This Privacy Policy applies to your access and use of all products and services that are made available by Stafford & Vos Capital LLC (SNV) or its affiliates (the “Services”) through our websites, including but not limited to staffordandvos.com (the “Website”).

This Privacy Policy describes the information that we gather from you, how we use your information, whom we share your information with, and the steps we take to protect your information. By using the Services, you consent to the privacy practices described in this Policy.

This Policy applies to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or through any communication that you may have with one of our partners, such as a financial service provider.

Please note: Our Website and Services are intended to be accessed and used only by adults and are not offered or directed to minors. We do not knowingly collect personally identifiable information by anyone under the age of 18, and you should not provide us with any information regarding an individual under the age of 18.

INFORMATION WE COLLECT

Personal Information Collected. We may collect personally identifiable information (“Personal Information”) to use as part of our Service. This Personal Information may include, but is not limited to:

• Name, postal address, e-mail address, telephone number; and/or
• Any other identifier by which you may be contacted online or offline.

Other Information Collected. We may also collect the following information (together with Personal Information, “User Information”):

• Information about you but individually does not identify you, such as your income and your credit score;
• Information that you choose to provide about a third party that is not seeking financial information; and/or
• Information about your internet connection, the equipment you use to access our Website and usage details.

You may still access and use our Website and Services if you choose not to provide us with any of the above User Information, but some of our Website features and Services may not be available to you and may not be as accurate or complete.

You may provide information about other people, such as their name and email address. This information is used for whatever reason it may have been provided. The third party may contact us at [email protected] to request that we remove this information from our database.

HOW WE GET YOUR INFORMATION

Information You Provide to Us Directly. This includes information that you provide by filling in forms on our Website. This includes information provided at the time of requesting a match to specific financial service providers, or posting material. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website or Services. It also includes records and copies of your correspondence (including email addresses), if you contact us, your responses to surveys that we might ask you to complete for research purposes, details of transactions you carry out through our Website or any of our Services, and your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. This includes details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. It also contains information about your computer and internet connection, including your IP address, operating system, and browser type.

We may enter contracts with third-party service providers, such as Google Analytics, to collect non-personally identifiable data on behalf of SNV and provide us with information, reports, and analysis about the usage, general location information, and browsing patterns of users of the Website and Services. All of the data collected by these providers on our behalf is owned by us.

The technologies we may use for automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Information from Third Parties. The information you will need to submit in order to receive specific quotes and rates about financial services and products will be submitted on a third party service provider website, and will not be collected by SNV, unless such third party chooses to provide the information to SNV, as specified above. The collection and use of the information will be governed by the privacy policies of the financial services providers, and not this Policy. If you submit such request to a financial service provider, you may be contacted directly via mail, telephone, text message, fax, email and other means of communication by such service provider. You may receive telemarketing calls, even if you are on the national do not call registry.

HOW WE USE YOUR INFORMATION

We use, store and process your information to provide and improve our Services and ensure a secure, safe and trusted experience. For example, we may use information that we collect about you or that you provide to us, including any Personal Information:

• To provide you the Services you request and enable both affiliates and non-affiliated third parties to provide additional services to you.
• To operate, maintain and improve the Services and create new features and functionality.
• To understand and analyze usage trends and preferences of our users across different devices.
• For fraud detection and information security.
• We may use your e-mail address or other personal information (a) to contact you for administrative purposes such as customer service and (b) to send you promotional materials, offers, and/or messages related to the Services and the activities of affiliates and third parties we work with. Generally, you can opt out of receiving promotional communications, through links provided in the messages, or by contacting us directly at [email protected].
• We may use Cookie Information and Automatically Collected Information to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) pre-fill forms; (c) provide customized advertisements, content, and information across your devices; (d) monitor and analyze the effectiveness of Services and third-party marketing activities; (e) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (f) track your entries, submissions, and status in any promotions or other activities.

HOW WE SHARE YOUR INFORMATION

We may disclose User Information that we collect or you provide, as well as information that you provide to us about third parties, as described in this Policy:

• To our subsidiaries and affiliates.
• To other service providers and third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may disclose your information in connection with providing the Services and the operation of our business. For example, we may share personal information, such as name, email, address and other identifying information, with both affiliates and nonaffiliated third-party service providers to verify your identity in connection with your use of certain aspects of the Services.

We may share information collected directly from you with both affiliates and nonaffiliated third-party lending partners or third-party service providers in connection with your use of specific aspects of the Services, including but are not limited to: when you report a complaint about a product or a third-party lending partner featured on our Website; we may forward your complaint to that lending partner.

We may share automatically collected information such as IP address and Clickstream Data as well as de-identified information with nonaffiliated third-party lending partners when you leave our Website to go to a third-party lender site to request information or apply for financial products.

We may share your information with third-party service providers to support our internal and business operations. In such cases, service providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure. For example:

• For website, application development, hosting, data storage, maintenance, and other services for us.
• For internal marketing, delivery of emails, including promotional, marketing and transactional materials, delivery of other promotional materials, including via postal mailers, SMS and text messaging, and online and social media promotions and advertising.
• For fraud prevention and security purposes.

We may share de-identified and/or aggregate analytics with third-party partners about how users interact with our Services, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.

By submitting a request through our Services, you consent to the disclosure of your information to affiliates and third parties in order for us to carry out your request. The collection and use of your information by third parties is subject to each third party’s specific privacy policy and terms of use. SNV has no control over the means by which third parties further use or disclose your information.

If you submit a request through our Services, a third-party service provider may directly contact you with quotes or information via telephone, auto-dialed prerecorded calls, SMS, fax, and/or email. You may also receive telemarketing calls as a result of submitting the request, even if you are on the National Do Not Call Registry or any other similar registry.

Do not submit a request for information or services if you do not want your personal information shared as described above. Once you have submitted a request through the Services and we have shared your information as described above, the terms of the third party’s privacy policy will apply to that party’s use of your information.

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

You have the option to refuse any offers for services provided after you submit a request to a third party through the Services.

We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiations of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, financial service providers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers.

HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the User Information you provide to us and that we collect. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Promotional Offers from SNV; Disclosure of Your Information for Third-Party Advertising. If you do not wish to have your email address/contact information used by SNV to promote our own, affiliates or third parties’ products or services or do not want us to share your User Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you use the “Unsubscribe” link in the email to opt-out of such communications.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to [email protected].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from Google by visiting Google Ad Settings and from members of the Network Advertising Initiative (“NAI”) by visiting the NAI’s website.

California residents may have additional personal information rights and choices. Please see our CALIFORNIA PRIVACY POLICY for more information.

ACCESSING AND CORRECTING YOUR INFORMATION

You may send us an email at [email protected] to request access to, correct or delete any User Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

DATA SECURITY

We have implemented measures designed to secure your User Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls and will be encrypted using SSL technology.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to the Policy on this page with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat User Information, we will notify you by email to the primary email address we have on file or through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

CONTACT INFORMATION

This Website is operated by Stafford & Vos Capital LLC.

To ask questions or comment about this Policy and our privacy practices, contact our PR advisor: [email protected]