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PRIVACY


YOUR PRIVACY IS IMPORTANT TO UPGRADE AND ITS BANK PARTNERS.

Privacy Policy

California Privacy Policy

Federal Privacy Notices

Upgrade Privacy Notice

Cross River Bank Privacy Notice

Blue Ridge Bank Privacy Notice


PRIVACY POLICY



Effective date: January 31, 2023

Protecting your privacy is important to Upgrade, Inc. (DBAs include Universal
Credit, and the names here, collectively “Upgrade,” “we,” “us,” and “our”).
Please read this Privacy Policy (the “Privacy Policy”) before using the Site.
The “Site” refers to any website or mobile application operated by Upgrade,
including www.upgrade.com, or any other online or mobile service that links to
or otherwise presents this Privacy Policy to you.

This Privacy Notice describes how we collect, use, share, process, and delete
personal information; what rights and choices you may have with respect to your
information; how you may contact us, and how we protect your personal
information when you visit the Site or access or use products, services, and
related applications offered by Upgrade (collectively, the “Services”) such as
creating or managing your account. This Privacy Policy applies to all
prospective, current, and former Upgrade customers as well as businesses that
interact with Upgrade. This Privacy Policy does not apply to job applicants who
apply to work for Upgrade or employees employed by Upgrade.

By accessing or using the Site, you consent to this Privacy Policy and the Terms
of Use. We may periodically update or revise this Privacy Policy to describe new
Services or changes to our practices. You can determine when this Notice was
last revised by referring to the “Effective Date” at the top of this Notice. We
encourage you to review the Policy whenever you interact with us to stay
informed about our privacy practices and the ways that you can help protect your
privacy. If we make significant changes to this Policy, we will notify you
through a prominent notice on our Site or Services, release updates, or via
email address associated with your account. Your continued use of our Site is
deemed to be acceptance of those changes.


INFORMATION UPGRADE COLLECTS ABOUT YOU

The information that we collect depends on the context of your interactions with
us and the choices that you make, your location, and applicable law. The
sub-sections below describe the information we collect about you and how we
collect it.

A. Information You Provide Directly to Us

We collect the following information directly from you when you use our Site
and/or Services:

 * Personal Information: Name, address, email, phone number, Social Security
   number, date of birth, account log in, password, Upgrade card number, loan
   ID, government ID, selfie, geolocation and IP address.
 * Payment Information: Information about your payments, loan terms, or
   transaction history;
 * Employment Information: Information about your employment, start date, work
   phone, salary, paystub, and annual income;
 * Company Information: Information about your company, company name, location,
   your percentage of ownership;
 * Bank Information: Your bank information, including your bank name, account
   number, and routing number; debit and credit cards details
 * Verification Information: Information for verification (fraud) checks,
   including verification of your identity and other information you provide;
 * Other information that you voluntarily provide to us when you report a
   problem with our Services or when we provide you with customer support by
   phone or email or otherwise or that we may collect as permitted by law and
   with your consent (where required by law).

B. Information We Receive from Third Parties

We receive the following information about you from third parties such as credit
bureaus, our partners, and service providers to support our business operations:

 * Credit reporting agencies: Information such as your name, address, Social
   Security number, credit score, and other information from credit reporting
   agencies;
 * Business partners: we may receive your personal information, such as name,
   email, date of birth, Social Security number or employment information from
   businesses we partner with to offer our Services;
 * Service providers: we may also receive your personal information, such as
   name, address, phone number from service providers which perform services
   solely on our behalf;
 * Banking and Financial Institutions: When you choose to link your bank account
   for the purposes of direct deposit and related services, we may receive the
   financial information associated with those accounts, including account
   balances and transaction history.

C. Information We Collect Automatically

We use Google Analytics on our Site which automatically collects the following
information about you, your device, and your usage of our Site:

 * Website Usage information – We collect information about your usage and
   behavior on our Site and/or Services, such as your browsing history of the
   content you have visited on our Site, including how you were referred to our
   Site via other websites.
 * Device information – We collect information about the type of device you use
   when you access our Site including details of your computer or mobile, such
   as the unique device identifier, unique advertising identifier, and browser
   used to access our content.
 * Geolocation information – We collect information about your IP address, which
   is a numerical code to identify your device, together with the country,
   region or city where you are based.
 * Anonymized statistical information – We may collect other information
   provided to us through analytics services.


HOW UPGRADE USES INFORMATION

We limit our use of your personal information to the purposes described in this
Notice. Upgrade is a service provider to its bank partners, and all loans or
bank accounts facilitated through the Site are provided by a bank partner.

Upgrade uses collected information in the following ways:

 * Provide and Improve our Site and Services – We use your personal information,
   credit information, employment information, bank information, and
   verification information to manage your account, provide, operate, monitor,
   maintain and administer our Site and Services, and to improve our offerings
   to you, including to develop new products and services.
 * Facilitate your loan or account with a bank partner – We use your personal
   information, credit information, employment information, bank information,
   and verification information to generate your borrower profile, process your
   loan or account application on behalf of the bank partner providing the loan
   or account, and to enable automatic payments and fund transfers with other
   financial institutions.
 * Communicate with you about our Services – We use your personal information to
   contact you regarding updates to our Services or to communicate with you
   concerning your account and transactions.
 * Send and improve marketing communications – We use your personal information
   for our Marketing Activities according to your preferences, such as
   communicating with you via email or SMS.
 * Provide customer support – We use your personal information to provide
   customer support if you run into issues with our Site or Services, or to
   verify your identity when exercising your privacy rights.
 * Provide and improve necessary functionality – We use your website usage
   information, device information, geolocation information, and anonymized
   statistical information to provide the necessary functionality required for
   you to use our Site and Services and to improve our Site based on this
   information.
 * Promote the security of our Site and Services – We may use your personal
   information, website usage information, device information, geolocation
   information, and anonymized statistical information to investigate and
   prevent malicious, deceptive, fraudulent, or illegal activity, and enforce
   our terms and policies.
 * Legal, regulatory, safety, and compliance purposes – We may use the
   categories of information collected for purposes of compliance with laws or
   regulations and to review compliance with applicable usage terms.
 * Other purposes – We may process the categories of information collected for
   other purposes about which we notify you in advance or for which we receive
   your consent (such as in the event of a corporate sale, merger, or
   acquisition).


INFORMATION UPGRADE DISCLOSES

Upgrade may use and disclose your information to provide our product and
services to you and in accordance with applicable law. We do not share or sell
your personal information with any third party other than as described in this
Privacy Policy.

We may disclose your information with the following third parties in the
following instances:

 * Contractors, Service providers, and other third parties we use to support our
   business, our products and services, such as for fraud prevention, servicing,
   bill collection, debt collection, marketing and technology services, product
   development;
 * Nonaffiliated financial institutions that we partner with to market or
   provide the products or services to you;
 * Credit reporting agencies to report account information as authorized by you
   or otherwise permitted by law;
 * Investors who may purchase your loan directly from us or as part of servicing
   of your loan or account;
 * Law enforcement, government officials, or other third parties as required by
   law and when we believe that such disclosure is necessary to protect our
   rights and/or comply with a judicial proceeding, court order, regulatory
   request or other legal process;
 * Third parties when we have a legitimate business purpose as permitted by law;
   or
 * Buyer or other successor in the event of a merger, divesture, restructuring,
   reorganization, dissolution, or other sale or transfer of some or all of
   Upgrade’s assets in which personal information held by Upgrade about our Site
   users is among the assets transferred; or
 * Other third parties with your consent or authorization.

We also partner with third parties to manage our advertising on other sites and
to evaluate the Site performance.


THIRD PARTY WEBSITES

This Site may contain links to other websites operated by third parties,
including social media providers. Upgrade cannot and does not control the
privacy practices of these third-party websites. Upgrade does not endorse the
content or information of any third-party website or resource and, further,
Upgrade does not warrant that such websites or resources will not contain
viruses or other malicious code or will not otherwise affect your computer. By
using any link on our Site to connect to a third-party website, you agree and
understand that Upgrade shall not be responsible or liable, directly or
indirectly, for any damages or losses caused or alleged to be caused by or in
connection with the privacy practices of any third-party websites.


HOW UPGRADE PROTECTS YOUR PERSONAL INFORMATION

Our goal is to protect the security of your information. We have implemented
technical, organizational, and physical measures designed to protect against
loss or unauthorized access, disclosure, alteration, or destruction of the
information you provide on the Site. For example, technical safeguards that we
use to achieve data security include a combination of firewalls, intrusion
detection system, malware detection system, and data loss prevention systems.
Upgrade also conducts vulnerability scans of applications and systems regularly.


ADDITIONAL STEPS YOU SHOULD TAKE TO ENSURE THE SECURITY OF YOUR INFORMATION

Upgrade does not and cannot guarantee the security of your information submitted
through the Site, and we encourage you to take steps to secure your information.

You should not include any personal identifying information in your account ID.
You should always choose a password that is difficult for others to guess and
change your password frequently. At a minimum, we require the use of both
numbers and letters in your password. You should never share your password with
anyone. Your password is not known to Upgrade, and we will never ask for your
password.

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

We also recommend you avoid using public computers and networks and delete
browser cache files after using the Site.

If you believe the security of your account is compromised or to report any
concerns, please contact us at security@upgrade.com.


CHILDREN’S PRIVACY

This Site is not intended for children or minors under the age of 18. We do not
knowingly collect personal information from, or market to, children under the
age of 13. If we become aware that a child under the age of 13 has provided us
with personal information without parental consent, we will take steps to comply
with applicable legal requirements to remove such information.



CALIFORNIA PRIVACY POLICY

If you are a California resident, the California Consumer Privacy Act of 2018
(the “CCPA”) and the California Privacy Rights Act (the “CPRA”) require us to
provide you with certain notices prior to our collection and use of your
personal information.

This notice for California residents supplements the information provided in the
rest of this Privacy Policy, which also applies to you. Any terms defined in the
CCPA or CPRA have the same meaning when we use them here.

We collect personal information about prospective, current, and former Upgrade
customers. In particular, we have collected the following categories of personal
information from consumers in the last twelve (12) months:

 * Identifiers such as Name, address, phone number, email address, Social
   Security number, and date of birth;
 * Characteristics of protected classifications under California or federal law;
 * Commercial Information;
 * Internet or other similar network activity;
 * Certain geolocation data; and
 * Professional or employment-related information.

Additionally, we have collected the following categories of sensitive personal
information from consumers in the last twelve (12) months:

 * Social security number, driver's license, state Identification card, or
   passport number.
 * Account log-In, financial account, debit card, or credit card number in
   combination with any required security or access code, password, or
   credentials allowing access to an account.
 * Precise geolocation

Upgrade does not “sell” any personal information we collect. We disclose
personal information within the categories of third parties described in the
“Information Upgrade Discloses” section above.


YOUR RIGHTS AND CHOICES UNDER THE CCPA

Subject to certain exemptions, California residents have the right to request to
know details about the categories and specific personal information we collect;
to correct inaccurate information about themselves; to delete their personal
information; to opt out of “sale” or “sharing” of personal information; to limit
use or disclosure of sensitive personal information; and be free from unlawful
discrimination for exercising these rights under the CCPA.

Financial regulations, including the Fair Credit Reporting Act (“FRCA”) and the
Gramm-Leach-Bliley Act (“GLBA”), may prevent us from disclosing or deleting
certain information that may be requested by California residents.


HOW TO EXERCISE YOUR RIGHTS UNDER THE CCPA

If you are a California resident, you may make a request to exercise your rights
under the CCPA by either of the following methods:

 * Submitting a webform request; or
 * Calling us toll-free at (877) 418-4547; when prompted, dial PIN: 461370

Before responding to a request, we will request information from you, which at a
minimum will include your full name, date of birth, and email address, and any
additional information to verify your identity. Under the CCPA, you may have an
authorized agent submit a request on your behalf, and we will collect certain
authorization and verification information from you and your authorized agent.
We will respond to all requests within 45 days. If the matter cannot be resolved
within 45 days, we will contact you regarding the reason for requiring
additional time.





FEDERAL PRIVACY NOTICES

All loans made and accounts obtained through Upgrade are provided by a bank
partner.

For applicants and borrowers of the Personal Loan (“PL”) product offered by
Upgrade’s bank partners through Upgrade, the following Federal Privacy Notices
apply.

For applicants, borrowers and/or users of financial products or services offered
by Cross River Bank through Upgrade, the following Federal Privacy Notices of
Upgrade and Cross River Bank apply.

 


UPGRADE GLBA PRIVACY NOTICE

Rev. Jan. 2023

FACTS

WHAT DOES UPGRADE, INC. 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 Credit History

 * Account Balances and Transaction History

 * Payment History and Employment Information

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

How?

All financial institutions need to share customer's personal information to run
their everyday business. In the section below, we list the reasons financial
companies can share their customer's personal information; the reasons Upgrade
chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Upgrade share?

Can you limit

this sharing?

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

Yes

No

For our marketing purposes—

to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes—

information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes—

information about your creditworthiness

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

Questions?

Call 844-319-3909 or go to www.upgrade.com

Who we are

Who is providing this notice?

Upgrade, Inc.

What we do

How does Upgrade protect my personal information?

To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.

Upgrade employees only access your personal information as necessary to perform
their role.

How does Upgrade collect my personal information?

We collect your personal information, for example, when you

 * Open an account or provide employment information

 * Apply for a loan or provide account information

 * Give us your contact information

We also collect your personal information from others, such as credit bureaus or
other related companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

 * sharing for affiliates’ everyday business purposes information about your
   creditworthiness.

 * affiliates from using your information to market to you

 * sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.

Definitions

Affiliates

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

 * Upgrade Tech Canada, Inc.

Nonaffiliates

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

 * Upgrade shares with nonaffiliates, including other financial services
   companies and service providers, to help Upgrade market to you and provide
   products and services to you.

Joint marketing

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

 * Upgrade’s joint marketing partners include our bank partners, financial
   companies, lenders, and other consumer financial platforms.

Other important information

California Residents: We will not share your information with companies outside
of Upgrade except for our everyday business purposes, for marketing our products
and services to you or with your consent. Please see the “Important Privacy
Choices for Consumers” notice, which will be provided to you separately, for
more information about your privacy rights.

Vermont Customers: 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. Additional information concerning our privacy
policies can be found at www.upgrade.com/privacy or call 844-319-3909.

Nevada Residents: Notice provided pursuant to state law. To be placed on our
internal Do Not Call List, call 844-319-3909. If you would like more information
about telemarketing practices, you may contact us at Upgrade. Attn: Nevada
Marketing Information, 275 Battery Street, 23rd Floor, San Francisco, CA 94111
or email  support@upgrade.com. For more on this Nevada law, contact Bureau of
Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington
St., Suite 3900, Las Vegas, NV 89101; Phone number: 1-702-486-3132; e-mail:
BCPINFO@ag.state.nv.us.

Texas Residents: Upgrade is licensed and examined under the laws of the State of
Texas and by state law is subject to regulatory oversight by the Office of
Consumer Credit Commissioner. Any consumer wishing to file a complaint against
Upgrade should contact the Office of Consumer Credit Commissioner through one of
the means indicated below: In Person or U.S. Mail: 2601 North Lamar Boulevard,
Austin, Texas 78705-4207. Telephone No.: (800) 538-1579. Fax No.: (512)
936-7610. E-mail: consumer.complaints@occc.state.tx.us . Online:
https://occc.texas.gov/contact. . Website:
https://occc.texas.gov/consumers/file-a-complaint.

Telephone Communications: All telephone communications with us or our authorized
agents may be monitored or recorded.

 


CROSS RIVER BANK PRIVACY NOTICE

Rev. Nov. 2018

 

FACTS

WHAT DOES CROSS RIVER BANK 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 Account balances

 * Payment history and Transaction History

 * Account transactions and Wire transfer instructions

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; the reasons Cross
River Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Cross River Bank share?

Can you limit this sharing?

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

Yes

No

For our marketing purposes –

to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates' everyday business purposes –

information about your transactions and experiences

No

We don't share

For our affiliates' everyday business purposes – information about your
creditworthiness

No

We don't share

For nonaffiliates to market to you

No

We don't share

Questions?

Call toll-free 1-877-55CRB55 or go to www.crossriverbank.com

What we do

How does Cross River Bank protect my personal information?

To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.

We also maintain other physical, electronic and procedural safeguards to protect
this information and we limit access to information to those employees for whom
access is appropriate.

How does Cross River Bank collect my personal information?

We collect your personal information, for example, when you

 * Open an account or Apply for a loan

 * Make deposits or withdrawals from your account or Provide employment
   information

 * Give us your contact information

We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only

 * sharing for affiliates' everyday business purposes-information about your
   creditworthiness

 * affiliates from using your information to market to you

 * sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.

Definitions

Affiliates

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

 * Cross River Bank does not share with our affiliates.

Nonaffiliates

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

 * Nonaffiliates we share with can include loan finance companies

Joint marketing

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

 * Our joint marketing partner(s) include loan finance companies.

Other important information

For Alaska, Illinois, Maryland and North Dakota Customers. We will not share
personal information with nonaffiliates either for them to market to you or for
joint marketing-without your authorization.

For California Customers. We will not share personal information with
nonaffiliates either for them to market to you or for joint marketing-without
your authorization. We will also limit our sharing of personal information about
you with our affiliates to comply with all California privacy laws that apply to
us.

For Massachusetts, Mississippi and New Jersey Customers. We will not share
personal information from deposit or share relationships with nonaffiliates
either for them to market to you or for joint marketing-without your
authorization.

For Vermont Customers. 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. Additional information
concerning our privacy policies can be found at www.crossriverbank.com or call
1-877-55CRB55.

 


BLUE RIDGE BANK PRIVACY NOTICE

Rev. January 2023

 

FACTS

WHAT DOES BLUE RIDGE BANK, N.A. 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 employment information

 * Account balances and transaction history

 * Credit history and investment experience

How?

All financial companies need to share customers' personal information to run
their everyday business. In the section below, we list the reasons financial
companies can share their customers' personal information; the reasons Blue
Ridge Bank, N.A. chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Blue Ridge Bank, N.A. share?

Can you limit this sharing?

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

Yes

No

For our marketing purposes–

to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We don't share

For our affiliates' everyday business purposes –

information about your transactions and experiences

Yes

No

For our affiliates' everyday business purposes –

information about your creditworthiness

Yes

Yes

For our affiliates to market to you

Yes

Yes

For nonaffiliates to market to you

No

We don't share

To limit our sharing

Call (888) 331-6521 to speak with a customer service representative

Please note:

If you are a new customer, we can begin sharing your information 30 days from
the date we sent this notice. When you are no longer our customer, we continue
to share your information as described in this notice. However, you can contact
us at any time to limit our sharing.

Questions?

Call (888) 331-6521 or go to www.mybrb.com

Who we are

Who is providing this notice?

Blue Ridge Bank, N.A.
BRB Financial Group, Inc.


What we do

How does Blue Ridge Bank, N.A. protect my personal information

To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.

How does Blue Ridge Bank, N.A. collect my personal information

We collect your personal information, for example, when you

 * Open an account or apply for a loan

 * Use your credit or debit card or seek advice about investments

 * Make deposits or withdrawals from your account

We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only

 * Sharing for affiliates’ everyday business purposes—information about your
   creditworthiness

 * Affiliates from using your information to market to you

 * Sharing for nonaffiliates to market to you

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

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

 * Hammond Insurance

 * Exchangers LTD

Nonaffiliates

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

 * Blue Ridge Bank, N.A. does not share with nonaffiliates so they can market to
   you

Joint marketing

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

 * Blue Ridge Bank, N.A. does not jointly market.