Introduction

This Online Privacy Policy (“Policy”) applies to this Dwello, LLC online interface (i.e., website or mobile application) and any Dwello, LLC affiliate or subsidiary online interface that links to this Policy. Dwello, LLC has provided this Online Privacy Policy to describe our personal information handling practices, and to assure you of our continuing commitment to protect all personal information that we handle in the course of commercial activities.

“Dwello” or “we” or “us” or “our”, as used in this Policy, means Dwello, LLC and any of its affiliates or subsidiaries. “Personal information”, as used in this Policy, means information about an identifiable individual.

When you submit information to or through the Website, you consent to the collection and processing of your information as described in this Privacy Policy. By using the Website, you accept the terms of this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS AND CONDITIONS, THEN PLEASE DO NOT USE THIS WEBSITE.

Personal Information Collected

Dwello limits the amount and type of personal information collected to that which is necessary for our identified purposes, and we collect personal information directly from you and your use of the Website by fair and lawful means.

• Customer name and contact information
• Credit history and credit scores

• Social Security number and Income
• Driver’s License
• Bank Account Information

We collect personal information and sensitive personal information from you when you create an account to use one of our services, contact us, or otherwise voluntarily provide it.

There is also information about your computer hardware or software that is automatically collected by Dwello. This information may include your IP address, browser type, domain names, access times, and referring website addresses. Generally, we do not consider such data as Personal Information because it, by itself, usually does not identify an individual. This information is used by Dwello for the general operation of its business, to maintain quality of service, and to provide general statistics regarding the use of Dwello and DwelloLending.com.

Dwello’s site is for a general audience. Dwello does not knowingly collect any personal information from anyone under the age of 16.

Any personal information collected through the Website is processed in the United States or in other countries in which we or our affiliates, subsidiaries, or service providers host the Website or services. When you provide personal information to us through the Website, you consent to the processing of your data in, and the transfer of your data to, the United States or any other country in which we or our affiliates, subsidiaries, or service providers host Website or services.

Personal Information Security

To protect your personal information from unauthorized access and use, we use appropriate security measures designed to protect the security of all information submitted through the Website. These measures include technical, physical, and administrative safeguards.

Although Dwello endeavors to protect your personal information, it cannot guarantee the security of your personal information transmitted to its website. Any transmission of personal information is at your own risk. Users of the Website are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of our digital services. In order to protect you and your data, we may suspend your use of any of Website and related services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Website are restricted to authorized users only.

Use of Personal Information

Dwello may disclose personal information in a number of circumstances, including:

• To credit bureaus, credit reporting agencies and to your current or future creditors for the purpose of maintaining your credit history and providing credit references;
• To third parties as reasonably necessary to support our business;
• To enforce your contracts with us and otherwise for the collection or payment of a debt owed to us;
• For the purposes of detecting and preventing fraud;
• To affiliates and other third parties in connection with audits, management, billing or other administrative purposes, including defending and bringing legal actions;
• For the purposes of meeting legal, regulatory, industry self-regulatory, risk management and security requirements;
• For providing payment solutions;
• Unless you have opted out, to affiliates of Dwello to enable them to offer you additional products and services;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of Dwello’s assets;
• For other purposes you have consented to or have provided it for;
• To comply with a court order, law, or legal process, including to respond to any government or regulatory request;
• As otherwise permitted or required by applicable law.

We will use and share any information that we collect on this website from or about you in accordance with our Privacy Notice

Dwello may also use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, divestiture, restructuring, dissolution, assignment or other disposal of all or part of Dwello or our business or assets (including your loan or lease and any agreement to which it relates), for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Dwello or our business or assets may use and disclose your personal information for similar purposes as those described in this Policy.

Use of Cookies

Dwello may use cookies, web beacons, or other technologies to collect information about you when you use our website. A “cookie” is a small data file that certain websites write to your hard drive when you visit them. If you prefer not to receive cookies through our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. If you choose not to accept cookies, some features of our site may be disabled or rendered unusable. Cookies enable us to improve the Website by customizing user experience, analyze technical and navigational information, and detect and prevent fraud.

Disclosure of Personal Information

In the course of fulfilling the purposes described above, Dwello may transfer your personal information to service providers, including affiliates or other third party organizations or individuals retained by Dwello to perform functions on its behalf, such as marketing, data processing, customer service, office, security, collections, insurance, financial and taxation services. We may disclose information as described at the time the information is collected or as follows:

• To present this Website or to perform services;
• With service providers performing services on our behalf;
• For legal purposes;
• To fulfill the purpose for which you provide it;
• With your consent;
• For any other purpose disclosed by us when you provide the information;
• To apply our terms of use and other agreements; or
• To facilitate corporate changes such as a merger, sale, acquisition, or other change of ownership or control; or
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Dwello, our customers, or others.

When personal information is transferred to service providers, we use contractual or other means to ensure that a comparable level of protection is provided. Some of our service providers may be located outside the United States and will be subject to applicable legal requirements in that country including lawful requirements to disclose personal information to government authorities in certain circumstances.

Online Advertising

Our advertising management partners may use data collection tools through the Website to enable them to recognize a unique Cookie that has been placed on a user's browser, which in turn enables us and these ad management partners to learn which advertisements bring users to the Website. In addition, we and our ad management partners may use these data collection tools to track the actions of users of the Website, to measure statistics of our marketing efforts, and to deliver advertisements that may be more relevant to individual consumers and to improve the consumer experience on the Website.

We and our ad management partners also may use data collection tools to record the actions of users of the Website, to measure statistics of our marketing efforts, to deliver advertisements that may be more relevant to individual consumers and to improve the consumer experience on the Website.

Users may "opt out" of receiving online interest-based advertisements by following the instructions at:
• www.aboutads.info/choices
• www.networkadvertising.org/choices/

After opting out, an "opt-out" Cookie will be placed on the user's device indicating that the user does not want to receive interest-based advertisements. If a user deletes Cookies generally, the user will need to opt-out again.

Important Information About Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

Changes to Your Contact Information & Closing Your Account

If your personal information changes, you can update or correct it in your account by contacting Dwello customer support at (833) 264-4465 or via email at privacy@dwellolending.com. We will retain your information for as long as your account is active or as needed for our operations. In addition we retain personal information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions, and perform other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies. If you wish to close your account or request that we no longer use your information, contact us at privacy@dwellolending.com and we will respond to you in a reasonable timeframe. We will retain and use your information as necessary to comply with any legal obligations, resolve disputes, and enforce our terms of service.

Privacy Notice for California Residents (CCPA)

This Privacy Notice for California Residents supplements the information contained in Dwello, LLC's Online Privacy Policy and Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice. This Privacy Notice for California Residents only covers information our Website collects. Information collected from transactions on our platform is not subject to the CCPA or this Privacy Notice for California Residents.

Information We Collect

Our Website may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the scope of applicable state data privacy and protection laws, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category A — Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Collected: YES

Category B — Personal information under Cal. Civ. Code § 1798.80(e)
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Collected: NO

Category C — Protected classification characteristics
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: NO

Category D — Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES

Category E — Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: NO

Category F — Internet or other similar network activity
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected: YES

Category G — Geolocation data
Physical location or movements.
Collected: YES

Category H — Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: NO

Category I — Professional or employment-related information
Current or past job history or performance evaluations.
Collected: NO

Category J — Non-public education information
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO

Category K — Inferences drawn from other personal information
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: NO

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• From service providers or third parties. For example, from the merchant fulfilling your order to purchase a product or service.

Use of Personal Information

Dwello, LLC may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To contact you and provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business, including to detect, prevent, and mitigate fraudulent or illegal activities.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To comply with a court order, law, or legal process, including to respond to any government or regulatory request.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Dwello, LLC may also use and disclose personal information in connection with the proposed or actual financing, securitization, insuring, sale, divestiture, restructuring, dissolution, assignment or other disposal of all or part of Dwello, LLC or our business or assets (including your loan or lease and any agreement to which it relates), for the purposes of evaluating and/or performing the proposed transaction.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We do not sell personal information other than as part of a transaction with a debt collection agency to collect unpaid debts. Company has provided the following categories of personal information to debt collection agencies to collect unpaid debts in the preceding twelve months:

• Name
• Address
• Telephone number
• Email address

We share your personal information with the following categories of third parties:

• Service providers
• Data aggregators

In the preceding twelve (12) months, Company has disclosed personal information for a business purpose. In the preceding twelve (12) months, Company has not sold personal information.

Your Rights and Choices

The CCPA may provide consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You may have the right to request that we disclose certain information to you about our collection, use, and disclosure 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.

Correct Inaccurate Information

You have the right to request that we correct inaccurate information that we collect about you.

Your Right to Limit our Use and Disclosure of Sensitive Personal Information

You have the right to request that we limit our use and disclosure of sensitive personal information.

Deletion Request Rights

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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by:

• Emailing us at privacy@dwellolending.com; or
• Calling customer support at (833) 264-4465.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

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.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail.

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.

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.

Personal Information Sales Opt-Out

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age. To exercise the right to opt-out, you (or your authorized representative) may submit a request by:

• Emailing us at privacy@dwellolending.com; or
• Calling customer support at (833) 264-4465.

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, or provide you a different level or quality of goods or services.

Changes to this Privacy Notice for California Residents

The Effective Date of this Privacy Policy is set forth at the top of this webpage. We may, in our sole discretion, change this Privacy Notice for California Residents from time to time without notice to you by posting a revised version at www.DwelloLending.com/PrivacyPolicy. When we do so, changes in the Policy will be effective immediately. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. Please review the Policy periodically for changes.

Additional State Privacy Rights

Other state consumer privacy laws may provide their residents with rights regarding our use of their personal information. For example:

California, Colorado, Connecticut, Indiana, Iowa, Montana, Tennessee, Texas, Utah, and Virginia, may provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

California, Colorado, Connecticut, Indiana, Montana, Tennessee, Texas, and Virginia also may provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please:

• Email us at privacy@dwellolending.com; or
• Call customer support at (833) 264-4465.

Only you or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. Your request to know or delete must (1) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative and (2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not discriminate against you for exercising any of your privacy rights.

Changes to this Policy & Questions about the Privacy Policy

We may, in our sole discretion, change this Policy from time to time without notice to you by posting a revised version at www.DwelloLending.com/PrivacyPolicy. When we do so, changes in the Policy will be effective immediately. Please review the Policy periodically for changes.

If you have any questions about this Policy, you may contact Dwello customer support at (833) 264-4465 or via email at privacy@dwellolending.com.

Dwello Privacy Notice

FACTS — WHAT DOES DWELLO FINANCIAL 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.

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 Dwello chooses to share; and whether you can limit this sharing.

What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Customer name and contact information
• Social Security number and Income
• Account balances and payment history
• Credit history and credit scores
• Driver's License
• Bank Account Information

Reasons we can share your personal information

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
Does Dwello share? YES
Can you limit this sharing? NO

For our marketing purposes – to offer our products and services to you
Does Dwello share? YES
Can you limit this sharing? NO

For joint marketing with other financial companies
Does Dwello share? YES
Can you limit this sharing? NO

For our affiliates' everyday business purposes – Information about your transactions and experiences
Does Dwello share? YES
Can you limit this sharing? YES

For our affiliates' everyday business purposes – Information about your creditworthiness
Does Dwello share? YES
Can you limit this sharing? YES

For our affiliates to market to you
Does Dwello share? YES
Can you limit this sharing? YES

For nonaffiliates to market to you
Does Dwello share? YES
Can you limit this sharing? YES

To limit our sharing

Please note:

• Call (833) 264-4465 – our menu will prompt you through your choice(s) or
• Email privacy@dwellolending.com

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 (833) 264-4465 or email privacy@dwellolending.com

What we do

How does Dwello 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. Only authorized employees have access.

How does Dwello collect my personal information?
We collect your personal information, for example, when you:

• Apply for financing or open an account
• Provide account information or pay your bills
• Use your credit or debit card

We also collect your personal information from others, such as credit bureaus, affiliates, or 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. See above for more on your rights under state law.

Definitions

Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include companies with a common corporate identity of Dwello.

Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Nonaffiliates we can share with include our merchant partners and marketing service providers.

Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Our joint marketing partners include banks.

Other Important Information

Special Notice for State Residents
For California Residents. We will not share information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, or credit report to nonaffiliated third parties to market to you except with your consent ("opt in") or as permitted by California law.

For Vermont Residents. We will not share information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, or credit report to nonaffiliated third parties to market to you except with your consent ("opt in") or as permitted by Vermont law.