Privacy Policy Last revised March 2024.. Getting Established Online Privacy Policy (last revised March, 2024) Overview of our Privacy Policy This privacy policy describes Getting Established’s (“Getting Established” or “we” or “us” or “our”) privacy practices in connection with its website: gettingest.com. This policy is designed to inform you of the information we collect, how we collect that information, how we secure that information, how that information is used and with whom that information is shared. If our information practices change, we will post an updated policy on our website. You can tell if the policy has changed by checking the revision date that appears above. If we change the policy in a material way, we will provide appropriate notice to you. You may exercise your choices about how we collect and use your information consistent with this policy at any time. If you have any questions about our privacy policy, please contact us as described in the section entitled, “Contacting Us”, below. Information we collect How do we collect information about you? Collection Notice How do we use the information we collect about you? More Information On Data Trackers: Third-Party Cookies Do we share your personal information? Sharing Information with Service Providers and Business Partners Sharing Information with Other Third Parties Sharing Information To Provide Reviews or Testimonials Sharing Information in Connection with a Company Sale or Transfer Is my personal information secure? When You Use Widgets Listed on Our Web Pages Third Party Sites Where do you store my personal information? How long will you keep my personal information? Will you transfer my personal information across national borders? Notice Regarding Your Data Rights What if I have a dispute about how you handle my personal information? Will you market products or services to me? Notice to Vermont Residents Notice to Nevada Residents Protecting Children’s Privacy Online Will this privacy policy change? Contacting Us Information we collect When you visit one of our web pages, engage our services, or contact us for support or other offerings, we collect information that identifies you. Some of this information identifies you personally (such as name) and other is non-personal (such as your activity on our website). The following is a general list of the types of information we collect: identifiers (e.g., name, IP address, mailing address, email address, phone number); Payment Information such as billing address or account numbers. Contact Information including your name, address, email address, telephone number, etc. Online Identifiers: When you access our web pages, we obtain your Internet Protocol address, browser user agent, and your device id. Data Trackers, Including Cookies and Web Beacons: We collect information on what pages you access or visit; user-specific information on what pages you access or visit; information you volunteer, such as survey information and/or site registrations; bandwidth use; referral source; operating system; mobile carrier (where applicable); and system and connection performance. How do we collect information about you? We collect the above information through the following means and technologies: Directly. Directly from you when you provide it to us through this website. Automatically. Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and/or other tracking technologies. o Tracking Software. We employ software technology that enables us to track certain aspects of a user’s visit to the Website. This technology helps us better manage content on the Website by informing us what content is effective, how consumers engage with the Website, and how consumers arrive at and/or depart from the Website. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user. o Click Through. If you arrive at the Website by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Website, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Website to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Targeted and Cross-Context Behavioral Advertising o We may work with third-party advertisers, search providers, ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Website or services we offer as well as other websites and services. These companies may use cookies, tracking pixels, and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users and Advertisers may collect identifiers, commercial information, characteristics of protected classification, and internet information in connection with targeted and cross-context behavioral advertising activity. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Website or on third-party websites. You can visit the Network Advertising Initiative website at www.networkadvertising.org for information about Internet advertising companies and how to reduce information collection by such companies. Please also see the Additional State Consumer Rights section below regarding rights you may have under state laws to opt out of our sharing of Personal Information for targeted or cross-context behavioral advertising purposes. Social Media Widgets o The Website may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them. Before you choose to interact with these features, you should review the relevant social media company’s privacy policy. Third Party Merchants. o We may work with third party merchants who provide us with your personal information so that we may process it on their behalf. We may hold/process data at the direction of businesses that use our platform subject to our data processing agreement with such merchant. Collection Notice As a company that conducts activities that are financial in nature, Getting Established is a “financial institution” as that term is defined in the Gramm-Leach-Bliley Act (“GLBA”). While the state law does not exempt financial institutions like Getting Established, from its requirements, it does exempt personal information collected by a financial institution pursuant to the GLBA. Accordingly, much, if not all, of the data consumers provide to Getting Established, or that we collect from our merchant clients regarding their consumers, will fall within the GLBA exemption. Getting Established recognizes the eleven (11) broad categories of personal information referenced in state law that a business may collect about a consumer. In particular, Getting Established has collected the following categories of personal information from consumers within the last twelve (12) months. Category Examples Collected A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers. YES B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. YES C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental YES disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES G. Geolocation data. Physical location or movements. YES H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO I. Professional or employmentrelated information. Current or past job history or performance evaluations. YES J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, NO predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Personal information does not include: Publicly available information from government records. De-identified or aggregated consumer information. Information excluded from California law’s scope, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Any data that falls under one of the bullet points above will not be considered “personal information” under California law. Getting Established will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing notice to you. Such notice may be delivered, for example, by posting an updated Privacy Policy. How do we use the information we collect about you? We use contact information, including email addresses, to communicate with our customers and provide requested services. This also helps us notify you about updates to our web pages, products and policies, and marketing releases. We also use this contact information for billing purposes and to carry out your requested services. Online identifiers and data trackers are used to secure the limited access portions of our web pages and services. Data trackers help our web pages work. They also help us to improve our content and to customize the content and/or layout of our page for each individual visitor. In addition, we use online identifiers and data trackers to prevent and reduce fraudulent practices. For more information about our use of cookies, web beacons, and similar technologies, please read “More Information On Data Trackers” below. Getting Established may use this information to: Provide you with the information, products, or services you request from us. Fulfill the reason you provided or we received the information, such as connecting you with a company that will provide services that you are interested in. Personalize your website experience and deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent where required by law). Advertise and market products and services to you from both affiliated and non-affiliated entities, which includes sending promotional communications, target advertising, and presenting you relevant offers. Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business. Process your requests, transactions, and payments Provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitor and improve our responses. Test, conduct research, analysis, and product development, including developing and improving our website, products, and services. Prevent transactional fraud. Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. Carry out our obligations and enforce our rights arising from any contracts entered into between you and us. As described to you when collecting your personal information or as otherwise set forth in California law. More Information On Data Trackers: Cookies are small text files that are stored by your web browser when you use websites. When you visit our web pages, our web server sends a cookie to your computer. You can control how websites use cookies by configuring your browser’s privacy settings (please refer to your browser’s help function to learn more about cookie controls). Note that if you disable cookies entirely, our web pages may not function properly. We use cookies in several ways, such as: To show whether you have visited a web page previously; To store your preferences; To show how you navigate around a web page and the most commonly clicked links on a specific web page; To gather certain technical information, such as your browser version and operating system; and To estimate and report how many different users are on our websites. The use of cookies allows us to make your experience on our website simple and meaningful, to customize web page content, to alert you to new areas that we think might interest you, to provide better services, and to ensure that you are not repeatedly sent the same banner ads, when you return to our web pages. It also helps us to conduct research to improve the content and services of our web sites. Web beacons (sometimes called “tracking pixels”, “transparent gifs”, “clear gifs”, “pixel gifs”, or “pixel tags”) are tiny, invisible images that are embedded on web pages and emails and are stored on a your hard drive. They help us to count users who visit our web sites or open our emails. Tracking pixels help us figure out if certain features, notifications, and products or services are effective and if they can be improved. You can modify your browser settings to control web beacons. Third-Party Cookies We may also from time to time engage third parties to track and analyze data and statistics that do not identify you. This practice helps us administer our websites and improve their quality. These third parties may use cookies and web beacons to help track visitor behavior. Their cookies and web beacons may track how you interact with a web site through the use of cookies and the data collected may include how you navigate around a web page and the most commonly clicked links on a specific web page. They may also collect technical information, such as your browser version and operating system. If collected, this information will be used by us to evaluate and, if necessary, modify our website to improve the functions and make it easier for customers to use. Your name and contact information is not collected or used for this purpose. As a part of our efforts to carry out and improve our services to you and to monitor and improve the functions of our websites, we may also undertake profiling or automated individual decision-making. Automated individual decision-making refers to a decision made solely on the basis of automated processing of your personal data, without human involvement. For instance, we may process personal information using an algorithm or a software code. Profiling is automated processing of personal data to evaluate certain information collected about an individual. We conduct profiling and automated decision-making to better understand your interests and preferences and to adapt our communications to your user profile. You can address any questions or concerns about this practice by contacting us. Do we share your personal information? Getting Established works with companies that help us run our business. From time to time, we need to share some of your personal information with these companies so that they can perform requested services. They can only access your personal information to carry out the tasks we have asked them to do. They are required to hold this information in confidence, and they must meet both legal and industry standards to ensure that your data is protected. We may share your personal information with service providers, business partners, or other third parties. To see information regarding your data rights, and how you may exercise your rights, please visit the Notice Regarding Your Data Rights Section. Sharing Information with Service Providers and Business Partners Getting Established shares information with business partners in order to carry out the services that you have requested. For example, we may share information with a merchant in order to provide a consumer with a requested product, including loans or other financial services. This sharing is always done with the prior consent of the consumer. When we do so, Getting Established enters into a contractual arrangement that describes the business purpose and requires the recipient to both: (A) keep that personal information confidential; and (B) not use it for any purpose except performing the obligations under the contract. Please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices. We work with companies who help us: host our services and data, manage how our services function, improve and automate our marketing techniques, incorporate customer service and other software platforms, process payments from third parties, and market and promote products and services, including by email. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Getting Established may also share information about visitors, members, and/or customers with our service providers to ensure the quality of information provided. Without your permission, Getting Established does not share, sell, rent, or trade any information with third parties for their promotional purposes. We share your personal information with the following categories of third parties for a business purpose: Affiliates Service providers Third-Party Lenders Third-Party Debt Relief Providers Data aggregators Internet cookie data recipients (e.g., Google analytics) State laws requires Getting Established to provide you with a statement on its personal information disclosures for a business purpose that reference the eleven (11) categories of information reflected in the chart above. In the preceding twelve (12) months, Getting Established has disclosed the following categories of personal information for a business purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category F: Internet or other similar network activity. Sharing Information with Other Third Parties We and our advertisers may collect information about you using cookies and web beacons. You can control the collection of such information using cookies and web beacons by adjusting the settings on your web browser. We also work with partners to create programs that help you to get the most out of our services and provide you the opportunity to purchase complementary products and services that may be used in tandem with our services. We partner with third party ad networks to display advertising on our web pages or to manage our advertising on other websites. Our ad network partners may use cookies and web beacons to collect information about your activities on our websites and other websites to provide you targeted advertising based upon your interests. To opt out of this type of cookies, visit the Network Advertising Initiative (NAI) website by visiting OPT OUT OF INTEREST-BASED ADVERTISING. Even if you opt out through the NAI website, you can still receive communications you have signed up to receive from us unless you opt out of these communications as well. Sharing Information to Provide Reviews or Testimonials We may select and post customer testimonials about our services, which may contain personal information such as your name and/or the city, state, or country in which you live. We will obtain your consent before we post any testimonial with your name. When you submit a review, you give us permission to post that review. If you post this content, it will be available to other users. Your posting may also become public and we cannot prevent that information from being used in a manner that may violate our privacy policy or the law. If you would like us to remove or delete your name, testimonial, or review from our web pages, please contact us. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of our web pages for a period of time. Sharing Information in Connection with a Company Sale or Transfer We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies. Is my personal information secure? We use reasonable and diligent efforts to maintain accurate information on our customers and have adopted and implemented reasonable industry standard security procedures to protect any such information collected against the loss, misuse or alteration. We constantly monitor our systems, which are protected using industry-standard security measures. Although we will use reasonable efforts to secure network communications and our website, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure. When You Use Widgets Listed on Our Web Pages A widget is a small application with limited functions. It can be installed and used within a web page. It occupies a portion of a webpage and does something useful with information fetched from other websites. We may provide widgets on our web pages so you can share information on third-party platforms. Our web pages may also include social media features, such as the Facebook® or Twitter® button and similar widgets and interactive mini-programs that run on our site. The companies running those widgets may collect your IP address, which page you are visiting on our site, and may set a cookie to enable their widget to function properly. Social media widgets are either hosted by a third party or hosted directly on our web pages. Since these other parties have their own privacy policies—and your use of their widgets is governed by their policies—we encourage you to review the privacy statements for the companies running those widgets. Third Party Sites Our website may contain links to third party websites. Please note that the privacy and other policies of any such third-party website may differ materially from this Policy. We strongly recommend that customers review the privacy policies of any such third party prior to submitting personally identifiable information. Getting Established has no control over and is not responsible for the information practices of other websites, including those to which we may link and those which may link to us. Where do you store my personal information? Your personal information and files are stored on Getting Established servers and the servers of companies we hire to provide services to us. Your personal information may be transferred across national borders because we have servers located worldwide and the companies we hire to help us run our business are located in different countries. How long will you keep my personal information? We will retain your personal information for as long as necessary to provide you with the product and services you have requested and as needed to comply with our legal obligations and enforce our agreements. Will you transfer my personal information across national borders? We primarily store information about our visitors, members, and customers in the United States. However, we may transfer your personal information across national borders to other countries in compliance with applicable laws. If you are a European resident, we transfer your data based on one or more of the following legal mechanisms: Standard Contractual Clauses. Notice Regarding Data Your Rights Your Choices Regarding Your Personal Information; Opting Out Unsubscribing to Marketing Communications. If you no longer wish to receive bulletins, updates, or other marketing-related materials from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in the Contact Us section below. • Access, Deletion, and Do-Not-Sell Requests. You may have certain rights regarding the information we collect and share with third parties. To exercise those right, please visit our Data Requests Page. Information regarding your data rights. Specifically, we provide the following rights with respect to your Personal Information: • Copies of Personal Information. You may request a copy of the following: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling (if applicable) the Personal Information; (iv) the categories of third parties with whom we share Personal Information; and (v) the specific pieces of Personal Information we have collected about you. • Deletion of Personal Information. You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes consistent with the terms under which it was collected. • Do-Not-Sell or Share Requests. You may request that we do not share or sell your Personal Information with third parties to be used for purposes not described in this Privacy Policy. The California Consumer Privacy Act refers to this as a “Do Not Sell” request. Getting Established only seeks to refer, share, or otherwise transfer Personal Information with marketing providers, service providers (including third-party lenders and debt resolution companies) and others described above for purposes identified in this Privacy Policy. Please note, however, that Online Activity Information or Anonymous Information collected by service providers providing pixels or other third-party technologies on our Website could potentially be used by those service providers for their own purposes, some of whom may be able to associate such information with you based on other information they have collected. We will endeavor to block such sharing upon request. • Submission of Requests. You can submit any of these requests by e-mailing us at ksmith@gettingest.com or by visiting the Data Requests Page. You may authorize another person (your “Agent“) to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it or advise you of an exemption. • Response to Requests. Please be advised that Getting Established will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please email us at ksmith@gettingest.com or contact us as provided in the Contact Us section below. Anonymous Information. We will not delete Anonymous Information from our database other than in the regular course of business, and nothing in this Privacy Policy restricts our use of Anonymous Information. To exercise your data rights under this section, please visit our Data Requests Page. To protect customer privacy and security, we reserve the right to take reasonable steps to verify your identity prior to granting access to or processing changes or corrections to such information. What if I have a dispute about how you handle my personal information? While this Site is not intended for European residents, if you are an E.U. resident and you have a dispute about how we are handling your personal information you may have a right to lodge a complaint with your local supervisory authority. Otherwise, all users may contact us with questions or disputes at our address, telephone and/or e-mail provided at the bottom of this Policy. Will you market products or services to me? Getting Established and companies we hire to help us market our web pages and services on our behalf may use your information to provide you with information and offers related to our services. You may decline to receive these offers by contacting us. You may also opt out of receiving future promotional/marketing messages from us by clicking the “unsubscribe” link found in the footer of our email messages. Please note that if you opt out of promotional/marketing messages, you may continue to receive certain communications from us, such as administrative and services announcements and/or messages about your account/profile. Notice to Vermont Residents In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we not share your information with nonaffiliated third parties, and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you. Notice to Nevada Residents We are providing you this notice pursuant to state law. First, Getting Established does not sell consumer information. Second, as a NV resident may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing at info@iMergeFinancial.com. Nevada law requires that we also provide you with the following contact information: 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; e-mail: BCPINFO@ag.state.nv.us. Protecting Children’s Privacy Online This website is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the website. We do not knowingly collect information from children under 13. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA). If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us at our email or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information. Will this privacy policy change? If our information practices change at some time in the future we will post the changes to our Privacy Statement web page to notify you of these changes. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices. Contacting Us • Legal/Privacy Compliance • Address: Getting Established, 4245 N Central Expy, #490 Dallas, TX 75205 • Phone: 1-214-254-4962 • E-mail: ksmith@gettingest.com Text messaging originator opt-in data and consent will only be shared with providers of the Text Message services.