Prime Website Privacy Policy

Effective Date: October 18, 2023

This Privacy Policy describes how Prime Financial Technologies, Inc. (“Prime”, “we” or “us”) handles personal information that we collect through our website, platform, and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

Personal information we collect

Information users submit to us:

• Contact and account information, such as your first and last name, phone number, mailing address, email address, username, and password.

• Commercial loan application information, including your social security number, credit and employment information, financial account information, transaction history, and information about your business.

• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

• Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit, and information you provide when you use any interactive features of the Services.

• Marketing information, such as your preferences for receiving communications about our Services, and details about how you engage with our communications.

• Other information that we may collect, which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties:

• Social media information
• We may maintain pages on social media platforms, such as Facebook, LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information.
• Other sources
• We may obtain your personal information from other third parties, such as marketing partners, background check providers, credit reporting agencies, financial institutions, publicly-available sources, and data providers.

Automatic data collection

We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our Services, our communications and other online services, including:

• Device data: such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
• Online activity data: such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

To operate our Services:

• Provide, operate, maintain, secure and improve our Services.
• Provide our users with customer service.
• Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
• Understand your needs and interests, and personalize your experience with our Services and our communications.
• Respond to your requests, questions and feedback.

For research and development

We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Direct marketing

We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email and in-app notifications. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

Compliance and protection

We may use personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
• Audit our internal processes for compliance with legal and contractual requirements and internal policies.
• Enforce the terms and conditions that govern our Services.
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal information

Service providers

We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as lawyers, bankers, auditors, insurers, customer support, hosting, analytics, email delivery, marketing, and database management). These third parties also include entities that assist us in the administration, processing, servicing, and sale of your loan, such as fraud detection services, underwriting services, title companies, and financial institutions.

Authorities and others.

We may disclose your personal information to law enforcement, government authorities, and private parties, that we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your choices

Access or update your information

You may update your personal information in your account by logging in and editing your information or contact us at [email protected].

Opt out of marketing communications

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. However, you may continue to receive service-related and other non-marketing emails.

Online tracking opt-out

There are a number of ways to limit online tracking, we have summarized some of the options below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser available at: https://tools.google.com/dlpage/gaoptout.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other sites, mobile applications and services

Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to contact us

Please direct any questions or comments about this Policy or our privacy practices to [email protected].

© 2023 Prime Financial Technologies, Inc.