When you engage with us or use our products and services, we collect a variety of information from and about you. The kind of data we collect about you depends on who you are (broker, borrower, applicant, etc.) and how you use our services. If you are a Consumer who did not complete an application, we will have less information about than if you are an existing borrower for whom we service a loan. Even if you don’t have a loan with us, we may still collect some data about you if you engage us in your professional capacity for information about our products and services.

Generally, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, we have collected the following categories of Personal Information from its Consumers within the last twelve (12) months.

Category Examples Collected

• Publicly available information from federal, state or local government records.
• De-identified or aggregated consumer information.
• Information exempted from the CCPA’s scope, like:

• • Personal Information covered by certain sector-specific privacy laws, including without limitation, the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), if applicable.

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

• • Directly from you and your authorized agents. For example, from documents you provide to us related to the services for which you have engaged us.
  • Indirectly from you and your authorized agents or representatives. For example, through information we collect from our clients in the course of providing services to you.
  • Directly from your activity on our website (acralending.com), excluding Unique Identifiers. For example, from submissions through our website or Borrower Portal, or online form.
  • From service providers that help us perform the services we provide. For example, from title and escrow companies.
  • From third-parties that interact with us in connection with the services we perform. For example, from lead generation companies.

• We carefully evaluate how we use data to make sure that we are using your information to personalize our services and provide value for you. We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• • To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to provide a loan estimate, we will use that information to prepare loan estimates and submit it for an application.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. In the event we would like to use your Personal Information in a way that is not described here, we will let you know in advance so you can decide if you are comfortable with that use.

• We understand that sharing information with third parties is big responsibility. We are committed to only sharing information when needed for a legitimate business or legal purpose, and then only with recipients who will protect the data. When we disclose Personal Information for a business purpose to offer products and services, we enter a written agreement that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except as need to provide those products and services and only subject to the terms of this privacy policy. When we need to disclose Personal Information to satisfy a legal or regulatory requirement, including responding to a subpoena or other lawful government request, we will share only information as necessary to comply with that requirement. We may also share information if needed to enforce our legal rights, detect or prevent fraud or security concerns and protect public safety. We may share your Personal Information incidental to the sale or securitization of loans. If we are involved in a merger, acquisition or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding we may share your information in connection with that transaction. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information described above for a business purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category D: Commercial information. Category I: Professional or employment-related information. We disclose your Personal Information for a business purpose to the following categories of third parties:

• • Our partners.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

We take reasonable steps designed to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this disclosure. The criteria for determining the duration for which we will retain your personal information are as follows:

We will retain copies of your personal information in a form that permits identification only for as long as:

• We maintain an ongoing relationship with you (e.g., while you remain an employee, or where you are still receiving services from us); or
• Your personal information is necessary in connection with purposes set out in this disclosure

Plus:

• The duration of any applicable limitation period under applicable law; and where required
  and
• In addition, if any relevant legal claims are anticipated/brought, we may continue to process your personal information for such additional periods as are necessary in connection with that claim.

During the periods noted above we will restrict our processing of your personal information to storage of, and maintaining the security of, that information except to the extent that that information needs to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods above, each to the extent applicable or permitted by applicable law, have concluded, we will 1) permanently delete or destroy the relevant personal information, or 2) archive your personal information so that it is beyond use; or 3) anonymize the relevant personal information.

• The CCPA provides Consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Your Right to Know and Access the Personal Information That Is Collected About You. You have the right to request that we disclose certain Personal Information to you about our collection and use of your Personal Information over the past 12 months. We shall not be required to provide personal information to a consumer more than twice in a 12 month period and are not required to retain any Personal Information collected for a single, one-time transaction, if such information is not sold or retained by us and not maintained in a manner that would be considered Personal Information. You also have a right to access your Personal Information and request a copy, which at our sole discretion may be delivered by mail or to the extent feasible, in a readily usable portable electronic format, of your Personal Information that we collected, used, disclosed or sold over the past 12 months. Once we receive and confirm your Verifiable Consumer Request, we will disclose to you:

• • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

• You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. 1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
   2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
   3. Debug products to identify and repair errors that impair existing intended functionality.
   4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
   5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
   6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
   7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
   8. Comply with a legal obligation.
   9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• We do not sell Personal Information. We do not have any future plans to sell Personal Information. If that changes, we will provide you advance written notification so that you may understand and exercise your right to “Opt-Out” of the sale. We will provide you with information on how to request that we “Do Not Sell Your Information.” If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

• Please be advised that the we do not and have not sold any personal information in the last twelve months. See our Privacy Notices for full details. We do not have any future plans to sell personal information. If that changes, we will provide you advance written notification so that you may understand and exercise your right to “Opt-Out” of the sale. We will provide you with information on how to request that we “Do Not Sell Your Information.” We encourage you to periodically check our website for updates to our privacy policy.

• We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• • Deny you services.
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of services.

To exercise your rights as described above, please submit a Verifiable Consumer Request to us by:

• Filling out the CPRA / CCPA Request formand follow the provided instructions.
• By visiting acralending.com/CCPA
• By calling us at (888) 800-7661
• Emailing us at [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

• We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you through a Notice on our website or other direct communications like email or mail. We encourage you to periodically review our Privacy Notice to stay informed about our data protection practices and the ways you can help protect your privacy.