Providus Trust Privacy Policy

Providus Trust LLC (together with our subsidiaries and Affiliates, "Providus Trust", "we", "our" or "us"), respect your privacy. This Privacy Policy explains how we may collect, use, and share this Personal Information (defined below) in connection with our software, mobile applications, websites, and APIs (each, together with its subdomains, content and services, a "Site"); and our products and services, such as the Providus Trust lines of credit, term loans, the Credit Builder service and Flex Pay service (each, a “Service”). The Site and any Service are individually and collectively referred to herein as the "Services".

1. Introduction

This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. "Personal Information" means any information that may be used, either alone or in combination with other information, that relates to an identified or identifiable living individual or business. This Privacy Policy only applies to Personal Information that is processed by Providus Trust in our capacity as a “business” or other similar term under applicable data protection laws. Except as otherwise stated herein, this Privacy Policy does not apply to any uses of Personal Information by a Third Party or any Personal Information that Providus Trust processes on behalf of the Third Party pursuant to a separate customer agreement. If you are a customer of a Third Party, you should check the privacy policies of the Third Party to understand how they may use your Personal Information. The Services may, from time to time, contain links to and from the websites of other businesses. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for their privacy obligations. Please check their privacy notices before you submit any Personal Information to these websites.

2. Personal Information We Collect

In order to participate in the Service, you are required to create an account enabling you to login and utilize the Services ("Account"). The types or categories of Personal Information we collect and how we collect and process it depends on the nature of the relationship you have with Providus Trust and the requirements of applicable law. We may collect the following information:

2.1. Information You Provide Directly to Providus Trust.

We collect Personal Information you provide directly to us, including Personal Information (which may include sensitive personal information) and transaction information when you use the Services, including your Account information such as name, phone number, email address, and other business information included in the online registration form. You may be required to provide us with certain information about your business and business personnel ("Business Information"). Such information may include Personal Information about yourself or your business personnel. If you provide, or make available, any Personal Information about any business personnel you agree that you have obtained proper consent to disclose such information to us in accordance with applicable laws.

2.2. Information from Third Party Accounts.

Regardless of which method you choose to register your Account, we may send an email to your nominated email address, or to the email address that you have designated in your Third-Party Account, to instruct you how to confirm your registration

3. How We Use Personal Information

We collect and process Personal Information for a variety of business purposes, including the following:

3.1. To Provide and Improve our Services.

We will use your Personal Information to provide the Services. For example, if you have an Account, we will use your Personal Information in connection with your transactions including to (i) process payments for purchases (such as obtaining funding); (ii) verify your identity to approve transactions, and monitor your online behavior to identify potentially fraudulent, prohibited or illegal transactions (including through the use of automated decision-making technologies); and (iii) communicate with you about your purchases.

3.2. Administrative Purposes

We may use your Personal Information for our administrative purposes, including (i) to respond to your questions, comments, and other requests for customer support, technical support, or information, including information about potential or future services; (ii) to provide you access to certain areas, functionalities, and features of the Services; (iv) for internal quality control purposes; (v) if you have an Account, to communicate with you about your account and the Services, including by sending emails to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, and changes to our policies; (vi) to enforce our agreements; and (vii) to generally administer the Services.

3.3. To Market the Services

We may use Personal Information to market the Services as permitted by applicable law. Such uses include (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you; (iii) conducting market research; (iv) developing and marketing new products and services, and measure interest in Providus Trust services; (v) other purposes disclosed at the time you provide Personal Information; and (vi) as you otherwise consent.

3.4. De-identified and Aggregated Information

We may use Personal Information to market the Services as permitted by applicable law. Such uses include (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you; (iii) conducting market research; (iv) developing and marketing new products and services, and measure interest in Providus Trust services; (v) other purposes disclosed at the time you provide Personal Information; and (vi) as you otherwise consent.

3.5. Cookies and Similar Technologies

The Sites may contain links and may enable you to post content to third party websites that are not owned or controlled by Providus Trust. We are not affiliated with, have no control over, and assume no responsibility for the content, privacy policies or practices of any third party websites. You (i) are solely responsible and liable for your use of and linking to third party websites and any content that you may send or post to a third party website, and (ii) expressly release Providus Trust from any and all liability arising from your use of any third party website. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party website that you may choose to visit, link to or post content on.

4. How We Share Information

4.1. Service Providers

We may share and transfer any information we receive with service providers that help us provide the Services, including Business and Personal Information. The types of service providers to whom we entrust Personal Information include service providers for: (i) the provision of the Services and loan servicing activities; (ii) the provision of hosting, IT and related services; (iii) the provision of information and services you have requested; (iv) payment processing and performance; and (v) customer service activities. For instance, information used to determine creditworthiness may be shared with FEB or LB, if your loan is originated by FEB or LB and/or with credit bureaus, consumer reporting agencies, financial institutions, collections agencies, and fraud prevention services in order to, among other things, perform various checks, locate borrowers, or recover debts.

4.2. Affiliates

We may share Personal Information, Business Information, Providus Trust credit decision and process, as well as Third Party Account information (with or without compensation) to Providus Trust platform merchants/vendors, affiliated brokers and advertisers in order to facilitate your use of the Service, and as required to fulfill contractual obligations. Our Affiliates and broker partners are all required to preserve the confidentiality of any personal information they may access. Affiliate” means any entity that, directly or indirectly, controls, is controlled by, or is under common control with Providus Trust. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

4.3. Disclosures to Protect Us or Others

We may disclose your Personal Information or any information you submitted via the Service if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Providus Trust, our users, yourself or the public.

4.4. Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

5. How To Exercise Your Rights

5.1. How To Exercise Your Rights

You may choose not to receive future promotional, advertising, or other Services-related emails from us by selecting an unsubscribe link at the bottom of such emails that you receive from us. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative emails (for example, in connection with a password reset request, an email verification, or a payment-related email) that are necessary to facilitate your use of the Services.

5.2. Your Privacy Rights

In accordance with applicable privacy laws, you may have the right to: (i) obtain access to or a copy of your Personal Information; (ii) receive an electronic copy of Personal Information that you have provided to us, (the “right of data portability”); (iii) object to or restrict our uses of your Personal Information; (iv) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; (v) withdraw your consent; and (vi) request erasure of Personal Information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below. We will process requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

6. Data Security & Accuracy

6.1. Data Retention

Providus Trust retains the Personal Information we receive as described in this Privacy Policy for as long as you use the Services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

6.2. Data Accuracy

In order to continue using the Services, it is necessary to maintain accurate Personal Information. You may use the tools that we make available on the Service to remove or modify certain information in your Account (you may also be able to remove or modify certain information via your Third-Party Account that you have linked to). If you would like to correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to [email protected]. Your email should include adequate details of your request. Providus Trust may retain archived information that you have provided in the course of obtaining or attempting to obtain services through Providus Trust in order to comply with applicable law, regulation, legal process, partner contractual obligations and our own internal policies.

6.3. Data Accuracy

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.

7. Children's Privacy

The Services are not directed to children. If you are under the age of 16 you are not permitted to use the Providus Trust Services. We do not have actual knowledge that we collect, sell, or share Personal Information from children under 16 for cross behavioral advertising or other purposes. If you learn that your child has provided us with Personal Information without your consent, you may alert us at [email protected]. If we learn that we have collected Personal Information of a child under 16, we will take steps to delete such information from our files as soon as possible and terminate the child’s account.

8. Updates to this Privacy Policy

By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, you may not access or otherwise use the Services. We may revise this Privacy Policy at our sole discretion. If we make material changes to this Privacy Policy, we will notify you as required by applicable law. We will post any Privacy Policy revisions on this web page, and the revised version will be effective immediately when it is posted. If you continue to visit our website or use the Services after such changes have been made, the revised Privacy Policy will be applicable to you. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

9. Contact Us

If you have any questions, comments, or suggestions about our privacy practices, this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please send us a "Contact Us" request or email us at [email protected], you may be required to provide us with certain information such as your name and email address.