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Privacy Policy

Effective Date: 19 March 2022

Introduction and Purpose

We at Vouchpad Inc. (collectively, “we” or “us”) are proud to offer you services and products, either directly or indirectly, that help improve accessibility and affordability of private student loans while ensuring both short and long-term student success.

Vouchpad Inc. of 2401 Fountain View Dr. Suite 312 #2583, Houston, Texas, United States of America (“USA”) is committed to protecting and respecting your privacy. Vouchpad Inc. acts as an interactive online platform that identifies high-potential students through its proprietary algorithm and matches them with partner financial institutions that provide private student loans.

This privacy policy (“Privacy Policy”) sets out the basis on which we will process, store, and disclose any Personal Data (see definition in Section 1) we collect from you or that you provide to us in connection with the website owned and operated by Vouchpad Inc., https://vouchpad.com (“Site”), or in connection with the products and services that we directly or indirectly offer, including repayment rating, lender matching, loan disbursement, cosigning, loan servicing, career development/placement, immigration support, credit building, scholarships and tuition assistance, mentoring, and relevant marketing (“Services”).

By using the Site, you signify that you have read, understand, and agree to be bound by the Privacy Policy, regardless of whether you have registered to use any of our Services. Please read the Privacy Policy very carefully. If you do not wish to be bound by the Privacy Policy, you should not access or use the Site or use the Services.

This Privacy Policy may change from time to time. This version was last updated on March 19, 2022, and historic versions can be obtained by contacting us. The data protection law in the USA may change periodically and such updates will be reflected in a timely fashion. Although this Privacy Policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests as we are still working towards getting our systems ready for some of these changes. Any changes we may make to our Privacy Policy in the future will be posted on this page. Unless otherwise stated, any updates to this Privacy Policy become effective when we post the updates on the Site. Your use of the Site or Services following an update to the Privacy Policy means that you accept the updated Privacy Policy.

Vouchpad Inc. is a Data Controller and Data Processor and thus responsible for your Personal Data. A Data Controller is the person that determines the purposes and means of data processing. A Data Processor processes the Personal Data on behalf of the Data Controller. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Our full details are:

Full name of legal entity: Vouchpad Incorporated

Email address: privacy@vouchpad.com | info@vouchpad.com

Postal address: 2401 Fountain View Dr. Suite 312 #2583, Houston, Texas, USA

Telephone number: (+1) XXX XXX XXXX

You have the right to make a privacy complaint at any time to the Consumer Financial Protection Bureau (CFPB), USA’ s government agency dedicated to making sure consumers are treated fairly by banks, lenders and other financial institutions, https://www.consumerfinance.gov/privacy/file-privacy-complaint/ . We would, however, appreciate the chance to deal with your concerns before you approach the CFPB or other relevant agency so please contact us in the first instance.

Table of Contents

1. What Personal Data we collect

2. Updating your Personal Data

3. How we collect your Personal Data

4. Where we store your Personal Data

5. How we use your Personal Data

6. Disclosure of your Personal Data

7. Data Retention

8. Fraud prevention agencies and credit agencies

9. Your rights with respect to your Personal Data

10. Lending

11. Children’s Privacy

12. Do Not Track

13. Contact

1. What Personal Data we collect

Personal Data means any information or data about an individual from which that person can be identified. It does not include data or information where the identity has been removed (anonymous data).

Vouchpad Inc. may collect and process the following information about you (together “Personal Data”) through your use of the Site or Services:

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. Except in extreme circumstances such as death or a medical illness and only if there is a Legitimate Business Interest (see definition in section 5) for us to do so, we do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health and genetic and biometric data).

Personal Data may be given to us directly by you or by people or companies authorized by you to act on your behalf (for example, a potential lender, a university, a past/current employer or an alumni association you are a member of). We may also collect Personal Data about you from third parties in connection with our Services (for example, a credit reporting agency). No Personal Data about you will be collected without your consent for us to do so.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Please note that you are not required to provide any Personal Data for publication on the public areas of our Site.

2. Updating your Personal Data

You must notify us by emailing privacy@vouchpad.com within thirty days of any change in your name, physical address, telephone number, email address, or any other information that is necessary for us to provide Services to you.

You must also immediately notify us of your withdrawal or dismissal from your university or school.

3. How we collect your Personal Data

We use different methods to collect Personal Data from and about you including through:

We may use third-party service providers that collect data about users over time and across different websites in order to serve advertisements on our behalf that are more targeted and relevant to your interests. Vouchpad Inc. complies with the Digital Advertising Alliance (“DAA”) Principles for Online Behavioral Advertising. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly, such as by clicking on the “Ad Choices” icon in or around the advertisement. The DAA provides a single location where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit www.aboutads.info to exercise choice with respect to participants of the DAA.

We also use Google Analytics, which is a service provided by Google. Google utilizes the data collected to track and examine the use of our Site and may share this data with other Google services. You can learn more about Google’s privacy practices by visiting their website at http://www.google.com/policies/privacy/partners/ .

Similarly, our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers, or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

4. Where we store your Personal Data

Your Personal Data is generally stored in the USA, but it may also be transferred to, and stored at, a destination outside the USA for processing by our service providers or by service providers of Lenders or our partners. It is important that you are aware that we may need to transfer Personal Data to other countries outside the USA depending on business needs and employee location for purposes of processing.

Such processing may include the processing of your payment details and the provision of support services (such as with regard to credit checks and debt collection). By submitting your Personal Data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. The transmission of Personal Data via the Internet is not completely secure and, while we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site; any transmission is at your own risk.

5. How we use your Personal Data

Vouchpad Inc. acts as a Data Controller when using your Personal Data in providing you with Services and as a Data Processor on behalf of the Lenders.

We use Personal Data held about you in the following ways:

A “Legitimate Business Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us, privacy@vouchpad.com .

6. Disclosure of your Personal Data

We may disclose your Personal Data to a parent company, affiliates, franchisees, subsidiaries, joint ventures, or other companies under common control with us, based in the United States or elsewhere. We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your personal data. We may transfer Personal Data to countries outside the USA for processing depending on business needs. We have ensured that the recipient parties (including those within and outside the USA) comply with the relevant USA data privacy laws.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. Whenever we transfer your Personal Data out of the USA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us at privacy@vouchpad.com if you want further information on the specific mechanisms used by us when transferring your Personal Data within and outside the USA or if you would like details on third parties within and outside the USA with whom we share your Personal Data.

We aim to keep your Personal Data confidential and only disclose it to others for the purposes described in this Privacy Policy, including:

7. Data Retention

To ensure fair processing, Personal Data will not be retained by us for longer than necessary in relation to the purposes for which it was originally collected. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which it was processed and whether the purpose can be achieved through other means as well as the applicable legal requirements. We categorize any identified or identifiable individual person or “Data Subject” into:

  1. someone that has successfully completed an application for a loan and received funding from us or our partner financial institutions;
  2. someone that has created an account or registered on the platform (and has no other products with Vouchpad Inc. causing him or her to fall within category 1), but who’s application is in a state other than disbursed or settled due to:
    - it having been deemed unsuccessful;
    - it having been withdrawn by the Data Subject; or
    - it currently being in a pending state.
  3. someone that has applied for employment with us and submitted his/her CV and supporting documents through the Site; or
  4. a visitor to our Site.

In the case of category 1, we will retain all Personal Data for a minimum period of 6 years subsequent to the account having been settled or the completion of the loan repayment. In the case of categories 2 and 3, we will retain all Personal Data for a minimum period of 3 years unless the Data Subject formally requests that their Personal Data be erased. In the case of 4, we collect the visitor’s IP Address for security and audit tracking purposes as well as maintaining digital records of what the visitor did on the website. This data is retained for a period of 90 days.

In some circumstances you can ask us to delete your Personal Data (see Right to Erasure in section 9 below for further information). We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Fraud prevention and credit agencies

In order to process your application, we may perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). To do this, we will supply your Personal Data to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

We will continue to exchange Personal Data about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. Importantly, we will only be sharing information about your debt with us and your repayment thereof with CRAs in the jurisdiction that, according to our records, you are resident in. If you would like CRAs in other jurisdiction to also receive this information, you need to arrange that yourself.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share Personal Data, data retention periods and your data protection rights with the CRAs are explained in more detail at https://www.ftc.gov/system/files/documents/statutes/fair-credit-reporting-act/545a_fair-credit-reporting-act-0918.pdf .

Any CRA we use for a search will keep a record of any search, and other lenders may use it to assess applications they receive from you in the future. As a general rule, we will give you at least 28 days’ notice of any decision to file notice on your credit reference file of any default by you in your obligation to make repayments. However, we may not always give you notice beforehand, for example, if an enforcement action is planned.

If you are attending a school in the United States or are a United States resident at the time of making the loan application, then the provisions relating to credit reference and fraud agencies consumer reporting agencies and fraud prevention services shall be set out in the loan agreement that we enter into with you and other legal disclosures that we provide to you.

9. Your rights with respect to your Personal Data

You have the right to:

If you wish to exercise any of the rights set out above, please contact us at privacy@vouchpad.com .

10. Lending

Vouchpad Inc. may communicate with your university or other relevant parties to acquire information including, but not limited to, verifying your most recent physical address, education status, contact details during the processing of your loan and until the loan has been fully repaid.

As part of your loan application, you will be asked to agree to the terms of this Privacy Policy and the Personal Data collection, use, and disclosure provisions specific to the Services you receive. In particular, you will be asked to authorize (a) Vouchpad Inc. to request Personal Data from your university relating to you for the purpose of originating and servicing your loan; and (b) your university to disclose to Vouchpad Inc. any Personal Data relating to you that Vouchpad Inc. validly requests for the purpose of originating, servicing your loan, or optimizing your post-graduation outcomes.

11. Children’s Privacy

Our Site is not intended for use by children. We do not knowingly collect Personal Data from children under the age of 13 years. If we become aware that a child under 13 years of age has provided us with Personal Data, we take immediate steps to delete such Personal Data.

12. Do Not Track

The Site is not currently configured to respond to Do Not Track signals sent by Internet browsers.

13. Contact

You agree that we may call you, leave you a message, or send you a text, email, or other electronic message for any purpose related to your expression of interest in our Site, your loan with us, our Services, or surveys or research (each a “Communication”), to the extent permissible by law. You agree that we may call or text you at any telephone number associated with your loan, including cellular telephone numbers and may send an email to any email address associated with your loan. You also agree that we may include your Personal Data in a Communication. In addition, you understand and agree that we may communicate with you in any manner permissible by law that does not require your prior consent.

If you have any questions regarding this Privacy Policy, please email us at privacy@vouchpad.com .

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