Terms and Conditions

1. Eligibility

Use of the Blink App and access to Blink's Earned Wage Access services are restricted to individuals who meet all of the following criteria. The user must be at least eighteen (18) years of age or older, which is the age of majority under Florida law. Furthermore, the user must be a legal resident of the United States with valid work authorization documentation and the State of Florida where they and where Blink maintains a primary residence in is authorized to deliver its services under applicable state law. Presently, Blink's services are available exclusively in the State of Florida, with potential expansion to additional states at Blink's discretion.

The user must possess a valid and active checking account issued by a U.S.-based financial institution that supports ACH transactions and is eligible for electronic funds transfers under Regulation E, Florida law, and the Florida Money Transmitter Code (Chapter 560, Florida Statutes). This account must be in good standing and not subject to any legal encumbrances or limitations that would prevent successful electronic funds transfer. Users must also provide accurate and verifiable personal and financial information including, but not limited to, full legal name, residential address, date of birth, social security number or other government-issued identification as required by Florida law (including but not limited to F.S. § 560.125), employer information, and access credentials for bank account linking through authorized third-party providers who comply with Florida data security requirements under F.S. § 501.171 and maintain appropriate cybersecurity measures, federal banking regulations, and maintain SOC 2 Type II certification and comply with Florida Information Protection Act security requirements, including annual security audits and data breach notification protocols.

Blink reserves the right, subject to applicable Florida consumer protection laws including the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), to deny access to its services or suspend an existing account upon at least fifteen (15) days' prior written notice, should it detect discrepancies, suspicious activity, potential violations of any eligibility requirement, or other activities that may violate Florida's anti-fraud statutes (F.S. § 817.001 et seq.), or as otherwise required by applicable Florida law or federal regulations, except where immediate action is necessary to prevent fraud or protect system security. Blink may also disqualify any applicant or user who provides inaccurate, misleading, or fraudulent information or who otherwise attempts to circumvent Blink's identity verification protocols or risk-based assessment tools. Nothing in these Terms shall be construed as a guarantee or entitlement to receive Blink services.

2. BlinkAdvance® Service

The BlinkAdvance® service is a core feature of the Blink App, designed to provide eligible users with non-recourse, earned wage access ('EWA') in the form of a fixed-sum advance based on income already accrued but not yet paid. This service is designed to provide access to earned wages and, as currently structured and operated, does not constitute a loan, credit facility, or deferred presentment transaction under Florida law, and is not governed by the Truth in Lending Act (TILA) or Chapter 560, Florida Statutes. This classification is based on the current regulatory framework and interpretation of applicable laws, including Florida Office of Financial Regulation guidance on earned wage access programs and CFPB Advisory Opinion 2020-06. BlinkAdvance® is offered as a financial convenience product aligned with applicable state and federal guidance on earned wage access.

BlinkAdvance® is offered as an earned-wage-access program ("EWA Service") consistent with CFPB Advisory Opinion 2020-06 and Florida Office of Financial Regulation guidance on earned wage access programs.¹ The Service: advances no more than the lesser of US $350 or 50% of wages already earned but not yet paid; charges only a flat transaction fee that does not vary with time outstanding; and deducts repayment on or before the next pay-day you designate.

Based on these features, current regulatory guidance, and analysis of applicable Florida statutes and regulations, Blink has determined that the Service is not a "loan," "credit," or "deferred-presentment transaction" under chapter 516 (Florida Consumer Finance Act) or §§560.402–.408 (Deferred Presentment).²

Your Acknowledgment. You agree that each advance is nevertheless a contractual debt you owe Blink. Failure to repay constitutes a breach of contract, and Blink may: (i) suspend your access to future advances, (ii) set-off amounts you owe against funds held for you, and (iii) report the delinquency to consumer-reporting agencies, all without charging interest, late fees, or rollover fees.

Regulatory Re-characterization. If a court or regulator later determines that BlinkAdvance® is a loan or deferred-presentment product, or if Blink changes the Service so that it no longer meets EWA criteria, then: Blink will convert outstanding and future advances to a 0%-interest, no-fee consumer loan and will provide any disclosures required by the Truth-in-Lending Act, ch. 516, or ch. 560; All principal will remain immediately due as scheduled, and Blink may use all remedies available to a creditor under applicable law, including assignment to a licensed collection agency and litigation; and Blink will give you fifteen (15) calendar days' written notice before the change takes effect, unless a shorter period is required by law. Your continued use of BlinkAdvance® after receipt of such notice constitutes acceptance of the revised terms.

Eligible users may request an advance of up to three hundred and fifty dollars ($350.00) per pay period, subject to any applicable state regulatory limits on earned wage access amounts. The exact amount of the advance for which a user may qualify is determined solely by Blink's proprietary decisioning model, which incorporates risk assessment, income verification, repayment behavior, and financial transaction patterns obtained through authorized open banking data access. The approved amount may vary per user and per transaction based on objective criteria consistent with Florida consumer protection laws and Blink's risk assessment policies.

The user agrees to pay a flat transaction fee as consideration for the use of the BlinkAdvance® service. The fee will be disclosed clearly and conspicuously prior to each transaction in accordance with Florida consumer disclosure requirements, including all applicable fee amounts, payment terms, and processing timeframes and is not dependent on the size of the advance. For users selecting standard processing via Automated Clearing House (ACH), a flat fee not exceeding twenty dollars ($20.00) shall apply, and funds will be disbursed within one to two (1-2) business days, required by applicable Florida money transmitter regulations (F.S. § 560.208). For users selecting expedited disbursement via Real-Time Payment (RTP), a flat fee not exceeding twenty-five dollars ($25.00) shall apply, with funds typically delivered within minutes when technically feasible, subject to payment network availability, bank partner cooperation, and any applicable Florida money transmitter processing requirements.

Users who repay the full balance of the advance within seven (7) calendar days (excluding legal holidays) of disbursement shall receive a ten percent (10%) discount applied to the original transaction fee. This discount will be applied automatically and cannot be waived or modified except as required by applicable Florida law, including but not limited to the Florida Consumer Collection Practices Act (F.S. § 559.55 et seq.) and FDUTPA. This Early Repay Reward will be automatically credited at the time of repayment. Blink reserves the right to modify, suspend, or discontinue this reward upon thirty (30) days' prior written notice to users, as required by Florida consumer protection laws, provided that any such changes shall not affect rewards already earned but not yet credited.

For the avoidance of doubt, the BlinkAdvance® service is considered effective and contractually initiated at the moment the user authorizes the disbursement request through the Blink App interface, irrespective of the chosen settlement method. The user's authorization establishes the formal commencement of the earned wage access transaction, as the service pertains to the right to access wages already earned and verified through employer or timesheet data using methods compliant with Florida wage verification standards, including those set forth in F.S. § 448.110, rather than the timing of fund receipt. The disbursement method selected—whether standard (ACH) or expedited (RTP)—merely determines the operational speed at which the funds are transmitted and is treated separately as a fee-based facilitation service related to payment processing infrastructure, not to the availability or timing of wage access itself. This distinction reflects common industry practices regarding the optional use of faster clearing rails and bears no effect on the legal nature or initiation point of the advance.

At any given time, users may only hold one (1) active BlinkAdvance®. A new advance may not be requested until the outstanding balance, including the associated transaction fee, is paid in full and successfully cleared. Blink does not permit advance stacking or rollover; unpaid balances are not refinanced, extended, or carried forward, in accordance with Florida consumer protection laws and regulations governing earned wage access services.

Blink does not assess interest or annual percentage rates (APR) under any circumstance, consistent with Florida's treatment of earned wage access products. The transaction fee is fixed, disclosed in advance in accordance with Florida consumer disclosure requirements, and does not vary with repayment timing or user behavior, except as explicitly defined by the Early Repay Reward. Blink does not perform credit inquiries, nor does it report repayment activity to any consumer reporting agency.

All BlinkAdvance® transactions are discretionary. While Blink maintains the right to approve or deny advance requests based on objective eligibility criteria, underwriting outcomes, risk controls, compliance concerns, or other factors as permitted by Florida law, such decisions shall be made in accordance with Florida consumer protection laws and without discrimination as prohibited by Florida Civil Rights Act (F.S. § 760.01 et seq.). Use of the BlinkAdvance® service is entirely optional and must be affirmatively selected and authorized by the user for each disbursement.

3. BlinkInsights®

BlinkInsights® offers informational and analytical tools, regulated under Florida Statute § 494.00115 (Florida Loan Originator Act), Florida Administrative Code Rule 69V-560.1013, Florida Administrative Code Rule 69V-560.1012, and other applicable Florida financial services regulations, that help users understand their financial behaviors and improve money management. This feature analyzes information obtained from linked external financial accounts, providing personalized reports and suggestions for budgeting and cash flow. Use of BlinkInsights® is entirely optional, and users may opt-out at any time as provided under Florida consumer protection laws, including the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), and is not a condition of eligibility for BlinkAdvance® or any other Blink product.

The BlinkInsights® feature is a complimentary and non-binding financial information service provided by Blink as part of the Blink App. Its primary purpose is to empower users with personalized financial data analysis, aiming to improve awareness and understanding of individual spending behaviors, income stability, and overall cash flow management. BlinkInsights® aggregates and analyzes financial data obtained from user-linked external financial accounts in accordance with Florida Statutes § 501.171 and other applicable laws. Through authorized third-party data aggregators operating in compliance with Florida's Information Protection Act (FIPA), Florida Administrative Code Rule 69V-560.1013, and federal regulations, Blink accesses transactional records, balance histories, recurring debits, deposits, and other indicators of financial behavior necessary for service provision, as permitted by applicable Florida privacy laws. This information is then utilized to generate individualized financial summaries, alerts for recurring expenses, anticipated low-balance warnings, and recommendations for budgetary adjustments or savings behavior.

It is expressly acknowledged by the user that BlinkInsights® is an informational service only and does not constitute legal, tax, investment, financial, or credit counseling advice as defined under Florida law. Users should consult appropriate licensed professionals, including those licensed under Florida law, for advice regarding personal financial decisions. The user agrees that reliance upon any insights, reports, or suggestions provided through the Blink App is entirely at their own discretion and risk.

While Blink strives to ensure the accuracy and timeliness of all financial insights, no guarantee is made as to their completeness, real-time accuracy, or fitness for any specific purpose. Delays, omissions, or misrepresentations may occur due to latency in third-party data integration or discrepancies in the user's external financial accounts. Except as otherwise required by Florida law, including but not limited to Florida Statute § 501.211 (FDUTPA), Blink is not liable for decisions made by the user based on information presented via BlinkInsights®; provided, however, that this limitation does not apply to damages resulting from Blink's gross negligence, willful misconduct, or violations of FDUTPA as permitted under Florida law.

Blink reserves the right to modify or discontinue the BlinkInsights® feature with reasonable advance notice of at least thirty (30) days, except in cases of immediate security concerns or regulatory requirements. Blink may also limit access to this feature in the event of suspected misuse, data integrity concerns, or upon termination of a user's eligibility to participate in Blink's broader service offerings.

4. Data Access and Usage

In order to provide core functionalities such as BlinkAdvance® and BlinkInsights®, the Blink App requires access to user-permissioned financial data through third-party data aggregation services, including but not limited to Plaid Inc. By linking your external bank account(s) within the Blink App, you explicitly consent to the collection, use, and storage of your financial data, as permitted under Florida law and applicable federal regulations, for the purpose of service delivery, eligibility assessment, fraud prevention, compliance verification, and operational enhancements. You may revoke this consent at any time as provided under Florida law, subject to any outstanding obligations and regulatory retention requirements, with such revocation to be processed in accordance with Florida Administrative Code Rule 69V-560.1013(4).

Upon granting access, and in accordance with Florida Information Protection Act (FIPA), Blink is authorized to retrieve and securely maintain only the financial information necessary for service provision, including: current account balances, historical transaction records, deposit and withdrawal activity, recurring payment obligations, income flow patterns, and specific metadata required to support Blink's decision-making processes and analytical tools. All data collection and retention shall comply with FIPA's requirements for data minimization and security, including the requirement to maintain all records for a minimum of five (5) years from the date of creation or last activity as specified in Florida Administrative Code Rule 69V-560.1012, including but not limited to the implementation of reasonable measures to protect and secure data in electronic form containing personal information, as well as the specific encryption requirements under Florida Statute § 501.171(2). This data is utilized to determine your eligibility for BlinkAdvance®, to inform the risk management protocols, and to deliver real-time insights within the Blink App through BlinkInsights®.

All financial information accessed through third-party providers is encrypted using industry-standard security protocols both in transit and at rest, in accordance with the encryption standards specified in Florida Statute § 501.171(2). Blink adheres to all applicable federal and state data protection regulations, including but not limited to the Gramm-Leach-Bliley Act (GLBA), the Florida Information Protection Act (FIPA), and has implemented robust internal access controls and governance procedures to safeguard user data in accordance with applicable law. Blink does not sell, lease, rent, transfer, or commercially exploit user financial data under any circumstances, except as expressly permitted by applicable law and with prior written consent of the user, and maintains appropriate administrative, technical, and physical safeguards as required by FIPA and other applicable Florida data protection laws.

Users may withdraw their consent for ongoing data access at any time by disconnecting their linked financial accounts through the Blink App interface. Upon revocation, Blink will cease retrieving new data; however, previously collected data may continue to be stored and processed in accordance with Blink's Privacy Policy, FIPA requirements, and other applicable laws, including retention requirements for legal, regulatory, and compliance purposes.

Any request to permanently delete user data must be submitted in writing and will be processed in accordance with Florida Information Protection Act (FIPA) requirements, subject to identity verification and consideration of any outstanding balances or regulatory retention obligations. Blink will respond to such requests within 45 days as required by Florida law, and will maintain written records of all such requests and responses for a minimum of five years. Blink will make reasonable efforts to respond to such requests in a timely and lawful manner.

Use of the Blink App and its services, following clear disclosure and opportunity for review as required by Florida law, constitutes express acknowledgment and acceptance of the aforementioned data access and use terms. Users who do not wish to grant access to their financial data will not be able to utilize BlinkAdvance® or related features that require banking integration.

5. Repayment Terms

All Blink Advances disbursed to eligible users are subject to mandatory automatic repayment via ACH debit transaction on the date selected by the user at the time of disbursement confirmation. By initiating a BlinkAdvance®, the user agrees and authorizes Blink, through its authorized payment processing partners, to withdraw from their linked financial account an amount equal to the original advance amount plus the applicable fixed transaction fee as disclosed during the transaction confirmation, subject to the user's rights under Regulation E and Florida law to stop payment or revoke authorization, including the right to receive written confirmation of revocation processing within one (1) business day of receipt, with such revocation to be processed within three (3) business days of receipt or such shorter period as may be required by applicable Florida law, provided that any pending transactions will be completed in accordance with Florida Statute § 670.411.

Repayment is scheduled on a user-specified date, which must fall within fifteen (15) calendar days of the date of disbursement, unless a shorter period is required by applicable Florida law. On the scheduled repayment date, Blink will initiate an ACH debit from the user's linked account. The user is solely responsible for ensuring that sufficient funds are available in their account to cover the full repayment amount. Should the available balance in the linked account be insufficient to satisfy the full repayment amount on the scheduled date, Blink may, after providing at least 24 hours advance written notice to the user through the communication method specified in the user's account settings, attempt to debit a partial amount equal to the funds currently available. If the account balance is less than one dollar ($1.00), Blink may, in its sole discretion, refrain from initiating the debit and will reattempt the transaction on the following business day, provided that such forbearance shall not constitute a waiver of any rights or remedies available to Blink.

You must maintain a ledger balance equal to or greater than the total repayment amount in your designated account by 11:59 p.m. Eastern Time on the business day preceding the scheduled debit. If the available balance is insufficient for any reason, Blink may (i) initiate a partial debit up to the available amount, (ii) retry the remainder up to three (3) times within the next ten (10) days, and (iii) assess a one-time administrative fee of fifteen dollars ($15.00), as permitted under Florida Statutes § 68.065 and provided that such fees are not prohibited by applicable Florida law and are reasonably related to the actual costs incurred by Blink.

In the event that a repayment is not successfully completed within the originally selected date, Blink will continue to attempt to collect the outstanding balance for a grace period of four (4) calendar days. During this grace period, Blink will initiate retry debits in accordance with applicable NACHA rules and guidelines. In addition, a reasonable administrative fee, directly related to actual processing costs, not exceeding two dollars ($2.00) may be assessed, with advance notice to the user, for every twenty-four (24) hour period during which the full repayment remains outstanding, subject to limitations under Florida law, including but not limited to the Florida Consumer Collection Practices Act and Florida Deceptive and Unfair Trade Practices Act. This administrative fee is capped at a reasonable level to ensure compliance with applicable consumer protection standards and to avoid punitive or unconscionable collection practices.

During any period in which an advance remains partially or fully unpaid, the user will not be eligible to receive a new BlinkAdvance®. Access to other services within the Blink App may also be suspended, at Blink's discretion, until all outstanding balances are repaid in full. The user may contact Blink's support team to report financial hardship. Blink will evaluate such requests in good faith in accordance with its hardship policies, which are available upon request, and applicable Florida consumer protection laws, and may grant extensions or waive fees based on documented circumstances, with written notice of the determination provided within five (5) business days, or sooner if required by applicable Florida law, including a detailed explanation of the decision and any available appeals process as required by Florida consumer protection laws.

To maintain access to the BlinkAdvance® service, you must have at least one valid alternative repayment method on file in the Blink: Cash Advance mobile app ("Payment Methods" screen). Failure to establish or maintain this in-app method will result in suspension of your BlinkAdvance® privileges.

The user acknowledges that failure to maintain sufficient funds may result in overdraft fees or nonsufficient funds (NSF) fees charged by their financial institution. Blink does not impose overdraft or NSF fees and, while not responsible for charges assessed by the user's bank as a consequence of a failed debit, will provide clear advance notice of scheduled debits as required by Florida consumer protection laws, including notice at least three (3) business days before any scheduled debit.

The user's continued use of the BlinkAdvance® service constitutes acceptance of these repayment terms. It is the user's obligation to review and understand the repayment obligations prior to initiating each transaction. For questions about repayment or to discuss account options, users may contact Blink 24/7 Customer service representatives are available during normal business hours (9:00 AM to 5:00 PM Eastern Time, Monday through Friday, excluding federal holidays).at support@blinkfinances.com or toll-free at 1-786-675-5247. Blink will respond to all inquiries within two (2) business days, with an acknowledgment of receipt provided within one (1) business day as required by Florida consumer protection standards.

6. User Responsibilities

As a condition of continued use of the Blink App and its associated services, including but not limited to BlinkAdvance® and BlinkInsights®, and in accordance with Florida consumer protection requirements, all users must fulfill a set of responsibilities designed to ensure the integrity, compliance, and operational reliability of the Blink platform. Each user agrees to provide accurate, complete, and up-to-date personal information during registration and at all times thereafter, as required under Florida law and federal regulations, and acknowledges that failure to do so may constitute a material breach of this agreement. This includes, but is not limited to, legal name, physical address, date of birth, employment status, and any other information reasonably required by Blink to verify identity, assess eligibility, and comply with applicable regulatory requirements such as Know Your Customer (KYC) and Anti-Money Laundering (AML) protocols.

Users must maintain sufficient funds in their linked bank account(s) beginning one (1) business day prior to and continuing through the scheduled repayment date to satisfy any outstanding BlinkAdvance® and applicable transaction fee. Users acknowledge that maintaining insufficient funds may result in additional fees from their financial institution. The user agrees to actively monitor their account activity and to notify Blink immediately upon becoming aware of any anomalies, errors, or unauthorized access. In the event a user anticipates an inability to fulfill their repayment obligation due to insufficient funds or hardship, they must contact Blink in advance to discuss potential remedies, including, but not limited to, deferred repayment or temporary account suspension.

Furthermore, users agree not to engage in any action that misrepresents their income, falsifies transaction history, or otherwise manipulates financial information with the intent to deceive Blink's underwriting or risk evaluation processes. Such conduct constitutes a material breach of these Terms and may result in immediate account termination, referral to relevant regulatory authorities including the Florida Office of Financial Regulation and the Consumer Financial Protection Bureau, and potential civil or criminal liability under applicable state and federal laws, including but not limited to Florida Statute § 817.034 (Florida Communications Fraud Act) and § 817.568 (Criminal Use of Personal Identification Information). Blink will notify users in writing within five (5) business days, or sooner if required by applicable law, of any suspected fraudulent activity detected on their account.

Blink requires users to communicate any changes to their linked financial account, repayment schedule, or contact information in writing at least three (3) business days before the scheduled transaction date. Changes requested with less notice may not be processed until after the next scheduled transaction. Failure to provide timely notice may result in missed payments, system-generated fees, and disruption of service access.

You are solely responsible for maintaining an active bank-link via authorized third-party providers (e.g., Plaid). If your linked account becomes disconnected or inactive, you must reconnect it through the Blink: Cash Advance mobile app. Failure to do so when a repayment is due—resulting in a failed connection—may constitute a breach of this agreement and may result in legal action. Blink will provide in-app support guidance to assist you, but ultimate responsibility for reconnection rests with you.

Any attempt to access or use the Blink: Cash Advance feature without proper authorization, or in a manner that disrupts Blink's operations, will be treated as a breach of these Terms and may constitute a violation of Florida Computer Crimes Act (§ 815.01 et seq., Florida Statutes). Blink reserves the right to investigate any suspected misuse, including unauthorized access attempts or manipulation of the app's functionality. Users found to have engaged in such misconduct may have their access suspended or terminated, and Blink may pursue all available legal remedies, including civil and criminal action, on behalf of Rise Digital Financial Corp.

By continuing to use the Blink App, the user expressly acknowledges and agrees to comply with the above responsibilities. Failure to meet these obligations may result in the temporary or permanent suspension of access to Blink services, denial of future BlinkAdvance® eligibility, or other remedial actions as deemed appropriate by Blink, subject to the requirements of Florida consumer protection laws and after providing written notice and a reasonable opportunity to cure any alleged violations.

7. Authorization for ACH Transactions

As a condition of using BlinkAdvance® and related services, the user provides express written authorization, in accordance with Florida Electronic Signature Act (§668.50, Florida Statutes), the Florida Consumer Collection Practices Act (§559.55 et seq., Florida Statutes), and the Electronic Fund Transfer Act (15 U.S.C. § 1693 et seq.), to Blink, as well as its designated third-party payment processors (who shall be registered with the Florida Office of Financial Regulation as required by Florida Statute § 560.204 and maintain such registration throughout the duration of services), to initiate electronic funds transfers to and from the user's linked deposit account through the Automated Clearing House (ACH) network, in accordance with NACHA Operating Rules and Guidelines. This authorization encompasses both debit and credit entries, including the collection of repayment amounts associated with Blink Advances, transaction fees, and any applicable administrative charges, as well as the disbursement of refunds, reversals, or Early Repay Rewards where applicable.

This authorization shall be deemed ongoing and shall remain in full force and effect until such time that the user submits a written notice of revocation to Blink, delivered via the prescribed communication channels, and with no fewer than five (5) full business days' notice prior to any scheduled debit or credit transaction. Blink shall provide written confirmation of receipt of such revocation within one (1) business day.

Any revocation of ACH authorization must be accompanied by an alternative payment method acceptable to Blink and compliant with Florida money transmitter regulations. A reasonable administrative fee not exceeding $5.00 may be assessed for revocations submitted less than five (5) business days before a scheduled payment, provided such fee is disclosed in advance, represents actual costs incurred, and is waived in cases of demonstrated financial hardship as required by Florida consumer protection laws.

Users retain all rights under Florida law, including Florida Statutes § 670.101 et seq., and Regulation E to stop payment or revoke authorization for electronic fund transfers. Any attempt to revoke authorization that does not comply with this timeline may result in the processing of pending authorized entries before cancellation is effected, subject to the consumer protection requirements of Florida Statutes § 559.72.

All ACH transactions conducted under this authorization shall be governed by the rules and operating procedures of the National Automated Clearing House Association (NACHA), the Florida Consumer Collection Practices Act (FCCPA, Florida Statutes § 559.55 et seq.), the Florida Electronic Funds Transfer Act, the Florida Uniform Electronic Transaction Act (§ 668.50, Florida Statutes), and any applicable laws or regulations enforced by state or federal banking authorities. The user affirms that they are the lawful holder and/or authorized signatory of the bank account linked to the Blink App and that said account is not subject to any legal restrictions or third-party claims that would impair the enforceability of this authorization.

While Blink makes reasonable efforts to avoid triggering bank fees, except as required by applicable Florida law, Blink shall not be liable for any fees or charges assessed by the user's financial institution, including but not limited to overdraft fees, nonsufficient funds (NSF) fees, or processing charges arising from unsuccessful debit attempts, except where such fees result from Blink's gross negligence or willful misconduct. It is the user's responsibility to ensure that adequate funds are maintained in the linked account and to promptly notify Blink of any changes in account status or banking relationship that may affect ACH transaction processing.

Prohibition on Balance Manipulation. You agree not to manipulate or otherwise structure your account balance for the purpose of causing overdraft, NSF, or similar bank-assessed fees. If Blink determines, subject to the consumer protection requirements of Florida Statutes § 501.201 et seq., that such conduct occurred, Blink may (a) treat the advance as immediately due and payable, (b) reverse any flat-fee discounts applied to that advance, and (c) suspend your eligibility for future BlinkAdvance® transactions for up to ninety (90) days, subject to written notice and opportunity to appeal such determination within fifteen (15) business days.

By initiating a BlinkAdvance® or by continuing to use the Blink App, the user reaffirms and ratifies their ACH authorization as set forth herein.

8. Service Availability and Limitations

Blink endeavors to maintain a consistent, secure, and uninterrupted user experience in accordance with Florida consumer protection standards and applicable federal regulations. However, the user expressly acknowledges and agrees that access to the Blink App and its associated services, including BlinkAdvance® and BlinkInsights®, may occasionally be delayed, suspended, or disrupted due to routine maintenance, updates, third-party system outages, telecommunications interruptions, or events beyond Blink's reasonable control, including but not limited to force majeure events such as natural disasters, civil unrest, acts of terrorism, or governmental intervention, provided that Blink shall make commercially reasonable efforts to restore service as promptly as possible and shall provide notice twenty-four (24) hours via email or SMS of any material service disruption, and in any event no later than twenty-four (24) hours for any outage expected to exceed forty-eight (48) hours, as required by Florida consumer protection laws, including Florida Statutes § 501.201 et seq.

Except as required by Florida law, including but not limited to the Florida Deceptive and Unfair Trade Practices Act, or in cases of gross negligence or willful misconduct, Blink shall not be held liable for any inability to access the Blink App or delay in the provision of services resulting from such occurrences, provided that Blink makes reasonable efforts to restore service and provide timely notice of extended outages. Blink does not guarantee continuous or error-free operation of the App, nor does it warrant that all functions will be available at all times or that all defects will be corrected promptly or without consequence.

Blink reserves the right, subject to applicable Florida consumer protection laws and upon at least thirty (30) days' advance written notice where required by law, to suspend, modify, discontinue, or limit access to the App, or to any feature or functionality thereof. This includes the right to temporarily or permanently suspend user accounts based on usage behavior, system integrity concerns, compliance findings, or failure to adhere to these Terms. Blink also retains the authority to refuse any request for a BlinkAdvance® based on reasonable business considerations and objective criteria, including without limitation eligibility changes, risk assessment results, or limitations imposed by payment partners or regulatory updates.

Additionally, Blink may place limits on the frequency or amount of advances, implement temporary service maintenance periods, not to exceed forty-eight (48) hours, during which no new disbursements are issued, or apply usage thresholds to ensure operational stability and equitable service distribution among users. These operational safeguards are necessary to ensure the long-term integrity and regulatory compliance of the Blink platform.

By continuing to use Blink, the user accepts the reasonable limitations of digital service delivery, as defined in this Agreement and subject to Florida consumer protection standards, provided that Blink shall remain liable for service interruptions resulting from gross negligence, willful misconduct, or violations of Florida consumer protection laws, and shall take commercially reasonable steps to minimize service disruptions.

9. Fees and Disclosures

In accordance with Florida Statutes § 501.201 et seq. (Florida Deceptive and Unfair Trade Practices Act) and F.S. § 501.0117, Blink provides clear, conspicuous, and pre-transactional disclosure of all applicable fees and related consumer protection regulations. Users will be presented with a full summary of charges associated with each BlinkAdvance®, including the specific transaction fee amount, the disbursement method selected, and any associated processing timelines, prior to final confirmation and authorization.

Blink does not charge interest, annual percentage rates (APR), variable repayment fees, hidden charges, gratuities, or voluntary tips, as defined under Florida Statutes Chapter 516, Chapter 687, the Florida Consumer Finance Act, and applicable federal law. All costs associated with use of the BlinkAdvance® product are fixed, flat-fee transactions not exceeding the maximum amounts permitted by Florida law, that are clearly disclosed and agreed to in advance in accordance with Florida consumer protection requirements, including the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), F.S. § 501.201 et seq. The fee structure for BlinkAdvance® is not contingent upon the advance amount, repayment behavior, or user profile beyond the selection of disbursement method (ACH vs. RTP). Blink does not impose late fees, rollover fees, or penalty interest.

Although Blink does not assess overdraft or nonsufficient funds (NSF) fees, users may incur such fees from their financial institution if a debit initiated by Blink fails due to insufficient account balance. Blink shall not be responsible or liable for fees or penalties imposed by the user's bank, except where such fees result from Blink's gross negligence or willful misconduct, nor shall Blink be held liable for indirect, consequential, or special financial outcomes arising from failed repayment attempts, except as prohibited by Florida law, provided that this limitation shall not affect any rights or remedies available under Florida law.

Subject to applicable Florida law, Blink reserves the right to update or modify its fee schedule upon providing required notice under Florida law and this Agreement, provided that no such changes shall apply retroactively to existing transactions. In the event of a material change to fee structures or related policies, Blink shall issue a notice to users via in-app messaging and email communication at least thirty (30) calendar days prior to the effective date of such changes, as required by Florida consumer protection standards. Continued use of Blink services after the effective date of any such modifications shall constitute the user's acceptance of the updated fee structure, provided that any fee increases shall not apply to BlinkAdvances® initiated prior to the effective date of such changes.

Blink shall maintain records of all disclosed fees, user acknowledgments, and related transaction documentation for a minimum of five (5) years in a readily accessible format that permits immediate retrieval upon request by Florida regulatory authorities in accordance with Florida record retention requirements under Florida Administrative Code Rule 69V-180.080 and other applicable regulatory and compliance standards. All fee disclosures shall comply with Florida consumer protection laws and regulations, including Chapter 501 of the Florida Statutes, as well as consumer financial protection frameworks relevant to non-loan earned wage access products, including all applicable regulations promulgated by the Florida Office of Financial Regulation.

10. Compliance

Blink commits to maintaining all required consumer disclosures and complaint procedures as required by Federal law and Florida law, including but not limited to the Florida Consumer Collection Practices Act (FCCPA) and Florida Deceptive and Unfair Trade Practices Act (FDUTPA). Users in Florida may contact the Florida Office of Financial Regulation, Division of Consumer Finance, 200 E. Gaines Street, Tallahassee, FL 32399-0376, toll-free at 1-800-848-3792 or (850) 487-9687, flofr.gov, to file a complaint if any issue remains unresolved. Other state residents may refer to similar regulatory authorities in their own jurisdiction, and Blink will provide contact details as required. Filing such a complaint does not waive or limit any other rights under the law.

Blink operates under a comprehensive compliance framework, including adherence to Florida Office of Financial Regulation guidance and requiring compliance with applicable federal, state (including Florida Office of Financial Regulation requirements), and local regulatory obligations related to earned wage access services, consumer financial protection, data privacy, and electronic fund transfers. Blink expressly affirms that BlinkAdvance® is structured and operated as an earned wage access product and not as a loan, credit extension, or deferred payment product, as defined under applicable Florida and federal law, including but not limited to the Florida Consumer Finance Act (Chapter 516), the Truth in Lending Act (TILA), Regulation Z, or any comparable lending statute.

Blink classifies its BlinkAdvance® product as a non-recourse, non-interest-based earned wage access solution structured to provide users with access to wages already accrued but not yet disbursed. Blink does not impose interest or finance charges and does not perform credit checks or report payment activity to consumer credit reporting agencies. These structural elements are intended to ensure compliance with existing guidance issued by state financial regulators, the Consumer Financial Protection Bureau (CFPB), and applicable fintech industry standards.

Blink maintains compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations. All users are subject to identity verification procedures, and user activity is monitored using automated tools designed to detect suspicious transactions, prevent fraudulent activity, and comply with Florida's anti-money laundering requirements under F.S. § 560.123. Blink's compliance protocols include regular compliance audits at least annually, with results maintained for a minimum of five (5) years as required by Florida law, staff training, secure data handling in accordance with the Florida Information Protection Act of 2014 (FIPA), Florida Statutes § 501.171, and the Florida Administrative Code Rule 69V-560.1012 requirements, and a zero-tolerance policy toward misuse of its services.

As permitted under Florida law, including Florida Statutes Chapter 560, Blink operates as an earned wage access provider and is not a licensed money transmitter, credit services organization, or financial institution as defined by Florida Statutes. Blink does not take custody of user funds beyond the limited scope required for advance disbursement and repayment in accordance with applicable state and federal regulations. Blink does not escrow, invest, or redirect user funds for any purpose unrelated to the core provision of the BlinkAdvance® service.

In jurisdictions where additional licensing or disclosures are required to operate earned wage access programs, including Florida, Blink shall comply with all applicable registration, reporting, and operational requirements, including the Florida Consumer Collection Practices Act (FCCPA) and Florida Deceptive and Unfair Trade Practices Act (FDUTPA), with at least thirty (30) days advance written notice to users via email or in-app notification. Any modifications to Blink's service structure, fee model, or compliance posture shall be made in accordance with Florida consumer protection laws and applicable regulations.

By using Blink, users acknowledge that the product is designed to operate in accordance with established non-credit EWA frameworks and that Blink is committed to upholding all applicable legal and regulatory obligations.

11. Limitation of Liability

Blink, its affiliates, directors, officers, employees, and partners disclaim liability for indirect, incidental, punitive, or consequential damages arising from service access, delays, outages, or errors by third-party providers, except in cases of gross negligence or willful misconduct, provided that nothing in this section shall limit Blink's liability for violations of Florida consumer protection laws. Aggregate liability for direct damages is limited to the greater of: (i) the user's most recent BlinkAdvance® transaction fee; or (ii) five hundred dollars ($500.00), except where such limitation would be prohibited by Florida law, including but not limited to the Florida Deceptive and Unfair Trade Practices Act (FDUTPA) and other consumer protection statutes.

,and except for cases of gross negligence willful misconduct, or where prohibited by Florida law,Subject to applicable Florida law and consumer protection regulations, Blink shall not be liable for any indirect, incidental, special, punitive, or consequential damages whatsoever, including without limitation damages for loss of income, loss of profits, loss of data, business interruption, or reputational harm arising out of or in connection with (i) your access to or use of, or inability to access or use, the Blink App or any component thereof; (ii) delays, failures, or disruptions of any kind in the operation of the Blink App or in the delivery of BlinkAdvance® or BlinkInsights®; (iii) unauthorized access to or alteration of your transmissions or data; (iv) any failure of a third-party payment processor, financial institution, or open banking provider utilized in the delivery of Blink services; or (v) any other matter relating to the Blink App or the services provided therein, regardless of the legal theory asserted and whether or not Blink has been advised of the possibility of such damages.

Some jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages; in such jurisdictions, Blink's liability is limited to the maximum extent permitted by law.

12. Dispute Resolution

To promote the efficient resolution of disputes and to minimize the cost and uncertainty associated with litigation, you and Blink agree that any dispute, claim, or controversy arising out of or relating to these Terms, your use of the Blink App, or any services provided by Blink (whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory) shall be resolved through final and binding arbitration administered by the American Arbitration Association (AAA) in accordance with its Consumer Arbitration Rules then in effect, except for claims that under Florida law must be brought in a court of competent jurisdiction, including but not limited to claims under the Florida Consumer Collection Practices Act (§559.55 et seq.), claims seeking injunctive relief under Florida consumer protection laws, and small claims court actions under Florida Small Claims Rules.

The arbitration will be conducted in English and take place in the county where you reside or another mutually agreed location within Florida. If you reside outside Florida, the arbitration will take place in Miami-Dade County, Florida, unless otherwise mutually agreed in writing at least fourteen (14) days prior to the scheduled arbitration date. The arbitration shall be presided over by a single neutral arbitrator, and judgment on the arbitrator's award may be entered in any court of competent jurisdiction. The arbitrator shall have exclusive authority to resolve any dispute relating to the interpretation, applicability, enforceability, or formation of these Terms, including the arbitrability of any dispute and any claim that all or any part of these Terms is void or voidable.

You acknowledge and agree that by entering into these Terms, you and Blink are each waiving the right to a trial by jury or to participate in a class action or class arbitration. All claims and disputes must be brought on an individual basis and not on a class, consolidated, or representative basis. The arbitrator shall have no authority to consolidate claims or award class-wide relief.

You may opt out of this arbitration agreement by providing written notice to Blink at support@blinkfinances.com within thirty (30) calendar days of your initial acceptance of these Terms. The opt-out notice must include your full name, address, and a clear statement that you wish to opt out of mandatory arbitration. Blink will provide written confirmation of receipt of your opt-out notice within seven (7) business days. Opting out of arbitration will not affect your other rights or responsibilities under these Terms.

This arbitration provision shall survive the termination of your relationship with Blink and the cessation of your use of the Blink App.

13. Waiver of Claim of Garnishment

Users acknowledge that Florida law provides certain garnishment exemptions which cannot be waived, including but not limited to head of household wage exemptions under Fla. Stat. § 222.11, wage garnishment limits under 15 U.S.C. § 1673(a), and other statutory wage protections under Florida and federal law. Any waiver of garnishment exemptions shall be limited to the specific transaction at issue and only to the extent expressly permitted by Florida law, provided that such waiver must be made knowingly, separately, and in writing for each transaction, in accordance with Florida Statutes Section 222.11 and other applicable laws.

14. Attorney Fees Provision

In any legal action, arbitration, or similar proceedings between the parties, the prevailing party shall be entitled to recover reasonable attorneys' fees, costs, and expenses, not to exceed the actual amount incurred, as determined by the court or arbitrator in accordance with Florida Statutes Section 57.105 and other applicable laws.

15. Liquidated Damages Clause

If a user willfully and fraudulently breaches these Terms by obtaining an advance with no intention or ability to repay, or by intentionally obstructing Blink's lawful attempts to collect, as established by clear and convincing evidence and after providing the user with at least fifteen (15) calendar days to respond and present contrary evidence, the user agrees to pay Blink liquidated damages of a reasonable amount not to exceed actual damages as proven by Blink, not to exceed two hundred fifty dollars ($250.00), representing Blink's actual administrative costs, collection expenses, and damages, as documented by Blink's contemporaneous business records maintained in accordance with Florida Administrative Code Rule 69V-180.080 records. This represents a good faith estimate of Blink's anticipated administrative and operational costs due to such misconduct, in addition to the outstanding balance and any other remedies allowed by law. This provision applies only where actual damages would be impracticable to calculate and is not intended as a penalty.

16. Governing Law

These Terms and Conditions and any dispute arising from or relating to the subject matter hereof shall be governed and interpreted in accordance with the laws of the State of Florida, United States of America, including without limitation the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Chapter 501, Part II, Florida Statutes and other applicable consumer protection laws and regulations, without regard to its conflict of laws principles. This governing law provision applies regardless of your place of residence or the location from which you access or use the Blink App.

To the extent any claim arising under these Terms is determined to be non-arbitrable under Section 12 or is otherwise permitted to be brought before a court of law, such claim shall be submitted to the appropriate state or federal courts located in Miami-Dade County, Florida, or where otherwise required by applicable law. You hereby irrevocably submit to the personal jurisdiction of such courts and waive any objection based on inconvenient forum, venue, or jurisdiction to the extent permitted by law.

Nothing in this section shall preclude either party from seeking equitable relief, including injunctive or other provisional remedies, in any jurisdiction where such relief is deemed necessary to protect their respective rights or to preserve the status quo pending arbitration or judicial proceedings.

17. Modifications to Terms

Blink reserves the right, subject to the Florida Deceptive and Unfair Trade Practices Act (FDUTPA),and other applicable lawBlink reserves the right, subject to Chapter 501, Part II, Florida Statutes and other applicable laws, to modify, amend, supplement, or replace these Terms and Conditions with reasonable notice to users. Any such modifications will become effective upon posting a revised version of the Terms within the Blink App or on Blink's official website, or upon delivery of electronic notice to users via their registered email address, provided that such notice complies with Florida consumer protection requirements.

In the case of material modifications that may substantively impact users' rights or obligations, Blink shall endeavor to provide reasonable prior notice, no fewer than thirty (30) calendar days in advance of the effective date, unless immediate implementation is required by legal, regulatory, or security concerns, in which case notice will be provided as soon as practicable. Material changes may include, but are not limited to, revisions to service eligibility, fee structures, dispute resolution provisions, or terms governing data access and privacy.

By continuing to access or use the Blink App after receiving clear notice and after the effective date of any changes, as required by Florida Statute §501.201 et seq., users signify their acceptance of the revised Terms, provided that such changes comply with applicable Florida law. If a user does not agree to the modified Terms, they must cease all use of the Blink App and its associated services and may request account deactivation by contacting Blink Support.

, with email notices sent to the user's registered email address,through both email and prominent display within the Blink AppBlink will provide users with at least thirty (30) days' advance written notice of any material changes to these Terms, as required by Florida law, and such changes will become effective only after the notice period has expired. Blink's liability limitations regarding notice of amendments shall be subject to applicable Florida consumer protection laws and regulations regarding contract modifications.

18. Severability, Waiver & Survival

If any provision is found unenforceable under Florida law or otherwise, including but not limited to violations of Florida's consumer protection laws, such provision shall be modified to the minimum extent necessary to make it enforceable while preserving its intent, and if not modifiable, shall be severed without affecting the validity and enforceability of the remaining provisions, which shall remain in full effect. No waiver of any right under these Terms shall be effective unless in writing and signed by the waiving party, and Blink's failure to enforce any right shall not constitute a waiver. Obligations regarding dispute resolution, compliance, liability limitation, and any accrued financial obligations survive account closure or termination of these Terms.

19. Notices, Communications, and Contact

All notices, legal inquiries, or other formal communications required or permitted under these Terms shall be made in writing (including electronic communication that complies with Florida Electronic Signature Act §668.50) and delivered to Blink through one of the following official communication channels (each a "Notice Channel"), with notice deemed given upon confirmed receipt by the receiving party, provided that such confirmation shall be provided within two (2) business days of receipt, unless a shorter period is required by applicable Florida law:

By email: support@blinkfinances.com
By mail: [Physical Address Required by Florida Law]

Through the Blink App: via in-app support or secure messaging functionality, where available. Users will receive timestamped confirmation of all in-app communications within twenty-four (24) hours, in accordance with Florida consumer protection standards and electronic communication laws.

By accepting these Terms, users expressly consent to receive all communications and disclosures from Blink electronically, either by email or through the Blink App, in accordance with Florida Electronic Signature Act (§668.50) and other applicable laws. Users may request paper copies of any electronic communication at no additional cost, and certain legally required notices will be provided in paper form. (or sooner if required by applicable Florida law)Paper copy requests must be fulfilled within five (5) business days of receipt, at no cost to the user except for reasonable shipping and handling fees not exceeding actual costs, which shall be clearly disclosed prior to fulfillment, as permitted by Florida law and §501.0117, Florida Statutes. Such communications include, but are not limited to, amendments to these Terms, legal notices, account updates, transaction confirmations, compliance requests, and other disclosures related to Blink services.

It is the user's responsibility to ensure that the email address and contact information associated with their Blink account remains accurate and up to date, and users agree to update such information within ten (10) business days of any change. Users are responsible for any consequences that may arise from failing to maintain current contact information, subject to applicable law and any non-waivable rights under Florida consumer protection laws.

In accordance with Florida Electronic Signature Act (§668.50), any notice sent by Blink shall be deemed received by the user upon (i) confirmation of delivery, if sent via email to the user's registered email address, or (ii) five (5) business days after mailing, with tracking number provided to user, if sent via U.S. Postal Service with delivery confirmation to the last known mailing address provided by the user, unless return receipt or delivery confirmation indicates otherwise.

All user-initiated notices shall be deemed received upon actual receipt by Blink, with electronic notices deemed received when accessible by Blink as provided under Florida Statutes § 668.50(15). Blink shall acknowledge receipt of such notices within two (2) business days. For urgent matters involving unauthorized transactions or security concerns, Blink will respond within one (1) business day of receipt, and within twenty-four (24) hours or such shorter time period as may be required by applicable Florida law for suspected fraud or unauthorized access. Users seeking support, clarification of these Terms, or to report any service-related issue should direct such communications to the Blink Support Team during regular business hours:

Blink Support Team
123 Main Street
Miami, FL 33101
ATTN: Legal Notices Department
support@blinkfinances.com

For urgent matters requiring immediate attention, please mark your email "URGENT" in the subject line. Urgent matters will receive priority response within four (4) hours during business hours, or by the start of the next business day if received outside of business hours. For emergencies involving unauthorized access or suspected fraud, please also call our toll-free number during business hours.
Toll-free: [INSERT ACTUAL TOLL-FREE NUMBERS] (available Monday through Friday, 9:00 AM to 5:00 PM Eastern Time, excluding Florida state holidays)

Monday–Friday, 9:00 AM to 5:00 PM (Eastern Time)

Users acknowledge and agree that all oral, electronic, written, and other forms of communication, including but not limited to telephone calls, video conferences, emails, text messages, and in-app communications, between the parties may be recorded or archived by Blink only after receiving explicit notice and providing affirmative consent to such recording as required by Florida Statutes § 934.03. Such recording and archiving shall be conducted for quality assurance, training, dispute resolution, fraud prevention, and regulatory compliance purposes, in accordance with Florida law including but not limited to Florida Statutes § 934.03 and applicable federal laws. Users will be notified of any recording through clear and conspicuous notice prior to the start of any recorded communication, and may withdraw consent to recording at any time, provided that such withdrawal may impact service availability.