Privacy Policies

PRIVACY POLICY

LAST UPDATED AUGUST 27, 2024

WELCOME TO THE ENGINE BY MONEYLION PRIVACY POLICY!

Welcome to the ML Enterprise Inc. (which may also be referred to as "Engine by MoneyLion”, “Engine”, “Fiona”, “ML Enterprise”, “we”, “us”, or “our”) Privacy Policy. This Privacy Policy describes how we collect, use, and disclose your information in connection with our websites and platforms (the “Site”) and any other online content, tools, or services that we control and that link to this Privacy Policy. This Site is operated by Engine by MoneyLion and has been created to provide information to our visitors (“you,” “your”) about our company and our online content, tools and services, whether such content, tools and services are accessed on the Site or through third-party websites, mobile sites and/or applications (together with the Site, the “Service(s)”). This Privacy Policy describes how Engine by MoneyLion collects, uses and discloses information from visitors to the Services, including personally identifiable information (“Personal Information”).

Engine by MoneyLion provides a platform to help match consumer needs, whether they navigate directly to our Site or engage with one of our online forms, tools, widgets or content items on websites operated by third-party business partners (such partners, “Channel Partner(s)”) with the right personalized offers from lenders, credit card issuers, banks or other similarly situated financial institutions (such partners,“Financial Partner(s)”, and together with the Channel Partner(s), the “Marketplace Partner(s)”). For clarity, Engine by MoneyLion is not a lender, credit card issuer, bank or other similarly situated financial institution. Any loan or related product to which you may become a party by using our Services is solely transacted between you and the applicable Marketplace Partner, and is not a part of the Services. Should you navigate to the website of a Marketplace Partner or establish a direct relationship with a Marketplace Partner, that partner’s use of your Personal Information is governed by their own privacy policy, and not by this Privacy Policy.

WHY THIS MATTERS

We want to build an indispensable platform to aid people in making smart comparisons and connecting them to companies to help meet their financial needs. Knowing certain things about our users helps us do that better. Please be sure to read this entire Privacy Policy before using or submitting information through the Services. By using or submitting information through the Services, you are indicating that you agree to the collection, transfer, manipulation, processing, storage, disclosure, and other uses of your Personal Information as described in this Privacy Policy, and you agree to be bound by the terms of this Privacy Policy. You also agree that such Personal Information may be transferred from your current location to our offices and servers, and to those of our Marketplace Partners. This Privacy Policy is incorporated into Engine by MoneyLion’s Terms of Service and any other agreement entered into by and between you and Engine by MoneyLion.

CONTENTS

• WHAT PERSONAL INFORMATION WE COLLECT
• HOW WE USE PERSONAL INFORMATION
• HOW WE DISCLOSE PERSONAL INFORMATION
• OTHER IMPORTANT INFORMATION
• YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION **

1. WHAT PERSONAL INFORMATION WE COLLECT

Because we are a financial institution regulated under the Gramm-Leach-Bliley Act, the Personal Information that we collect in connection with your request for consumer financial products and services constitutes “nonpublic personal information” subject to our Financial Privacy Notice, and we may be exempt from certain state privacy laws.

When you visit the Site or use our Services, you signify acceptance to the terms of this Privacy Policy and the Financial Privacy Notice and consent to the collection, use, and disclosure of your Personal Information as described herein and therein.

I. PERSONAL INFORMATION THAT YOU PROVIDE OR AUTHORIZE US TO COLLECT

We collect Personal Information from you when you voluntarily provide such information, including, but not limited to, when you access, complete and/or use one of our online forms, tools, widgets or content items and direct us to share this information with our Marketplace Partners so that you may receive personalized offers for financial products and services. When you interact with our Services, we may also request your Credit Authorization to obtain consumer and related information about you from one or more consumer reporting agencies for the purposes of identifying the Financial Partners who would be the best match for you, and to disclose this information to these Financial Partners.

Upon your direction, our Service will compare the information you have provided with the qualification criteria maintained by our Financial Partners offering the product or service you requested. If you satisfy the criteria for certain of our Financial Partners to offer financial products or services, we will pass your Personal Information along to that subset of our Financial Partners. The Personal Information you will be asked to provide when using our Services may vary depending on the type of financial product or service you are seeking, and may include: CONTACT AND DEMOGRAPHIC INFORMATION, which may include your name, address, date of birth, phone number, Social Security number, driver’s license number, passport number, or other similar identifiers, age, citizenship, marital status, sex, and veteran or military status. To the extent that you apply for a loan or a financial product or service along with a co-applicant, we may also collect these categories of personal information for the co-applicant. This information may be directly provided by you, sourced from identity verification and fraud prevention partners or public databases, and/or obtained from consumer reporting agencies when we perform a soft credit pull with your authorization.

PROFESSIONAL OR EMPLOYMENT INFORMATION, such as education levels and degrees, institutions attended and graduation dates, employment status, and income and pay frequency. This information may be directly provided by you, and/or obtained from consumer reporting agencies when we perform a soft credit pull with your authorization.

FINANCIAL INFORMATION, such as your credit score, credit data status (for example, how long you’ve had a credit file, whether your credit is frozen), your credit, payment and bankruptcy histories, and the type and amount of any outstanding loans. This information may be directly provided by you, and/or obtained from consumer reporting agencies when we perform a soft credit pull with your authorization.

RESIDENCE AND HOMEOWNERSHIP INFORMATION, for example, whether you own or rent your home, and the amount of any mortgage payments. This information may be directly provided by you, and/or obtained from consumer reporting agencies when we perform a soft credit pull with your authorization.

AUTO LOAN INFORMATION, including information on monthly payments, estimated mileage, and your vehicle identification number. This information may be directly provided by you, and/or obtained from consumer reporting agencies when we perform a soft credit pull with your authorization.

COMMERCIAL INFORMATION, such as purchase information, including details related to products and services you purchase from our Financial Partners (for example, the amount of any loan you take out with a loan partner and the purpose for the loan).

HEALTH-RELATED INFORMATION, on a self-reported basis and to the extent that you apply for a life insurance product through our wholly-owned subsidiary, LeapLife. This may include sensitive personal information, for example, your height, weight, prescribed medications, tobacco and alcohol use information, diagnoses, surgical and treatment information, and whether you have recently been declined for life insurance coverage.

CRIMINAL HISTORY INFORMATION, on a self-reported basis and to the extent that you apply for a life insurance product through LeapLife - specifically, whether you have been convicted of a felony and been put on probation or parole.

SUPPORT INFORMATION, including audio, electronic or similar information, or the information collected when you email or call our customer support center, which may include your name, email address, voice recording, and any other content or communications you send to or share with us.

SURVEY INFORMATION, if you elect to complete surveys about your user experience.

SENSITIVE PERSONAL INFORMATION, such as your Social Security number, driver’s license number, passport number, or other similar identifiers, age, citizenship, marital status, sex, and veteran or military status. To the extent that you apply for a loan or a financial product or service along with a co-applicant, we may also collect the above categories of personal information for the co-applicant. This information may be directly provided by you, and/or obtained from consumer reporting agencies when we perform a soft credit pull with your authorization. We may also collect business contact Personal Information in the context of business-to-business relationships to complete vendor and partner due diligence. By voluntarily providing us with Personal Information, you represent that the Personal Information you provide is true, accurate, current and complete, and that you are authorized to provide it to us. If you’d like to view a summary of our data collection, use, and disclosure practices in table format, please see Appendix A below. II. PERSONAL INFORMATION AUTOMATICALLY COLLECTED

Whenever you interact with the Services, Engine by MoneyLion may automatically receive and record information from your computer, browser and/or mobile device, which may include the following:

A. IP ADDRESS:

The requests you make to Engine by MoneyLion may contain your IP address (the Internet address of your computer). We may use visitors’ IP addresses for various purposes, including to display customized content, to analyze and report upon usage of the Services, to diagnose and prevent service or technology problems affecting the Services, and to monitor and prevent fraud and abuse. We may also use the IP address associated with your login to determine your general location in order to comply with applicable privacy regulations and serve you necessary notifications and/or consent mechanisms.

B. DEVICE IDs:

We may collect information on the type of device you are using, operating system, settings, browser and OS information, unique device identifiers, mobile carrier, browser type and language, network information and other device-specific information. The information collected may depend on the type of device you use and its settings. We collect this data to better tailor our services to you, and to audit ad impressions and compliance with various specifications and standards.

C. LOCATION DATA:

We may collect location data, which may include precise geolocation, based on your IP address and the geolocation of your device. We collect this data to better tailor our services to you and to help provide service offerings available to you in your geographic area.

D. USAGE INFORMATION:

We collect information about how you use our Services, such as the types and categories of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities on the Site. We use data analytics with this usage information to better understand your use of the Services and to improve the Services offered.

III. COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES:

In operating the Services, we may use cookies, web beacons, fingerprinting, and similar technologies to collect and use Personal Information about you, including for analytics purposes and to serve you interest-based advertising. This Privacy Policy covers the use of these technologies by Engine by MoneyLion only. Uses of these technologies by third-party advertisers or websites linked from the Services, including third parties with which we partner, are governed by each such third party’s privacy policy.

COOKIES & ANALYTICS: A cookie is a small text file placed in visitors’ computer browsers to store their preferences. Cookies help provide additional functionality to the Services, customize users’ experiences with the Services and help us analyze Services usage more accurately for research, advertising, and marketing purposes. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notifications when you are receiving a new cookie and on how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’ features, and, if you block or delete cookies, the Site may not work properly.

Google Analytics: Please note that we use Google Analytics cookies for data analytics purposes. You can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. You may choose to opt-out of Google Analytics by installing their opt-out browser add-on.

Lookalike Audiences: Additionally, we may share certain information with companies like Facebook and Taboola, that allow us to build aggregated user profiles and segments and to create custom or Lookalike Audiences. For more information about Facebook Lookalike Audiences, click here. To opt out of having such activity sent to Facebook, click here. You may find more information about Taboola and their cookie practices here. If you wish to opt-out of such activity sent to Taboola, click here.

Learn More: You can learn more about cookies on the following third-party websites:

• All About Cookies: http://www.allaboutcookies.org/
• Network Advertising Initiative: http://www.networkadvertising.org/

B. PIXEL TAGS/WEB BEACONS:

In addition to cookies, we may use web beacons (also known as “clear GIFs” or “pixel tags”), which are pieces of code embedded on the Site that collect information about users’ engagement on a web page. These help us to measure traffic to or from or use of our online forms, tools or content items, and related browsing behavior, and to improve your experience when using the Services. We may also use customized links or other similar technologies to track hyperlinks that you click, and we associate that information with your Personal Information in order to provide you with more focused communications. Web beacons may be placed on the Service by third parties, such as analytics providers, in order to support functionalities described in this Privacy Policy. The information collected by these third parties in this manner is subject to these third party’s own privacy policies.

C. SESSION REPLAY TECHNOLOGIES:

We also use research vendors, including session replay service providers, in order to better understand our users’ needs and to optimize our Services. Such technologies and third-party-provided services may observe or record user activities when using our Services, including certain movements, scrolling, visit duration, clicks, chatbot conversations and other interactions. These services may use cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Certain analytics may be removed via our privacy cookie controls.

D. DO NOT TRACK:

Please note that our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy, whether or not a DNT signal is received.
IV. PERSONAL INFORMATION COLLECTED FROM OTHER SOURCES: We may collect Personal Information about you from third parties to operate the Site and to provide you with our Services. As previously discussed, this may include information about you from one or more consumer reporting agencies, for the purposes of identifying the Financial Partners who would be the best match for you. We may also collect any of the above categories of Personal Information from third parties, such as Marketplace Partners, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, public databases, and data brokers. We may also collect information about you from our corporate affiliates, which we use to streamline and personalize your experience with our Site and our Services. We may also derive Personal Information about you in the form of inferences, which are derivations of information, data, assumptions, or conclusions from facts, evidence, or other sources of information or data about you. These inferences may be derived from the Personal Information that you provide to us or authorize us to collect, from the Personal Information automatically collected, from the Personal Information that we collect from third parties, as well as from the information collected by cookies, web beacons, and other tracking technologies.

2. HOW WE USE PERSONAL INFORMATION

We may use the Personal Information we collect for the following purposes:

A) TO PROVIDE PRODUCTS AND SERVICES

• To verify your identity, set up, and maintain your account (if applicable).
• To provide information relevant to the underwriting models and eligibility criteria of the Financial Partners who may provide you with personalized offers.
• To personalize the Services when you visit our Site and/or use one of our online forms, - tools, widgets or content items.
• To monitor your use of the Services.
• To maintain our Services and operations.

B) TO ENSURE THE INTEGRITY AND SECURITY OF OUR SERVICES

• To detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity, and prosecute the same.
• To debug to identify and repair errors in our systems.
• To verify or maintain the quality of our services, and to improve, upgrade, or enhance our services.
• To conduct due diligence or other reviews in connection with our vendor onboarding processes.

C) FOR ANALYTICS, RESEARCH, AND SERVICE IMPROVEMENT

• To monitor and measure your use of our products and Services in an effort to better understand you and our other users.
• To conduct testing, research, and surveys, to understand how our Services are being used and how they can be improved.
• To conduct analytics, such as usage trends.
• To perform financial analysis to better understand pricing and other financial matters.
• To improve the content and functionality of the Services.
• To test and improve the quality of our matching process.
• To better understand user needs.
• To pre-populate certain fields in our forms, helping to streamline your experience.

D) FOR QUALITY ASSURANCE AND TRAINING PURPOSES

• To monitor communications and interactions with you to ensure the quality of our support services and the appropriate training of our people, and to respond to and resolve your inquiries.

E) TO COMMUNICATE WITH YOU

• To contact you by email, postal mail, push notifications, in-app messages, phone or SMS, as permitted by applicable law, to provide you with:
  • Information regarding your application status, or other transactional information relevant to your account.
  • Opportunities, alerts, and promotions related to your submitted request available through the services or products of our Marketplace Partners that we think may be of interest to you.
  • Information or content – such as articles, white papers, and event registrations – that we believe would be of interest to you.
    • Each marketing-related e-mail communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. Generally, you can unsubscribe from our marketing emails or direct mail by submitting an unsubscribe request form or emailing [email protected] and asking to be removed from any correspondence. Although we will remove you from our marketing lists, you may still receive transactional messages related to your interactions with our Services. This process will not unsubscribe you from marketing communications from Marketplace Partners; in order to stop receiving these communications, please follow each partner’s own unsubscribe processes.

F) FOR PERSONALIZATION AND ADVERTISING

• To serve you with relevant advertising and content, which may include providing service offerings available in your geographic area, or to serve you with advertising for Marketplace Partner products or services, or the products or services of Engine by MoneyLion Related Companies (as defined below), on third party properties (cross-context behavioral advertising).
• To draw inferences to build a user profile reflecting your preferences, characteristics, or behavior, or to build aggregated user profiles and segments, which we may use to target “lookalike” audiences on other platforms or to improve our efforts to target appropriate advertising to you.
• To provide to Engine by MoneyLion Related Companies (as defined below) for marketing purposes.
  • For more information, see our Financial Privacy Notice.
• To assess the effectiveness of ads displayed to you.
• To display ads on the services of third-party advertising companies and social media companies.
  • These companies may use cookies and similar technologies to track your activity, and the information collected by these third parties in this manner is subject to that third party’s own privacy policies.
  • We may also use aggregated information from these sources for creating similar audiences in order to better target advertisements on their networks to potential consumers who appear to have shared characteristics. You may opt out of "similar audiences" in Google at https://adssettings.google.com/authenticated. You can also learn more about how to opt out of their collection in general by going to www.aboutads.info/choices, www.networkadvertising.or and/or www.youronlinechoices.com.

G) TO COMPLY WITH ANY APPLICABLE LAWS, REGULATIONS OR LEGAL PROCEEDINGS

• To investigate disputes or claims related to our Services.
• To respond to legal, government or regulatory requests.
• To comply with applicable laws.

H) FOR SAFEGUARDING AND DEFENDING OUR VITAL INTERESTS, FOR EXERCISING ANY RIGHTS, ASSERTING ANY CLAIMS, AND FOR ANY OTHER LAWFUL BUSINESS PURPOSE

• This includes any incidental business purpose related to or in connection with any of the above, or any other purpose disclosed to you at the point at which we collect your Personal Information.

J) FOR ANY OTHER LEGITIMATE BUSINESS PURPOSES NOT OTHERWISE PROHIBITED BY LAW

NOTE ON OUR USE OF AGGREGATED PERSONAL INFORMATION:

In an ongoing effort to better understand and serve our users, Engine by MoneyLion often conducts research on consumer demographics, interests, and behavior based on Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Engine by MoneyLion may share this aggregate data with our affiliates, agents, service providers, Marketplace Partners, and other third parties with whom we do business. This includes, but is not limited to, information such as consumer financial trends, choices, and comparisons. We may also use aggregated information from these sources to create similar audiences in order to better target advertisements on third-party advertising and social media networks to potential consumers who appear to have shared characteristics. Engine by MoneyLion may also disclose aggregated user statistics in order to describe our Services to current and prospective Marketplace Partners, and to other third parties for other lawful purposes. This aggregate information does not identify you personally. We will not attempt to re-identify the data once in aggregate or non-personally identifiable form.

**HOW WE DISCLOSE PERSONAL INFORMATION **

We may disclose your Personal Information to the following categories of recipients for our business or commercial purposes:

A) ENGINE BY MONEYLION RELATED COMPANIES: We may disclose your Personal Information to our corporate parent entities, MoneyLion Technologies Inc. and MoneyLion Inc., and their wholly-owned subsidiaries and affiliates (collectively, “Related Companies”), for purposes consistent with this Privacy Policy (including for marketing and advertising purposes).

B) THIRD-PARTY SERVICE PROVIDERS: Engine by MoneyLion, like many businesses, hires other companies and contractors to provide certain business-related services (for example, facilitating mailings, maintaining databases, providing customer service, cloud storage providers, and business analytics and marketing providers). We may also disclose this information to consumer reporting agencies, acting in a service provider capacity, as part of data studies intended to test the reliability of our internal data and improve the quality of our Services. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we ensure that we have appropriate contractual provisions protecting your Personal Information in place.

C) BUSINESS PARTNERS: When we partner with other businesses to provide content, products or services to you or to such business partners, we may disclose relevant Personal Information in connection with such content, products, or services. For example, we will disclose the information you provide when using our Services with Financial Partners whose pre-qualification criteria you may satisfy. In addition, if you originally engaged with our Services on a website or property owned and operated by a Channel Partner, we may provide summarized purchase information, on an aggregated and anonymized basis, back to such Channel Partner to support the accuracy of their financial and business analytics. We may also share this information with our Marketplace Partners to improve efforts to target appropriate advertising content to you.

D) CONSUMER REPORTING AGENCIES: We may disclose basic Personal Information to consumer reporting agencies, either for purposes of completing a “soft credit pull” with your authorization, or as part of data studies, with the consumer reporting agencies acting in a service provider capacity, which are intended to test the reliability of our internal data and improve the quality of our Services.

E) POTENTIAL PARTIES TO A CORPORATE TRANSACTION (AND THEIR AGENTS AND ADVISORS): We may disclose your Personal Information to actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, reorganization, financing, bankruptcy, receivership, sale of company assets, or transition of service to another provider. In this event, we will inform the transferee that it must use your Personal Information only for the purposes disclosed in this Privacy Policy.

F) LAW ENFORCEMENT BODIES, REGULATORS, GOVERNMENT AGENCIES, COURTS OR OTHER THIRD PARTIES: We may disclose your Personal Information to competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish, or defend our legal rights; (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent, or otherwise address security, fraud, or technical issues.

4. OTHER IMPORTANT INFORMATION

YOUR CHOICES:

In general, you can visit the Services without providing Personal Information. If you choose not to provide any Personal Information, however, you may not be able to use certain features of the Services.

REGISTRATION/ACCOUNT INFORMATION: If you choose to create an account, we may collect the same information described above in “What Personal Information We Collect” and/or other information to provide account related functionalities to our users. By registering, you agree to provide and maintain true, accurate, current, and complete information about yourself. Please note that if you allow others to use your account (including others you permit to set up profiles under your account), they may be able to view information about your account or any of the profiles under your account. If you no longer want to maintain an account, you can deactivate your account by contacting us at [email protected] or at the address below.

DATA RETENTION: We keep your Personal Information for only as long as necessary to provide you with the Services and for legitimate and essential business purposes, such as maintaining the performance of the website and associated services, making data-driven business decisions about new features and offerings, conducting audits, complying with our legal obligations, and resolving disputes. When we are no longer required to retain the Personal Information as described above, we will destroy, erase, or de-identify it. Legal data retention requirements, however, may require us to retain some or all of the Personal Information we hold for certain periods of time.

ACCURATE INFORMATION: We rely on you to ensure your information is accurate and up-to-date. If you have reason to believe that the Personal Information we possess about you is incorrect or not current, please contact us at [email protected] and we will take reasonable steps to update or correct your Personal Information.

CHILDREN’S PRIVACY ONLINE: The Services of Engine by MoneyLion are not directed to, or intended for, minors. Engine by MoneyLion does not knowingly collect Personal Information from minors. If you are under the age of 18, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their minor children’s Internet usage and to help enforce our Privacy Policy by instructing their minor children never to provide Personal Information on the Services without their permission. If you have reason to believe that a minor has provided Personal Information to Engine by MoneyLion through the Services, please contact us, and we will delete that information from our databases.

LINKS TO OTHER WEBSITES: This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Engine by MoneyLion (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that Engine by MoneyLion endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

SECURITY: We take steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the Personal Information) designed to protect against unauthorized use, disclosure or access to Personal Information, and we regularly adapt these controls to respond to changing requirements and advances in technology. However, no Internet or email transmission is ever fully secure or error free. If you are, or believe you have become, a victim of identity theft, you may visit the website of the Federal Trade Commission at https://www.identitytheft.gov/#/ for free information to help guard against identity theft and guidance on the recovery steps you can take.

SERVICE FOR U.S. USERS ONLY: The Service is hosted and intended solely for consumers in the United States. All Personal Information is stored on servers in the United States and is subject to United States law. By choosing to use the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with the Services will be in accordance with the Terms of Service. If you are visiting the Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and the global processing of such information. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

UPDATES TO ENGINE BY MONEYLION’S PRIVACY POLICY: We may update our Privacy Policy from time to time to reflect changes to our businesses and to account for changing privacy laws. We will obtain your consent to any material changes if and where this is required by applicable laws. Please review this Privacy Policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

5. YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION This section discusses applicable privacy rights as required by certain U.S. state privacy laws, including California, Oregon, and other future U.S. states that pass privacy legislation to which we are subject. This section includes our Notice at Collection for California residents, including those whom we interact with in our business-to-business relationships. To understand the types of Personal Information we collect, and how it is sold and shared, please view Appendix A. We will retain your Personal Information as described under “Data Retention”. To view our full Privacy Policy, please click here. We do not sell your Personal Information, but we do “share” your Personal Information as defined under California law. To review your Notice of Right to Opt-Out, please click here. Because we are a financial institution regulated under the Gramm-Leach-Bliley Act, the Personal Information that we collect in connection with your request for consumer financial products and services constitutes “nonpublic personal information” subject to our Financial Privacy Notice, and we may be exempt from certain state privacy laws. In light of these exemptions, this Notice does not apply to the collection, processing, sale, or disclosure of any information (i) that a consumer provides to us to obtain a financial product or service, or (ii) about a consumer resulting from any transaction involving a financial product or service; or (iii) about a consumer resulting from a consumer’s express direction to disclose the consumer’s information; or (iv) that we otherwise obtain about a consumer in connection with providing a financial product or service to that consumer. For information about our data collection practices in those contexts, please refer to our Financial Privacy Notice.

The definition of “Personal Information” may be different under individual state laws and regulations. As used in this Notice only, “Personal Information” refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. A. HOW WE COLLECT, USE, AND DISCLOSE YOUR INFORMATION For a table that describes how we currently collect, use, and disclose your information, and how we have collected, used, and disclosed your Personal Information over the last 12 months please see Appendix A.

All categories exclude text messaging originator opt-in data and consent; this information will not be shared with any non-affiliated third parties.

B. YOUR PRIVACY RIGHTS Under applicable law, you may have certain rights, such as:

1. Right to Know: You have the right to request, no more than twice in a 12-month period, any of the following, for the period that is 12 months prior to the request date:

• The specific pieces of Personal Information we have collected about you in the 12 months preceding your request
• The categories of Personal Information we have collected about you
• The business or commercial purposes for our collection of your Personal Information
• The categories of third parties, or a list of the specific third parties with whom we have disclosed or shared your Personal Information
• The categories of sources from which we have collected your Personal Information
• A list of the categories of Personal Information sold or shared about you in the prior 12 months, or a statement that no sale or sharing occurred. If we sold your Personal Information, we will explain: - The categories of your Personal Information that we have sold or shared - The categories of third parties to whom we have sold or shared Personal Information

2.Right to Deletion: You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need to keep certain Personal Information, such as for our legitimate business purposes or as required to comply with retention requirements under applicable laws.

3.Right to Rectification: You have the right to correct inaccurate Personal Information that we have about you.

4.Right to Withdraw Consent: You may have the right to revoke a consent that you previously granted to the collection and sharing of your Personal Information.

5.Right to Opt-Out of Profiling: You may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.

6.Right to Limit Use or Disclosure of Sensitive Personal Information: You have the right to limit the use of your sensitive Personal Information, as those terms are defined under respective state privacy laws. Please note that Engine by MoneyLion only uses or discloses your sensitive Personal Information as permitted under applicable law, and that such use or disclosure is reasonably necessary and proportionate for those purposes. As such, our use and disclosure of your sensitive personal information is already limited. Please note that we do not use your sensitive Personal Information to infer characteristics about you.

7.Right to Opt-Out of Sale, Sharing, or Use for Targeted Advertising: Some states allow residents to have the right to opt out of disclosures of Personal Information to third parties for monetary or other valuable consideration (which may be considered a “sale” even if no money is exchanged). You may also have the right to opt out of our “sharing” your Personal Information for the purposes of cross-contextual behavioral advertising. Our use of cookies, pixels, and similar tracking technologies may constitute “sharing” under some state laws.

To view the categories of Personal Information that we sell or share for advertising and marketing purposes, and the categories of third parties with whom we sell or share this information, please see Appendix A. We do not have any knowledge of the sale or share of Personal Information of those under 18 years of age.

To opt-out of the sale or sharing of your Personal Information, please visit our Data Rights Request Form. In addition to these rights, pursuant to California’s “Shine the Light” law, California residents who share Personal Information with us have the right to request and obtain from us once per year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for direct marketing purposes in the prior 12 months, as well as the type of Personal Information disclosed to those parties. If you would like to exercise this right, please use the contact information listed below to contact us. We will not discriminate or retaliate against you for any exercise of these rights. C. HOW TO EXERCISE YOUR PRIVACY RIGHTS

I. Submission If you would like to exercise your privacy rights, please fill out our Data Rights Request Form, call 1-800-614-7505, email us at [email protected] or mail your request to the attention of the Legal Department at ML Enterprise Inc., ℅ MoneyLion Technologies Inc., 249-245 West 17th Street, New York, NY 10011. You may exercise these rights yourself or via an authorized agent. If you have provided an authorized agent with a power of attorney pursuant to your state’s Probate Code, we will work directly with your authorized agent to complete your request. Where you have not provided an authorized agent with a power of attorney pursuant to your state’s Probate Code, we will reach out to you directly to confirm the authorized agent’s authority and collect the Verification Information (as defined below).

We do not typically charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. II. Verification and Response We are required to verify the requests we receive when you exercise privacy rights. We (or third parties we engage to assist us) may ask you to provide certain information to us in order for us to verify your request, including your name, state of residence, email address, Engine by MoneyLion account login, date of birth, and other data points as needed to verify that you are who you say you are (the “Verification Information”). If we are unable to locate you in our records, or we are unable to verify your identity, we will be unable to fulfill your privacy rights request. If we are able to successfully verify your request, we will respond within the timeframes prescribed by applicable laws. III. Appeals We make every effort to fulfill your request. However, we reserve the right to deny requests as permitted by applicable state law, such as where your identity cannot be confirmed, where we have a reasonable belief that the request is fraudulent, or where we must retain your information to comply with retention requirements under applicable laws. Depending on your state of residence, you may have the right to appeal a decision made in response to your request. If you would like to submit an appeal, you may do so via the Data Rights Request Form. Our response to your appeal will inform you of decisions and actions in response to your appeal, including an explanation of the reasons for the decisions.

CONTACTING US:

If you have questions about this Privacy Policy or our privacy practices generally, feel free to contact us as follows:
Email: [email protected]
Phone:1-800-614-7505

Postal Mail:
ML Enterprise Inc. ℅ MoneyLion Technologies Inc. 249-245 West 17th Street New York, NY 10011 Attn: Legal Department t

Use the link below to download Appendix A: Collection, Use, and Disclosure of Personal Information

Appendix A