Privacy Policy

Last Updated January 28, 2024

Introduction

This Privacy Policy applies to the CrediFi Solutions and Triple Threat Marketing hosted product platforms and websites owned and operated by CrediFi, including, but not limited to my.credifisolutions.com. Throughout this document, this website and all other CrediFi websites will be collectively referred to as the “Websites.” Services provided by or enabled via the Websites will be referred to as the “Services.”

At CrediFi (“CS”, “we”, “us”, “our”, or the “Company”), we are committed to protecting your privacy. This Privacy Policy (“Privacy Policy”) describes the types of information we collect about users of our Company websites, and users of websites hosted by the Company on behalf of our customers (“Customers”). This Privacy Policy is designed to help you understand how we collect, use, and safeguard the information you provide to us and to assist you in making informed decisions when using our Services.

CrediFi provides services through our platforms for the purpose of fulfilling our Customer agreements (Customer Agreements). CrediFi processes Customer data under the direction of its Customers and has no direct relationship, control, or ownership of the personal data it processes under the Customer Agreement. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or having a legal basis prior to transferring the data to CrediFi for processing purposes. If you are a customer of a CrediFi Customer, you should review any additional privacy policy and terms of use agreements before using a CrediFi Customer's website. CrediFi is not responsible for the content or privacy practices of non-CrediFi websites to which this website, or any other CrediFi website, may link.

CrediFi Platforms

In addition to the Websites, CrediFi operates cloud-based software for its Customers. The use of information collected through these platforms is strictly limited to the purpose of meeting our contractual obligations to our Customers and providing the services requested by our Customers, which are defined within our Customer Agreements.

What Data Do We Collect

Depending upon the CrediFi Website or Service you are accessing or other method of contact, we may collect the following information:

• Contact details such as (for example) your full (i.e., first, and last) name, phone number, email address, and postal address.

• Employment and application data

• Comments, feedback, posts, and other content you submit to the CrediFi Websites

• Interests and communication preferences.

How Do We Collect and Use Data

CrediFi provides products such as platforms, websites, and apps to our Customers. CrediFi' Customers are the owners of the personal information collected from their end-users. Our Customers decide what data to collect (this typically includes information about their end-users (customers, prospects, employees, consultants or independent contractors, suppliers, and other individuals or third parties). We only collect this information under the direction of our Customers and have no direct relationship with the individuals whose personal information we process on behalf of our Customers.

CrediFi accesses and collects information that you voluntarily give us via email, webform or other direct contact from you. We will use your information to respond to you, regarding the reason you contacted us. We will not sell or rent this information to anyone. We may disclose information to our corporate affiliates and third parties to provide products and services to you or related to products or services you have purchased or downloaded from CrediFi. Unless you ask us not to, we may contact you via email or text message in the future to tell you about our services, new products, changes to this privacy policy or to provide you with informational or educational newsletters.

CrediFi may access Customer Data for the purposes of providing and enhancing a service, preventing or addressing service or technical problems, responding to support issues, and responding to a Customer's instructions, or as may be required by law, in accordance with the relevant Agreement between the Customer and CrediFi. Our information collection and use practices are described in more detail below.

Product-Related Information Collection

CrediFi collects certain additional information in connection with your use of our Services, web-based products and/or desktop products with online features. For instance:

• Product Updates: Some products provide you with the ability to download and register product and/or tax updates as they become available. During the download and registration process, we collect “Business Information”, including customer ID number and product version, type, and serial number. This is collected so that we can authorize your access, provide you with the appropriate update, and to update our records as to the product and products updates you have downloaded or installed, so that we may provide the appropriate support.

• Online Product /Account Application: Certain products and services are subject to an application and enrollment process, which may be completed on paper or online. Information requested may include bank account, payroll, credit card and contact information. This information is used to process your enrollment request and, if approved, to set up and administer your account.

Third-Party Products. CrediFi may use your business information to inform you of special discounts or offers from other companies we have carefully selected and whose products and services may be of interest to you.

Surveys and Contests. From time-to-time, our Websites may request information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used to notify winners and award prizes, if applicable. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Websites.

Email and Text Communication. Each email and/or text we send will contain instructions on how to unsubscribe should you decide not to receive future promotional communication. If you choose to opt-out of receiving promotional email and/or text communications from CrediFi, we may still periodically communicate with you via email, mail, and telephone for non-promotional matters. Please allow up to 10 business days to be removed from our promotional communication list. We send notification emails about the Website and Services from time to time as necessary. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Third-Party E-mail Promotions. If you access and/or use any of our third-party provider's (our Partners) services from a link on our Websites, a CrediFi/Partner co-branded site or by any other means, any information you reveal in connection with such service is submitted to our Partner and is not subject to this Privacy Policy. You should consult the privacy policy of any Partners or third-party site with respect to its treatment of any information that you may reveal through such service.

Cookies. CrediFi may place “cookies” on the browser of your computer. Cookies are small pieces of information that are stored by your browser on your computer's hard drive. Cookies may enhance the convenience and use of the Websites. You may choose to decline cookies if your browser permits but doing so may affect your ability to access or use certain features of the Website. CrediFi may also utilize web beacons on our Websites. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. The information collected through these automated means may include information that we gather and store about your visit to, and use of, the Websites, such as your IP address, type of browser and operating system used, date and time you access the websites, pages you visit, and, if you linked to the Websites from another website, the address of that website. This data does not include Personal Information and is not treated as Personal Information under this Privacy Policy, but it may include the IP address of your device. We may link an IP address to information that is personally identifiable. Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling this function may impact your use and enjoyment of this Website.

Third-Party Analytics. We may also allow certain third-party analytics service providers to include cookies and web beacons within the pages of the Websites on our behalf and to retain and use the information received from such cookies and web beacons themselves. Third-party service providers that collect this data on our behalf may offer information about their data collection practices, and in some cases, an opt out on their respective websites which you can access here: http://www.google.com/analytics/.

How Long Do We Keep Your Data

We may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Web sites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements. How Do We Protect Your Data We take precautions to protect your information. When you submit sensitive information via the Websites, your information is protected both online and offline. We use appropriate security measures to protect the security of your data both online and offline. These measures vary based on the sensitivity of the information that we collect, process, store, and the current state of technology. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

How We Share Data

Unless you give us your permission, we don't share data we collect from you with third parties, except as described below:

Third-party service providers or consultants. We may share data collected from you on CrediFi Websites with third-party service providers or consultants who need access to the data to perform their work on CrediFi' behalf. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data.

Compliance with Laws. We may disclose your data to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of the CrediFi Site or our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If CrediFi is required by law to disclose any of your data that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.

California Privacy Rights

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including (i) the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information, (ii) the right to know and access personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the categories of personal information we have collected, used, disclosed, or sold about you, the categories of sources from which the personal information is collected, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold, and the categories of third parties with whom we have shared your personal information, (iii) the right to request CrediFi to transfer, to the extent feasible, personal information in certain forms and formats, (iv) the right to request that we delete/erase your personal information under certain circumstances, and (v) the right not to be subject to discrimination for asserting your rights under the CCPA. The personal information we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information is set forth in this Privacy Policy. To exercise any of the CCPA's data privacy rights set forth herein, please contact us in accordance with the “How to Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California. Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information under the CCPA, CrediFi will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. CrediFi will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA's rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa. Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt-out of the sale of their personal information. CrediFi does not sell your personal information.

Privacy Rights

CrediFi is a service provider to our Customers and the data in our systems is owned by our Customers, meaning, our Customers have jurisdiction over the data and any end-user data subject request should be submitted directly to the Customer. Customer's users may access, correct, and delete some information within the Platforms. If you have additional requests, please contact our Customer's directly. CrediFi supports our Customers in all requests. In compliance with Global Data Protection laws, CrediFi provides its Customers with specific additional rights such as the right to access, correction, and deletion as described below:

• request access to categories and specific pieces of personal information about you

• request that we correct inaccurate or incomplete personal information about you;

• request deletion of personal information about you;

• request restrictions, temporarily or permanently, on our processing of some or all personal information about you;

• request transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and

• opt-out or object to our use of personal information about you where either: o our use is based on your consent or our legitimate interests, or o you do not want us to share with third parties.

If you are a CrediFi Customer, you may exercise your rights by contacting [email protected]. All requests will be addressed within the timeframe required based on the applicable regulation. If the collection of your personal data was based on your consent, you have the right to revoke that consent at any time. Be aware that by revoking consent, you may lose access to Services you previously opted to use. If you are not a CrediFi Customer and rather a user of our Services through an account you have with a CrediFi Customer, please contact that Customer directly.

Changes to this Privacy Policy

We update this privacy statement when necessary to provide greater transparency or in response to:

• Feedback from customers, regulators, industry, or other stakeholders

• Changes in our products

• Changes in our data processing activities or policies

When we post changes to this statement, we will revise the "Effective Date" date at the top of the statement. If there are material changes to the statement, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how CrediFi is protecting your information.

How to Contact Us

CrediFi commits to resolve complaints about our collection or use of your personal information. CrediFi takes its users' privacy concerns seriously. If you believe that CrediFi has not complied with this Privacy Policy with respect to your personal information, please email us at [email protected] or by writing to the CrediFi Privacy Officer at the following address: CrediFi

Attn: Privacy Officer

14811 Attboro Place

Tustin, CA 92780 USA