Privacy Policy

This Privacy and Federal Privacy Notice (the “Policy”) is between Impruvu LLC, a limited liability company duly organized under the laws of the State of New Mexico (“Impruvu, Company, us, we, our”), and the User(s) of this website (“Users, you”), which you must accept to use any aspect of this website. By continuing to use this website, you assent to each term in this Policy, and you acknowledge that you have had the chance to review, consider, and agree to this Policy. If you do not understand or agree to this Policy, then you agree to immediately cease your use of this website.

We have prepared this Policy to explain how we collect, use, protect, store, and disclose information and data when you use Impruvu’s websites, services, and mobile applications, if one is developed; however, this Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Website. This Privacy Policy also explains your choices for managing information preferences, including opting out of certain uses of your personal information. By accessing or using Impruvu’s websites, mobile applications, or services, you consent to this Privacy Policy.

If you have questions or complaints regarding our Privacy Policy or practices, or if you need assistance in exercising any of your choices under this Privacy Policy, please contact us [email protected].

This policy applies to all current and former Impruvu customers. Note that, in order to use our services, you must be 18 years of age or older.

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”) provides specific rights and protections to California residents. If you are a California resident, please see the section entitled “Notice to California Residents” below for more information.

INFORMATION IMPRUVU COLLECTS ABOUT YOU

Depending on how you use our Website, you will be subject to different types of Personal Data collected and different manners of collection:

All Users: The Passive Data Collection that applies to Unregistered users shall also apply to all other users and/or visitors of our Website.

Co-applications: We may also collect information that you provide to us about your co-applicant in connection with a joint application, loan application, and/or any of Impruvu’s other financial products. By submitting information about someone other than yourself, you represent that you are authorized to provide us with that person’s information for the purposes identified in this Privacy Policy and/or in connection with our services.

Combined or Aggregated Information: We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update our Website for your and other consumers’ use. We may also share such aggregated information with others, but only if that aggregated information does not contain any Personal Data.

Content Interaction: Our Website may allow you to comment on the content that we provide or the content that other users provide, such as blogs, multimedia, or forum posts. If so, we may collect some Personal Data from you at that time, such as, but not limited to, username or email address.

Email Marketing: You may be asked to provide certain Personal Data, such as your name and email address, for the purpose of receiving email marketing communications. This information will only be obtained through your voluntary disclosure and you will be asked to affirmatively opt-in to email marketing communications.

Financing Platforms: You may also provide your information to certain third-party financing platforms who will process your application for credit and may provide your information to us. The use of your information by that online financing platform is governed by that company’s privacy policy.

Inquiry Data: In addition, we gather names, email addresses, and phone numbers of people who contact us with questions. We collect this information only for the purpose of responding to inquiries. If you use our referral program, we will collect information from you in order to process your referral request.

Registered Users: You, as a user of the Website, may be asked to register in order to use the Website or to purchase the Services available for sale. During the process of your registration, we will collect some of the following Personal Data from you through your voluntary disclosure:

Name, email address, physical address, billing address, phone number, and Personal Data may be asked for in relation to:

Interaction with our representatives in any way;

Making purchases;

Receiving notifications by text message or email about marketing;

Receiving general emails from us; and/or

Commenting on our content or other user-generated content on our Website, such as blogs, articles, photographs or videos, or participating in our forums, bulletin boards, chat rooms or other similar features.

By undergoing the registration process, you consent to us collecting your Personal Data, including the Personal Data described in this clause, as well as storing, using, or disclosing your Personal Data in accordance with this Policy.

Related Entities: We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities; however, we shall only share your Personal Data with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do.

Sales & Billing Information: In order to purchase any of the services on the Website, you will be asked to provide certain credit information, billing address information, and possibly additional specific information, so that you may be properly charged for your purchases. This payment and billing information will not be stored and will be used exclusively to assist with your one-time purchase.

Unregistered Users: If you are a passive user of the Website and do not register for any purchases or other service, you may still be subject to certain passive data collection (“Passive Data Collection”). Such Passive Data Collection may include through cookies, as described below, IP address information, location information, and certain browser data, such as history and/or session information.

User Experience: From time to time we may request information from you to assist us in improving our Website, and the Services we sell, such as demographic information or your particular preferences.

Information Gathered Based on Your Activity on the Impruvu Websites

In order to provide services to you, improve our business, and maintain records required by law, Impruvu collects information about your transactions and activity. For purchasers of Impruvu’s financial products, this includes your payment or transaction history. For all users, Impruvu and/or its service providers collect information about your visits to

www.impruvu.io and other Impruvu websites and the computer or device through which you access our websites, such as your IP address, geographical location, operating system, browser type, referral source, time and length of visit, button clicks and/or page views, and your mobile device identifier (IDFA or AAID). With respect to individuals that have not created user accounts with Imrpuvu, we do not associate the information that we collect with a particular consumer or household.

If Impruvu develops a mobile app(s), the mobile app(s) may periodically collect, transmit, and use geolocation information to enable certain features, including features that prevent fraudulent card use and send alerts, but only if you expressly authorize collection of such information. Geolocation information can be monitored on a continuous basis in the background only while the mobile app is being used or not at all, depending on your selection. You can change your location permissions at any time in your mobile device settings.

Tracking Technologies

Cookies and Web Beacons.

Impruvu and our marketing partners and service providers use technologies such as but not limited to cookies, beacons, tags, and scripts, to analyze trends, administer the Impruvu websites, track users’ movements around the Impruvu websites, and gather information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis.

We use cookies when you interact with Impruvu websites to keep track of your personal session, help authenticate your account, and detect fraud. Cookies are also used to gather statistical data, such as which pages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to Impruvu websites. You can control the use of cookies within your web browser; however, if you reject cookies, your ability to use some features or areas of Impruvu websites may be limited.

Social Network Plugins.

This Website incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard the privacy of users. Cookies may be set, however, if you make voluntary use of the plugin. Please note that if you browse while being logged into the social network, then you have already consented to the use of cookies conveyed through this Website at the time that you registered with the particular social network.

The collection and use of information obtained by means of the plugin are governed by the respective privacy policies of the social networks, which can be found below:

Facebook:

https://www.facebook.com/help/cookies

Twitter:

https://help.twitter.com/en/rules-and-policies/twitter-cookies

Google+:

https://about.pinterest.com/it/privacy-policy

Pinterest:

https://about.pinterest.com/it/privacy-policy

Add This:

http://www.addthis.com/privacy/privacy-policy

LinkedIn:

https://www.linkedin.com/legal/cookie-policy

Third Party Technologies.

We also may partner with third parties to manage our advertising services on other websites and evaluate overall Impruvu website performance, and/or to collect certain information when you visit and interact with Impruvu websites and services. These third party companies may use technologies such as cookies to recognize browsers and to gather information about your activities on Impruvu websites and other sites in order to provide you advertising based upon your browsing activities and interests or help us track the success of our marketing efforts, your interactions with Impruvu websites, and overall Impruvu website performance.

We may use Third-Party Service Providers to assist with information storage, such as cloud storage, and to host Impruvu websites. In this instance, the Third-Party Service Provider will have access to your Personal Data; however, we will not knowingly share your Personal Data with any third parties other than in accordance with this Policy.

If your Personal Data is ever at risk of being provided to a third party in a manner other than as explained in this Policy, you will be notified, and be given the opportunity to request that we not share that information. Moreover, in general, you may request that we do not share your Personal Data with third parties.

Please contact us via email, at [email protected], but please note this does not opt you out of being served ads. You will continue to receive generic ads.

Usage Data & Site Activity.

Impruvu primarily uses your Personal Data to help us provide a better experience for you on our Website and to provide you the services and/or information you may have requested, such as use of our Website. We also use Local Storage, such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.

Do-Not-Track Signals

Impruvu does not process or respond to “do not track” signals or other similar signals whereby a visitor to a website requests that it disable collection of information about the visitor’s online activities over time and across different websites.

Location

Please be advised the data processing activities take place in the United States, outside the European Economic Area. Data may also be transferred to companies within the United States, but will only be done so in a manner that complies with the EU’s General Data Protection Regulation or GDPR. The location where the data processing activities take place is as follows:

530B Harkle Road Suite 100, Sante Fe, NM 87505

HOW IMPRUVU USES YOUR INFORMATION

Processing Your Transaction/Providing You Services

If you become a Registered User and/or apply for one of Impruvu’s financial products, Impruvu will use your information to facilitate services provided to you. This may include:

Generating your account profile, processing your application for financial products, and verifying your identity and application information;

Improving your personal user experience;

Enabling automatic payments and fund transfers with other financial institutions;

Implementing collection activities as needed;

Communicating with you concerning your application, account, and/or transactions with us;

Marketing and advertising to you;

Fulfilling your purchases;

Providing other customer service to you;

Informing you of updates to the website or related Items; and

Addressing any disputes you may raise.

Analysis & Data Optimization

Impruvu also uses your information to conduct analyses related to our services and Impruvu websites. We use this information to improve our financial services. We also use this information to improve Impruvu websites’ usability and to evaluate the success of particular marketing campaigns and other activities.

Marketing & Surveys

Impruvu may also use your personal information to select you for certain marketing communications, newsletters, surveys and/or requests for feedback regarding your experience. Impruvu may use your personal information both to select you for offers and to communicate offers to you.

Opting out of Transmittals

From time to time, Impruvu may send you informational or marketing communications related to our Website, such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email:

[email protected]. You may also click the opt-out link which will be provided at the bottom of any and all such communications.

Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Website or about your account with us.

By providing any Personal Data to us, or by using our Website in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.

HOW IMPRUVU SHARES YOUR INFORMATION

Impruvu will share your personal information with nonaffiliates (companies not related by common ownership or control) and among affiliates (companies related by common ownership or control, including but not limited to the companies covered by this policy) only in the ways that are described in this Policy. By law, you are permitted to limit some types of sharing, but not others.

Impruvu shares your information with third parties as permitted by law, including in the following specific ways:

Affiliates.

Impruvu affiliates, including entities covered by this policy and other companies related by common ownership or control may share your information with each other, including information related to your creditworthiness, for purposes of general business analysis, or to present targeted marketing to you or others. Your rights with respect to this sharing are discussed in the following section.

Co-Applicants / Co-Borrowers.

We may share certain limited information with your co-applicant / co-borrower in order to process your application and/or loan or service your account, and as needed to provide our services.

Credit Bureaus.

Impruvu may share your personal information with credit bureaus to meet our credit reporting obligations.

Legal Requests & Regulatory Requirements.

Impruvu may also share information to comply with any applicable law, regulation, legal process, or governmental request; or for the purposes of limiting fraud; or in connection with an audit or the sale of Impruvu to a third party.

Lending Partners.

All types of credit offered through Impruvu are fulfilled by a third party bank(s) or non-bank lending partner(s) that may extend credit to you (“Lending Partners”). If you apply for a loan or credit card through Impruvu, you are also providing your information to the potential Lending Partners, and further information may be provided to those Lending Partners after your loan originates or your card is issued. The use of your information by your Lending Partner is governed by that Lending Partner’s privacy policy.

Merchants or Service Providers.

If you applied for a loan to be used with a merchant or service provider, Impruvu may share your information with the merchant or service provider associated with your loan application.

Public Information.

We may allow users to post their own content or information publicly on our website. Such content or information may include, but is not limited to, photographs, status updates, blogs, articles, or other personal snippets. Please be aware that any such information or content that you may post should be considered entirely public and that we do not purport to maintain the privacy of such public information.

Referral Partners.

If you were referred to Impruvu by another company (a “Referral Partner”) or person, Impruvu will share your information as necessary to honor the terms of its agreement with that Referral Partner or person and to process your transaction. In some cases, Impruvu may share with a Referral Partner for that Referral Partner’s own business purposes, such as to analyze and improve its business and provide targeted marketing to you. Your rights with respect to this sharing are discussed in the following section.

Sharing of Anonymized Data.

Impruvu may share aggregated and anonymized data sets with third parties, including but not limited to business partners, service providers, and among Impruvu affiliates. No personally identifiable information will be included in these data sets.

Third Party Service Providers.

Impruvu relies on third party service providers to help us conduct our business and marketing activities, such as maintaining our files and records, hosting Impruvu website, offering customer service, sending marketing communications, or facilitating fund transfers. Impruvu may share your information with such companies, which are authorized to use your personal information only as necessary to provide these services to Impruvu. Information may also be shared among affiliates (including but not limited to the companies covered by this policy) for this purpose where one affiliated company provides services to or on behalf of another affiliated company in connection with your account or application.

Your Consent.

Impruvu may share your personal information with third parties at your direction or whenever you consent.

IMPORTANT PRIVACY CHOICES

Consent to information sharing with third party companies (Referral Partners)

By accepting this Policy, you agree that Impruvu may immediately begin sharing your information with any third party company that referred you to Impruvu so that that company may use your information for their own business purposes, including to market to you. For example, if you were referred to Impruvu by another company through a website link or telephone transfer, Impruvu may share some of your information, such as the existence and terms of your financial products, with that company. You may revoke this consent at any time by following the procedures outlined below. If you revoke consent we will not subsequently share your information with these companies except as necessary to complete the transaction you initiated.

Right to restrict information sharing with companies we own or control (affiliates)

Impruvu may share your information among affiliated companies whether or not those companies are covered by this policy. Federal law gives you the right to limit this sharing where it includes information about your creditworthiness other than your transactions and experiences with Impruvu or is used for the purpose of marketing to you. If you would like to opt-out of this type of sharing, please follow the instructions below. We may begin sharing your information related to your creditworthiness or any information to be used for marketing purposes thirty (30) days from the date that we first provided this notice if you have not opted-out.

If you wish to opt-out of such information sharing, you may contact the following email:

[email protected]. Please note that your opt-out choices will also apply to your co-borrower.

Rights in relation to your Personal Data

Specifically, federal law gives you the right to:

Be informed about the processing of your Personal Data;

Have access to your Personal Data;

Update and/or correct your Personal Data;

Portability of your Personal Data;

Oppose or limit the processing of your Personal Data;

Request that we stop processing and delete your Personal Data;

Block any Personal Data processing in violation of any applicable law; and

Launch a complaint with the Federal Trade Commission (the “FTC”) in the United States or applicable data protection authority in another jurisdiction

Such rights can all be exercised by contacting us at the following email: [email protected].

If you would like to exercise your right to opt-out of information sharing by a company affiliated with Impruvu but not covered by this policy, you must consult that company’s privacy policy for instructions on how to exercise your right to opt-out of their information sharing.

ADDITIONAL FACTS ABOUT YOUR PERSONAL INFORMATION

How Impruvu Secures Your Information

Impruvu uses significant safeguards, including physical, technical (electronic), and operational controls to protect your personal information, both during transmission and once received. If you have any questions about the security of your information, you can contact us at the following email: [email protected].

Impruvu equips all servers with a Secure Socket Layer (SSL) certificate to ensure that when you connect to our websites you can tell that you are actually on our site and that all data entered into the websites are transmitted to us in a secure encrypted channel. Once on our system, personal information can only be read or written through defined service access points, the use of which is password-protected. Data security is achieved through technical safeguards that include a combination of encryption, firewalls, intrusion prevention system, malware detection system, and data loss prevention systems. Impruvu also conducts vulnerability scans of applications and systems regularly.

Access to the system is tightly controlled and limited to only those who have a need to access information. Administrative safeguards such as a security awareness program, background checks, and internal information use policy ensure that only trained and trusted staff are permitted to access personal information. Some additional features of our security program include:

Account Authentication

If you have an account, at a minimum, we require that you use a password or follow other secure steps we have instituted to allow you to access your account. If you create a password, you must use both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password. You should always choose a password that is difficult for others to guess and change your password frequently.

Secure Data Center

We store all sensitive financial information in state-of-the-art, highly secure data centers that are audited per AICPA SOC for Service Organizations. Physical access to the data centers is strictly controlled and we use the latest threat prevention technologies such as network and web application firewalls, VPN, antivirus, Web filtering and antispam technologies.

Additional Steps You Should Take to Ensure the Security of Your Information

Impruvu sends important communications regarding your account or application via email. You should therefore take steps to secure and restrict access to your email account and change your email account password frequently. You should also be aware of fraudulent emails known as “phishing,” from companies claiming to be Impruvu and requesting your login information or other account information. Impruvu will never ask for your login information in an email.

When you are finished using Impruvu websites, you should log out completely, then close the browser window and clear the browser’s cache files and saved passwords. This step is particularly important if you use a computer that is accessed by other people, such as in a public library or Internet café.

Changes to this policy

Any updates to the privacy policy become effective when posted on Impruvu websites. If we make any material changes, we will notify you by email or by providing the revised privacy policy in your account on www.impruvu.io if you have one. Your continued use of our services following the update means that you accept Impruvu’s updated privacy policy.

For additional information, or if you have any questions regarding this Policy or the privacy practices at Impruvu, please submit your questions or comments directly to [email protected].

You can also send questions or comments to:

Impruvu LLC

Attention: Compliance

530-B Harkle Road, STE 100,

Santa Fe, NM 87505

Last Updated:

Jun 22, 2023

NOTICE AT COLLECTION (CALIFORNIA RESIDENTS)

Effective January 1, 2020, the California Consumer Privacy Act (the “CCPA”) provides specific rights to California residents related to their “personal information,” as defined under the CCPA. Virtually all of the information that Impruvu collects about its users is exempt from the CCPA, as it is collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act (the “GLBA”). The information that Impruvu collects about its users pursuant to GLBA is described in the “

Information Impruvu Collects About You” section of this Privacy Policy.

Below is a description of the remaining “personal information” that is collected and disclosed to third parties, as well as your rights pertaining to this information.

This section only applies to California residents. The rights discussed in this section do not extend to individuals who are not California residents.

Personal Information Collected By Impruvu

Information about your interactions with our website and the mobile application. For all users, Impruvu collects information about your interactions with our homepage, landing pages, other Impruvu websites that you may visit prior to beginning the registration and/or application process, and information about the device you use to access the website and the mobile application. This includes your click movements on the webpage and the mobile application, IP address, mobile device identifier (IDFA or AAID), geographical location, operating system, browser type, referral source, time and length of visit, button clicks and/or page views. This information is collected by Impruvu and our third party service providers, who work with us to track your interactions on these pages.

We collect this information in order to:

Help detect security incidents and protect against malicious, deceptive, or fraudulent activity on our websites;

Identify and fix errors that affect the functionality of our websites;

Conduct internal research and analysis;

Determine eligibility for products and services; and

Improve our websites and services.

Information that you provide in surveys, questionnaires, and/or requests for feedback.

For users that complete surveys, questionnaires, and/or requests for feedback regarding their experience, we collect the information that you provide to us. This information is collected by Impruvu and our third party service providers, who may help facilitate these information requests.

We collect this information in order to:

Conduct internal research and analysis; and

Improve our websites and services.

Information from third parties for marketing.

For certain consumers, we may work with marketing service providers to obtain your personal information, such as your name, address, and/or email address.

We collect this information for marketing purposes in order to present you with offers, promotions, advertisements, and other marketing communications.

How Impruvu Discloses Personal Information

Impruvu may share your personal information with third party service providers to help us conduct the business purposes listed above. Our service providers are authorized to use your personal information only as necessary to provide these services to Impruvu. Impruvu does not and will not sell your personal information.

Your Rights Under the CCPARight to Know/Right to Access.

Under the CCPA, California residents have the right to request that Impruvu disclose what personal information we have collected, used, disclosed, or sold over the past twelve (12) months. Once we receive and confirm your verifiable consumer request for such information, (see “How You Can Exercise Your Rights Under CCPA”), we will disclose to you:

The categories of personal information we collected about you over the past twelve (12) months;

The categories of sources from which such personal information has been collected over the past twelve (12) months;

The business or commercial purpose for collecting, disclosing, or selling such personal information over the past twelve (12) months;

The categories of third parties with whom we shared your personal information over the past twelve (12) months; and/or

If we disclosed your personal information for a business purpose, the personal information categories that each category of recipients obtained.

Upon receiving your verified request for such information (see “How You Can Exercise Your Rights Under CCPA”), we will also disclose to you the specific pieces of personal information that we collected about you.

Right to Request Deletion.

Under the CCPA, California residents 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 (see “How You Can Exercise Your Rights Under CCPA”), we will delete your personal information from our records, and direct our service providers to do the same, unless an exception applies.

Right to Opt-Out of Sale of Personal Information.

Under the CCPA, California residents have the right to direct us to not sell your personal information (the “right to opt-out”). Impruvu does not and will not sell personal information of consumers.

Right to Non-Discrimination.

Under the CCPA, California residents have the right not to be discriminated against for having exercised the rights established by the CCPA. 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 for goods or services, including through granting discounts or other benefits or imposing penalties;

Provide you with a different level or quality of goods or services; nor

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Such financial incentives may include gift cards, credits, and other monetary offerings; additional details related to the material terms of these financial incentives will be provided to you at the time the incentive is presented to you. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

How You Can Exercise Your Rights Under CCPA

In order to exercise the right to know/right to access information and the right to request deletion, you or your authorized agent may submit a verifiable consumer request in one of the following ways:

You may exercise these rights by contacting us at the following email: [email protected]. Please note that if you contact us with your request via email we may request additional information from you or your authorized representative as needed to authenticate your request. You may only make a verifiable consumer request to know or request for access twice within a 12-month period.

The verifiable consumer request must:

Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information or that you are an authorized representative; andDescribe your request with sufficient detail so that we can properly understand, evaluate, and respond to it.

Upon receiving a request to know/request for access or a request for deletion, we will confirm receipt within ten (10) days. If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing. Additionally, in our response, we will specify the manner in which we have deleted your personal information, in accordance with the CCPA.

We will not disclose information to you or delete information if we cannot verify your identity.

How California Residents Can Designate an Authorized Representative

Only you as a California resident, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request to know/request for access, request for deletion, or request to opt-out.

To appoint an authorized representative to submit requests on your behalf, please provide us with written instructions stating the identity of the authorized representative and your authorization to have the representative act on your behalf as outlined below:

Please send the written instructions appointing your authorized representative to [email protected]. We may also request additional information from you as needed to authenticate your request. If an authorized representative is acting on your behalf to make a request to know/request for access, request for deletion, or request to opt-out, your representative may also contact us at [email protected] with a brief description of the request. Please note that we may request additional information from your representative as needed to authenticate your request.

Federal Privacy Notice

Jun 22, 2023

FACTS

WHAT DOES IMPRUVU 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.

What?

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

Social Security Number and income

Account balances and transaction history

Credit history, credit scores, and employment information

When you are no longer our customer, we continue to share your information as described in this notice

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; and the reasons Impruvu chooses to share.

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

For our marketing purposes — to offer our products and services to you

For joint marketing with other financial companies

For our affiliates’ everyday business purposes — information about your transactions and experiences

For our affiliates’ everyday business purposes — Information about your creditworthiness

For our affiliates to market to you

For nonaffiliates to market to you

To limit our sharing

All consumers may contact us at [email protected] and we will assist you in disabling such information sharing.

Following the instructions above will also revoke your consent provided in the above privacy policy for certain information sharing with non affiliated companies.

Please note that your opt-out choices will also apply to your co-borrower.

Please note:

If you are a new customer, we can begin sharing your information thirty (30) days from the date we sent this notice (except where we have received your affirmative consent to begin sharing information sooner, through our privacy policy or otherwise). 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?

Email us at [email protected]

Who we are

Who is providing this notice?

Impruvu LLC

What we do

How does Impruvu 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 building.

How does Impruvu collect my personal information?

We collect your personal information, for example, when you

Open an account;

Apply for one of Impruvu’s financial products; and/or

Provide us information including your income and employment information

We also collect your 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.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

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

Telephone Communications.

Impruvu and its authorized agents, service providers, Lending Partners and partners may monitor and/or record all telephone communications in accordance with applicable law.

Vermont Residents.

We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Nevada Residents.About + CTA + Footer

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by calling 855-755-1919 or emailing [email protected].

Nevada law also requires us to provide you with the following to obtain additional information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; Phone: 702.486.3132; Email: [email protected].