Privacy Notice for ACQUALIFY LLC

Effective Date: 12/17/2020

I. Introduction

This Privacy Notice (“Notice”) provides information about how Acqualify LLC (“ACQUALIFY”, “We,” “Us,” or “Our”) collects, uses, protects, and shares information about you and describes the rights you may have regarding that information. This Notice applies to ACQUALIFY, its websites, applications, products (“The Products”), features, and application program interfaces, when you communicate or interact with us either directly or through the use of any of our online systems and applications (collectively, the “Online and Offline Services”).

Use of our Online and Offline Services constitutes your agreement to the terms of this Notice. If you do not agree with the terms of this Notice, then do not use our Online or Offline Services.

II. Collection and Use of Your Information

We may collect the following information, including, but not limited to:

  • Name (first, last, and/or maiden name) including the names of family members; home address, billing address, or other physical address; an email address (to communicate with you); a telephone number.
  • Certain other information, such as employment information, education, certifications or licenses.
  • Information collected passively via cookies and/or similar technology.
  • IP addresses, device identifiers, and application identifiers.
  • Account and password information.

From whom or how we may collect it:

  • Consumers.
  • Information collected passively via cookies and similar technology.
  • Advertising Partners.
  • Credit reporting agencies and their affiliates.
  • External data providers, vendors, or other third parties.

Why we may collect it:

  • To verify your identity, certifications or licenses.
  • To enroll you in the Platform.
  • To provide you access to the Platform and its features.
  • To send your emails and other alerts or otherwise communicate with you.
  • To provide you with quality customer service.
  • For product development, product research, and product improvement by ACQUALIFY and its Business Partners or Sponsors as defined below in Section III.
  • To prevent fraud on your account, or to identify fraudulent activity towards ACQUALIFY.
  • To enhance and optimize your experience on our Online and Offline Services and improve our Products, for example, to test new products, to determine if products that we are contemplating may be desirable to our customers, for analytics, marketing research, and business analysis.
  • To perform analytics, improve user experience, improve our product offerings.
  • To maintain the accuracy of your information.
  • To participate in our affiliate program, subscribe to our emails or newsletter, participate in one of our contests or surveys or transact other business with us.
  • To display, optimize and provide you with personalized advertisements.
  • For fulfillment of your requests and other communications about the Online Services, Offline Services and Platform; promotional opportunities and generally for ACQUALIFY’s and its Business Partners’ internal business purposes such as, for example, internal analyses and audits.
  • For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law.
  • For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access.

Additionally, we may collect the following internet or other similar network activity information, including, but not limited to:

  • Information about your interactions with the Platform, for example, when you view or search content, we receive and may track that information; web session; log file information; information such as the website(s) you visited, when you visited the website, how long you stayed, your behavior while you were on our website and from what device you accessed the website; device identification information which we may associate with a mobile telephone number you provide used to access the website; the IP address and information related to that IP address, the internet service provider or proxy used, operating system information, browser information (the pages you view, how long you stay on each page, how often you come back and your behavior while you are on our websites); and which advertisement, emails, SMS notifications or other push notifications related to the Platform, offer or online content you view, access, or click on, including to get to the Online Services or while you are on the Platform.
  • Information collected from any advertising partners.
  • Local Storage Objects such as HTML5 and Flash to store content information and preferences.

From whom or how we may collect it:

  • Directly from individuals.
  • Cookies and similar technology.

Why we may collect it:

  • To continually enhance and optimize the Platform and the Online Services, based on up-to-date user experience and available technology.
  • To improve the delivery and development of the Platform.
  • To customize your customer service experience.
  • To develop new products.
  • To display, optimize, and provide you with personalized advertisements.
  • To measure advertising effectiveness.
  • To perform site analysis.
  • For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law.
  • For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access. It is likely you authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship. ACQUALIFY limits the use of this information to prevent fraud and unauthorized access or disclosures of your personal information.

III. Sharing Your Personal Information

A. By providing your information on our Platform or website, you grant us full rights to buy, sell or lease your information with the following categories of recipients (you can opt-out at any time):

1. Business Partners & Sponsors - ACQUALIFY may disclose or share your information to Business Partners or Sponsors, including Credit Saint, LLC, Credit Squad, LLC, United Services Credit LLC, Morristown Road LLC, and/or Katama LLC. Partners and Sponsors are under a confidentiality agreement not to disclose any of your information to outside parties unless it is (a) necessary to provide the services you requested; or (b) given with your express permission. Unless you direct ACQUALIFY otherwise, ACQUALIFY may share your information with National Debt Relief, Bills.com, or any other Business Partner or Sponsor (including lenders). This sharing of information with our Business Partners or Sponsors will allow them to market products to you that they believe you will be interested in.

2. Third Party Service Providers - ACQUALIFY may also share your information with companies who are service providers of ACQUALIFY, provided those companies are under a confidentiality agreement not to disclose any of your information to outside parties unless it is necessary to provide the services you requested or given with your express permission.

3. Third Party Data and Data in the Aggregate - Under confidentiality agreements, ACQUALIFY may match user information with third party data. Also, ACQUALIFY may disclose aggregated user statistics (for example, “15% of our users are located in New Jersey”) in order to describe our services to prospective partners, advertisers, and other third parties, and for other lawful purposes.

4. Legal Process - We may also disclose your information as is necessary to: (a) comply with a valid subpoena or court order; (b) cooperate with law enforcement or other government agencies; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors, suppliers, and customers; (e) defend against legal claims; (f) help with internal and external investigations; or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of ACQUALIFY or any transaction that involves the sale or assignment of some or all of our assets.

5. Other - ACQUALIFY may also disclose account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any contract or agreement with ACQUALIFY or may be causing injury to or interference with (either intentionally or unintentionally) ACQUALIFY’s rights or property, other ACQUALIFY Website or Platform users, or anyone else that could be harmed by such activities. ACQUALIFY may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.

B. Personal information of Children

You must be at least 18 to access our Online and Offline Services and Products or become a member of any membership program entitled to membership benefits. Our Online and Offline Services are not intended for use by children and we do not knowingly solicit or collect information from children.

We do not sell the personal information of children under the age of 16.

C. By providing your information on or through the Platform or our website, or in connection with the Online or Offline Services provided by ACQUALIFY, you agree that:

• All the information you have provided is true, accurate and correct;

• You are allowing ACQUALIFY, its Business Partners & Sponsors and Third Party Service Providers to contact you about products or services; and

• ACQUALIFY may buy, sell, rent, lease, share or provide third party companies your personal information that was provided to us as set forth in this Notice.

IV: California Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA).

A. Right to Know

You have the right to request a disclosure of the personal information collected, sold, and shared about you over the past 12 months and the purpose for doing so. Upon submission of a verifiable consumer request, we will provide you with the following information.

• The categories of personal information we collected about you.

• The categories of sources from which we collected your personal information.

• Our business or commercial purpose for collecting or selling the personal information.

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

• The specific pieces of personal information we collected about you.

• The categories of personal information that we sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of personal information.

• The categories of personal information that we disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties with whom we disclosed that particular category of personal information.

If we provide this information to you electronically, the information will be in a portable format. To the extent that it is technically feasible, we will provide you the information in a readily useable format that you can easily transfer to another entity.

B. Right to Be Free from Discrimination

You have the right to be free from discrimination for exercising any of the California consumer privacy rights. If you choose to exercise any of your CCPA rights, we will not:

• Deny you goods or services;

• Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of good or services; or

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

C. Right to Opt-Out of the Sale of Personal Information

You have the right, at any time, to opt out of the sale of your personal information to our Busines Partners, Sponsors, or other third parties. If you would like to exercise this right, visit our “Do not sell my personal information” page.

V: Contact Information

If you have questions or concerns regarding this Notice or the protection of your information and privacy rights, you may contact us in the following ways:

ACQUALIFY LLC

1 International Blvd

Suite 400

Mahwah, NJ 07495

Toll-Free Phone: (877) 637-2673

VI. Opt Out

ACQUALIFY will offer you the opportunity to choose (opt out) whether your personal information is: (a) disclosed to a third party and that third party intends to use it for a purpose that is materially different from the purpose for which it was originally collected; or (b) used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you.

VII: Notice Changes and Effective Date

We may periodically make changes to this Notice and recommend that you check back to review this Notice so that you always know how we collect, use, and share your personal information. ACQUALIFY reserves the right to change this Notice at any time without prior notice. The effective date denotes the date that we publish this Notice. Use of the Product following any change constitutes your acceptance of the Notice then in effect. We encourage you to check the website periodically for updates to our Notice.