Last Updated January 2021

Your privacy is important to CreditInnovationGroup(“CIG”). Please read our Privacy Policy carefully to understand how we collect, use, disclose, transfer, and store your information. By visiting CIG’s website or agreeing to content that includes a link to this document (“Online Ads”), you agree to the practices described in this Privacy Policy and our Terms of use.

Our Collection and Use of Personal Information

Personal Information is information you provide us that can be used to uniquely identify or contact a single person, such as your name, email address, phone numbers and tax identification number.

You may be asked to provide Personal Information when you interact with CIG, Online Ads, or one of CIG’s related companies, such as in connection with a completed or abandoned transaction or a request for information from CIG. CIG and its related companies may share your Personal Information with each other and use it consistent with this Privacy Policy.

CIG may supplement the Personal Information you provide with Personal Information available from other sources, such as public databases, data aggregators, and other commercially available sources.

Examples of Personal Information We Collect and How We Use It

You may provide CIG a variety of Personal Information, including your name, mailing address, email address, phone number, payment information, and tax identification number.

The Personal Information we collect allows us to deliver requested products, services and information to you, to stay in contact with you, and to manage CIG’s relationship with you. By providing CIG with Personal Information, you consent to CIG’s transfer and storage of that information.

CIG also may use your Personal Information for research, development, and analysis, and for advertising, marketing, product and service offerings, security, fraud prevention, and other business activities.

Our Collection and Use of Non-Personal Information

Non-Personal Information is information in a form that does not allow for direct association with a specific person. This information is compiled and analyzed on both a personal and an aggregated basis. We may collect, use, monitor, analyze, transfer, and disclose Non-Personal Information for any purpose.

Examples of Non-Personal Information We Collect and How We Use It

We may collect and aggregate information regarding user access, activity and behavior on our website, such as when you visit the website and what content is of interest or seems to be most useful to you. If we combine Non-Personal Information with Personal Information, the combined information is treated as Personal Information for purposes of this Privacy Policy.

Non-Personal Information includes:

Device Information – We may collect specific information for the device you use to access our website. For example, we may collect device model, IP address, MAC address, operating system version, application software, fonts, and other device information and identifiers.

Cookies and Other Technologies – We use a variety of technologies to collect and store information when you visit our website. This technology may involve sending web beacons and cookies or anonymous identifiers to your device.

We use Cookies and Other Technologies to analyze your behavior when accessing our website and to deliver ads to you that relate to your interests.

Log Information – When you visit our website, we collect certain information automatically and store it in log files. This information includes IP address, browser version, ISP data, referring and exit pages, operating system version, date / time stamps, cookie data, and clickstream data.

We use Log Information to administer the website, analyze trends, maintain site security, learn about user behavior, and improve the overall quality and availability of the site.

Click-Through URLs – In some email messages, we use a Click-Through URL to link to content on our website. When you click one of these URLs, you pass through a separate web server before reaching our site.

We use Click-Through URLs to help us determine interest in a particular topic and to measure the effectiveness of our email communications.

Anonymized Information – If we separate Non-Personal Information from Personal Information, the separated information is treated as Non-Personal Information for purposes of this Privacy Policy.

Our Sharing of Information with Others

Personal Information

We do not share Personal Information with businesses or individuals outside of CIG, except under the follow circumstances:

Consent – We will share your Personal Information with others outside of CIG when we have your consent to do so.

Service Providers – We provide Personal Information to related companies and other trusted businesses or persons who use, analyze, or process it on our behalf, based on our instructions and in compliance with appropriate confidentiality and security measures. For example, we may use others to:

• deliver, evaluate the effectiveness of, and assist in improving our products and services

• conduct consumer research and satisfaction surveys

• assist us in analyzing and understanding consumers and how to reach them more effectively

• assist us in fraud prevention, with our security measures, and to provide us technical support

• provide customer support

• manage customer data, and to ensure data integrity and accuracy

• process financial transactions and perform accounting functions

• advertise, market, or make product or service offerings

Legal Reasons – We will share Personal Information with others outside of CIG if we have a good-faith belief that disclosure is necessary or appropriate to:

• comply with applicable law, regulation, legal process or enforceable governmental request
• protect our operations or customers
• detect, investigate, or address fraud, security, or technical problems
• investigate potential violations of and enforce applicable terms of service

In the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third-party.

Non-Personal Information

We may share Non-Personal Information publicly and with our strategic partners. For example, we may share Non-Personal Information to describe the size and success of our company.

Transparency and Choice

CIG may use third-party display advertising companies, including Google, to serve CIG ads on its behalf on sites across the Internet. CIG and its display advertisers use cookies to inform, optimize, and serve ads based on your past visits to CIG’s website.

You may find additional information, opt-out of, or otherwise customize display advertising from Google or DoubleClick by visiting Google’s Ads Preference Manager.

You may find additional information and opt-out of other participating third-party display advertising by visiting the Network Advertising Initiative opt-out page.

CIG may use third-party analytics companies, including Google Analytics and Omniture to analyze and understand user behavior when visiting our website.

You may find additional information and opt-out of Google Analytics by visiting the Google Analytics opt-out browser add-on.

You may find additional information and opt-out of Omniture Analytics by visiting the Adobe opt-out page.

You also may want to consider disabling cookies within your browser. Please note, however, that certain features of the CIG website will not function properly or be available once cookies are disabled.

Social Media Plug-ins

Plug-ins for social networks, such as Facebook, Twitter, LinkedIn, Yahoo, Windows and Google plus (among others), are integrated on CIG’s website.

By interacting with us through a social media plug-in, certain information will be transmitted to the related social network, and you permit us to have on-going access to information from your social network profile.

If you do not want the social network to collect information about you, or to share it with CIG and other third parties, please review the privacy policy of the relevant social network and/or log out of the relevant social network before you visit CIG’s site.

Information Security and Retention

CIG takes precautions to safeguard your Personal Information from loss, theft, and misuse, as well as unauthorized access, disclosure, alternation, and destruction. These precautions include technical, physical, and managerial procedures.

Because email and instant messaging are not recognized as secure communications, we request that you not send private information to us by email or instant messaging services.

We regularly review our compliance with our Privacy Policy and enforce safeguards within the company.

We are committed to working with appropriate regulatory authorities to resolve any complaints regarding the transfer of Personal Information that we cannot resolve with our customers directly.

CIG uses Secure Sockets Layer (SSL) encryption on all pages where Personal Information is collected. This protects the confidentiality of your Personal Information while it is transmitted over the Internet.

For your own protection, you should exercise care with the information you share over the Internet. You should always use a secure browser and exercise good judgment in using passwords, such as using a combination of upper and lower case letters, numbers, special characters, and you should avoid using the same or similar passwords across multiple sites.

Clients may access their Personal Information by logging into their account. We make good-faith efforts to give you ways to update or to delete your Personal Information quickly, unless we need to keep that information for a legitimate business or legal purpose. Some changes require personal contact with an assigned CIG representative.

CIG retains Personal Information and Non-Personal Information for the time necessary and reasonable to fulfill the purposes outlined in the Privacy Policy, unless a longer retention period is required or permitted by law.

We may reject requests to change or delete information that are unreasonably repetitive, require disproportionate technical effort (for example, requiring the development of new systems or fundamental changes to existing systems), risk the privacy of others, or would be extremely impractical (such as information stored on backups).

We work to protect data from accidental or malicious destruction. Accordingly, we may not immediately delete or change residual copies and we may not delete or change information from our backup systems. Unless a disproportionate effort is required, we will provide information access and correction without charge.

Third Party Privacy Policies

This Privacy Policy only addresses the use and disclosure of information we collect from you. This policy does not apply to the practices of companies that CIG does not own or control or to people that CIG does not employ or manage. CIG does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others. For more information about each such third party, please refer to the third party’s privacy policy.

If you provided your information on the website of an entity not related to CIG, and that entity shared your information with us, the privacy policy of that website governs the non-related entity’s use of your information, which may be different from this policy.

Children

We do not knowingly collect Personal Information from children under 13. If we learn that we have collected the personal information of a child under 13, we will take steps to delete the Personal Information as soon as possible.

Privacy Policy Changes and Questions

CIG may update its Privacy Policy from time to time. Changes to this Privacy Policy will be posted on CIG’s website, with a corresponding revision date. Please check the website and Online Ads each time you use them for the most current information and to ensure that you are aware of any updates.

Request for Information

If you have any questions or concerns about CIG’s Privacy Policy, please contact us: CS@CreditInnovationGroup.com