California Consumer Privacy Act Policy

This California Consumer Privacy Act Notice (“Notice”) is provided by LendingPad Corp. (LendingPad) pursuant to the California Consumer Privacy Act (“CCPA”) to any natural person who is a California resident (“California Consumer”) and whose personal information we process. If you are not a California Consumer, this Notice does not apply to you.

The purpose of this Notice is to supplement our Privacy Policy and inform our users who are California Consumers of the categories of personal information that we collect from them and disclose to third parties, and the purposes for which such personal information will be used. This Notice also explains certain rights that California Consumers are granted by the CCPA and explains how they can exercise these rights.

During the preceding 12 months, LendingPad has collected the following categories of personal information concerning California Consumers (“Personal Information”):

1. personal unique identifiers, such as your name, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
2. personal information such as telephone number, employment, employment history, bank accounts, credit card number, credit information, assets, debts and other financial information;
3. characteristics of protected classes or groups under state or federal law, such as age, sex, marital status, or veteran or military status;
4. commercial information such as records of personal property, products and services purchased and transaction histories;
5. professional or employment-related information such as current or past job history;
6. geolocation data such as your physical location;
7. internet and electronic network activity information, such as information about your interactions with our websites, applications, or advertisements; and
8. inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics.

We receive the categories of Personal Information listed above from the following categories of sources:

• Directly from you;
• Parties to whom you have directed or authorized our disclosure; and
• From other service providers.

During the preceding 12 months, LendingPad has disclosed the categories of Personal Information listed above for our business purposes.

We disclose Personal Information to third parties for the business purposes set forth below:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a mortgage loan from your lender, we will use that personal information to facilitate a response to your inquiry.
• To conduct after-sale services.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests and prevent fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To provide you with email alerts and other notices concerning our products or services, or events or news, or those of third parties, that may be of interest to you.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

In addition, your Personal Information may be accessible to third parties with whom you interact or direct us to share your information through our services.

LendingPad does not “sell” your Personal Information for purposes of the CCPA.

We share your Personal Information with the following types or groupings of third parties:

• Parties to whom you have directed or authorized our disclosure;
• Third-party service providers with whom we share Personal Information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development;
• Government agencies including to support regulatory and legal requirements.

If you are a California Consumer, the CCPA allows you to request that we give you access, upon a verifiable request, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of Personal Information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the Personal Information was shared (Access Request).

In addition, if you are a California Consumer and have submitted a verifiable consumer request, you also have the right to request that we delete your Personal Information (Deletion Request). Note that, consistent with California law, we are not required to comply with a request to delete your Personal Information if it is necessary for us to maintain such information in order to:

1. Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
3. Debug to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
6. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
7. Comply with a legal obligation.
8. Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

You have the right not to be discriminated by us, and we will not discriminate against you, for exercising the privacy rights conferred by the CCPA, although some of the functionality and features available to you may change or no longer be available to you.

You (or your authorized agent) can make an Access Request or a Deletion Request by emailing us at contact@lendingpad.com. Once we receive your request, we will verify it by requesting information sufficient to reasonably verify your identity and have the proper authority to make the request.

For information and questions about the use of your Personal Information or this California Consumer Privacy Notice, you may contact us at contact@lendingpad.com.