# Privacy Policy

#### Last Updated: December 23rd, 2019

### Introduction:

Our mission at libertyloansus.com ("Liberty Loan US") is to connect you with our marketplace of third party lenders, financial service providers, debt relief providers, aggregators, direct mail marketers, and email marketers ("Service Providers").

To assist us in carrying out our mission, we collect and process certain information you provide us. We work hard to be good stewards of your information. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

This Privacy Policy applies to information we collect on the Liberty Loan US website located at www.libertyloansus.com.

### What Information Do We Collect and How?

### Anonymous and Aggregated Web Traffic Information.

General traffic, site usage, browser information, length-of-stay information, and location data is collected and stored in log files. This type of information is collected and shared on an anonymous, aggregated basis meaning that we do not connect this information to your name or other personal information.

### Personal Information (non-financial).

We collect all or some of the following personal information: first and last name, phone number, email address, cell phone number, date of birth, age, military affiliation, educational background, mailing address, employer, work phone number, driver’s license, social security number, and zip code in the following contexts:

- Requests for Service: To start the process of getting connected with a Service Provider, we collect the above personal information on the Loan Request form on our home page.

- Other Requests: We collect information volunteered by users, including from requests via the Contact Us Form on our website. We also may collect email addresses of those who communicate with us via email.

### Financial Information.

When you request service through our Loan Request form, we also collect your bank name, bank account type, bank account number, bank routing number, months at your bank, pay dates, loan request amount, loan purpose, monthly income, pay period, primary source of income, the total amount of your debt and the type of debt (i.e. credit card debt, personal loan debt), information about your estimated credit score, income source and amount, employment information, and information about asset ownership.

### Categories of Sources.

We collect information from the following categories of sources:

- Directly from you. For example, when you complete online forms or use our website to utilize our services.

- Third Parties. For example, when we receive data from an affiliate, aggregator, publisher, marketer, lead generator, referring website or advertising campaign.

We may combine personal information we collect from you with other information about you that we receive from third party sources. Service Providers that purchase your information may also supplement your personal information with other information about you that they obtained from other sources.

### What We Do with the Information We Collect:

We use anonymous and aggregated information to operate, develop and improve our services.

We process your personal information for the legitimate interest of connecting you with a Service Provider. We may use your financial information for the purpose of connecting you with a Service Provider.

By submitting your contact information to us, you are expressly consenting to be contacted by us or by one or more Service Providers by telephone, email or postal mail. Your information may be going to an aggregator or marketer and not a lender, financial service provider, or debt relief provider. Your information can be sold multiple times leading to multiple offers from lenders, financial service providers, debt relief providers, aggregators, and other marketers.

In addition, we may share some or all of your information with third party marketers and list managers with whom we have a business relationship, and these third party marketers and list managers may use your personal information to communicate with you about other marketing or business offers via telephone, email, direct mail, text message (std. text message rates may apply), or other channels.

We may also use or disclose your information where we conclude that we are required by law or have a good faith belief that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of Liberty Loan US, its users or the public.

Processing your information for the purposes described is necessary for us to do what we do and it's in both of our interests. When we use your information based on our legitimate interests, we conduct a balancing test based on the legitimate interest, necessity of processing your information, and how such processing impacts you.

If you have any questions or concerns with us processing your information for this legitimate interest, please contact us.

We'll ask for your consent before using your information for a purpose that extends beyond what you may reasonably expect from a company offering referrals to a marketplace of lenders, financial service providers, or debt relief providers and that has a more significant privacy impact.

Liberty Loan US works with trusted vendors in the following categories to help fulfill our mission and process your information for the purposes described: call center services, delivering email, and storing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other purpose.

As we continue to develop our business, we may buy or sell businesses or assets. In such transactions, confidential customer information generally is one of the transferred business assets. In the event of a transaction involving the sale of some or all of Liberty Loan US's businesses, customer and site visitor information may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction. In such case, the transferred information may become subject to a different privacy policy.

### Third Party Advertisers

In order to provide services free of charge, we may display advertisements. By accessing or using this Website, you expressly agree to receive these advertisements. These advertisers may use their own tracking technologies, including cookies, to collect information about you and other users of this website who view or interact with their advertisements. Please be advised that when you click on an advertiser's advertisement on our website, you may be redirected to a different website operated by that advertiser or that advertiser's marketing partner. The information practices of those third party websites are not covered by this policy. You should review the privacy statements and terms of use of all third party websites you access.

### What Are Cookies and How Do We Use Them?

As part of offering and providing customizable and personalized services, we use cookies and other online tracking technologies to store and sometimes track information about you to:

- Provide you with personalized content based on your use of our websites

- Enable you to more easily use our websites by remembering and using contact information and form information

- Evaluate, monitor and analyze the use of our websites and their traffic patterns to help improve our websites and services

The types of technologies we use include:

### Cookies.

A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer's hard drive. Cookies enable us to identify your browser as a unique user. Cookies may involve the transmission of information from us to you and from you to us. Cookies may also be used by another party on our behalf to transfer information to us in accordance with their privacy policy. Some cookies are "persistent cookies". They are used by us each time you access our website. Other cookies are called "session cookies". Session cookies are used only during a specific browsing session. We may use a session cookie, for example, to remember that you have already navigated through a particular menu. We may also use "analytics cookies" that allow web analytics services to recognize your browser or device and, for example, identify whether you have visited our website before, what you have previously viewed or clicked on, and how you found us. This information is provided anonymously for statistical analysis only. Analytics cookies are usually persistent cookies.

You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent. You may lose some features or functionality when you disable cookies. Remember, also, that disabling cookies is browser specific. If you log on using Microsoft Edge, you must also disable cookies in Safari if you use that browser at a different time.

### Log Files.

"Log files" track actions occurring on our websites and collect data including your IP address, browser type, internet service provider, referring/exit pages and date/time stamps.

### Web Beacons.

"Web beacons," "tags," and "pixels" are electronic files used to record information about how you browse the site. You cannot disable web beacons or pixel tags and they are not visible when browsing.

### Choices You Have Regarding Your Information:

You have the right to have your personal information corrected and/or erased. You may contact us to request access to, correct, or delete any personal information that you have provided to us. Please note, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

You may have heard about "Do Not Track" (DNT), which is a privacy preference that users can set in their web browsers. Our website does not support DNT codes.

### How We Protect Your Information:

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those employees and Service Providers who have a genuine business need to know it to provide you with lending, financial services, debt relief services, or other marketing offers. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

- Our online forms use encryption technology for personal and financial information.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

### How Long We Keep Your Information:

We keep your information only so long as we need it to provide the service you've requested and to fulfill the purposes described in this policy. Because people who purchase or download resources from Next Day Personal Loans are often interested in other solutions and resources, we keep your information on file to enable you to receive such resources. If you subscribe to our mailing list, we keep your contact information on file until you instruct us to remove it. If you unsubscribe from an email list or opt-out of email communications, we keep your email address on our opt-out list.

### Children's Online Privacy Protection Act Compliance:

This website is not intended for use by individuals under the age of 18. We are in compliance with the requirements of the Children’s Online Privacy Protection Act (COPPA) and we do not knowingly collect any information from anyone under 13 years of age. Our website and services are directed to people who are at least 18 years of age and older. When notified of a user who is not over the age of 18, we will take immediate remedial measures to remove that individual from our user database.

### For Our Friends in CA:

This Privacy Notice for California Residents supplements the information contained in above in our general privacy policy and applies solely to all visitors, users, and others who reside in the State of California.

### Your Rights

The California Consumer Privacy Act ("CCPA") grants State of California residents the following rights, to:

1. Know what personal information is being collected about them;

2. Know whether their personal information is sold or disclosed and to whom;

3. Say no to the sale of their personal information;

4. Access their personal information;

5. Have their personal information deleted; and

6. Have the right to equal service and price, even if they exercise their privacy rights under this law.

### Categories of Personal Information We Collect

We collect information that identifies you, your household or your device or is reasonably capable of being connected with or linked to you, your household, or your device ("Personal Information"). Personal information does not include public information available from government records, de-identified or aggregated information or information that is protected by certain laws such as HIPAA for health related information and the Gramm-Leach Bliley Act (GLBA) for certain financial information.

We collect the following categories of Personal Information:

- Identifiers

  - First and last name

  - Mailing address (including length at address)

  - Telephone number (including best time to call)

  - Email address

  - Birth month and date

  - Military affiliation

  - Social Security Number

  - Zip code

  - Driver’s License

  - Marital status

  - Internet Protocol (IP) Address

- Personal Information Listed in the California Customer Records Statute

  - The above identifiers

  - Employment information

    - Employment status

    - Employer

    - Length of employment

    - Job title

    - Monthly income, pay period and paycheck type

    - Illness/disability

    - Work phone number

  - Credit card information

    - Debt amount and rate

    - Past due amount

    - Credit status

  - Financial information

    - Auto status

    - Own/rent car

    - Own/rent home

    - Bank name

    - Bank account type (checking or savings)

    - Bank account number

    - Bank routing number

    - Length at bank

    - Loan amount

    - Loan purpose

    - Debt amounts (including mortgage debt, auto debt unsecured debt, tax debt, secured debt, student loan debt, medical debt, payday loan debt, personal loan debt)

    - Primary income source

- Characteristics of Protected Classifications

  - Age

  - Military affiliation

- Commercial Information

  - Information about your debt history

  - Information about your assets

- Biometric Information

  - Not collected

- Internet or Other Electronic Network Activity Information

  - Cookies

  - Domain name

  - Browser type and version

  - Operating system

  - Usage data

  - Visit frequency

  - Referring affiliate information

  - Referring ad campaign

  - Time on site

  - Source URL

  - Redirect URL

- Geolocation Data

  - Information that tells us from where you access our website

- Sensory Data

  - Not collected

- Professional or Employment-Related Information

  - Employment status

  - Employer

  - Length of employment

  - Job title

  - Monthly income, pay period and paycheck type

  - Illness/disability

  - Work phone number

- Non-public Education Information

  - Degree attained

  - Education level

  - Graduation year

- Inferences Drawn from Other Personal Information

  - Your potential preferences for lending services, debt relief services, or other financial services

### Categories of Sources of Personal Information

We collect information from the following categories of sources:

- Directly from you. For example, when you complete online forms or access our Website to utilize our services.

- Third Parties. For example, when we receive data from an aggregator, marketer, lead generator, referring website or advertising campaign.

### How We Share Your Personal Information

We share information in each of the above categories as follows:

- All categories of information

  - We will share information in all of the above categories if our company is sold or we engage in a merger or other such transaction.

  - We will share information in all of the above categories of information in connection with a law enforcement request that is compliant with the California Electronic Communications Privacy Act.

- Identifiers

  - We share identifiers with service providers who use that information only to provide services to us such as shipping, name and address verification, email distribution and promotions management.

  - We share identifiers with Service Providers such as lenders, financial service providers, debt relief providers, aggregators and other marketers whose services we believe may be of interest to you. To opt-out of this sharing, see how to submit an opt-out request below.

- Personal Information Listed in the California Customer Records Statute

  - We share this information with Service Providers such as lenders, financial service providers, debt relief providers, aggregators and other marketers whose services we believe may be of interest to you. To opt-out of this sharing, see how to submit an opt-out request below.

- Characteristics of Protected Classifications

  - We share this information with Service Providers such as lenders, financial service providers, debt relief providers, aggregators and other marketers whose services we believe may be of interest to you. To opt-out of this sharing, see how to submit an opt-out request below.

- Internet or Other Electronic Network Activity Information

  - We share this information with our data analytics providers

  - We share this information with Service Providers to track referrals and ad campaign activity.

- Professional or Employment-Related Information

  - We share this information with Service Providers such as lenders, financial service providers, debt relief providers, aggregators and other marketers whose services we believe may be of interest to you. To opt-out of this sharing, see how to submit an opt-out request below.

- Non-public Education Information

  - We share this information with Service Providers such as lenders, financial service providers, debt relief providers, aggregators and other marketers whose services we believe may be of interest to you. To opt-out of this sharing, see how to submit an opt-out request below.

- Inferences Drawn from Other Personal Information

  - We share this information with Service Providers such as lenders, financial service providers, debt relief providers, aggregators and other marketers whose services we believe may be of interest to you. To opt-out of this sharing, see how to submit an opt-out request below.

### How We Use Your Information

See "What We Do with the Information We Collect" above to learn how we use your information. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

### How We Retain and Store Your Personal Information

We retain your personal information for as long as necessary to fulfill the purpose(s) for which we collected it and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage.

### Requests to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

- The categories of personal information we collected about you.

- The categories of sources for the personal information we collected about you.

- Our business or commercial purpose for collecting or selling that personal information.

- The categories of third parties with whom we share that personal information.

- The specific pieces of personal information we collected about you (also called a data portability request).

- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  - sales, identifying the personal information categories that each category of recipient purchased; and

  - disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

### Requests to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

6. Comply with a legal obligation.

7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

### How To Submit a Request to Know or a Request to Delete

To request this information please submit a verifiable consumer request to us by either:

- Mailing us at Search ROI, 8, The Green, Dover, State of Delaware, 19901, United States of America or

- Contacting us at the Contact Us Form on our website.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, Contacting us at the Contact Us Form on our website and we will provide you with a form to make a designated agent request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. To make a request, you must:

- Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or that you are an authorized representative

  - If you request the categories of information we collect, we require your first and last name and your date of birth.

  - If you request the specific information or to have your information deleted, we require your first and last name, date of birth and at least one additional data point from the above list of identifiers.

- Describe your request with sufficient detail that allows us to understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

### How To Submit an Opt-Out Request

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do Not Sell My Personal Information.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

### Timing and Fees for Requests

We will try to respond to your request within forty-five (45) days of when we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

### Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

- Deny you goods or services.

- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

- Provide you a different level or quality of goods or services.

- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

### Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the Contact Us Form on our website. Please make sure to state that you are a California resident.

### Your Nevada Privacy Rights

Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. If you are a Nevada resident and wish to opt-out of the sale of your personal information, you must send a request by contacting us at the Contact Us Form on our website. Please make sure to state that you are a Nevada resident.

### How We Make Changes to This Policy:

We may change this policy from time to time and if we do, we'll post any changes on this page. If you continue to use our website after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide a more prominent notice or get your consent, as required by law.

### Push Notifications:

With your consent, we may send push notifications or alerts to your web browser or your mobile device. These notifications may include marketing messages from us or from third parties. You can deactivate these messages at any time by changing the notification settings on your mobile device or browser.

### How to Contact Us:

If you have any questions about this policy or need to contact the Company to exercise your privacy rights, please contact Search ROI’s Privacy Officer at: contact us or by mail at Search ROI, 8, The Green, Dover, State of Delaware, 19901, United States of America.