Financial Privacy Policy

FINANCIAL PRIVACY POLICY

Company Name:

Effective Date:

Purpose

This Financial Privacy Policy (Policy) describes the types of nonpublic personal information we collect in the course of providing financial products and services, how that information is used and disclosed, the safeguards we maintain to protect such information, and the choices available to consumers with respect to sharing of their information. This Policy applies to financial services and products offered by the Company to individuals and entities.

Scope

This Policy governs information collected in connection with the evaluation, origination, servicing, or collection of accounts, loans, investment products, and other financial services. It does not cover information collected in the context of employment screening or public information lawfully obtained from public sources.

Definitions

"Nonpublic personal information" means information about a consumer not publicly available, including information provided by the consumer, resulting from transactions, or otherwise obtained. "Affiliate" means a company that controls, is controlled by, or is under common control with the Company. "Nonaffiliated third party" means a third party that is not an affiliate.

Information We Collect

We collect the following categories of information necessary to provide and administer financial services. Please indicate which categories apply to your accounts (check all that apply):

Identifying information (name, address, date of birth, SSN or taxpayer ID) Account information and transaction history (account numbers, balances, payment history) Credit and underwriting information (credit reports, scores, employment verification) Payment methods and banking instructions Other

Use of Information

We use nonpublic personal information for purposes that are necessary or incidental to the provision of financial products and services, including underwriting, account administration, recordkeeping, fraud prevention, regulatory compliance, and to evaluate and improve our products and services. We also use information for risk management, loss mitigation, and responding to subpoenas or legal process.

Sharing and Disclosure

We may disclose nonpublic personal information as follows. Each category below contains representative legal bases and reasonable limits on disclosure.

Affiliates: We may share customer information with our affiliates for purposes consistent with the services we provide, including joint product offerings, risk management, and servicing. Such disclosures are limited to what is reasonably necessary for the stated purposes and are subject to our internal access and use controls.

Nonaffiliated third parties and service providers: We may disclose information to third-party service providers that perform services on our behalf, such as payment processing, data storage, document management, analytics, and credit reporting. We require service providers to implement appropriate safeguards and to use information only for the contracted purpose.

Legal or regulatory requirements: We may disclose information where required or permitted by law, including law enforcement requests, regulatory examinations, or to protect our legal rights and property.

Consumer Choices and Opt-Out

Consumers may exercise choices available under applicable law with respect to the sharing of nonpublic personal information for purposes other than those necessary to provide core financial services. Please indicate the method by which the consumer may opt out of certain information sharing:

If an opt-out is exercised, we will honor the request consistent with applicable law and the nature of the request. Certain disclosures necessary to service an account, to comply with law, or to protect against fraud cannot be limited by opt-out.

Security Safeguards

We maintain administrative, technical, and physical safeguards designed to protect nonpublic personal information against unauthorized access, disclosure, alteration, or destruction. These measures are regularly reviewed and updated to reflect changes in technology and regulation.

Data Retention and Disposal

We retain customer information for the period necessary to fulfill the purposes described in this Policy and to meet legal, regulatory, and business requirements. When information is no longer required, we dispose of it in a manner intended to protect against unauthorized disclosure.

International Transfers

To the extent information is transferred to recipients located outside the country where the consumer resides, we will take reasonable steps to ensure that the recipient provides appropriate protections for such information consistent with this Policy and applicable law.

Changes to This Policy

We may amend this Policy to reflect changes in our practices, legal requirements, or product offerings. Material changes will be communicated to affected consumers in writing or by other means reasonably calculated to provide notice prior to the effective date of the change.

Consumer Inquiries and Complaints

Consumers may direct privacy inquiries, requests to limit sharing, or complaints to the Company’s compliance contact below.

Certification

The undersigned certifies that the information contained in this Policy accurately describes the Company’s practices with respect to the collection, use, retention, disclosure, and protection of nonpublic personal information as of the Effective Date above. The undersigned further certifies that the Company will implement and maintain reasonable procedures to comply with the obligations set forth herein.

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