IMPORTANT – Please read carefully and retain this Account Agreement for your records.
Your account(s) is issued and operated by Cheese. If you have any questions about this notice, please contact us at firstname.lastname@example.org
Terms and Conditions/Definitions
This Account Agreement (the “Agreement”) contains the rules that govern, where appropriate, your account(s) and card(s) with Cheese Financial, Inc. (the “Cheese,” “we,” or “us”).
The funds in your account(s) with Cheese are - held at Coastal Community Bank (“CCB” or “Bank”), an FDIC insured depository institution. Your cheese card is issued by Coastal Community Bank, pursuant to license by Mastercard International. - -
The words “you” and “your” mean each account owner and anyone else with authority to deposit, withdraw, or exercise control over an account. If there is more than one owner, then these words mean each account owner separately, and all account owners jointly.
An “owner” is one who has the power to deal with an account in his, her or its own name.
An “agent,” in contrast, is one whose power to withdraw from an account comes from, or is on behalf of, the owners. Authorized signers, attorneys-in-fact, and convenience signers are examples of agents.
“Personal accounts” are accounts in the names of natural persons (individuals). They are to be distinguished from “non-personal accounts” which are accounts in the name of corporations, partnerships, trusts and other entities.
“Deposit Account” means any -cheese account opened with Cheese.
“Card” means the Cheese MasterCard debit card which is issued by CCB in the name of the Cardholder for carrying out of all Card Transactions from an account held with Cheese, as provided for in these Account Agreement Terms and Conditions.
“Cardholder” means the person in whose name an Account has been opened and in whose name a Card is issued
“Card Transactions” means any payment made for goods or services, cash withdrawals from a bank or financial institution (including ATM withdrawals) or transfer of funds made through the use of the Card or the Card number
“Financial Service” means a Deposit Account, overdraft credit account, Bill Payment service, Funds Transfer service, or any other financial product or service available through Cheese.
Unless it would be inconsistent to do so, words and phrases used in this Agreement should be construed so that the singular includes the plural and the plural includes the singular.
Consent to Terms and Conditions and Modifications
We may amend or change any terms of this Agreement or any account disclosures and documents provided to you. Notice of the amendment or change will be provided to you as required under applicable law.
If at any time the terms, conditions or fees associated with your account are not acceptable to you, you may terminate this Agreement by closing your account after paying any fees or charges owed to us. We may cancel or suspend your account, debit card, or other account services or this Agreement at any time.
For purposes of these disclosures, our business days are Monday through Friday, unless stated otherwise. Federal holidays are not included.
Waivers and Precedents
Any waiver by Cheese must be approved by an authorized representative of Cheese or the Bank. If a waiver is approved by us, we are not obligated to provide similar waivers in the future.
Identification Notice (USA PATRIOT ACT)
To help the government fight the funding of terrorism and money laundering, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
This means that when you open an account or use our services, we may ask for your name, physical 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 driver’s license or other documents that validate your identity.
Even if you have been an existing customer of ours, we may ask you to provide this kind of information and documentation because we may not have collected it from you in the past or we may need to update our records.
If, for any reason, any owner is unable to provide the information necessary to verify their identity, your account(s) may be blocked or closed, which may result in additional fees assessed to the account(s).
You are responsible for the accuracy and completeness of all information supplied to us in connection with your account and/or account services and for keeping your personal data with us updated if you move or otherwise make changes to your personal data.
General Terms and Conditions
Who Can Use the Service
Only individuals 18 years of age or older who can form a legally binding contract can use our Services. We may impose other restrictions as well.
An account opened for personal use cannot be used for business purposes. If your personal account is identified as being used as a business account, business-related transactions will be reversed, your account privileges will be suspended, and your account may be closed if business related activities continue.
Overview of Cheese Services
Cheese offers a zero-fee debit card powered with cashback, saving bonus, and cool user-friendly experiences. Cheese aims to improve the banking experiences for consumers who wish to experience simple but powerful features all within their mobile application. Users can manage their spending and rewards, while monitoring debit card balances. More importantly, Cheese promotes the financial well-being of our consumers by simplifying the banking process through content creation and knowledge sharing. Some services may not be immediately available and will be made available to consumers at Cheese’s discretion.
Coastal Community Bank
Cheese will provide you with any and all notifications as well as all customer support related to your Account.
Please contact us if you have any questions at email@example.com.
You agree to maintain a positive balance and will not incur overdrafts. If you manage your account in such a way that it results in a negative balance or becomes overdrawn, you agree to rectify the matter by transferring sufficient funds from your linked external account to pay the overdrawn balance. Your failure to bring your account to a positive balance could result in the temporary or permanent suspension of your Account and services. Further consequences may be enacted if you do not remedy the situation in a timely manner and may include: (1) freezing your account until the negative balance is rectified; (2) the reporting of your negative balance to a reporting agency; and/or (3) legal action.
We will disclose information about your account or the transactions you make to third parties:
- When it is necessary to complete transactions;
- To verify the existence and standing of your account with us upon the request of a third party, such as a credit bureau or merchant;
- In accordance with your written permission;
- In order to comply with court, governmental, or administrative agency summonses, subpoenas or orders; and
- On receipt of certification from a federal agency or department that a request for information is in compliance with the Right to Financial Privacy Act of 1978.
If you wish to close your account with us, you agree to withdraw all of the funds from your account and we may require you to notify us of this intention in writing. After an Account is closed, we have no obligation to accept deposits or pay outstanding items but may do so at our discretion. You agree to hold us harmless for refusing to honor any item on a closed account. If funds remain in the account after you have notified us of your intent to close your account, we will require you to submit your request to us in writing and we will return any remaining funds to your linked external account. All related closing fees will be deducted from the final balance.
If you have moved outside of the United States or have frequent international transactions, you may be contacted about the international activity in your account and for further verification of your address. If you are moving, traveling, or will be temporarily residing overseas, we recommend you contact us to prevent any disruption in your account activity. Your account may be closed if you no longer reside in the United States.
Inactive and Dormant Accounts
We may consider a Deposit Account to be “inactive” after a period of no owner-initiated activity defined as 120 days. After a period of “inactive” status, we may consider a Deposit Account to be “dormant”, at which time it will be closed.
If the account becomes inactive or dormant, the account will continue to be subject to any service charges in accordance with our schedule of fees. If an account becomes inactive, we will notify you with specific instructions on how to restore the account to an active status without the need to make any transactions.
Death or Incompetence
You or your appointed party, designee, or appointed individual agree to notify us promptly if any agent or person with signatory rights on your account dies or becomes legally incompetent or incapacitated. We may continue to honor any items submitted until (a) we know of the fact of death or of a legal determination of incompetence or incapacitation and (b) we have had a reasonable opportunity to act on that knowledge. You agree that, even if we have knowledge of death of an agent or person with signatory rights, we may pay on items drawn on or before the date of death for up to 10 days after that date, unless ordered to stop payment by someone claiming an interest in the account. We may require additional documentation to confirm any claims made on the account.
Levies, Garnishments, and Other Legal Processes
If your account becomes subject to legal action, such as a tax levy or third-party garnishment, we reserve the right to refuse to pay any money from your account, including checks or other items presented for payment, until the action is resolved. If we are required to pay an attachment, garnishment or tax levy, we are not liable to you. Payment is made after satisfying any fees, charges or other debts owed to us. You agree that you are responsible for any expenses, including legal expenses and fees we incur due to a garnishment, levy or attachment on your account. We may charge these expenses to your account. Until we receive the appropriate court documents, we may continue to process transactions against your account, even if we have received an unofficial notification of an adverse claim. You will indemnify us for any losses if we do this.
Withdrawals from Accounts
Unless otherwise indicated by us, anyone who is listed as an account owner, or is assigned Power of Attorney privileges may withdraw or transfer all or any part of the account balance at any time on forms approved by us or with your debit card, through Bill Pay, or other available services.
We reserve the right to refuse any withdrawal or transfer request that is attempted by any method not specifically permitted or that exceeds any frequency or monetary limitations. Even if we honor a nonconforming request or allow a transaction or transaction(s) to overdraw your account, repeated abuse of the stated limitations, or regularly overdrawing your account, may force us to close the account. We will use the date a transaction is completed by us (as opposed to the day you initiated it) to apply the frequency limitations.
Deposits to Accounts
All items deposited will be handled by us as agent for you. All checks submitted for deposit must be made payable to you. We do not accept cash. We do not accept third-party checks. We do not accept deposits in foreign funds or checks drawn on banks outside the United States. We reserve the right to reject a deposit if it is made payable to Cheese or Coastal Community Bank and contains no other information that might assist us in identifying the account to which it should be deposited. We reserve the right to refuse any other type of deposit if we believe it is fraudulent, will not be paid, it is not made payable to you, or is otherwise suspicious in nature. We will not be held liable if such action causes outstanding items to be dishonored and returned, or payment orders to be rejected. Refused deposits will be returned to you.
Automated Clearing House Deposit
We do not accept cash deposits. Please do not send cash deposits through the mail. In the event that a cash deposits is received for your Account, you agree that Cheese’s determination of the amount of the deposit will be final. We are not liable for any deposits, including cash, lost in the mail, lost in transit, or not received by us.
You may initiate direct deposits by providing your employer or government benefits administration with our Routing Number, 125109019, and your 12-digit Account number, which can be found by logging in to the Cheese App. If we deposit any amount into your account which should have been returned to the Federal Government for any reason, you authorize us to deduct the amount of our liability to the Federal Government from your account or from any other account you have with us, without prior notice and at any time, except as prohibited by law. We may also use any other legal remedy to recover the amount of our liability.
If a direct deposit posts to your account and is later found to be made payable to someone other than yourself or another account owner listed in our records, the amount of the deposit will be deducted from your account and returned to the originator without prior notice to you.
If offered by Cheese, checks sent via mobile deposit shall not be considered to have been received by us until we have received the valid electronic check image file. Limits to the number of mobile deposits permitted and the amount of funds that can be deposited are imposed for security reasons. For this purpose, we may not readily disclose those limits to you.
You agree to properly endorse all items captured and submitted using the Mobile Deposit Service. This should include a signature(s) from the named payee(s). It is also required that you write “For Cheese Mobile Deposit Only.” You agree, after you submit an item for deposit using the mobile deposit service, you will not redeposit, otherwise transfer, or negotiate the original item.
All deposits will be credited to your account in accordance with our Funds Availability Schedule.
Deposited Items Returned
If final payment is not received on any item you deposited to your account, or if any direct deposit, ACH deposit or Electronic Fund Transfer to your account is returned to us for any reason, you agree to pay us the amount of the return.
We may charge any account of which you are an owner or re-present any item you deposit with us that is returned to us unpaid without prior notice to you. We may charge a fee for returned deposited items in accordance with our Schedule of Fees.
You authorize us to attempt collection of previously returned items that you deposited. In our attempts to collect these items, you agree that we may allow the payor bank (the bank on which the item is drawn) to hold the item beyond its midnight deadline. If an item you deposit is returned unpaid, you waive the requirement for notice of this return.
If a claim is made on any item subsequent to final payment on the grounds that the item was altered, bears a forged or unauthorized endorsement, or was not otherwise properly payable, we may withhold credit for the item from your account until final determination of the claim. In addition, we will not be liable for a check, draft or other item that you deposit that has been forged or altered in such a way that a reasonable person could not discover the forgery.
Funds Availability Policy
Information contained in this section is to assist you in understanding our Funds Availability Policy. - Cheese does not accept in-person or mailed deposits.
It is our policy to review each deposit and determine how the funds are being deposited. We make the funds available to you according to the deposit type and when the funds are applied to your account. Some deposit types may not be available for immediate use. When we delay the availability of funds or place a hold on a deposit made to your account, you may not withdraw those funds, and we will not use them to pay bills or other debits, such as ACH withdrawals or wire transfers, during the hold period.
We reserve the right to refuse any deposit. If final payment is not received on any item you deposited to your account, or if any direct deposit, ACH deposit or Electronic Fund Transfer to your account is returned to us for any reason, you agree to pay us the amount of the return, plus any fee in accordance with our schedule of fees.
The length of delay in the availability of funds varies depending on the type of deposit. Special rules may apply to new accounts.
The length of delay in the availability of funds is counted in business days from the day your deposit is applied to your account. Deposits received after 5:00 PM (CST) will be considered to be received on the next business.
Funds from wire transfers, transfers between Cheese accounts, preauthorized electronic payments such as payroll direct deposits, or other preauthorized electronic payments will be available on the day the deposit is applied to your account.
Funds from Customer-initiated electronic payments or transfers will be applied to the account when Cheese has verified the external account and received payment in collected funds. Once the funds are applied to your account, they will have same-day availability.
Your deposit will be available no sooner than the fourth business day after we receive the check.
Funds you deposit by check may be delayed for a longer time period based on our review of the check and your account history. They will generally be available no later than the seventh business day after the day of your deposit.
If you need to be sure when a particular deposit will be available for withdrawal, you can verify the availability of your deposit by viewing the transaction detail on your Cheese mobile app or contact us.
Special Rules for New Accounts
Special rules apply during the first 30 days of any new account you open with Cheese:
- Funds from wire transfers or ACH direct deposits will be available on the same business day after the deposit is applied to your account.
- All check deposits may be held for an extended period of time but no longer then nine business days after deposit is received.
Electronic Fund Transfer (“EFTs”) Disclosures
We offer account services that may be considered “Electronic Fund Transfers,” including, but not limited to, ATM transactions; ACH transactions, including, but not limited to, direct deposits and pre-authorized withdrawals; and online transfers. This disclosure (as required by Federal Regulation E: Electronic Fund Transfer Act) provides information that describes your rights and responsibilities regarding these services. The Electronic Fund Transfer services are services that we can provide, assuming that you specifically request and arrange them and qualify for the service.
You must activate your Card in accordance with the instructions provided with your Card before it can be used. You will need to provide your personal and card information in order to verify your identity and activate your card. You must sign the signature strip on the back of the card as soon as it’s received.
ATM and Debit Card Transactions
Consistent with applicable law, you may use your debit card with your signature or PIN to perform most routine transactions on the accounts that are accessible by your debit card, such as to:
- Make cash withdrawals
- Obtain your most recently available account balance
- Pay for purchases at places that have agreed to accept the card
Some of the above services may not be available at all ATMs or locations.
Authorized Card Users
You are responsible for all authorized transactions initiated and fees incurred by use of your card. If you permit another person to have access to your card or card number, we will treat this as if you have 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.
International ATM Transactions
International transactions made using your debit card will be converted to U.S. currency according to the rules and regulations of the card network. The conversion of the currency to U.S. currency may occur on a date other than your original transaction date and fees may be assessed by these networks. You are responsible for the U.S. currency amount plus any fees assessed for the currency conversion. Some services may not be available at international ATM terminals. International ATM transactions may be subject to a fee in accordance with our Schedule of Fees.
Your Cheese debit card does not permit deposits at ATMs.
Debit Card Point-of-Sale Transactions
You may use your debit card to purchase goods and services and/or obtain cash where permitted by the merchant, from any merchant who accepts MasterCard®. The merchant may require your signature instead of your PIN to authorize the purchase request. You may also use your debit card with your PIN at any merchant location where ATM cards are accepted to purchase goods, services, and/or obtain cash where permitted by the merchant. The amount of all purchases, including any cash obtained, will be deducted from your Cheese account. When you make a purchase through the Card network, we may place a hold on the funds in your Cheese account in the amount that may be necessary to cover the amount of the transaction. (Please see Preauthorization Holds for additional information.)
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 prior to swiping your card, the card transaction is likely to be declined.
Transactions Using Your Card Number
If you initiate a transaction without presenting your Card (such as for mail order, internet or telephone purchase, a Prefunded Check purchase or an ACH debit purchase), the legal effect will be the same as if you used the Card itself.
Limitations on Frequency of Debit Card Transactions and Cash Withdrawal Limits
Frequency-of-use limitations are imposed on card transactions for security reasons and for the protection of your account. They are not disclosed for this reason and may be changed at any time. You will be denied the use of your card if:
- You exceed the daily ATM withdrawal or purchase limit;
- You do not have sufficient available funds in your account;
- You do not enter your correct PIN; or
- You exceed the limit on the number of times you can use your card each day.
The receipt provided by the ATM or merchant terminal will notify you of the denial. There is a limit on the number of such denials permitted, beyond which the machine may retain your card. The number of attempts that will cause the retention of your card is also not disclosed for security reasons.
You may not withdraw more than $500.00 cash at an ATM and during a POS purchase, or purchase more than $5,000 worth of goods or services on any calendar day.
When your debit card or other network enhancement feature related to the card is used at a point-of-sale location to obtain goods or services or obtain cash, the merchant may attempt to obtain preauthorization from us for the transaction. We may place a hold on your account for the amount of the preauthorization request for a duration based on the vendor type. This can range from 2 days to 30 days and may vary in some cases from the amount of the actual purchase, depending on the merchant’s request. If the preauthorization request varies from the amount of the actual transaction, payment of the transaction may not remove the hold, which will remain on the account until the end of the hold period. This hold may affect the availability of funds from your Cheese account to pay checks or for other Electronic Fund Transfers. We will not be responsible for damages for wrongful dishonor of any items that are not paid because of the hold.
Preauthorized (ACH) Debits or Credits
You may arrange to have certain recurring payments automatically deposited (credited) to your account. Examples of this service include the direct deposit of Social Security and other government payments, and the direct deposit of your payroll. If you have arranged to have direct deposits made to your account at least one every sixty (60) days from the same person or company, you can verify the availability of your deposit by viewing the transaction details on your Cheese mobile app or contacting us.
You may arrange to have certain recurring withdrawals automatically paid (debited) from your account. For example, you may arrange to have insurance premiums paid automatically.
These preauthorized transfers are governed by federal regulations pertaining to Electronic Fund Transfer services that entitle you to certain protections. Requests for these services must be authorized by you, in writing, to the Originator of the transaction prior to becoming effective.
Right to Stop Preauthorized Electronic Transfers (ACH)
If you want to permanently revoke an ACH you authorized from a third party, you will need to first send written instructions to the originating third party to cancel your ACH transfer.
If you have authorized regular payments out of your account, you can stop any of these payments by notifying Customer Service by telephone or email. If you notify us by telephone, you may be required to confirm the information provided by writing to us at firstname.lastname@example.org
Your request must include your account number, the name of the payee, the amount of the item to be stopped, and the date payment was scheduled to be made. This request needs to be received by us three (3) or more business days before the payment is scheduled to be made. If your request is by telephone or email, we may also require you to put your request in writing and ensure that it is received by us within 14 days after your call or email.
You are subject to the general rules of Stop-Payment Orders in this Agreement.
Stop Payment Liability
If you request that we stop payment on any preauthorized transfer according to the requirements above and we fail to do so, we will be liable for your proven loss or damages, unless:
- You failed to give us enough information, proper instructions or sufficient time to act on the stop payment; or
- We do not receive written confirmation of your telephone or email request to stop payment within 14 calendar days, and the preauthorized transfer occurs after the 14 calendar days.
In any case, we will only be liable for actual proven damages if the failure to stop payment on your transaction resulted from an error on our part, despite our procedures to avoid such errors. If we pay a preauthorized transfer despite your valid and timely stop order request, we may re-credit your account. If we do this, you will sign a statement describing the dispute with the payee. You agree to transfer to us all of your rights against the payee. In addition, you will assist us in any legal action taken against the payee.
Additionally, if you want to permanently revoke a recurring preauthorized electronic transfer, you will need to first send written instructions to the originating third party to cancel your preauthorized transfer. We may ask you to provide us with a copy of your letter to the originating third party and sign an Affidavit revoking authorization.
Our Liability for Failure to Complete an Electronic Fund Transfer
If we fail to complete an Electronic Fund Transfer transaction on time or in the correct amount when properly instructed by you, we will be liable for damages caused by our failure unless:
- There aren’t sufficient funds in your account to complete the transaction through no fault of ours.
- The funds in your account aren’t available at the time the EFT posts to your account.
- The funds in your account are subject to legal process;
- The ATM system has insufficient cash to complete the transaction;
- Your card has been reported lost or stolen and you are using the reported card;
- We have a reason to believe that the transaction requested is unauthorized;
- The failure is due to an equipment breakdown that you knew about when you started the transaction at an ATM or merchant terminal;
- You attempt to complete a transaction at an ATM or merchant terminal that is not a permissible transaction listed above; or
- The transaction would exceed security limitations on the use of your debit card.
In any case, we will only be liable for actual proven damages if the failure to make the transaction resulted from an honest error despite our procedures to avoid such errors.
Tell us immediately if you believe your debit card and/or PIN has been lost or stolen, or if you believe that an electronic fund transfer has been made without your permission. Contacting us by phone or email is the best way to keep your potential losses down. You could lose all the money in your account!
If you tell us within 2 business days after you learn of the loss or theft of your debit card and/or PIN, you can lose no more than $50 if someone used your debit card and/or PIN without your permission.
If you do NOT tell us within 2 business days after you learn of the loss or theft of your debit card and/or PIN, and we can prove we could have stopped someone from using your debit card and/or PIN without your permission if you had told us, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, including those made by card, code or other means, tell us at once. If you do not tell us within 60 days after your account statement is made available to you, you may not get back any money you lost after the 60 days, if we can prove that we could have stopped someone from taking the money if you had told us in time. If extenuating circumstances kept you from telling us, we may extend the time periods at our sole discretion.
You may be required to confirm the information provided over phone or email in writing. In these cases, we will advise you accordingly, provide you the necessary forms for confirming your dispute in writing, and give you instructions for sending us the signed form.
Errors or Questions and How to Contact Us
In case of errors or questions about your Electronic Fund Transfers, you agree to promptly contact Customer Service by telephone 1-866-657-8863 or by email at email@example.com. You may be required to confirm the information in writing within 10 business days. In these cases, we will advise you accordingly, provide you the necessary forms for confirming your dispute in writing, and give you instructions for sending us the signed form.
If you believe an Electronic Fund Transfer transaction was processed in error or was unauthorized, or if you need more information about a transfer listed on your statement or receipt, you must contact Cheese no later than 60 days after the problem or error first appeared on your statement.
In your communication with us, please provide the following information:
- The account name, account number, and last four digits of the debit card number, if applicable;
- A description of the suspected error or the transfer about which you are unsure, why you believe there is an error, or why you need more information;
- The dollar amount of the suspected error; and
- The date of the suspected error.
When we receive your dispute notification, we will advise you of the status of our investigation within 10 business days. In all cases, we will correct any error promptly.
If we need more time to investigate your question or complaint, we may take up to 45 calendar days for ATM transactions (other than international transactions) and ACH transactions. For errors involving new accounts within 30 calendar days after the first deposit, point-of-sale transactions or foreign-initiated transactions, we may take up to 90 calendar days to investigate your complaint or question. If this is necessary, we will provisionally credit your account for the amount you believe is in error within 10 business days of your original complaint or question, so that you will have the use of the money during the time it takes us to complete our investigation. If we do not receive your written confirmation of your questions or complaint within 10 business days, we may decide not to provisionally credit your account.
For errors involving new accounts, point-of-sale, or foreign-initiated transactions, we may take up to 90 calendar days to investigate your complaint or question. For new accounts, we may take up to 20 business days to credit your account for the amount you think is in error.
We will send you a written explanation within three (3) business days after we finish our investigation. You may ask for copies of the documents we used in our investigation. If provisional credit was given and it is determined that there was no error, you must repay to us the amount of the provisional credit for the disputed item(s). You will have access to those funds for five (5) business days, and then we may deduct such amounts from your account without further notice.
Debit Card Revocation
You agree that your debit card remains the property of Coastal Community Bank and shall be surrendered upon demand. The card is non-transferable, and it may be canceled, reposed, or revoked at any time without prior notice subject to applicable law.
If you do not use your debit card for an extended period, defined by Cheese as 90 days, or we believe the card may be lost/stolen or is being used improperly, it may be canceled for security reasons and will be unusable. This may occur without prior notice to you.
If your card is reissued or reactivated, we may charge you a fee for its reissue/replacement in accordance with our schedule of fees.
Fees and Charges
You will pay any applicable fees and charges we assess for your Card services and/or other electronic services that you select. Applicable fees will be deducted from your account and listed on your account statement. These charges and fees are assessed in accordance with our schedule of fees.
You may be charged a foreign transaction fee for point-of-sale purchases made internationally. The terminal owner may also charge you a fee for use of their ATM. You may, however, be assessed a fee by the card association, for example, MasterCard, for using your Card at an ATM or making a point-of-sale purchase.
PIN, Passwords, and Passcodes
You will be prompted to assign a 4-digit card PIN for your Cheese debit card during card activation. You may change the PIN at any time by accessing the card PIN change process through the mobile app.
Password and Passcode
You will be prompted to establish a password (Login Credentials) during your Cheese enrollment. Depending on your app settings, you may be required to enter your full password for subsequent logins to the Cheese mobile app to view your account(s), card information, and other Cheese services. Your Cheese password may be changed at any time after you’ve signed into your app session and following the steps for resetting your Password, available in Settings. We at Cheese encourage all customers to secure their Cheese application using advanced security (e.g. facial recognition).
Your Login Credentials and PIN are identification methods that are both personal and confidential. You are required to use your PIN with your debit card at an ATM or POS merchant terminal. It is a security method by which we help you maintain the security of your account. Your Login Credentials are another security method that maintains the security of your account and the transactions you process through the mobile app.
Therefore, you agree to take all reasonable precautions to protect the confidentiality of your Login Credentials, PIN and/or other access devices. Further, you agree that you will not reveal your Login Credentials, PIN, or any other access device information, to any person not authorized by you to use your debit card; not write your PIN or Login Credentials on your card or on any item kept with your debit card; and not leave your mobile or other device unattended after you have logged on using your Login Credentials.
Funds Transfer Service
“Funds Transfer” is an electronic transfer service provided by Cheese and powered by Coastal Community Bank that enables you to securely transfer funds from an account at another financial institution to your account with us, and/or from your account with us to an account at another financial institution. Prior to use, you are required to register your external bank account for verification and security purposes. Once your Funds Transfer service is active, please refer to the Funds Availability schedule to see when your Funds will be available for your use in your account. In all cases, funds may be held until we receive verification that the transaction has settled.
By using the Funds Transfer service, you agree that the Bank will transfer funds through ACH services and that the transaction is subject to completion upon our final review and verification. You agree that such requests constitute authorization for such transfers. This authorization is to remain in full force until the Bank has received written notification from you of its termination, you have electronically deleted a registered bank account or credit card from the Funds Transfer service, or you have electronically canceled an account and/or transfers from the Funds Transfer service in such time and in such manner as to afford the Bank and the other financial institution a reasonable opportunity to act on it.
This service may be subject to a fee in accordance with our schedule of fees. This service may not be available for all customers and/or account types. Please review our Funds Transfer FAQs for information on availability.
By using the Funds Transfer service, you are certifying that the registered external accounts that you transfer funds to and from, and the debit or credit cards used to transfer from are under the same ownership as the account with us. In the event that the accounts are not titled the same or ownership among the transferring accounts changes, you will indemnify us for any losses incurred as a result of any transaction you initiate between these accounts that is later returned or is reported unauthorized. If you initiate a transfer that is found to be unverifiable or is unable to be completed for other reasons, you agree to hold us harmless for any loss resulting from the incomplete transfer. If a transfer is made from a third-party’s account or registered as an external deposit account, before we detect it, we may without notice to you, place those funds on hold and debit your account, and return the funds to the third party’s account in the form of a bank check or funds transfer, once we have confirmed the funds cleared the external account.
If you use the Funds Transfer service to transfer funds to or from an account that has multiple owners, you agree that each owner authorizes the others to (a) initiate the transfer of funds between your accounts with us, as permitted by the Funds Transfer service, (b) register any external bank account or credit card, as permitted by the Funds Transfer service, and (c) initiate the transfer of funds between your account(s) with us and any registered external bank account or credit card. This authority will cease only after we have received and have been given a reasonable amount of time to act on the appropriate documentation needed to change or remove the owner from the account. Each account owner agrees to be jointly and severally liable to Cheese for any losses incurred as a result of the improper use of this service up to and including the transfer amount, any applicable fees and any legal expenses. Your Funds Transfer request will only be completed if you have sufficient funds in the account from which you wish to transfer funds and the accounts are linked for transfer capabilities. Funds Transfer transactions are subject to dollar amount limitations, which are determined by us and may be set according to your Account type and/or the type of Funds Transfer service you are using. These limitations are set for security reasons and are not disclosed for that reason.
Cheese reserves the right to limit the number of external accounts that can be linked to your account for purposes of transferring funds; to limit functionality of the Funds Transfer service by imposing limits, holds, or other measures; and to close your account if unlawful activity is found or suspected.
Truth in Savings
Opening Deposit and Balance Requirements:
There is no minimum opening deposit requirement to open a Cheese Account. There are no maintenance fees on Cheese Accounts.
Fees are charged in accordance with our fees outlined below. If we assess a fee for any other service or make a change to our Schedule of Fees and Charges, we will let you know in advance.
To the extent you access our Services through a mobile device, your wireless service carrier’s charges, data rates, and other fees may apply.
Schedule of Fees and Charges
ATM Transaction Fee – MoneyPass Network
No Charge *surcharge fees may be applied by the ATM owner
ATM Transaction Fee – Non MoneyPass Network (Domestic)
No Charge *surcharge fees may be applied by the ATM owner
Bill Pay Services
Card Replacement Fee
$5.00, after first replacement
Deposit Item Returned
International ATM Withdrawal Fee
International Debit Transaction Fee
Returned Item Fee
Stop Payment Fee
Deposited Check Return
Rights to Setoff
If you owe us any amount, you give us a security interest in your Cheese Account. You also give us the right, to the extent not prohibited by law, to set off against your funds to pay the amount owed to us. You agree that the security interest you have given us is consensual and is in addition to our right of set off. If we exercise our right of set off, we will notify you to the extent required by law.
If any provision of these Terms is found unenforceable, then that provision will be severed from these Terms and not affect the validity and enforceability of any remaining provisions.
If an arbitrator or court finds any provision to be invalid, you and we agree that the arbitrator or court should give valid effect to the intention of that provision, and that the remainder of the Terms remain in full force and effect.
Cheese wants to hear your comments, concerns, suggestions, or questions. Email us at firstname.lastname@example.org.
1. Consent to Electronic Communication
We would like to communicate with you using electronic means. When you click or tap the “I Agree” button below, this tells us:
- You agree to receive any electronic communication from us for any purpose;
- You agree to receive an electronic version of any written notice or disclosures we must send you under law (“Legal Disclosures”); and
- You understand that to receive Legal Disclosures, you must meet the requirements in Section 2 below.
When we send electronic communication, including a Legal Disclosure, it may come in the form of an update to our website or within our app; as an email, text, or communication on social media; as a notification on mobile, tablet, or wearable devices; or through other electronic means. When you sign-up for an Account with Cheese, we will request your mobile telephone number. We request this information in order to send you security confirmation text messages and information about your Account and our Services. By clicking or tapping the “I agree” button below, you are telling Cheese that you consent and agree to accept and receive communications from us, including via e-mail, text message, calls and push notification to the mobile telephone number you provide us. As part of this consent, Cheese, or someone on our behalf, may send you communications generated by automatic telephone dialing systems [and/or deliver prerecorded messages] that includes (i) security confirmation messages; (ii) communications about your Account (such as transfers you requested or received), (iii) communications about use and updates to our Services, and (iv) other information concerning your Account and our Services. Cheese does not charge you when we communicate with you via text message, but your phone carrier will apply standard text messaging charges and data rates.
2. Technology Requirements
In order to receive electronic communications, including Legal Disclosures, you must have:
- A computer or mobile device, iPhone SE (1st generation) or newer, with an internet connection.
- iPhone versions iOS 13
- A web browser that includes 128-bit encryption, with cookies enabled.
- A valid email address and phone number.
- Sufficient storage space to save any Legal Disclosure or an installed printer to print them.
- We may change these requirements, but we will notify you promptly of any material changes.
- The ability to view and retain Portable Document Format (PDF) files.
3. Paper Versions
If you would like a paper copy of any Legal Disclosure we send you, please contact us as email@example.com and we will mail one to you at no cost.
4. Withdrawing Consent
If you would like to withdraw your consent, you can tell us at any time by emailing firstname.lastname@example.org. Once you do withdraw your consent, we will no longer send you paper copies of any Legal Disclosure. Also, please be aware that once you withdraw consent, we may – but are not obligated to – cancel your account with us.
5. Saving and Reviewing this Consent
The Terms & Conditions can be printed and saved for your records.
EFFECTIVE ON NOVEMBER 2020
2. Business Review
3. Glossary of Terms
4. ODFI Relationship
6. ACH Access/Segregation of Duties
10. Exposure Limits
The purpose of this policy is to establish guidelines by which Cheese Financial, Inc. (“Cheese”) and its employees can monitor and control risk related to Automated Clearing House (“ACH”) activities while operating in compliance with all appropriate regulatory requirements. This policy specifically addresses ACH related activities associated with Cheese’s products and services.
2. Business Review
Cheese is a Zero-fee debit card powered with cashback, saving bonus, and cool user-friendly experiences. Cheese aim to improve the banking experiences for consumers who wish to experience simple but powerful features all within their mobile application. Users can manage their spending and rewards, while monitoring debit card balances with the backing with FDIC. More importantly, Cheese promotes the financial well-being of our consumers by simplifying banking process through content creation and knowledge sharing.
Customer’s Cheese Spend Account > Galileo
Galileo > Originating Depository Financial Institution (ODFI) (Electronic File)
Cheese FBO > Originating Depository Financial Institution (ODFI) (Funds Movement)
Originating Depository Financial Institution (ODFI) > Fed Reserve
Fed Reserve > Receiving Depository Financial Institution (RDFI)
Customer’s External Account > External Bank (ODFI)
External Bank (ODFI) > Fed Reserve
Fed Reserve > Receiving Depository Financial Institution (RDFI)
Receiving Depository Financial Institution (RDFI) > Cheese FBO (Funds Movement)
Receiving Depository Financial Institution (RDFI) > Galileo (Cheese Customer) (Electronic File)
3. Glossary of Terms
“Automated Clearing House” (ACH) – an electronic funds transfer system governed by rules and regulations established by NACHA (National Automated Clearing House Association) and the Federal Reserve.
“Notification of Change” (NOC) – a non-monetary entry transmitted by RDFI for the purpose of identifying incorrect information contained within an entry and providing correct data to be used on future entries.
“Originating Depository Financial Institution” (ODFI) – a participating financial institution that receives the payment instructions from Originators or Third-Party Senders and forwards the entries to the ACH Operator.
“Originator Agreement” – written agreement between ODFI and Originator or Third-Party Sender (on behalf of Originator)
“Originator” – person/entity that has authorized ODFI (directly or through Third Party Sender) to transmit, for the account of that person, an ACH entry to the Receiver’s account at the Receiving Depository Financial Institution.
“Receiver” – a person that has authorized an Originator to initiate an ACH entry to the Receiver’s account with the Receiving Depository Financial Institution.
“Receiving Depository Financial Institution” (RDFI) – a participating financial institution that receives ACH entries from the ACH Operator and posts them to the accounts of its depositors (Receivers). “Return Entry” – a credit or debit entry initiated by an RDFI that returns a previously originated credit or debit entry to the ODFI within the time frames established by NACHA Rules.
“Reversing Entry” – a credit or debit entry that reverses an Erroneous entry within the time frames established by NACHA Rules.
“Reversing File” – a file that reverses all entries in an erroneous entry within the time frames established by NACHA Rules.
“Settlement Date” – the day on which settlement occurs and actual exchange of funds.
“Third Party Sender” (TPS) – organization that performs any functions on behalf of the Originator related to the processing of entries. TPS acts as intermediary between Originator and ODFI and there is no contractual agreement between Originator and ODFI.
4. ODFI Relationship
Coastal Community Bank (“CCB”) shall act as the ODFI and shall perform the ACH functions on behalf of Cheese. An agreement shall be in place between CCB and Cheese as well as Cheese and Galileo to establish this relationship and outline the duties and responsibilities of each party. Cheese shall act as the Originator and intermediary between customer and the ODFI and shall be responsible for communicating with the customer regarding the ACH process.
Cheese has a third-party vendor (Galileo) that transmits files via SFTP, with credentials provided by CCB (ODFI). Files are stored on Galileo's servers and moved to CCB (ODFI) at predetermined times on a daily basis.
6. ACH Access/Segregation of Duties
Cheese shall ensure that the ACH process contains the appropriate system access to provide limited access to ACH files, and that duties are also segregated in order to reduce risk level.
ACH file Access – ACH transactions are initiated by Cheese’s customers via the Cheese application and transmitted to Galileo via API. Galileo will create the appropriate ACH files and securely transmit to CCB. Only those employees within Galileo that support the ACH process will have access to the files. Files are then sent to the Federal Reserve by CCB through the prescribed delivery methods. Cheese does not currently have access to ACH files.
Duties – ACH file creation and movement duties are outlined above. Reconciliation duties will be supported by Galileo, CCB and Cheese.
Cheese shall provide training to all personnel involved with the ACH process related to Cheese. Training will include a review of the relationship between all parties and the segregation of duties internally for control purposes, as well as a review of NACHA Rules as it relates to Cheese’s business.
Cheese’s online registration requires customers to read and accept the ACH Authorization Agreement. Cheese captures the date the account was established (which is also the date of acceptance of the Agreement) as part of their audit trail. A customer must accept the Agreement before being able to establish an account.
ACH Origination: Cheese will only move funds from their customer’s account if they are clear and available. Cheese will place a hold on originated debits to minimize the risk of losses due to returns. Returns for “unauthorized” or “stopped payment” can still occur and are monitored carefully in order to evaluate risk. If a return is received, Cheese will work with their issuing bank partner to determine next steps.
ACH Receipt: Cheese will credit or debit customers on the effective date of the received ACH transaction. If funds are called back by the ODFI, Cheese will work with their issuing bank partner to request a “letter of indemnity” before returning available funds.
Following the list of Return Codes is new rule affecting new return rate levels required as of September 15, 2015:
R02 - Account Closed- A previously active account has been closed by action of the customer or the RDFI.
R03 - No Account/Unable to Locate Account – account structure is valid and passes editing process, but does not correspond to individual or is not an open account (this can also be because the account type is wrong)
R04 - Invalid Account Number Structure- The account number structure is not valid. The Entry may fail the check digit validation or may contain an incorrect number of digits.
R05 - Unauthorized Debit to Consumer Account Using Corporate SEC Code - CCD or CTX debit Entry was Transmitted to a Consumer Account of the Receiver and was not authorized by the Receiver.
R06 - Returned per ODFI’s Request- The ODFI has requested that the RDFI return an Erroneous Entry, or a credit Entry originated without the authorization of the Originator,
R07 - Authorization Revoked by Customer – consumer, who previously authorized ACH payment, has revoked authorization from Originator (must be returned no later than 60 days from settlement date and customer must sign affidavit).
R08 - Payment Stopped – Receiver has stopped payment on one or more ACH debit entries. (RDFI should verify the Receiver's intent when a request for stop payment is made to insure this is not intended to be a revocation of authorization).
R10 - Customer Advises Not Authorized, Improper or Ineligible - customer has notified RDFI that Originator of transaction is not authorized to debit account (must be returned no later than 60 days from settlement date of original entry and customer must sign affidavit).
R15 - Beneficiary or Account Holder Deceased- (1) The beneficiary is deceased; or (2) the account holder is deceased.
R16 - Account Frozen – funds unavailable due to specific action by the RDFI or by legal action or OFAC has instructed the RDFI to return entry.
R24 - Duplicate Entry – RDFI has received what appears to be a duplicate entry (i.e., trace number, date, dollar amount and/or other data matches another transaction).
R29 - Corporate Customer Advises Not Authorized- The RDFI has been notified by the Receiver (Non-Consumer) that a specific Entry has not been authorized by the receiver.
Return files are reviewed by Operations and IT and reviewed with Cheese’s issuing bank partner as needed. The highlighted return codes above are reviewed carefully for each file for customer follow up and to ensure there were no fraudulent activities associated with the original transactions.
Return Rate Levels (Rule effective September 18, 2015)
1. Reducing the Unauthorized Return Rate Threshold
All Participants: NACHA expects all ACH Network participants to benefit from the reduction of the return rate threshold for unauthorized debit entries.
ODFIs: ODFIs should already have monitoring in place regarding their Originators and Third-Party Senders unauthorized debit return rates.
Originators and Third-Party Senders: Originators and Third-Party Senders with unauthorized debit return rates above the new threshold may be required by their ODFIs, and, in the case of some Originators, their Third-Party Senders, to take action to reduce their return rate, and will incur costs in doing so.
Unauthorized Return Rate Threshold
• This rule reduces the return rate threshold for unauthorized debit entries from 1.0 percent to 0.5 percent. All other aspects of the Rules regarding the Unauthorized Return Rate Threshold remain the same.
Return codes included in the Unauthorized Return Rate Threshold
• The Unauthorized Return Rate Threshold covers Return Reason Codes R05, R07, R10, R29 and R51 (N/A).
SEC Codes included
• Unauthorized Return Rate Threshold covers debits using any SEC Code. It does not apply to credits returned as unauthorized.
2. Establishing Inquiry Process for Administrative and Overall Return Rate Levels
All Participants: NACHA expects all ACH Network participants to benefit from the establishment of an inquiry process to research the facts behind an Originator’s ACH activity should an Originator exceed an established administrative return or overall return rate level. The amendment is expected to encourage ODFIs to focus on reducing the number of Returns and thereby reducing the number of transactions entering the ACH Network that result in exceptions and returns. Finally, all ACH Network participants should benefit from the ability of NACHA and the ACH Operators to collectively monitor returns at the Network level.
Originators and Third-Party Senders: Originators and Third-Party Senders with return rates above the new levels may be required by their ODFIs, and, in the case of some Originators, their Third-Party Senders, to take action to reduce their return rates, and will incur costs in doing so.
The rule establishes two new Return Rate Levels, which allow for the preliminary inquiry process:
• A Return Rate Level of 3.0 percent will apply to debit entries returned due to administrative or account data errors (Return Reason Codes R02, R03 and R04).
• A Return Rate Level of 15.0 percent will apply to all debit entries (excluding RCK entries) that are returned for any reason.
10. Exposure Limits
File Limits are set as Follows:
Daily Debit File: $1,000,000.00-If file limit is exceeded, review of transactions at Originator and bank level.
Daily Credit File: $1,000,000.00-If file limit is exceeded, review of transactions at Originator and bank level.
11. Office of Foreign Assets Control (OFAC)
Cheese does an OFAC check at account opening and then on an ongoing basis for all existing customers. If a match is found, all funds will be frozen and Cheese’s issuing bank partner will be notified immediately. The Issuing Bank partner will monitor files for IAT OFAC related requirements. If a match is found Cheese will freeze all funds and work with their Issuing Bank partner on next steps.
Cheese retains evidence of ACH entries for six (6) years.
When requested to do so by the ODFI, Cheese will provide all records in the format required within the timelines identified.
EFFECTIVE ON NOVEMBER 2020
The “Cheese Service” means any websites, mobile applications, and other services under the control of Cheese, in connection with providing an online or digital platform for Cheese's services.
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, date of birth, social security number, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third-party to easily identify a specific individual.
1. How We Collect Your Information
We collect information, including Personal Information when you:
- Register to use the Cheese Service;
- Use the Cheese Service; and
- Communicate with us.
1.1. Creating a Cheese Account.
You must register to use the Cheese Service. When you choose to create an account, you must provide information including your email address and phone number. You may decline to provide additional Personal Information, however, doing so may prevent you from engaging with and using certain parts of the Cheese Service.
1.2. Social Media Connection.
We may collect information, including Personal Information, from social media websites, such as Facebook or Twitter.
1.3. Using the Cheese Service.
We collect information from you as you use the Cheese Service such as when you initiate a transaction, when you send payments, or otherwise engage with or use the Service.
1.4. Customer Support.
We may collect information, including Personal Information from you through your communications with our customer support team.
1.5. Mobile Device Information.
We may obtain information from your mobile device such as your device type, machine or mobile device identification number, location data including time zone, language setting, browser type and IP address.
1.6. Location data.
If you have ‘background location’ turned on, the Cheese app will, from time to time, tell us about your device’s location even if you are not directly interacting with the application.
When we have location information, we use it to tailor our Services for you and others, like helping reduce card fraud by matching your card activity with your location.
1.7. Cookies, Automatic Data Collection, and Related Technologies.
When you visit the Cheese Service, we and third-parties that provide certain functionality on the Cheese Service may engage, receive and record information from your use of the Cheese Service and server logs from your browser, including your IP address, and from cookies and similar technology. This information is used for security purposes, to authenticate your identity, to improve the quality of the Cheese Service, such as to store your preferences, customize the Cheese Service, and provide more relevant advertising. Most browsers allow you to block and delete cookies.
2. How We Use Your Information
We use the information we collect, including Personal Information to:
- verify your identity
- comply with regulatory requirements
- facilitate and improve the Cheese Service; and
- communicate with you.
2.1. Internal and Service-Related Usage.
We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Cheese Service. We may use and retain any data we collect to provide and improve our services.
We may send email to the email address or text to the mobile phone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.
We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission. We also do not provide any Personal Information to any third-party ad networks. We may use your Personal Information and other information to communicate with you by email or text message to provide you with information and offers we think may be of interest to you. We will send you text messages only with your consent, and you may opt out of emails or text messages by using the opt-out link in an email or text.
2.4. Aggregate Data.
We may anonymize and aggregate data collected through the Cheese Service and use it for any purpose. Information that has been anonymized does not allow a third party to easily identify a specific individual to be Personal Information.
We may share your information, including Personal Information:
- with our third-party service providers;
- to comply with legal obligations;
- to protect and defend our rights and property; and
- with your permission.
3. How We May Disclose Your Information
3.1. Vendors and Service Providers.
We may share any information we receive with vendors and service providers retained in connection with the provision of the Cheese Service.
3.2. Social Networking and Other Website Services.
The Cheese Service may allow you to share information, including Personal Information, with third-party services and social networking websites, such as Facebook and Twitter. We do not share your Personal Information with them unless you direct the Cheese Service to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.
3.3. As Required By Law and Similar Disclosures.
We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours', ours' or others' rights, property, or safety.
3.4. Merger, Sale, or Other Asset Transfers.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information. We may also disclose your Personal Information with your permission.
4. Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By using the Cheese Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Cheese Service. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Cheese Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at email@example.com.
5. Links to Third-Party Services
6. International Users
If you are visiting Cheese’s website or application from other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.
7. Update Your Information or Pose a Question
If you have any questions or concerns about this Policy or the use of your information, or to modify or update any information we have received, please contact firstname.lastname@example.org.
7.1. Modifying Your Information.
If you are a registered user of the Cheese Service, you may modify your account settings and information through the Settings portal within the Service.
7.2. Deleting Your Cheese Account.
You can close and delete your Cheese account at any time. When you close and delete your account, you and other Cheese users will no longer be able to view your account or profile information, but we may continue to have access to your information for a period of time in order to comply with applicable legal or service obligations.
7.3. Data Retention.
We will retain your account and associated information for as long as your account is active or as needed to provide you the Cheese Service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Changes to Our Policy and Practices
8.1. Posting of Revised Policy.
We may update this Policy to reflect changes to our information practices. If we make any change in how we use Personal Information we will notify you by means of a notice on the Cheese Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
8.2. New Uses of Personal Information.
From time to time, we may desire to use Personal Information for uses not previously disclosed in our Policy. If our practices change regarding previously collected Personal Information than stated in the version of this Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.