Effective: Apr. 3, 2024
This Privacy Policy (“Policy”) describes how WithClutch, Inc. (“Clutch,” “we,” “our,” “us”), collects, uses, and maintains certain personal information obtained through our website (“Site” or “Platform”), in order to contact you directly. By visiting our Site, using the features made available to you on the Site, and/or utilizing our financial Platform services (collectively, the “Services”), you agree to the terms of this Policy. Please note that information collected in relation to our financial Platform services is subject to the federal Gramm-Leach-Bliley Act (GLBA) and, in some cases, the Fair Credit Reporting Act (FCRA). Please review our GLBA notice to learn more about how we comply with federal law. What Information We Collect and Maintain About You:
We collect personal and other information from you directly when you provide it to us through the website. We may also automatically collect certain information about you and your device when you use, access, or interact with our Site. Personal information collected: In order to contact you, users of our services are required to provide certain personal information such as name, address, e-mail address, Social Security number, and income. You may provide this information when you go through our loan application process; sign up for other products or services through Clutch; or when you communicate with us regarding our services through email or other means. We may collect the following information about you from you directly:

• Application information: You provide this on your application by phone, or online. It includes your name, street, and e-mail addresses, phone number, driver's license number, Social Security number, date of birth, gender, marital status, and type of vehicle. It also includes information about other persons authorized to drive your vehicle.
• Identity information: Including name, date of birth, marital status, Social Security number, and other data on government-issued identification documents (e.g., passport and driver's license). We collect this information, in part, to meet federal requirements and to combat money laundering activities. Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens a financial account. When you open a financial account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.
• Contact information: Including home address, telephone, email address, and emergency contact details.
• Employment information: Including job title/position and annual income.
• Characteristics of protected classifications under California or federal law: Such as age, citizenship, and marital status.
• Preferences: Such as your preferences for receiving our marketing communications and privacy choices.
• User-generated content: Such as questions, messages, reviews, blog posts, and other content or information that you generate, transmit, or otherwise make available

• Financial information: Such as student loan, personal loan, and credit card information; banking details; tax information; expenses; stock and, equity details; and, financial account details of linked financial accounts.
• Audio, electronic, visual, or similar information: Including recordings of calls and online user sessions. We collect and use this information to measure and improve our member relationship protocols, to train and educate employees, and for compliance purposes. Sensitive Personal Information We Collect:
• Unique Identifiers: Your Social Security, driver's license, state identification card, or passport number.
• Financial accounts: We collect account log-in and, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
• Precise geolocation data: With your consent, we collect precise geolocation data (any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet).
• Biometric data: As part of the verification process, we may collect biometric information from government IDs and images to verify your identity. Personal information collected in other contexts: If you are not utilizing our lending or account opening services and are instead using other features on the Site, such as our “Careers” section, or if you contact us with any questions, we may collect personal information from you, such as your name, contact information, and any other information related to your request. Server logs: Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to the Site on a particular time and day and collect information such as your device ID or IP address. Pixel tags: A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email. Cookies: We also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer's operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to

decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly. Aggregated and deidentified information: From time to time, we may also collect aggregated or deidentified information about Site users, such as by publishing a report on trends in the usage of the Site. Such aggregated or deidentified information will not identify you personally. How We Use Your Information for Business Purposes:
The purposes for which we may use your information include to:
• Provide you with our Services: We use your personal information to display services and products to you and to determine eligibility for financial and insurance products and process transactions and payments, fulfill orders, and verify customer information.
• Respond to your questions or requests concerning the Services: Communicate with you about products and services that may be offered to you, including by sending you announcements, updates, security alerts, and support.
• Fulfill the terms of any agreement you have with us.
• Fulfill your requests for our Services or otherwise complete a transaction that you initiate.
• Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails.
• Improve our artificial intelligence and machine learning.
• Deliver confirmations, account information, notifications, and similar operational communications.
• Improve your user experience and the quality of our products and Services.
• Comply with legal and/or regulatory requirements: We may use your personal information to comply with applicable laws, lawful requests, and legal process, such as respond to subpoenas or requests from government authorities; protect our, your, or others' rights, privacy, safety, or property; audit our internal processes for compliance with legal and contractual requirements or out internal policies; and enforce the terms and conditions that govern our Platform.
• Aggregate and deidentify information.
• Count and recognize visitors to the Services.
• Analyze how visitors use the Services and its features;
• Improve the Services and enhance users' experiences with the Services.
• Create new products and services or improving our existing Services.
• Enable additional analytics and research concerning the Services.
• Manage our business.
• Detect and prevent fraud.
We may link information gathered through Site with information that we collect in other contexts. In that event, we will handle the combined information in a manner consistent with this Policy. How to Contact Us:
Should you have any questions or concerns about this Policy, you can contact us by phone at 650-842-0703 or by email at legal@withclutch.com.

CALIFORNIA PRIVACY ADDENDUM
This section applies solely to residents of California and their personal information that is subject to the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) (collectively, the "CCPA"). The CCPA does not apply to the following:
-Publicly available information made lawfully available from government records. -Information that is de-identified, meaning that the information is rendered so that it cannot reasonably be used to infer information about or link to a specific person.
-Information subject to other laws, such as the following:
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach Bliley Act ("GLBA") or California Financial Information Privacy Act ("FIPA"), and the Driver's Privacy Protection Act of 1994.
California residents have the right to:
• Know what personal information we have collected about you;
• Request the deletion of certain personal information collected by us;
• Correct inaccurate personal information;
• Know/access or receive a disclosure of your personal information;
• In certain cases, limit the use and disclosure of sensitive personal information; and
• No retaliation for opting out or exercising any other rights, including an employee's right not to be retaliated against for the exercise of their CCPA rights.

How to Exercise Your Rights to Know (Access), Delete, or Correct Your Personal Information: We must verify your identity before processing most requests, which may require you to provide additional information. You may submit a request by emailing us at legal@withclutch.com or by calling us at 650-842-0703.

We strive to honor requests within forty-five (45) days of receipt. In certain instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity. We will notify you if we are unable to process your request within that time or at all and provide you an explanation. How to Exercise Your Right to Opt-Out:

We must verify your identity before processing most requests, which may require you to provide additional information. You may submit a request by emailing us at legal@withclutch.com or by calling us at 650-842-0703.

We strive to honor requests within forty-five (45) days of receipt. In certain instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity. We will notify you if we are unable to process your request within that time or at all and provide you an explanation.

How to Exercise Your Right to Limit the Use of Sensitive Personal Information at Clutch:
We must verify your identity before processing most requests, which may require you to provide additional information. You may submit a request by emailing us at legal@withclutch.com or by calling us at 650-842-0703.

We strive to honor requests within forty-five (45) days of receipt. In certain instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity. We will notify you if we are unable to process your request within that time or at all and provide you an explanation.

Submitting Requests on Another's Behalf/Authorized Agents:
You can designate an authorized agent to submit a request on your behalf by calling us at 650-842-0703. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us.