddle’s reasonable request, you will enter into an agreement with Straddle to enable Straddle and its Data Sources to access and use that Bridge End User data for uses approved by the End User.

4.4 Responses.

You must respond to Straddle’s requests for information under Section 4.2 of these Straddle Bridge Terms no later than 14 days after Straddle’s request. Straddle may suspend or terminate your access to the Straddle Bridge Services immediately if you fail to timely provide this information to Straddle.

4.5 Survival.

This Section 4 will survive termination of this Agreement.

5. Representation and Warranty.

You represent as of the Effective Date, and warrant at all times during the Term, that (a) each Express Consent complies with your applicable terms of use, your Privacy Policy, Law and this Agreement; and (b) you collect, use, retain, disclose and process each Bridge End User’s Bridge Data only in compliance with that Bridge End User’s Express Consent.

Nacha Authorization Requirements

Straddle Identity Services