PRIVACY NOTICE

Last updated: January 2024

This online privacy notice for Alt Lending LLC (“Company,” “we,” “us,” or “our”), describes how we collect, store, use, and/or secure the personal information we gather about you through our services (“Services”), such as when you:

•  Visit our website at http://www.altlendingllc.com, or any website of ours that links to this privacy notice (the “Site”).
•  Download and use our mobile application (Alt Lending), our Facebook application (Alt Lending), or any other application of ours that links to this privacy notice.
•  Engage with us in other related ways, including any sales, marketing, or events.

For purposes of this Notice , personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations, such as aggregated, anonymized, or deidentified data. Nothing in this Notice will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to the Company generally or in any specific context.

This Notice expressly incorporates any privacy notices we may issue to supplement this Notice. Depending on your residency, a supplemental privacy notice may apply to you. For example, if you are a California resident, please view our California Privacy Notice. If you are an employee or job applicant, please review our Employee Privacy Notice.

Questions or concerns? Reading this Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@thealtlender.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

YOU CONSENT TO THIS NOTICE

You should read this Notice carefully, so that you understand our privacy practices and our Terms of Use. By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Notice. If you do not agree to this Notice, you may not use the Services.

This Notice and the Terms of Use apply regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Notice together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Notice supplements these other notices and is not intended to override them.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

WHAT TYPES OF INFORMATION DO WE COLLECT?

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties. The categories of personal information that we collect and the purposes for which we collect that information are described below.

1. Categories of Personal Information We Collect
   The following list describes the categories of personal information we collect.

• Financing Application Information includes name, email address, postal mailing address, telephone number, date of birth, profile photo, username, and password. We may also collect identity verification information in connection with creating your account such as your Social Security Number, passport information, driver’s license information, other identity documents, and tax-related information. We collect this information for the purposes of account creation and maintenance, advertising and marketing, analytics and research, customer service, providing the Services, and website security and maintenance.
• Analytics Information. We collect certain analytics information automatically as you navigate our Services. This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails. For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below. We collect this information for the purposes of account management, advertising and marketing, analytics and research, customer service, providing the Services, and website security and maintenance.
• Contact Information includes name, email address, postal mailing address, contacts you choose to submit, and phone number. We collect this information when you provide it directly to us such as signing up for newsletters, requesting information about our services, creating an account, or filling out a form. We collect this information for the purposes of advertising and marketing, analytics and research, and customer service.
• Financial Information includes financial data, credit worthiness data, and student data. We, or our service providers, collect this information for the purposes of account management, customer service, providing the Services, and website security and maintenance.
• Responses to Surveys and Questionnaires includes information you provide to us when you respond to marketing materials, promotions, contests, or other surveys. We collect this information for the purposes of advertising and marketing, analytics and research, and customer service.
• Social Media Information includes your social media account information if you choose to register in this way and information that you post by sharing on a blog or another social media platform, or information you post on public areas of our Services, such as your profile photo. We collect this information when you provide it directly to us. Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private. We collect this information for the purposes of advertising and marketing, and analytics and research.
• Application Data. We may collect certain information if you use our application, including geolocation information, mobile device data. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access

We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. If you opt out, you may not be able to use certain aspects of the Services.

2. Purposes for Collection of Personal Information

The following chart identifies the purposes for which we collect your personal information, as well as information regarding our use and disclosure of that personal information. Please note that we may not collect each category of information about each user of our Services.

3. We do not sell any of your information.

4. Other Ways We Collect, Use, or Share the Information
   We also reserve the right to collect, use, or share personal information for the following purposes:

• To Provide the Services. We will use your personal information to provide the Services, including to improve operations and offerings and for security purposes.
• To Present the Site. We will use personal information to present our Site and its contents in a suitable and effective manner for you and your device.
• For Legal Purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful or unlawful user activity on this site. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Please note that we are in a highly regulated industry, and we therefore may need to provide your information to regulators, agencies, or other groups that have oversight. We may also use your information to fulfill our obligations under applicable laws, regulations, or standards, including relating to threat detection and to determine whether we can provide Services to you.

• Business Transactions or Mergers. We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence. If we close a transaction, we may transfer personal information to the purchaser or the third party may transfer personal information, which we would use as described in this Notice.
• Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
• Service Providers. We use service providers to perform various functions on our behalf. Such service providers will be under contractual obligations to safeguard your personal information and only process it in accordance with our instructions, or as otherwise permitted by applicable laws. We may also receive personal information from service providers.
  

• Business Partners and Affiliates. We may collect personal information from and share personal information with our business partners and affiliates, including legal advisors and financial advisors, and co-branded partners. We may combine that information with other information we collect about you, but we will always use the information as described in this Notice. We may also share information with our affiliates, subsidiaries, joint ventures or other companies under common control.

HOW DO WE USE “COOKIES” AND OTHER TRACKING TECHNOLOGIES?

We send cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.

1. What Are Cookies?

Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Services, we use cookies and other tracking technologies to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Services according to your individual needs;
• Contact you to provide you with information or services that you request from us;
• Advertise new content, events, and services that relate to your interests;
• Provide you with more personalized content that is most relevant to your interest areas; and
• Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties. You can manage your cookies preference as described in the “Managing Your Cookies” section below.

2. What Types of Cookies Do We Use and Why?

The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers. Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.

We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.

3. How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Services until the end of that particular browsing session. These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences, your use of the Services over time, and the effectiveness of advertising efforts.

4. Managing Your Cookies

 It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services. You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.

5. Does the Site Respond to “Do Not Track” Signals?

 At this time, our Site does not respond differently based on a user’s Do Not Track signal. 

HOW DO WE MANAGE YOUR SOCIAL LOGINS?

If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notices to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

COLORADO, CONNECTICUT, VIRIGINIA, AND UTAH USERS’ RIGHTS

Colorado, Connecticut, Utah, and Virginia residents have certain rights with respect to their data. These rights are established through the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”). The chart below explains these rights and lists the states whose residents may exercise those rights. To exercise any of the following rights listed in the chart below, please see our Data Subject Request page or our Your Privacy Rights page.

• Sensitive Information

Sensitive Data as defined in the CTDPA, UCPA and VCDPA includes precise geolocation information. We will not collect this information from Connecticut, and Virginia residents without first obtaining consent. Utah residents have the right to opt out of this collection.

• Exercising Your Rights

If you are a Colorado, Connecticut, Virginia, or Utah resident and wish to exercise one of the above rights and it applies to you, please visit our Data Subject Request page or our Your Privacy Rights page.

If necessary, we may request additional information reasonably necessary to authenticate you and your request.

In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights.

We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay. If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.

We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside. We may charge a fee in:

Colorado, Connecticut, and Utah, if you make more than one request in a twelve-month period; and Connecticut and Virginia, if the request is manifestly unfounded or excessive, or repetitive in nature.

• Appealing a Rights Request Decision

If you are a resident of Colorado, Connecticut, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision. To do this, you may email us at info@thealtlender.com. In the email appeal, please specify the right(s) you requested to exercise and the date you made such a request.

We will inform you in writing within 45 days of any action taken or not taken in response to the appeal. We will also provide a written explanation of the reasons for our decisions regarding your request(s).

ADVERTISING AND MARKETING CHOICE

We respect your rights in how your personal information is used and shared. We may communicate with you via email, telephone, postal mail, and/or your mobile device about our products and services. If at any time you would like to unsubscribe from receiving future marketing emails, you can email us at info@thealtlender.com. follow the instructions at the bottom of each applicable email, or reply "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, and we will promptly remove you from those marketing correspondences that you choose to no longer receive. Please note, however, that we may still need to contact you regarding other matters.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

If you use our mobile application, you can delete your account by submitting a request to info@thealtlender.com or by deleting your account through the application itself. If you delete your account from within the application, we will delete the accompanying personal data unless we are required to retain it for legal, regulatory, contractual, or other compliance purposes.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

WHERE IS YOUR PERSONAL INFORMATION HELD?

We process personal information on our servers in the United States of America and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

THIRD PARTY LINKS

Our Services may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Notice only applies to our Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

DO WE COLLECT INFORMATION FROM MINORS?

Protecting the privacy of the very young is especially important. Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact Us” section below.

DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Contact Us

If you have questions or comments about this Privacy Notice, you may email us at info@thealtlender.com or by mail to:

Alt Lending LLC
8701 E. Hartford Dr
Suite 125
Scottsdale, AZ 85255