Information Collection, Use, and Sharing SBC is the owner of the information collected on its websites and platforms. SBC has access to/collects information that you voluntarily give SBC via email, form, or other direct contact from you. SBC may also collect information about the SBC services that you use and how you use them. Such information may include IP address information, device identification, “cookie” information, type of browser or device being used to access our services. Also we automatically receive information about communications sent or received using our services which is relevant to SBC SMS or Voice services, such as delivery receipts, phone numbers, size, time of transmission, data, and other message transmission and conversion data.   We will not sell or rent this information to anyone. We will not share your information with any third party outside of its organization, other than as necessary to provide the services you request; to conform to legal requirements; to co-operate or comply with legal process, investigations, summonses, subpoenas and the like; to protect and defend the rights, property or legally protect-able interest of SBC , you or other third party; to enforce any of the provisions of SBC General Terms and Conditions; to protect SBC business or reputation; to detect, prevent or otherwise address fraud, security and technical issues and/or as otherwise specified in this Policy. We may also share your information with third parties if you provide your consent for us to do so.   Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.   Registration/ Sign Up Many of our services require you to sign up for a SBC Account. During registration, a user may be requested to provide certain information, such as name, email address, mobile phone number, country, time zone, Company name, Company address, Company phone number, website address, third party account credentials (for example, your login credentials for PayPal or other third party sites), your SMS providers, and other information. This information is used to contact you about the products/services on our site in which you have expressed interest and/or to set up your account and provide the services you purchase from us.   Online Purchases/ Payments To buy from us, you must provide contact information (like name and email address) and financial information (like credit card number, expiration date). This information is used for billing purposes and to provide the services you have purchased. If we need to communicate with you regarding the services you have purchased from us, we’ll use this information to contact you. We may use the services of trusted third parties to process online payments. We may share with such third parties your information in order to process online payments. WHAT INFORMATION WE COLLECT   We collect nonpublic personal information about you from your credit application, credit reporting agencies, and your transactions and experience with us.   HOW WE USE THAT INFORMATION   We use your personal, demographic and profile data to enhance your experience at our site and to enable us to present information we think you might be interested in. With your permission, we will share your information with third parties when we believe they can provide our customers relevant information about their products and services. Information may be delivered to you via email, wireless phone, mail or regular phone. We also maintain customer identifiable information per our Know Your Customer and Anti Money Laundering (AML) policy. Please refer to the loan application page for the customer information we collect. Information supplied by the applicant is verified to confirm customer identity. The company checks the OFAC list when customers submit their application and complies with government requests related to anti money laundering investigations. A designated employee has been assigned as the responsible manager for our AML policy. Our policy is reviewed annually.   We Do Not Share Your Information With Third Parties for Marketing Purposes.   We are permitted by law to disclose nonpublic personal information about you to third parties in certain circumstances. For example, we may disclose nonpublic personal information about your short-term loans to consumer reporting agencies and to government entities in response to subpoenas. Such disclosures are made as necessary to effect, administer and enforce the loan you request or authorize. Otherwise, we do not disclose nonpublic financial information about our customers or former customers to anyone, except as permitted by law. If you become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.   COLLECTION AND USE OF BANK ACCOUNT INFORMATION If we extend credit to a consumer, we will consider the bank account information provided by the consumer as eligible for us to process payments against. In addition, as part of our information collection process, we may detect additional bank accounts under the ownership of the consumer. We will consider these additional accounts to be part of the application process.   OUR SECURITY PROCEDURES We also take steps to safeguard customer information. We restrict access to nonpublic personal information about You to employees who need to know that information to provide products or services to You. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.   Cookies We use “cookies” or similar technologies on SBC websites and platforms. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our sites. We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services.   End Users Information and Analytics In order to provide you with analytics reports, we may collect and use some information from your End Users (see definition at SBC Solutions – General Terms and Conditions). Such information may include but is not limited to End User’s device-specific information, such as phone number and mobile network information, browser information, country location, city location, and other information such as online behavior and campaign subscription preferences. By using SBC platforms and providing SBC your End Users’ information, you are representing to SBC that you have been authorized by your End Users to share their information with SBC for the purposes stated in this paragraph.   Your Access to and Control Over Information You may take the following actions at any time by contacting us via the email address or phone number given on SBC website, unless doing so impairs your or SBC ability to perform the contractual obligations entered into between you and SBC :

• See what data we have about you, if any, in your Account Information.
• Change/correct any data we have about you in your Account Information.
• Opt out of any future email communications from SBC by unsubscribing from email communications via the link at the bottom of SBC email communications.

Updates Our Privacy Policy may change from time to time and all updates will be posted on this page. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice on our sites.   Underage User Policy You must be at least 18 years old to use SBC websites or platforms. You must not allow people under 18 years old to use SBC websites or platforms under your account. Make sure you follow these guidelines. If you don’t, you may be subject to a range of actions, including limitations, suspensions or cancellations of your account. If you think that a violation of this Underage User Policy has occurred, please report it to us at abuse@Shamrockbusinesscapital.com Make sure to include any relevant information about why you think there has been a violation and include any relevant information that will facilitate our enforcement of this Policy. SBC websites and platforms are not directed to children under 18 years old. SBC is not aware of actual usage of SBC websites and platforms by children under 18 years old.   Contact Us If you have any questions regarding our use of your data contact us at abuse@Shamrockbusinesscapital.com When you contact us, we may keep a record of your communication to help solve any issues you might be facing. We may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or which are impractical.