Privacy Policy

This Privacy and Federal Privacy Notice (the "Policy") is an agreement between Impruvu LLC, a New Mexico limited liability company, and its wholly owned subsidiary AdvisorHub LLC (collectively, the "Company, us, we, our"), and website users ("Users, you"). By continuing to use this website, you accept all terms in this Policy. If you disagree, cease using the website immediately.

The Policy explains how we collect, use, protect, store, and disclose information when you use our websites, services, and mobile applications. It does not cover information obtained through other sources. This Policy also explains your choices for managing information preferences and opting out of certain uses.

If you have questions about this Policy, contact info@impruvu.io. This policy applies to current and former customers. Users must be 18 years or older to use our services.

INFORMATION WE COLLECT ABOUT YOU

Collection methods vary based on your website usage:

All Users

Passive data collection applies to all visitors.

Co-applications

We collect information about co-applicants provided in connection with joint applications or loan applications. By submitting another person's information, you represent authorization to provide it.

Registered Users

Registration may require you to voluntarily disclose:

• Name, email address, physical address, billing address, phone number
• Information related to interactions with representatives, purchases, notifications, general communications, and content participation

By registering, you consent to us collecting, storing, using, and disclosing your personal data per this Policy.

Sales & Billing Information

Purchase transactions require credit information, billing addresses, and possibly additional details. Payment and billing information is not stored and is used exclusively for one-time purchases.

Unregistered Users

Passive users may experience passive data collection including cookies, IP address information, location information, and browser data (history/session information).

INFORMATION GATHERED BASED ON YOUR ACTIVITY

We collect transaction and activity information to provide services, improve our business, and maintain legally required records. This includes: IP address, geographical location, operating system, browser type, referral source, visit duration, button clicks, page views, and mobile device identifiers.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We and our marketing partners use cookies, beacons, tags, and scripts to analyze trends, administer websites, track user movements, and gather user base information. Cookies help track personal sessions, authenticate accounts, and detect fraud. You can control cookies in your browser, though this may limit some website features.

Third Party Technologies

We partner with third parties for advertising management and website performance evaluation. These companies use cookies and similar technologies to recognize browsers and gather activity information, providing targeted advertising or tracking marketing success. We use third-party service providers for information storage (cloud services) and website hosting.

DO-NOT-TRACK SIGNALS

We do not process or respond to "do not track" signals or similar requests to disable online activity tracking.

HOW WE USE YOUR INFORMATION

We use information to facilitate services including:

• Generating account profiles and processing financial product applications
• Verifying identity and application information
• Improving personal user experience
• Enabling automatic payments and fund transfers
• Implementing collection activities
• Communicating about applications, accounts, and transactions
• Marketing and advertising
• Providing customer service
• Addressing disputes

HOW WE SHARE YOUR INFORMATION

We share personal information with nonaffiliates and among affiliates only as described here. Federal law permits limiting some, but not all, sharing types.

Affiliates

Our affiliates may share information with each other, including creditworthiness data, for business analysis or targeted marketing.

Credit Bureaus

We may share personal information with credit bureaus to meet credit reporting obligations.

Legal Requests

We may share information to comply with applicable laws, regulations, legal processes, governmental requests, limit fraud, or in connection with audits or sales to third parties.

Lending Partners

Credit offered through us is fulfilled by third-party banks or non-bank lending partners. If you apply for loans or credit cards, you're providing information to potential Lending Partners. Your Lending Partner's privacy policy governs their information use.

Third Party Service Providers

We rely on third-party service providers for file and record maintenance, website hosting, customer service, marketing communications, and fund transfer facilitation. They're authorized to use personal data only as necessary for service provision.

IMPORTANT PRIVACY CHOICES

Rights in relation to your Personal Data

Federal law gives you the right to:

• Be informed about personal data processing
• Access your personal data
• Update and/or correct your personal data
• Personal data portability
• Oppose or limit personal data processing
• Request we stop processing and delete your personal data
• Block personal data processing violating applicable law
• Launch complaints with the Federal Trade Commission (FTC) or applicable data protection authority

Exercise these rights by contacting info@impruvu.io.

HOW WE SECURE YOUR INFORMATION

We use significant safeguards — physical, technical (electronic), and operational controls — to protect personal information during transmission and after receipt. All servers have Secure Socket Layer (SSL) certificates ensuring website connection authenticity and secure encrypted data transmission. Security involves encryption, firewalls, intrusion prevention systems, malware detection, and data loss prevention.

We store sensitive financial information in state-of-the-art, highly secure data centers audited per AICPA SOC for Service Organizations. Physical access is strictly controlled, employing latest threat prevention technologies.

CHANGES TO THIS POLICY

Policy updates become effective when posted on our websites. For material changes, we'll notify you via email or by providing revised policies in your account. Continued service use following updates means you accept our updated policy.

NOTICE AT COLLECTION (CALIFORNIA RESIDENTS)

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) provides specific rights to California residents regarding "personal information." Nearly all information we collect is exempt under the federal Gramm-Leach-Bliley Act (GLBA).

Your Rights Under the CCPA

Right to Know/Right to Access: California residents may request that we disclose collected, used, disclosed, or sold personal information over the past 12 months.

Right to Request Deletion: California residents may request we delete collected and retained personal information, subject to exceptions.

Right to Opt-Out of Sale: We do not and will not sell consumer personal information.

Right to Non-Discrimination: California residents may not be discriminated against for exercising CCPA rights.

To exercise your rights, contact info@impruvu.io. You may only make verifiable consumer requests twice within 12 months.

FEDERAL PRIVACY NOTICE

What Does Impruvu Do With Your Personal Information?

Financial companies choose personal information sharing methods. Federal law gives consumers the right to limit some, but not all, sharing. Collected and shared personal information types depend on your product or service, and include:

• Social Security numbers and income
• Account balances and transaction history
• Credit history, credit scores, and employment information

When you're no longer our customer, we continue sharing information as described.

Reasons we can share your personal information

• Everyday business purposes — processing transactions, maintaining accounts, responding to court orders and legal investigations, or reporting to credit bureaus
• Our marketing purposes — offering our products and services
• Joint marketing with other financial companies
• Our affiliates' everyday business purposes — information about your transactions and experiences
• Our affiliates' everyday business purposes — information about your creditworthiness
• Our affiliates' marketing to you
• Nonaffiliates' marketing to you

To limit our sharing

All consumers may contact info@impruvu.io for assistance disabling information sharing. Your opt-out choices also apply to your co-borrower.

How does Impruvu protect my personal information?

We use security measures complying with federal law to protect personal information from unauthorized access and use. These include computer safeguards and secured files and building.

How does Impruvu collect my personal information?

We collect personal information when you:

• Open an account
• Apply for Impruvu financial products
• Provide information including income and employment information

We also collect information from others like credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only:

• Affiliates' everyday business purposes sharing — information about your creditworthiness
• Affiliates using your information to market to you
• Nonaffiliates marketing to you sharing

State laws and individual companies may give additional sharing limit rights.

DEFINITIONS

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

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliated companies we share with include financial services companies, marketing companies, and other service providers.

Joint marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.

OTHER IMPORTANT INFORMATION

Vermont Residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information to nonaffiliated third parties for marketing, unless Vermont law permits otherwise, unless you authorize us.

Nevada Residents: Per state law, you may be placed on our internal Do Not Call List by calling 855-755-1919 or emailing info@impruvu.io.

For additional information or questions, contact info@impruvu.io or: