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PRIVACY POLICY

FACTS

WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

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

• Identifiers and contact information (e.g., name, email, phone numbers, address).

• Application/request information (e.g., date of birth, military and employment status, employer and job title, time at job and address, income and pay details, requested amount and purpose, whether you own a car or home, mortgage status, self-reported credit score or debt amount, best time to call).

• Sensitive identifiers (e.g., Social Security number; driver’s license number and issuing state).

• Financial account information (e.g., bank name, routing and account number, account type, time with bank, direct deposit status).

• Transaction and experience information related to your request and interactions with us (e.g., submission dates, servicing and customer support records, survey responses).

• Credit information (e.g., results of a soft inquiry obtained with your written instructions; not shared with third parties; participating lenders may obtain credit reports directly from consumer reporting agencies).

• Technical and security data used to protect and process your request (e.g., IP address and device/user-agent, cookies/session identifiers used for fraud prevention, authentication, and consent logging; not used for cross-context behavioral advertising).

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share; and whether you can limit this sharing.

SHARING YOUR PERSONAL INFORMATION

Reasons We Can Share Your Personal Information

Do We Share?

Can You Limit Sharing?

For our everyday business purposes — to process your request, verify identity, prevent fraud, evaluate eligibility, and route/transmit your information (including via a lender “ping” process) to participating Lenders/Networks or Third-party Marketers - personal-finance-related service providers at your direction

Yes

No

For our everyday business purposes — information about your creditworthiness (e.g., enabling an FCRA-permitted soft inquiry pursuant to your written instructions; Lenders obtain reports directly from CRAs)

Yes

No

For our marketing purposes — to market our own websites and Services to you (e.g., to bring you back to complete your request)

Yes

No (communications preferences/TCPA & CAN-SPAM still apply)

For joint marketing with other financial companies

No

We don’t share

For our affiliates’ everyday business purposes — information about transactions and experiences

No

We don’t share

For our affiliates’ everyday business purposes — information about your creditworthiness

No

We don’t share

For our affiliates to market to you

No

We don’t share

For nonaffiliates to market to you

Yes

Yes (consent/ direction exception applies)*

*Clarification about exception: When Lenders/ Networks contact you about the credit you asked us to match you for, that disclosure occurs to effect, administer, or enforce your requested transaction and/or at your direction. It is not a “nonaffiliate marketing” share. Non-selected recipients in the ping process are contractually prohibited from contacting you and must not retain your information.

We disclose your information to Lenders/ Networks and Third-party Marketers at your direction (consent), so they can contact you about their products. We retain records of your direction.

To Limit Our Sharing

Email contact@upfinances.com with subject “GLBA opt-out” and include your name, email, and phone number used on your request.

What this does: Your choice limits our sharing of your nonpublic personal information with non-affiliated third parties so they can market their own products to you.

What it doesn’t limit: This choice does not limit disclosures needed to evaluate, effect, administer, or enforce your current request (including lender “ping” eligibility checks), disclosures to our service providers/contractors acting on our behalf.

Duration & scope: Your choice remains in effect until you tell us otherwise. We will apply it as soon as reasonably practicable and include your preference when we share leads.

When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions?

Email us at contact@upfinances.com

 Sharing Your Sensitive Personal Information

We share Sensitive Personal Information only with our Marketing Partners when necessary to assist you in finding a loan, when required by law, or with your explicit consent. The non-exhaustive list of Marketing Partners is available here.

Definitions

Affiliates

Companies related by common ownership or control. They are non-financial companies.

Non Affiliates

Companies not related by common ownership or control. They can be financial and non-financial companies (see categories below).

Third-party Marketers

Non-affiliated providers or promoters of personal-finance products/services (and their intermediaries), including credit, banking/fintech, credit-monitoring/builder/education or repair, and debt-management/relief offerings.

Lenders/ Networks

Non-affiliated lenders, together with their intermediaries (including agents, aggregators, brokers, lead networks, and marketplaces) and service providers acting on their behalf.

Marketing Partners

Lenders/ Networks and Third-party Marketers

Categories of Non-Affiliates We Share Information With

• Lenders/ Networks
• Third-Party Marketers
• Service Providers (Cloud storage and hosting providers (e.g. AWS), Email/SMS delivery providers, Consumer Reporting Agencies (CRAs) or facilitators, advertising platforms).

WHO WE ARE

Who is providing this notice?

This notice is provided by  upfinances.com, the entity responsible for collecting and processing your personal information as you interact with our platform.

WHAT WE DO

How We Protect Your Information

We employ industry-standard security measures, including:

• Secure transmission of credit data under § 1016.30(b) (GLBA Safeguards (encryption).
• Firewalls and secure data storage.
• Restricted access to sensitive information.
• Multi-factor authentication
• Regular security assessments
• Breach response plans
• Controlled data sharing: We ensure that any transfer of data to our partners is limited to specified purposes and governed by agreements that include strict security and confidentiality obligations.

However, no method of transmission over the Internet is 100% secure.

How Do We Collect Your Personal Information?

We collect your personal information when you:

• Submit an inquiry on our platform or on our affiliates’ websites.
• Interact with our website, including browsing, filling out forms, answering surveys.
• Communicate with us.

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies as permitted.

Under applicable laws you can’t limit sharing personal information for business purposes, such as but not limited to: processing your request to connect you with a lender, preventing fraud, etc.

You may limit our sharing with non-affiliated marketers for their own offers – see State Track for additional opt-outs that do not apply to GLBA data.

OTHER IMPORTANT INFORMATION

We do not sell or share personal information collected on this loan offer inquiry page for cross-context behavioral advertising, and we do not use targeted advertising on this page. Limited hashed identifier uploads to advertising platforms are conducted outside the loan form context and are covered under Part B.

When we process information in connection with a financial product or service, it is governed by GLBA/FCRA. Accordingly, state-law rights (e.g., “Do Not Sell/Share,” limit Sensitive PI, GPC/UOOM) do not apply to these processings.

Category (collected on this site)

Examples

Sources

Purpose

Shared with

Identifiers

Phone, email

From you on this site

Identification, to contact about offers from Marketing Partners, Communication

Third-Party Marketers (Non-GLBA Uses)

Service Providers

Internet / Network Activity

Cookies/pixels/SDKs, pages viewed, referrers/UTM, approximate IP-based location

Automatically via our systems when you visit the site

To create, manage, and optimize advertising audiences on platforms such as Meta and TikTok

Advertising Platforms

Communications & Consent Records

TCPA/email consents, “Do Not Sell/Share”, unsubscribe logs

An explicit form submit

To comply with applicable laws

Third-Party Marketers (Non-GLBA Uses)

Service Providers

Shared With (Category of Third Party)

Categories of Personal Information Sold/Shared

Third-Party Marketers (Non-GLBA Uses)

Identifiers, Commercial, Internet / Network Activity, Inferences (from this site), Geolocation (approx.), Consent Records

Categories of Service Providers

Business Purpose for Disclosure

Categories of Personal Information

Cloud Storage and Hosting Providers (e.g. AWS)

 Securely storing and managing data

All categories of Personal Information

Email/SMS Delivery Providers

Transactional and marketing communications

Identifiers

Consumer Reporting Agencies (CRAs) or facilitators

Obtain consumer report information to verify identity, assess eligibility, and determine which services/offers you may qualify for from participating Marketing Partners

Identifiers

Advertising Platforms

To create, manage, and optimize advertising audiences on platforms such as Meta and TikTok

Identifiers, Internet or Other Electronic Network Activity (hashed only)

Right

Description

Right to Know / Access

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, including the sources, purposes for collection, categories of third parties with whom we share it, and whether it was sold or shared.

Right to Delete

You can request that we delete personal information we have collected from you. We will comply unless there is a legal or business reason to retain it, such as completing a transaction, detecting security incidents, or complying with legal obligations.

Right to Correct

You have the right to request that we correct any inaccurate personal information we maintain about you, and we will use commercially reasonable efforts to do so upon verification of your identity.

Right to Data Portability

You have the right to obtain and reuse your personal information for your own purposes. We will provide your information in a structured, commonly used, and machine-readable format upon request.

Right to Opt-Out of Sale/Sharing

You may opt out of the sale or sharing of your personal information, including sharing for targeted advertising purposes.

Right to Opt-Out of Automated Decision-Making

In states like Colorado, Connecticut, and Virginia, you may opt out of profiling and automated decision-making that produces legal or similarly significant effects.

Right to Limit Use of Sensitive PI

You may request that we limit the use or disclosure of your sensitive personal information (e.g., account log-in) unless it's strictly necessary to provide the requested services.

Right to Non-Discrimination

You have the right not to be discriminated against for exercising your privacy rights. This means we won’t deny services, charge different prices, or provide a lower level of service based solely on your privacy choices.

Right to Appeal

If we deny your request to access, delete, or correct your information, you can appeal the decision. We will provide clear instructions on how to submit an appeal and respond within the time period required by law.

Right to Lodge Complaint

If you believe your data privacy rights have been violated, you may file a complaint with your local data protection authority or relevant regulatory body.