Global Group US LLC Privacy Policy

This Privacy Policy shall be effective as of 5/2/25.

This website is owned and operated by Global Group US LLC ("Global Group"). We at Global Group respect and protect the privacy of visitors to our website and the privacy of our customers. This Privacy Policy demonstrates our commitment to protecting your privacy. Except where otherwise noted, this Privacy Policy applies to and describes our information handling practices when you access our services, which include our content located on this website, or any other websites, pages, features, or content we own or operate (collectively, the "Site(s)") or third-party applications relying on API, and related services (referred to collectively hereinafter as "Services").

Global Group operates two primary business lines: (1) a small business marketplace that assists small businesses in accessing and managing capital, primarily through debtfreeagency.com and getzerointerest.com; and (2) direct mail marketing and lead generation services for businesses through our websites hometownad.com and globalgroupus.com. This Privacy Policy applies to everyone who utilizes any of these Sites.

We encourage you to review Global Group’s Terms of Service. Where consent is required by law to process your personal information, we will ask for your consent to the collection, use, and sharing of your personal information as described further below, otherwise your receipt of notice of our privacy policy constitutes sufficient consent for Global Group to collect and process your personal data in a manner consistent with this Privacy Policy and the law. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

For each section, Global Group will provide a summary of the section in the hopes that it will assist Global Group customers to better understand Global Group’s privacy practices and policies.

1. Types of Information that are collected

1.1 Personal information

While Global Group strives to only collect information about your business, due to the nature of small businesses, Global Group invariably collects Personal Information about business owners as they seek business capital. Personal Information is defined as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. The definition of Personal information does not include:

- Publicly available information from government records.

- Deidentified or aggregated consumer information.

To establish an account and access our Services, we’ll ask you to provide us with some important information about you. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.

Please note that we may not be able to serve you at all, or our Services may be degraded if you choose not to share certain information with us.

1.2 Types of Personal Information

While offering Services, Global Group may collect the following information from you:

Personal Identification Information: Full name, date of birth, utility bills, photographs, phone number, home address, IP Address, social security number, and/or email.

Formal Identification Information: Government issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial, consumer protection, and commercial lending laws or contractual obligations imposed upon us by our banking partners.

Business Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.

Marketing and Social Media Information. Physical mailing addresses, geographic location data, demographic targeting parameters, QR code scan data, text message communications, campaign engagement metrics, audience demographics, lead source information, and conversion metrics.

Financial Information: Bank account information, tax return information, Federal and State Tax ID, profit and loss statements, income statements, credit score, business invoices, and wire instructions.

Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.

Employment Information: Office location, job title, and/or description of role. Correspondence: Survey responses, information provided to our support team or user research team.

Business Information: Type of business, list of officers, members, or managers of the business, articles of incorporation, certificates of good standing, and ownership structure.

1.3 Device/Digital Information

We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services or access our Site or Services from another website – such as by interacting with an advertisement, or by interacting with Global Group’s. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or device IP addresses.

Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

- How you came to and use the Services;

- Device type and unique device identification numbers;

- Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);

- How your device interacts with our Sites and Services, including pages accessed and links clicked;

- Geographic location; and,

- Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser and other information about you.

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third-party site.

1.4 Third-party information about you

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. As needed, we will obtain your consent to obtain this information from third parties. These sources may include:

Public Databases & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law.

Credit Bureaus: With your consent, we obtain information from credit bureaus, including your credit report. We will not disclose your credit report without your explicit permission. We obtain your credit information to better provide services to you, to match you with appropriate lenders, to ensure your identity, and to avoid fraud.

Credit Inquiry Types: Credit Inquiry Types: When we obtain your credit information, we may use either a 'soft' credit inquiry (which does not affect your credit score) during the pre-qualification process, or a 'hard' credit inquiry (which may affect your credit score) if you choose to proceed with a specific financing offer. You will be notified before any hard inquiry is performed.

Financial Institutions: With your consent, we may obtain information directly from your financial institution, including copies of your account statements. We obtain this information to assist in providing Services to you, including the underwriting process. To do this, we may utilize third-party service providers that facilitate the secure transfer and aggregation of your financial data. The privacy policies of these third-party service providers govern their collection and use of your personal data.

Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.

Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation.

2. How information is collected

We obtain information about you during the application process, and through your interactions with our Sites.

As we’ve noted previously, where we require your consent to process your personal information, we will ask for your consent to the collection, use, and sharing of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data, IF YOU DO NOT AGREE WITH OR YOU ARE NOT COMFORTABLE WITH ANY ASPECT OF THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY DISCONTINUE ACCESS OR USE OF OUR SERVICES

We obtain the categories of personal information listed below from the following sources:

Directly from you: For example, from forms you complete or by using our Products and Services.

Indirectly from you: For example, from observing your actions on our Sites.

Third Parties: For example, from third-party services which you connect to as part of using our Services.

2.1 During the application process.

To process your initial application for funding, you may provide to us your name, address, phone number, email address and other personal information. You may also be required to provide the name of your business, its address, its federal and state tax ID, the type of business, business location, average monthly sales, state of incorporation, name of Landlord. Such information is used primarily to process your application for business funding, but may also be used as otherwise described in this privacy policy.

2.2 Emails and telephone calls.

You provide us with an email address when you register for our services. We use your email for both transactional (e.g., application status, application updates, application confirmation, etc.) and promotional (e.g., newsletters, new product offerings, event notifications, special third-party offers) purposes. We may send e-mail messages to you that may contain code that enables us or our vendors to track your usage of the e-mails, including whether the email was opened and what links (if any) were clicked.

Additionally, during the application process, you may engage in email communications about your transaction, and provide Global Group with information about you, your business, and your application. If you would rather not receive promotional emails from us, please see the section below labeled “Choice/Opt-Out”. We reserve the right to send you certain communications relating to the Global Group services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them.

We may also contact you by telephone or text message (including to any wireless number you may provide to us), and you may provide to us information, in connection with Global Group’s services, or for marketing purposes if you consent to receiving such telephone calls or text messages. If you would rather not receive telephone calls or text messages from us, you may change or delete your number from your account preferences page(s), or ask to be placed on our internal do-not-contact list if you receive a call or text message from us. We fully comply with the requirements of the U.S. CAN-SPAM Act, the Telephone Sales Rule, the Telephone Consumer Protection Act (TCPA), and relevant state laws governing telephone calls.

2.3 Third-Party Service Providers

Global Group offers multiple ways for customers to interact with us and access information to support their business financing journey. These may include embedded videos, chat features, AI chatbots, third-party web monitoring services, and other general services. In some cases, you may provide information directly to third-party service providers (such as through chat features or embedded tools), and those service providers then share your information with Global Group. In other cases, Global Group may share your information with service providers to facilitate the delivery of our Services, as described in Sections 3 and 4 below. To the extent possible, Global Group minimizes the data it collects and shares and anonymizes and aggregates your data. Additionally, Global Group implements restrictions to screen sensitive personal information from collection or use by third-party service providers.

2.4 Log files

Any time you visit any of our Sites, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This gives us an idea of which parts of our site users are visiting. We do not share the log files externally.

2.5 Cookies

We use “cookies” to keep track of some types of information while you are visiting our Sites or using our services. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to our Sites and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track user trends. We rely on cookies for the proper operation of our Sites. Some of those cookies also transmit information about you back to third parties.

2.6 Web beacons

“Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our Sites for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers. We do not link the web beacons to any personally identifiable information.

2.7 Other sources and third parties

We may obtain information about you from third parties. We combine this third-party data with information we already have about you to create tailored advertising and other relevant product recommendations. If you provide information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Any information obtained from a third-party will be used to assist matching your business with various lenders.

The sites contain links to other websites that are maintained by third parties. These third parties are solely responsible for their own websites, and we encourage you to reach out to such third parties for copies of and information regarding their privacy and security practices. We do not control, and are not responsible for, the privacy and security practices of these third parties.

3. How your information is used

3.1 Global Group services

We process your personal information to provide the Services to you. For example, when you wish to seek business financing from one of our financing partners, we require certain information such as your identification, contact information, income information, and other information as requested by our business financing providers. When you engage with our direct mail marketing and lead generation services, we process your information to create and distribute targeted direct mail campaigns, generate qualified leads, track campaign performance through QR codes and response rates, and facilitate communications between businesses and potential customers.

3.2 Artificial Intelligence and Machine Learning

As part of offering our Services, Global Group works with vendors who utilize Artificial Intelligence ("AI") and Machine Learning ("ML") models. Your information may be processed by these vendors using their AI and ML models as part of the services they provide to us.

If you wish to opt out of certain AI/ML processing of your data, please contact us at [email protected]. Please note that Global Group does not directly control the AI/ML models operated by third-party providers. We can assist by forwarding your opt-out request to the relevant third-party providers who own and operate these models; however, the actual opt-out process and its effectiveness are determined by those providers. Opting out may limit some functionality of our Services.

3.3 Service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes;

3.4 Customer service

We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services;

3.5 Research and development purposes

We process your personal information to better understand the way you use and interact with Global Group’s Services. In addition, we use such information to customize, measure, and improve Global Group’s Services and the content and layout of our applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services;

3.6 To enhance your experience

We process your personal information to provide a personalized experience and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services;

3.7 Facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.

3.8 Maintain legal and regulatory compliance

Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Global Group must identify and verify customers using our Services in order to comply with commercial lending laws across jurisdictions.

3.9 Enforce our terms in our user agreement and other agreements

Global Group handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services;

3.10 Detect and prevent fraud

We process your personal information to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or information loss;

3.11. Ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services;

3.12 Ensure network and information security

We process your personal information to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services;

3.13 Data Anonymization and Data Aggregation

We may use data we have anonymized and aggregated for any business purpose. Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine so that it no longer identifies or references an individual customer).

Global Group may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.

Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators. Moreover, should you request that your information be deleted in accordance with the policies set forth more fully below, some of your information may be anonymized or aggregated, which complies with applicable law regarding deletion of personal information.

3.14 Direct Mail Marketing and Lead Generation

For users of our direct mail marketing and lead generation services, we process your personal information to:

Create, design, and distribute direct mail postcards and other marketing materials

Target specific geographic areas and demographic segments for campaign delivery

Generate and qualify leads for your business through QR code scanning and text message responses

Track campaign performance, response rates, and conversion metrics

Facilitate communications between businesses and potential customers

Analyze audience demographics and engagement to optimize future campaigns

Provide affiliate marketing services connecting businesses with service providers

Provide social media marketing services, including paid and organic advertising on platforms such as Google, Instagram, Facebook, and TikTok

3.15 Social Media Marketing Trial Period

When you sign up for our social media marketing services, you may be eligible for a 30-day trial period. During this trial period, we collect and process your information to create and manage advertising campaigns on platforms such as Google, Instagram, Facebook, and TikTok. The specific platforms used, and other details of your service will be determined during your onboarding process. Information collected during the trial period is subject to the same privacy protections and practices outlined in this Privacy Policy, regardless of whether you continue with the service beyond the trial period. If you choose not to continue after the trial period, you may request deletion of your information in accordance with Section 5 of this Privacy Policy.

4. Sharing your information with third parties

4.1. Disclosure by law

Global Group may disclose information you provide if required to do so by law, at the request of a third party pursuant to a court order, or if we, in our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law) and (2) protect or defend Global Group´s, or a third party´s, rights or property.

4.2. Financing providers

As part of applying for business financing, you agree that Global Group will share your information with lenders, business financing providers, banks, and brokers ("Financing Providers") within our marketplace, including 7 Figures Funding. 7 Figures Funding is a key intermediary partner that may receive your information and connect you with direct lenders, credit card issuers, and other financial product providers. 7 Figures Funding maintains its own privacy policy at https://www.7figuresfunding.com/privacy-policy, which governs how they handle your information once received.

When you apply for financing through the Services, the following categories of information may be shared with 7 Figures Funding: (1) Personal identification information (such as your name, date of birth, address, phone number, email, and government-issued identification numbers); (2) Business information (including business name, address, Employer Identification Number, ownership structure, and business formation documents); (3) Financial information (such as bank account details, tax returns, profit and loss statements, and income statements); (4) Credit information (including credit reports and credit scores); and (5) Transaction history (such as records of previous financing applications and funding activity).

4.3 Marketing Partners

For users of our direct mail marketing and lead generation services, we may share your information with printing services, mail delivery providers, text messaging platforms, social media platforms (such as Google, Instagram, Facebook, and TikTok), marketing analytics providers, and other marketing technology partners ("Marketing Partners") to create and distribute direct mail campaigns, manage social media advertising, facilitate communications between businesses and potential customers, measure campaign performance, and generate leads for your business. The information shared may include mailing addresses, demographic data, campaign metrics, and response data.

4.4. Sharing to Trusted Third Parties by Us

Global Group shares your information with various third parties who may offer products or services which Global Group believes may be of interest to you. Your information will only be shared with that party after you have elected to pursue their services (such as by clicking a link to their website). The third parties may offer services ranging from tax preparation, consumer loans, credit repair, or other ancillary services. We are not responsible for the material of the third parties or their actions. In addition, from time to time, we may share personal contact information (such as e-mail or mailing address) about our user base with carefully selected third parties, so they can offer goods and services that we believe may be of interest to our users.

4.5 Service Providers and Subcontractors

Global Group shares your information with subcontractors and service providers who assist in providing services to you. Our contracts require these service providers to only use your information in connection with the services they perform for us and prohibit them from selling your information to anyone else. We may share personal information with the following categories of service providers:

- Technology and Infrastructure Providers (e.g., cloud hosting providers, data storage, IT support, cybersecurity vendors).

- Communication and Marketing Providers (e.g., email delivery services, SMS/text platforms, marketing automation, survey tools).

- Analytics and Data Processing Providers (e.g., web analytics, business intelligence, AI/ML vendors, fraud detection, performance monitoring).

- Customer Support and Engagement Providers (e.g., help desk software, chatbots, call centers, customer feedback platforms).

- Payment and Transaction Processors (e.g., payment gateways, ACH processors, financial institutions).

- Professional Service Providers (e.g., legal counsel, auditors, consultants, compliance advisors).

- Document and Records Management Providers (e.g., e-signature platforms, document storage, records retention services).

- Other service providers as necessary to offer our Services to you.

All service providers are contractually obligated to protect your information, use it only for the purposes specified in our agreement, and are subject to security reviews and audits as appropriate.

4.6 As part of a Merger, Acquisition, or Fundraising Event

Global Group may share your personal information with companies or other entities that we plan to merge with or be acquired by, or who may provide us with funding. You will receive prior notice of any change in applicable policies.

4.7 Third party advertising platforms and providers

We may share certain personal information with, or make certain personal information available to, third party advertising platforms and providers. This occurs when you view our advertisements on third-party websites or interact with those advertisements. Doing so may place a third-party cookie on your computer. Generally, these companies do not collect information that can personally identify you, but, when combined with other information they may have in their database, such information may become personal information. We share aggregate website usage information with third party advertisers and related third party providers for the purpose of effectively targeting our online advertisements. These third-party advertising networks also track visitors’ online usage and behavior patterns. These companies may use information about your visits to Global Group and other websites to provide advertisements on this site and across other sites about products and services that may be of interest to you. The result of these efforts is the creation by the third party advertising company of an online profile and segments that attempt to predict individual user interests, preferences and purchasing habits. The third-party advertising networks then use the profile and segments to customize the advertising content served to users when visiting other websites.

4.8 Professionals

We may share personal information with our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.

4.9 Miscellaneous

We may share your personal information for any purpose with which you consent.

5. Updating, accessing, retaining, and deleting your information

You may choose to update, access, or delete your data; however, we may be legally required to retain your information to comply with the law.

You may update or access your contact information at any time by logging into your account and making any change or update. Any changes made will be updated immediately.

If you want to stop using your account, you may deactivate it. When you deactivate an account, your information will not be sent to any Funding Providers, but the information will not be deleted. By deactivating your account, you will have the ability to restore the account in its entirety.

You may delete your account from Global Group in certain circumstances upon submitting a request to Global Group to delete your account. In certain circumstances, Global Group is legally required to continue to maintain the information in your account. In these circumstances, Global Group will place your account into a deactivated status, will opt you out of all communications, and will disable your access to the account.

In the event that Global Group is able to comply with your request to delete your account, data you provide to Global Group will be retained by Global Group in a commercially reasonable manner and to comply with relevant lending laws. Once your account is deleted, Global Group will not share your information and will only use your data for internal research and Global Group marketing. Data that is retained by Global Group will be retained for a commercially reasonable period of time as determined by Global Group in conformance with applicable law.

We store your personal information securely throughout the life of your Global Group Account. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

Personal information collected to comply with our legal obligations under financial, consumer protection, and commercial credit laws may be retained after account closure for as long as required under such laws.

Contact information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.

Content that you post on our Site such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).

Recording of our telephone calls with you may be kept for a period of up to six years.

Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

Opting out of receiving electronic communications from us. If you no longer wish to receive promotional email communications from us, please follow the instructions provided in Section 7 below.

Your California privacy rights. In addition to the above, if you are a California resident, please review our California Privacy Notice to learn more about the personal information we collect, use and disclose, as well as your privacy rights related to your personal information under the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA), as well as other state laws.

Dispute Resolution: Any disputes regarding your privacy rights or our data practices are subject to the arbitration provisions set forth in Section 12 of our Terms of Service. Please review those provisions carefully, as they affect your legal rights regarding how disputes may be resolved.

6. Security

We employ commercially reasonable security measures to protect the loss, misuse and alteration of the information stored in our database. These measures include the use of industry standard encryption and access control protocols, as well as administrative access to site data, and other proprietary security measures which are applied to all repositories and transfers of user information. We will exercise reasonable care in providing secure transmission of information between your computer and our servers, but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or warrant the security of any information transmitted to us over the Internet and hence accept no liability for any unintentional disclosure. Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, Global Group cannot ensure or warrant the absolute security of any data or content you transmit to us.

In the event of a suspected breach of the security of your personally information, we will, to the extent required by law, notify you so you can take appropriate protective steps and to inform you of the steps Global Group is taking with respect to any such suspected breach.

We also encourage you to not share your account login and/or password with any other individual. Your account login and/or password is sensitive, and your sharing of your account information may lead to additional exposure to your account.

7. Choice / Opt out of Marketing

You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instruction included in these emails, or you can contact us at [email protected].

You can choose not to provide us with certain information, but this will likely result in the inability to use certain features of the site and to obtain the services and products you are seeking. As a general matter, do not post personal information on public forums. You are solely responsible for the posting of any personal information on public forums.

If, after signing up for our services, you decide you no longer wish to receive our services or future contact from lenders, brokers, or other third parties to which your information has been referred, you may cancel your account as discussed herein. Upon canceling your account, your information will no longer be sent to lenders, brokers, or other third parties. This does not guarantee that these lenders, brokers, or other third parties will cease contacting you or using your information. Please be sure to reach out to all lenders, brokers, and/or other third parties to ensure they cease contacting you.

Certain federal and state regulations require that we maintain a record of your information for certain periods of time. Due to these regulations, we may be unable to completely delete your information from our database until the time requirements of these regulations have expired.

8. California Privacy Notice

In addition to the rights provided for above, the information contained in this section applies solely to those individuals who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (together, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy.

Effective January 1, 2020, pursuant to the CCPA, California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

8.1 Personal information we collect

Global Group may collect, or has collected, the following categories of personal information from California residents within the last twelve (12) months:

CATEGORY EXAMPLES

Identifiers

First and last name; email address; phone number; home address; social security number, driver’s license, passport, or other government issued identity document; password and account credentials; Employer Identification Number (or comparable number issued by a government); and other contact and personal identification information

Personal information categories listed in the California Civ Code § 1798.80(e)

First and last name; phone number; home address; signature; social security number, driver’s license, passport, or other government issued identity document; payment card information; bank account information

Internet or other electronic activity information

Cookie identifiers; pixel tags; embedded scripts; tags; IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Websites and Apps you are visiting; geolocation data, browsing history, time spent on the Platform, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Platform including individual Websites and Apps

Characteristics of protected classifications under California or federal law

Date of birth; demographic information (e.g., nationality, gender)

Commercial information

Payment histories; account balances and activity; products and services that you have purchased, obtained, or considered; utility bills; profit and loss statements; income statements; credit score and other credit report information; information about transactions you make on the Services; and/or other purchasing or consumer histories, tendencies, and preferences

Geolocation data

Global Positioning System (“GPS”) data based on your IP address

Audio, electronic, or visual information

Photographs; recordings of calls to or from our customer service centers

Professional or employment-related information

Office location, job title, and/or description of role

Inferences about you

Inferences based on information about an individual to create a profile about a consumer reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.

Sensitive personal information.

Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law, including:

Social security, driver’s license, state identification card, and/or passport number

Account log-in combined with any required security or access codes, passwords, or other credentials allowing access to an account

Precise geolocation

The specific types of personal information we collect are further detailed in Section 1 of this Privacy Policy. Personal information does not include information excluded from the CCPA’s scope.

Global Group will not retain any information we collect form you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

8.2 Uses of personal information

Global Group may collect, use, or disclose personal information about California residents for purposes listed in Section 3 of this Privacy Policy.

The sensitive personal information that we collect as described in Section 10.1 above may be used for any of these purposes.

8.3 Sources of personal information

Global Group may collect personal information about California residents from the categories of sources listed in Sections 1.3 and 2 of this Privacy Policy.

8.4 Disclosure of personal information

We may disclose your personal information to the categories of service providers and third parties identified in Section 4 of this Privacy Policy, and in ways that are described in that section. This includes disclosures related to both our business financing services and our direct mail marketing and lead generation services.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each categories of personal information listed in Section 8(a), including the listed sensitive personal information, for a business purpose.

In addition, Global Group “sells”/”shares” certain personal information, as those terms are defined by the CCPA, for purposes of cross-contextual behavioral advertising, as that term is defined by the CCPA. Specifically, as with many online companies, Global Group partners with third parties advertising platforms and similar providers to manage our marketing of Global Group on other platforms, where such advertising is based on your past visits to our Sites and Services. These third-party partners may use technologies, such as cookies and pixels, to gather information about your activities on the Sites and Services to deliver such advertising to you when you visit their platforms. Please also review our disclosures in Sections 1.2, 2, and 5 of our Privacy Policy for more information about this activity.

The CCPA requires us to identify the categories of personal information that we have “sold”/“shared” under the CCPA in the preceding twelve (12) months. In the last twelve (12) months, we have “sold”/”shared” the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:

Identifiers

Internet or other electronic network activity information

Personal information categories listed in the California Civ Code § 1798.80(e)

Internet or other electronic activity information

8.5 Your California privacy rights

The CCPA provides California residents with specific privacy rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

If you are a California resident, you have the right to make the following requests under applicable California law in relation to your personal information, subject to certain exceptions:

Right to Know. You have the right, up to twice in a 12-month period, to request what personal information we have collected, used, disclosed, and/or sold about you during the 12-month period preceding your request, and to whom, as applicable. When you make a Right to Know request, you may request either a report disclosing the general categories of personal information we collect, or a report disclosing the specific pieces of personal information we collect about you. The information provided will include the categories of sources from which the information was collected, the business or commercial purpose for collecting, selling, or sharing the information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you, as required by law. We will respond to your verified request within forty-five (45) days of receipt as required by the CCPA, although we may extend the response period by an additional forty-five (45) days when reasonably necessary with appropriate notice.

Right to Delete. You have the right to request, under certain circumstances, the deletion of your personal information that we collect. We will respond to your deletion request within forty-five (45) days.

Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the “sale”/“sharing” of your personal information, as those terms are defined under California law.

Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.

Right to Correct. You have the right to request the correction of your inaccurate personal information.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

How to submit a request

You can exercise your rights by contacting us at [email protected] so that we may consider your request.

Any request you submit to us is subject to an identification and residency verification process as required by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information. To verify your identity, you must provide us with your first name, last name, and email address. Depending on the nature of your request and the sensitivity of the information requested, we may require additional information or documentation, such as a government-issued identification or proof of address, to match against our records. We will use this information solely for the purpose of verification and to fulfill your request, and we will notify you if we are unable to verify your identity with the information provided.

Requests by authorized agents. If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent’s request if they submit proof that they are authorized to be able to act on your behalf or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity

Household data. We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 18, as we do not collect personal information from any person under the age of 18.

Responses. We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. Global Group reserves the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

These rights are subject to various exclusions and exceptions under California law and other applicable laws. In addition, if we are unable to verify your identity to a degree of certainty as required by the CCPA through any reasonable method, we will state that we are unable to verify in a written response to you along with a reason as to why there is no reasonable method by which we can verify your identity.

Direct marketing by third parties. Global Group does not disclose personal information to third parties for their own direct marketing purposes. However, California residents additionally have the right to request information regarding such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please email [email protected].

We will continue to update our business practices as direct regulatory guidance becomes available.

8.6 Notice of Right to Opt-Out

As detailed in Section 10.4 above, Global Group “sells”/“shares” personal information with third parties for purposes of cross-context behavioral advertising, as those terms are defined by the CCPA.

If you wish to opt-out of the “sale”/“sharing” of the limited personal information that is gathered when you visit our Sites and Services for purposes of cross-context behavioral advertising, please contact us at [email protected].

9. Other State Privacy Laws

In addition to California, several other states have enacted comprehensive privacy laws that may provide additional rights to residents of those states. This section provides information about those rights.

9.1 Virginia Consumer Data Protection Act (VCDPA)

Effective January 1, 2023, Virginia residents have the following rights under the VCDPA:

- Right to confirm whether we are processing your personal data

- Right to access your personal data

- Right to correct inaccuracies in your personal data

- Right to delete personal data

- Right to obtain a copy of your personal data in a portable format

- Right to opt out of targeted advertising, sale of personal data, and profiling for certain decisions

- Right to non-discrimination for exercising these rights

9.2 Colorado Privacy Act (CPA)

Effective July 1, 2023, Colorado residents have the following rights under the CPA:

- Right to opt out of targeted advertising, sale of personal data, and profiling

- Right to access your personal data

- Right to correct inaccuracies in your personal data

- Right to delete personal data

- Right to data portability

- Right to appeal a business's denial to take action

9.3 Connecticut Data Privacy Act (CTDPA)

Effective July 1, 2023, Connecticut residents have the following rights under the CTDPA:

- Right to access your personal data

- Right to correct inaccuracies in your personal data

- Right to delete personal data

- Right to obtain a copy of your personal data in a portable format

- Right to opt out of targeted advertising, sale of personal data, and profiling

- Right to non-discrimination for exercising these rights

9.4 Utah Consumer Privacy Act (UCPA)

Effective December 31, 2023, Utah residents have the following rights under the UCPA:

- Right to access your personal data

- Right to delete personal data provided by the consumer

- Right to data portability

- Right to opt out of targeted advertising and the sale of personal data

9.5 Vermont Privacy Protections

Vermont residents have additional protections under Vermont law. These include:

- Limitations on the sharing of personal information with third parties

- Restrictions on sharing non-transactional information without explicit authorization

- Right to opt out of certain information sharing practices

- Enhanced protections for financial information

Note that Vermont law places additional limits on sharing information about Vermont residents as long as they remain residents of Vermont. We will not share information about Vermont residents to companies outside of Global Group except:

- As permitted by law

- To companies that perform services on our behalf

- Name, contact, and transaction information to financial institutions with which we have joint marketing agreements

- With the authorization or consent of the Vermont resident

9.6 How to Exercise Your Rights Under State Privacy Laws

To exercise any of these rights, please contact us at [email protected]. We will respond to your verified request within 45 days, with a possible extension of an additional 45 days when reasonably necessary. We will notify you of any such extension within the initial 45-day period.

9.7 Excluded States

Global Group does not offer its Services to businesses located in or operating from Nevada, North Dakota, North Carolina, and Vermont. If you are located in or operating from any of these states, you are not eligible to use our Services. The privacy rights described in this Privacy Policy do not apply to residents of these states as they are not eligible to use our Service.

10. Notification of Privacy Policy Changes

We reserve the right to update this Privacy Policy and will notify you if we do so; however, we encourage you to regularly review this policy for the latest information.

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Site. We encourage you to periodically review this page for the latest information on our privacy policy. When we make changes to this Privacy Policy we will revise the revision date at the top of the Privacy Policy.

11. Protecting Children’s Privacy

These Sites are general audience websites, and we do not knowingly collect personal, or other, information from children under the age of 18. If you are under the age of 18, please do not use our site. If we suspect that information provided to us is, in fact, personal information of an individual younger than 18 years of age, such information will be deleted, aggregated, or anonymized as soon as possible. Please notify us if you know of any individuals under the age of 18 using our services so we can take action to prevent access to our services.

12. Cookie Management and Online Tracking

12.1 Cookie Management

We use cookies and similar technologies to enhance your experience on our Sites. You can manage your cookie preferences in the following ways:

Browser Settings: Most web browsers allow you to control cookies through their settings. You can typically find these settings in the "options" or "preferences" menu of your browser.

Cookie Preference Center: We provide a Cookie Preference Center on our website that allows you to select which categories of cookies you accept or reject. You can access this tool by clicking on "Cookie Settings" in the footer of our website.

Opt-Out Links: We provide direct opt-out links for certain third-party cookies in our Cookie Preference Center.

12.2 Do Not Track Signals

Some browsers have a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Due to the lack of a common understanding of how to interpret Do Not Track signals, our Sites do not currently respond to Do Not Track signals. However, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving targeted advertising as described in this Privacy Policy.

12.3 Mobile Device Privacy

If you access our Services through a mobile device, you may be able to control tracking technologies through settings on your device. Please note that opting out of tracking on your mobile device by using these settings will not opt you out of tracking on other devices you use.

12.4 QR Codes and Response Tracking

Our direct mail marketing services may include QR codes and other response tracking mechanisms that collect information when scanned or activated. When you scan a QR code on our direct mail materials, information about the scan may be collected, including the time, location, and device used. This information is used to measure campaign effectiveness and facilitate communications between businesses and potential customers. By scanning a QR code, you consent to the collection and use of this information as described in this Privacy Policy.

13. Contact Information

If you have any questions about this Privacy Policy or wish to exercise one of your privacy rights, please contact us using the following information:

Global Group US, LLC

14706 Coconut Creek Parkway #934772

Margate, FL 33093-4772

Email: [email protected]