Borrower Privacy Notice

Scratch Financial, Inc. Privacy Notice

Rev. 11/25/2024

FACTS	WHAT DOES SCRATCH FINANCIAL, Inc. (“SCRATCHPAY”) DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and income Payment history and transaction history Credit history and credit scores 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 we choose to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Scratch 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	No	We don’t Share
For our affiliates’ everyday business purposes— information about your creditworthiness	No	We don’t Share
For our affiliates to market to you	No	We don’t Share
For nonaffiliates to market to you	No	We don’t Share

Questions?

Call 855-727-2395 or email [email protected]

Who we are
Who is providing this notice?	Scratch Financial, Inc.

What we do
How does Scratch 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 restrict access to your information to those employees who need to know it to provide products or services to you.
How does Scratchpay collect my personal information?	We collect your personal information, for example, when you apply for a loan or give us your income information provide employment information show us your government-based ID or pay your bills 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 information on your rights under state law.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Scratchpay does not share with our affiliates.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Scratchpay 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. Scratchpay does not jointly market.

Other important information

California residents: We will not share your personal information with nonaffiliates for their marketing purposes except with your express consent. We will not share your personal information with affiliates or with other financial companies for joint marketing purposes except with your consent or as otherwise permitted by law.

Nevada Residents: This notice is provided to you pursuant to state law. You may be placed on our internal Do Not Call List and contact us for more information about telemarketing by calling (855) 727-2395 or emailing us at [email protected] You may also contact the Nevada Attorney General’s office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: (702) 486-3132; email: [email protected]@ag.nv.gov.

North Dakota Residents: We will not share your personal information with joint marketing partners or with nonaffiliates for their marketing purposes except with your express consent. We will not share information about you with affiliates except to the extent permitted by law.

Vermont Residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal 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.

Texas Residents: Scratch Financial 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 Scratch Financial 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: [email protected] . App: www.occc.state.tx.us.

WebBank / Scratch Financial, Inc. Privacy Notice --- Rev. 11/25/2024

FACTS WHAT DOES WEBBANK DO WITH YOUR PERSONAL INFORMATION IN CONNECTION WITH YOUR SCRATCHPAY FINANCIAL, INC. ACCOUNT?

Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

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

Social Security number and income

Payment history and transaction history

Credit history and credit scores

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 we choose to share; and whether you can limit this sharing.

Reasons we can share your personal information Does WebBank 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 No We don’t Share

For our affiliates’ everyday business purposes—
information about your creditworthiness No We don’t Share

For our affiliates to market to you No We don’t Share

For nonaffiliates to market to you No We don’t Share

Questions? Call 855-727-2395 or email [email protected]

Who we are

Who is providing this notice? WebBank

What we do

How does WebBank 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 restrict access to your information to those employees who need to know it to provide products or services to you.

How does WebBank collect my personal information? We collect your personal information, for example, when you

apply for a loan or give us your income information

provide employment information

show us your government-based ID or pay your bills

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 information on your rights under state law.

Definitions

Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
WebBank does not share with our affiliates.

Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
WebBank 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.
WebBank does not jointly market.

Other important information

California residents: We will not share your personal information with nonaffiliates for their marketing purposes except with your express consent. We will not share your personal information with affiliates or with other financial companies for joint marketing purposes except with your consent or as otherwise permitted by law.

Vermont Residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal 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.

FACTS	WHAT DOES WEBBANK DO WITH YOUR PERSONAL INFORMATION IN CONNECTION WITH YOUR SCRATCHPAY FINANCIAL, INC. ACCOUNT?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and income Payment history and transaction history Credit history and credit scores 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 we choose to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does WebBank 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	No	We don’t Share
For our affiliates’ everyday business purposes— information about your creditworthiness	No	We don’t Share
For our affiliates to market to you	No	We don’t Share
For nonaffiliates to market to you	No	We don’t Share

What we do
How does WebBank 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 restrict access to your information to those employees who need to know it to provide products or services to you.
How does WebBank collect my personal information?	We collect your personal information, for example, when you apply for a loan or give us your income information provide employment information show us your government-based ID or pay your bills 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 information on your rights under state law.