Privacy Policy

This Privacy Policy explains how Econocredit and its affiliates (collectively, "Company," "we," "us," or "our") collect, use, share, and protect information about you when you visit our websites, open our emails, interact with our advertising, or otherwise use our services (collectively, the "Services"). By using the Services, you agree to this Privacy Policy and our Terms of Use. If a term in this Privacy Policy conflicts with the Terms of Use as it relates to personal information, this Privacy Policy controls.

1. Quick summary.

When you use our Services, we may collect the following categories of personal information, for the purposes described below, and retain them for as long as reasonably necessary for those purposes and as required by law.

• Identifiers and contact information (such as name, email address, IP address, device identifiers) to operate the Services, communicate with you, secure our systems, and comply with legal obligations.
• Commercial and usage information (such as pages viewed, links clicked, time on site, interaction with emails, and content preferences) to maintain and improve the Services, perform analytics, personalize content, and support advertising and measurement.
• Internet or network activity information (such as browser type, operating system, referral URL, and approximate location) to deliver and optimize the Services, detect fraud, and show ads that may be more relevant to you.
• Inferred preferences and audience segments created from the information above to help us and our advertising business associates provide you with more tailored offers and content.
• Credit profile information (when you enroll in our credit services), including credit reports, credit scores, and credit monitoring data, to provide credit education, monitoring and alerts, and personalized recommendations of credit cards, loans, and other financial products that may be relevant to you within our Services.
• Personal information you provide and that we collect about your use of the Services (such as contact information, location, declared interests, and engagement signals) to deliver personalized recommendations, offers, and consumer experiences that may help you save money, manage your finances, and improve your everyday situation.

Some of our use of third-party pixels, ad tech, and analytics tools may be considered "selling" or "sharing" personal information for cross-context behavioral advertising under certain state laws. You can opt out of those uses as described in the "Your privacy choices and rights" section below and through the "Do Not Sell or Share My Personal Information" link on our website.

2. What we mean by personal information.

"Personal information" (or "personal data") means information that identifies, relates to, describes, or can reasonably be linked with a particular consumer or household. It does not include de-identified, aggregated, or anonymized information that cannot reasonably be linked back to you.

3. Information we collect.

The information we collect depends on how you interact with us and the choices you make.

Information you provide directly.

We may collect information you choose to send to us, such as:

• Full name.
• Email address.
• Mailing address.
• Phone number.
• Date of birth.
• Last four digits of Social Security number (for identity verification).
• Full Social Security number (for credit report access - entered on our credit data partner's platform, not stored by Econocredit).
• Preferences and responses when you sign up for emails, promotions, or other offers.
• Content of messages you send when you contact us with questions or feedback.

Information collected automatically.

When you access the Services, we and our business associates automatically collect certain information using cookies, pixels, local storage, SDKs, and similar technologies, including:

• Device and network identifiers (IP address, device ID, browser type, operating system, mobile carrier, screen resolution).
• Usage data (pages or screens viewed, links clicked, time spent, referring/exit pages, navigation paths, timestamps, and interactions with emails).
• Approximate location (such as city or region) derived from your IP address.

Information from other sources.

We may receive information about you from:

• Marketing and analytics providers that help us measure performance, improve our content, and understand our audience.
• Advertisers and business associates who ask us to help run or measure campaigns.
• Service providers that support our operations, such as hosting, security, and fraud prevention.
• Credit bureaus, identity-verification providers, income- and employment-verification providers, and other data providers, in connection with delivering the credit and consumer services you have enrolled in. This may include credit profile data, identity verification signals, income and employment indicators, and other data points used to confirm your identity, monitor your credit profile, and tailor recommendations to you.

We may combine information from these sources to improve our Services and advertising.

Your Account Profile.

When you enroll in our Services, we create an account profile for you that includes the information you provide, the credit data we access on your behalf with your authorization, your communication preferences, and the engagement and inferred-preference signals we collect about your use of the Services. We use your Account Profile to operate the Services, deliver credit education, monitoring, and alerts, and personalize the recommendations and experiences we present to you.

Credit data partners and consumer reporting agencies.

When you enroll in our credit monitoring services, we work with third-party credit data partners to access your credit report and score information from one or more consumer reporting agencies. This is done only with your express authorization and in accordance with the Fair Credit Reporting Act (FCRA).

The information accessed through these services may include:

• Credit scores (one or more scoring models)
• Credit report data (accounts, inquiries, public records)
• Credit monitoring alerts (changes to your credit profile)

This data is provided to you for educational purposes only and is not financial, legal, or professional advice.

Our credit data partners may collect, use, share, and store data made available through the credit-related portions of our website in connection with their platform and in accordance with their privacy policies and all applicable laws. This data collection is separate from and in addition to our own data practices described in this Privacy Policy.

Credit data provider disclosure.

We use a third-party technology company (our “Provider”) as a data processor to deliver the credit-related services available through Econocredit. The Provider processes certain personal information on our behalf, including identity verification data and credit inquiry data, solely for the purpose of delivering these services to you. The Provider acts as a data processor and not an independent controller of your information for these services. The Provider may access credit bureau data on behalf of enrolled users from Experian. The Provider maintains its own privacy policy governing its data handling practices; a copy is available from us upon request.

Our Provider is a licensed credit data platform operator. Our contract with the Provider establishes it as a data processor subject to our instructions and applicable law.

Credit bureau relationship disclosure.

Credit data accessible through our services is sourced from Experian, a consumer reporting agency, through our credit data provider. Econocredit receives this data through its data processor and does not obtain it directly from the bureau. The accuracy of credit report data is the responsibility of the originating consumer reporting agency. If you believe any information in your credit report is inaccurate, you have the right to dispute it directly with Experian. For information on how to initiate a dispute, please visit the bureau's consumer dispute portal.

4. How we use information.

We use personal information for the following business and commercial purposes:

• To provide and maintain the Services, including operating the website, delivering content, and processing your requests.
• To communicate with you, including sending service messages, updates, offers, and content from us or our advertising business associates where permitted by law.
• To personalize content and advertising, including recognizing you across browsers or devices and showing you content we believe may interest you.
• To perform analytics, research, and development, including understanding how people use the Services and improving features, performance, and security.
• To protect against fraud, abuse, security risks, and other malicious activity, and to enforce our terms and policies.
• To comply with applicable laws, respond to lawful requests, and protect our rights, property, and users.
• To create aggregated, de-identified, or anonymized data that we may use and share for our lawful business purposes. We maintain such information in de-identified form and do not attempt to re-identify it except as permitted by law.
• To match enrolled users with personalized recommendations of credit cards, loans, and other financial products, and to power comparison and product-matching experiences within our Services that are tailored to the user's credit profile, in accordance with the FCRA permissible purposes described in Section 4A.
• To deliver personalized recommendations, offers, comparison experiences, and marketplace features that may help you save money, manage your finances, and improve your everyday situation, using the personal, usage, and inferred-preference information described above.

4A. Credit data and the Fair Credit Reporting Act (FCRA).

When you authorize us to access your credit information, we act as a user of consumer reports under the Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.). This means:

• We access your credit report and score only with your express authorization.
• We use your credit data to provide you with the credit-related services you have enrolled in, including: showing you your own credit reports, scores, and changes over time; alerting you to changes in your credit profile; sending you communications about your own credit profile; providing personalized recommendations of credit cards, loans, and other financial products that may be relevant to your credit profile, which you may choose to review and act on; and powering comparison and product-matching experiences within our Services that are tailored to your credit profile.
• We are not a lender. We do not make credit decisions. When you choose to apply for a product we recommend, your application is reviewed and decided by the third-party lender, not by us.
• Accessing your credit information through our services does not affect your credit score.
• We do not modify, alter, or reinterpret the underlying credit data provided by consumer reporting agencies - we display it as received, with visual formatting only.
• We comply with all FCRA obligations applicable to users of consumer reports, including the Notice to Users of Consumer Reports.

What we do not do with your credit data.

• We do not share your credit reports or credit scores with unaffiliated third parties, except agents acting on our behalf under contractual confidentiality obligations.
• We do not sell your credit reports, credit scores, or other credit data to third parties for their own advertising or marketing purposes.
• We do not use your credit data for credit repair, employment screening, insurance underwriting, or credit decisioning on behalf of a lender.

FCRA permissible purpose.

We access and use your credit report data under permissible purposes defined by the Fair Credit Reporting Act. In plain terms, this means we access your credit information at your request, for your own personal review, in connection with the credit services you have enrolled in. When you choose to engage with personalized recommendations or comparison and marketplace experiences within our Services, you are initiating a review of credit products that may be relevant to you. You are under no obligation to apply for any product, and the presentation of a recommendation is not a guarantee of approval by the underlying lender.

Estimates, approval odds, and simulators.

From time to time we may display estimates such as "approval odds" or eligibility indicators that compare your credit profile to other users who were approved for similar products, or to criteria provided by the lender. These estimates are educational and are not a guarantee of approval. Final credit decisions are made by the lender. We may also offer simulators, "what-if" tools, and similar educational features that help you understand how potential actions (such as paying down a balance or opening a new account) may affect your credit profile. Simulator outputs are illustrative and are not a guarantee of any particular outcome.

How we make money.

Our Services are free to consumers. We may receive compensation from third-party providers when you apply for, sign up for, or use products and services we recommend. This compensation may affect which products we display and how prominently they appear, but it does not change our obligation to present recommendations we believe may be relevant to your profile. We do our best to clearly identify advertising and sponsored content where applicable.

For more information about your rights under the FCRA, visit the Federal Trade Commission at consumer.ftc.gov.

5. Cookies, tracking technologies, and advertising.

What cookies and similar technologies we use.

We and our service providers and business associates use cookies and similar technologies to collect information about your browser or device, how you interact with the Services, and whether you have viewed or interacted with our emails and ads. These technologies include:

• Cookies (small text files stored on your device).
• Pixels and web beacons embedded in web pages or emails.
• Local storage and similar technologies in apps or browsers.

We generally use the following categories of cookies:

• Essential cookies are needed to provide core functionality (for example, page navigation, security, and session management).
• Performance and analytics cookies help us understand how the Services are used and improve performance.
• Functional cookies that remember your preferences (such as language, region, or certain choices you make).
• Advertising and targeting cookies that help us, and our business associates show ads, measure performance, and build audiences.

Your cookie choices.

You have several options to manage cookies and tracking technologies:

• Browser controls: Most browsers allow you to block and delete cookies. If you do so, some features of the Services may not function properly.
• Third-party tools: You can use tools offered by industry groups, such as the Network Advertising Initiative and Digital Advertising Alliance, to limit interest-based advertising in your browser.
• Analytics controls: You can limit certain analytics tools (such as Google Analytics) using provider-specific opt-outs where available.

We also honor certain browser-based signals as described below.

6. How we share information.

We may share personal information in the following ways:

• With service providers that perform services on our behalf, such as hosting, data storage, analytics, email delivery, security, customer support, and payment or billing. These providers are contractually restricted from using personal information for purposes other than providing services to us.
• With advertisers, marketing business associates, and data business associates that help us deliver, measure, and improve advertising and promotional content on our Services and on third-party sites or apps. This includes retargeting pixels and similar technologies, as well as limited data enrichment arrangements where we allow selected business associates to receive or use identifiers, device information, usage data, or audience segments created from that data to improve their own services and audience models. These activities may be considered a "sale" or "sharing" of personal information for cross-context behavioral advertising under certain state laws.
• With authorities, regulators, or other parties when we believe it is necessary to comply with law, respond to legal process, or protect the rights, property, or safety of our users, our company, or others.
• In connection with a corporate transaction, such as a merger, acquisition, joint venture, financing, restructuring, dissolution, or sale of some or all of our assets.
• In connection with an assignment, transfer, or change of service provider, vendor, or successor that operates or supports the Services. In these circumstances, we may transfer your personal information, your account, and the relationship governed by these Services - including by redirecting or migrating your account to a different website, domain, or service surface - without further notice to you, to the extent permitted by applicable law.

Sharing with affiliates.

We may share information with our affiliated companies to support the operation, security, analytics, marketing, and continuous improvement of our Services and the broader product ecosystem operated by our affiliates. Affiliates that receive your information are bound by data-handling commitments consistent with this Privacy Policy.

When you choose to apply for or interact with a partner.

When you click on a recommendation or marketplace offer and choose to apply for or use a third-party provider's product or service, you direct us to share your information (which may include identifiers, contact information, and where applicable credit or financial information) with that provider so they can process your request. Once you interact with the provider, the provider's own privacy policy and terms of service govern how they handle your information.

Co-branded and collaborative features.

From time to time we may offer co-branded features, joint research initiatives, or integrated experiences with partners. When we do, we may share information about you with the collaborating partner as needed to provide the feature. We will identify the partner and the nature of the collaboration where reasonably appropriate, and the collaborating partner's handling of your information will be governed by their own privacy policy in addition to ours.

We may share de-identified or aggregated information that does not reasonably identify you without further notice.

7. Your privacy choices and rights.

General marketing and tracking choices.

• Email marketing: You can opt out of marketing emails at any time by clicking the "unsubscribe" link in our messages or contacting us using the information below. We may still send you non-marketing messages, such as service or transactional emails.
• Advertising choices: You can use browser and device settings, as well as industry opt-out tools (such as the DAA or NAI sites), to limit interest-based advertising in your browser or on your device.

State privacy rights.

Depending on where you live, you may have certain rights regarding your personal information under U.S. state privacy laws, including those in force in California and other states that have adopted similar comprehensive privacy laws. These rights are not absolute and may apply only in specific circumstances, and we may deny your request where permitted by law (we will explain our reasoning if we do).

Subject to applicable law, you may have some or all of the following rights:

• Right to know / access - To request that we confirm whether we process your personal information and provide you with access to that information, including certain details about how we collected, used, disclosed, "sold," or "shared" it.
• Right to delete - To request that we delete personal information we collected from you, subject to applicable exceptions (for example, where we must keep information for security, fraud prevention, or legal obligations).
• Right to correct - To request that we correct inaccurate personal information we maintain about you.
• Right to data portability - To request a copy of certain personal information in a portable and, where technically feasible, readily usable format so that you can transmit it to another entity.
• Right to opt out of targeted advertising, "selling," or certain profiling - To request that we stop using or disclosing your personal information for "targeted advertising," certain "sales," or certain types of automated profiling, as those terms are defined in applicable state laws. This includes our use of retargeting pixels and data enrichment business associates that may be considered "selling" or "sharing" for cross-context behavioral advertising under some laws.
• Right to limit the use and disclosure of sensitive personal information (where applicable) - In states that recognize this right, if we collect "sensitive" personal information (for example, certain precise location, health, or similar data) and use it beyond limited purposes allowed by law, you may have the right to ask that we limit such use and disclosure.
• Right to appeal - In some states, if we decline to act on your request, you may have the right to appeal our decision by contacting us using the information below; if you remain dissatisfied, you may be able to contact your state attorney general or other regulator.

We will not discriminate against you for exercising any of these rights, such as by denying goods or services, charging different prices, or providing a different level or quality of services, except as allowed by law (for example, where a difference is reasonably related to the value of your data).

Your rights regarding credit-related data.

In addition to general state privacy rights, if you are enrolled in our credit monitoring services, you have the following specific rights regarding your credit data:

• Right to access credit data we hold: You may request a summary of the credit snapshot history and credit score records we have stored in connection with your account.
• Right to correction: Econocredit does not originate credit data. We display information as received from consumer reporting agencies through our credit data provider. If you believe your credit information is inaccurate, you must direct your dispute to the credit bureau directly. We can provide contact information for the relevant bureau upon request.
• Right to delete credit data: You may request deletion of your account and all associated credit data. Upon verified request, we will initiate deletion of your data and instruct our credit data provider to unenroll you from monitoring services. See our Privacy Rights Form for how to submit a deletion request.
• Right to opt out of credit monitoring: You may unenroll from credit monitoring at any time by contacting us at privacy@econocredit.com. Opting out will stop ongoing monitoring but will not retroactively delete previously stored credit snapshots unless you separately request deletion.

How to exercise your state privacy rights.

You can submit a request to exercise your state privacy rights by using any of the following methods (subject to availability in your state):

• Submitting a request through our online privacy form at: Your Privacy
• Emailing us at: privacy@econocredit.com

We will respond to your request within the timeframe required by applicable law, typically within 30 to 45 days, and may extend that timeframe where the law permits.

To help protect your privacy, we will take steps to verify your identity before fulfilling your request, which may include asking you to provide certain information that we compare to our records. If you authorize someone else (an "authorized agent") to make a request on your behalf, we will require proof of that authorization and may also ask you to verify your identity directly with us.

If we deny your request in whole or in part, and your state law provides a right to appeal, you may appeal our decision by following the instructions we include in our response or by contacting us using the details above.

Opting out of selling or sharing.

If you do not want us to sell or share your personal information for cross-context behavioral advertising, targeted advertising or data enrichment:

• Click the "Your Privacy" link in the footer of our website, or
• Submit a request using one of the methods above and indicate that you wish to opt out of "sale" and "sharing" of personal information.

When you opt out, we will stop using personal information associated with your browser or device for retargeting and similar cross-context advertising and will instruct our relevant advertising and enrichment business associates not to use such information for those purposes, subject to applicable technical limitations.

If your browser sends a Global Privacy Control (GPC) signal, we treat it as a request to opt out of sale and sharing for that browser, to the extent required by law.

8. Data security.

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, or alteration. However, no system is completely secure, and we cannot guarantee the security of information transmitted to or through the Services.

Where applicable, we maintain safeguards consistent with the requirements of the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations to protect the security and confidentiality of nonpublic personal information.

9. Data retention.

We retain personal information for as long as needed to achieve the purposes described in this Privacy Policy, including providing the Services, complying with legal obligations, resolving disputes, and enforcing our agreements. We may also retain backup copies, logs, and de-identified information for security, continuity, and legal compliance. When personal information is no longer required, we take steps to delete or de-identify it consistent with applicable law.

Retention of credit-related data.

We retain credit-related data in accordance with the following schedule:

• Active accounts: We retain credit snapshot history (credit score records and credit monitoring data) for as long as your account remains active.
• Deleted accounts: Upon account deletion, we will purge all credit report data and associated snapshots within 30 days of receiving deletion confirmation from our credit data provider. Some data may be retained for a limited additional period solely for legal compliance, fraud prevention, or audit purposes, after which it will be permanently deleted.
• Raw webhook and event data: Raw credit event data is retained for 90 days following the event, then purged, except where retention is required by applicable law.

10. Children's privacy.

Our Services are not directed to children under the age of 16, and we do not knowingly sell or share personal information of children under 16. If we learn that we have collected such information, we will take steps to delete it as required by law.

Additionally, we do not knowingly allow minors who are restricted by their applicable jurisdiction from using internet applications to access credit monitoring or credit report services through our platform.

11. Changes to this Privacy Policy.

We may update this Privacy Policy from time to time. When we make changes, we will revise the "Last Updated" date at the top of this page and post the latest version on our website. Your continued use of the Services after any update constitutes your acceptance of the revised Policy.

12. How to contact us.

If you have questions about this Privacy Policy or your privacy rights, please contact us at:

• Online: Your Privacy Form
• Email: privacy@econocredit.com