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PRIVACY POLICY



Effective date: 11/01/2021

Protecting your privacy is important to Upgrade, Inc. (DBAs include Universal
Credit, and the names at www.upgrade.com/landing/dba, 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 Policy describes the type of information we collect from you, what
we do with the information we collect, and how we protect the information we
collect. This Privacy Policy applies to all prospective, current, and former
Upgrade customers.

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 as indicated by
the effective date at the top of this page. Your continued use of our Site is
deemed to be acceptance of those changes. If you have questions about our
Privacy Policy or practices, please contact us at privacy@upgrade.com.


INFORMATION UPGRADE COLLECTS ABOUT YOU

Upgrade collects information about you directly from you and your use of the
Site, including when you apply for and use our products or services. We collect
information from your computer, mobile phone, or other access device that is
automatically reported by your browser or device each time you access the Site.
We may also collect information about you from third parties, such as credit
bureaus, our partners, and service providers.

We may collect the following information about you:

 * Name, address, phone number, Social Security number, and date of birth;
 * Your credit score, credit history, and other information from consumer
   reporting agencies;
 * Information about your payments or transaction history;
 * Information about your employment, salary, and income;
 * Your bank information, including your bank name, account number, and routing
   number;
 * Information for verification (fraud) checks, including verification of your
   identity and other information you provide;
 * Information about your internet activity, including access device, Internet
   Protocol (“IP”) address, geolocation data, browser type and platform,
   referral source, domain names, landing pages, length of visit, number of
   clicks and page views, and how you interact with links on the Site, domain
   names, landing pages, pages viewed, your use of third party applications, and
   other information related to your experience on the Site; and
 * Other information that you voluntarily provide to us or that we may collect
   as permitted by law.

Upgrade and third party referral partners and service providers also collect
information using tracking technologies such as cookies, beacons, tags, and
scripts. This information is used to analyze trends, administer the Site,
understand your use of the Site, and gather demographic information about you.
If you create an account on the Site, we use cookies when you sign in to your
account to keep track of your personal session, help authenticate your account,
and detect fraud. Upgrade and other third parties may collect personally
identifiable information about your online activities over time and across
different websites when you use our Site. For example, we use third parties like
Google Analytics to collect information so we can understand how users interact
with the Site. To learn more about Google Analytics and how to opt-out, click
here.

Your browser may have settings that allow you to control the use of cookies.
However, if you reject cookies, your ability to use some features of the Site
may be limited.

We do not respond to “do not track” signals from your browser at this time.


HOW UPGRADE USES YOUR INFORMATION

In general, Upgrade uses information we collect through the Site to:

 * Provide products and services you request;
 * Improve our offerings to you, including to develop new products and services;
 * Communicate with you or provide notices in connection with such products and
   services;
 * Process and respond to customer inquiries and provide support;
 * Detect security incidents and prevent fraud and illegal activities;
 * Fulfill our legal requirements and enforce our agreements;
 * Improve Site content, functionality, and usability;
 * Communicate with you, either directly or through our service providers,
   including for marketing and promotional purposes;
 * Improve our marketing and promotional activities; and
 * For our other legitimate business purposes permitted by law.

Upgrade is a service provider to its bank partners, and all loans or accounts
facilitated through the Site are provided by a bank partner. If you apply for a
loan or account using the Site, we will use your information to facilitate your
loan or account with a bank partner.

The information collected in connection with a loan or account may be used (as
applicable) to:

 * Generate your borrower profile or process your loan or account application on
   behalf of the bank partner providing the loan or account;
 * Enable automatic payments and fund transfers with other financial
   institutions; and
 * Communicate with you concerning your account and transactions.


INFORMATION UPGRADE SHARES

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 share your information with the following third parties in the following
instances:

 * Service providers as part of our products and services, such as for fraud
   prevention, servicing, bill collection, debt collection, marketing and
   technology services, product development, and with 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
 * 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 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 personally 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, we will take steps to comply with applicable legal
requirements to remove such information.



CALIFORNIA PRIVACY NOTICE

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

This notice for California residents under the CCPA supplements the information
provided in the rest of this Privacy Policy, which also applies to you. Any
terms defined in the CCPA 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;
 * Characteristics of protected classifications under California or federal law;
 * Customer records;
 * Commercial Information;
 * Internet or other similar network activity;
 * Geolocation data; and
 * Professional or employment-related information.

Upgrade does not “sell” any personal information we collect. We share personal
information with the categories of third parties described in the “Information
Upgrade Shares” 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 delete their personal information; to opt out of “sale” of personal
information that may be occurring; 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 request via email to ccpa@upgrade.com; or
 * Calling us toll-free at (877) 418-4547.

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.