PRIVACY POLICY

Effective Date: September 1, 2021

Solventa respect and protect the privacy of visitors to our websites and our customers. We use information and communication technologies; we operate through digital platforms with simplicity and agility in the process. Our main goal is to offer better alternatives to people who are joining the growing Fintech ecosystem, providing greater possibilities to finance unexpected expenses.

This Privacy Policy explains how we and our affiliates collect, secure, use, and disclose your personal information through our website www.solventa.com, and it applies to personal information we collect from you and from third parties. Also, how we protect personal information provided through the website and how we use that information in connection with our service offered through the Solventa’s services. Please take a moment to read this Privacy Policy carefully, as it will help you understand what we do with the information that we collect.

Providing us with personal information through Solventa website, you signify that you have read, understood and agree to our collection, storage, use, and disclosure of personal information about you as described in this Privacy Policy and any updates we make. We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. Our Terms of Use take precedent over any provision conflicting with our privacy policy.

Facts	What does Solventa 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: Social Security number and account balances Transaction history and income Account transactions and checking account information When you are no longer our customer, we continue to share your information as described in this notice.
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 Solventa chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Solventa share?	Can you limit this sharing?
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	YES	NO
For our marketing purposes — to offer our products and services to you	YES	NO
For joint marketing with other financial companies	NO	We don’t share
For our affiliates' everyday business purposes — information about your transactions and experiences	YES	NO
For our affiliates' everyday business purposes — information about your creditworthiness	YES	NO
For our affiliates to market to you	NO	We don’t share
For nonaffiliates to market to you	NO	We don’t share

To limit our sharing	Call 307-984-062 Contact us at: [email protected] Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. 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?	Call 307-984-062 or go to www.solventa.com

Who we are
Who is providing this notice?	Solventa Corp.

What we do
How does Solventa protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Solventa collect my personal information?	We collect your personal information, for example, when you: apply for a loan Open a Solventa account or provide account information Show your government issued ID When you use Solventa Services Give us your contact information We also collect information about you from others, such as credit bureaus and other companies.
Why can't I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates' everyday business purposes - information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account, I hold jointly with someone else?	Your choices will apply to everyone on your account - unless you tell us otherwise.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates with whom we may share can include: other financial services companies (including other financial institutions, such as banks) and non-financial service providers such as hosting platforms, and fraud protection vendors, sanctions screening vendors, data processors, marketing partners, and API integrators. Plaid: In order to provide you with the best service possible, the Company uses an Application Programming Interface supplied by Plaid Technologies, Inc. ("Plaid"), used to gather your data from financial institutions. By using the Website and/or Services, you acknowledge and agree to Plaid’s privacy policy, available at https://plaid.com/legal and acknowledge and agree that your information shall be treated in accordance with such policy.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Solventa does not perform joint marketing

Other important information
For California residents	If your Solventas account has a California mailing address, we will not share your personal information we collect about you with companies outside or nonaffiliates for their marketing purposes except with your express consent or as otherwise authorized by California law.
For Vermont residents	We will not share information we collect about you with nonaffiliated third parties, except as permitted by Vermont law, or with you provide authorization, such as to process your transactions or to maintain your account. We will not share information about your creditworthiness with our affiliates except with your authorization or as required or permitted by law. We may share information about our transactions or experiences with you within our corporate family without your consent.
For Alaska, Illinois, Maryland, and North Dakota Customers	We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization.
For Massachusetts, Mississippi and New Jersey Customers	We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing – without your authorization.

1. Personal information we collect

Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

1. Information you provided us

We collect personal information that you voluntary provide us when you register on the website, is collected from you to help you use our services. When we say “personal information,” we mean information that specifically identifies you. If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you, our services. Any information you provide to us that is not required is voluntary.

1. Personal information

Examples of personal information include:

• Personal Identification Information: Full name, date of birth, signature, phone number, home address, and/or email.

• Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.

• Employment Information: Office location, job title, and/or description of role.

• Financial Information: Bank account information, payment card primary account number (PAN), transaction history.

2. Information we collect about you

Is data we collect about your use of our or third-party websites or services used to help us understand consumer trends, needs, interests, and helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information includes:

• Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

• We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third-party site.

1. Consumer Reports

As a lending business, we receive and transmit data to consumer reporting agencies. We partner with these agencies to assess your creditworthiness and to prevent fraud and identity theft. This is done as part of our regular underwriting, fraud prevention and loan servicing processes.

Some of the information we collect from consumer reporting agencies are about open and closed credit accounts, the latest reported monthly balance and monthly payment, information about credit inquiries, information about late payments and collection actions occurring on open and closed credit accounts, information regarding public records of bankruptcy, judgements and other payment statuses, the credit score produced by the credit bureau providing the report, information about your transaction history, assets, and account balances, correcting information maintained by the credit bureaus.

Information related to your creditworthiness is maintained by the credit bureaus. If you find that there is an error or you want to dispute the information found in your credit report, please contact the credit reporting bureaus (Visit Equifax, Experian or Transunion website).

1.2.2 Website Use and Logging Data

Solventa collects information about your computer or mobile device to improve and evaluate your use of our website and our services. We may gather data such as your browser type, operating system, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device.

The information you share is available to everyone accessing that service, and may be read, collected or used by others for any purpose, including sending you unsolicited messages.

1.2.3 Cookies

We contract with third parties to place advertisements for our products and services on websites that are not our own. These advertisements on third-party websites allow us to track responses to our ads and evaluate its performance by using tools like cookies, web beacons and similar technologies. We use these tools to collect and store information about your visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site, in order to improve our service, our site and to provide more convenient and relevant experiences to you.

Most Internet browsers are set up to accept cookies automatically. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. For some web pages requiring an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages or their products and services.

1.2.4 Contacting us by Telephone

If you communicate with us by telephone, we may monitor or record the call. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of Solventas products.

2. How your personal information is used

Solventa’s primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience; to inform you about other information and services we think will be of interest to you, to facilitate your use and our operation of our website, and to improve our products and services. We generally use personal information to create, develop, operate, deliver content and advertising; and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

• To process transactions such as your loan application

• To underwrite your loan application

• To verify your identity

• To detect and prevent fraud and/or funds loss

• To create your account maintaining your login information on our site

• Contacting you regarding issues with your account

• To communicate with you about your transactions, such as to provide customer support

• To send monthly statements, service and collect amounts you owe

• For internal business purposes

• To maintain legal and regulatory compliance

• To ensure network and information security

• For research and development purposes

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties.

3. Sharing your personal information

We only share your personal information with nonaligned third parties as permitted or required by law; and we share your personal information with our associates as a normal part of conducting business and offering Services to you. We may share non-Personal Information with third parties; this may include aggregated user statistics. We may share your Device Identifiers with third parties with data related to you and your activities.

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. Solventa will never sell or rent your personal information to third parties without your explicit consent.

When we share your personal information with vendors and service providers who perform functions on our behalf, we require the security and confidentiality of your information, as well as limiting their use of the information to reasonably and necessarily to carry out their work with us and comply with applicable laws and regulations.

We will share your information in the following circumstances, but are not limited to:

• We may use Veriff, to verify your identity by determining whether a selfie you take matches the photo in your government issued identity document. The information collected from your photo may include biometric data. Veriff's Privacy Policy, available at https://www.veriff.com/privacy-policy describes its collection and use of personal information.

• We may use Plaid, Inc. ("Plaid") to connect your Solventa profile with your bank account, verify it and confirm your account balance prior to approving a transaction. Information shared with Plaid is treated by Plaid in accordance with its Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.

• We may use Equifax, to check your credit history as part of the evaluating process and of our regular underwriting, fraud prevention and loan servicing processes. Equifax’s Privacy Policy, available at https://www.equifax.com/privacy/.

• With financial institutions with which we partner to process payments you have authorized. With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.

Other circumstances that we may share your information are:

• For any purpose, you expressly consent to.

• As allowed or required by applicable law, regulation, governmental requests or legal process.

• In connection with a merger, acquisition, restructuring, asset transfer, or other operational or corporate changes to our company, such as any due diligence process.

• Other services that assist us in maximizing our business potential.

• Our loan servicing partners who provide your statements, process your payments, and service your account or loan

• Credit reporting agencies

• Auditors and examiners

4. How your personal information is protected and stored

On Solventa we know and understand how important your privacy is and we take the security of our members personal information very seriously, which is why we maintains (and require our third parties who we share your information with to maintain) appropriate physical, technical and administrative safeguards designed to protect your information’s security, confidentiality and integrity against unauthorized access or misuse. Solventa uses encrypted connections in order to prevent unauthorized parties from viewing such information and keep it safe.

To protect your Personal Information from unauthorized access and use, we use security measures include computer safeguards and secured files and buildings. The information collected through our websites may be stored and processed in the United States or any other country; whenever we save your personal information, it is stored on servers and in facilities that only selected and authorize employees who require it to fulfill their job responsibilities have access to. The safeguards include preventive, detective, and corrective controls, such as: physical safeguards like access badges and a video monitoring system; administrative safeguards like an employee security training program, employment background checks, and access controls; and technical safeguards like perimeter security, encryption, two-factor authentication, and regular security monitoring with layered and complementary controls.

We also periodically review and adjust security safeguards as the threat landscape evolves. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. Access to your own personal information is available through a unique user ID and password selected by you. It is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, please notify us immediately if you believe your password has been compromised. This password is encrypted while transmitted from your browser to our servers and while stored on our systems. In the event that any information under our control is compromised as a result of a breach of security, our policy is to take reasonable steps to investigate the situation and, where appropriate, communicate with affected individuals.

5. Retention of personal information

When you establish an online account with us, you have access to modify information about you (such as name, email address, and mailing address) that we collect online. As a registered user, you can update your password, email address, physical address, phone number, and certain bank account information at any time on the website. If you need to change any other information in your profile or remove your name or comments from our website, you can send a request to us at [email protected]. We may not be able to modify or delete information in all circumstances. Due to the regulated nature of our industry, we are under legal requirements to retain data and are generally not able to delete consumer transactional data, loan application data, or other financial information upon request.

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are: personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws; contact information for marketing purposes is retained on an ongoing basis until you unsubscribe; the recorded calls on our system may be kept for a period of up to six years and information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry the cookie.