PRIVACY NOTICE

This Privacy Notice for Shift 4 Financial INC (doing business as Shift 4 Funding) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at http://www.shift4funding.com, or any website of ours that links to this Privacy Notice
• Apply for commercial financing, working capital loans, or equipment financing through our services
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@shift4funding.com.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. DO WE COLLECT INFORMATION FROM MINORS?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. GRAMM-LEACH-BLILEY ACT (GLBA) PRIVACY NOTICE
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal and business information that you provide to us in connection with commercial financing applications and services.

We collect personal information that you voluntarily provide to us when you apply for financing, express an interest in obtaining information about us or our commercial financing solutions, when you participate in activities on our website, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the financing products and features you are interested in. The personal information we collect may include the following:

• Business owner names and personal information
• Business name, address, and contact information
• Phone numbers
• Email addresses
• Mailing addresses
• Job titles
• Contact preferences
• Tax identification numbers
• Business bank statements
• Business financial statements
• Information about business operations and revenue

Sensitive Information

When necessary to provide our financing services, with your consent, or as otherwise permitted by applicable law including the Gramm-Leach-Bliley Act (GLBA), we process the following categories of sensitive information:

• Financial data and statements
• Credit history and credit worthiness data
• Social security numbers or other government identifiers
• Bank account information
• Tax returns and related financial documentation

All personal and business information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such information.

Information collected from other sources

In Short: We may collect data from credit bureaus, public databases, marketing partners, and other outside sources to facilitate our financing services.

In order to enhance our ability to provide relevant financing solutions, evaluate creditworthiness, verify business information, and update our records, we may obtain information about you and your business from other sources, such as:

• Credit bureaus and reporting agencies
• Public databases and government records
• Business information services
• Joint marketing partners
• Data providers

This information may include credit history, public records, business registration information, mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, and custom profiles for purposes of evaluating financing applications and targeted marketing.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide commercial financing solutions, evaluate applications, communicate with you, comply with applicable laws and regulations, and prevent fraud.

We process your personal and business information for a variety of reasons, depending on how you interact with our Services, including:

• To evaluate financing applications. We process your information to assess creditworthiness, verify business information, and determine eligibility for our commercial financing solutions.
• To deliver and facilitate delivery of services to you. We may process your information to provide you with the requested financing services and related support.
• To respond to inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with our financing services.
• To send administrative information to you. We may process your information to send you details about our financing products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, including those under the Gramm-Leach-Bliley Act (GLBA), respond to legal requests, and exercise, establish, or defend our legal rights.
• To prevent fraud and assess risk. We may process your information to detect and prevent fraudulent applications, assess risk factors, and protect our business operations.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information with lending partners, service providers, and regulatory agencies as required to facilitate financing services.

Lending Partners and Financial Institutions. We may share your data with lending partners and financial institutions to facilitate financing solutions and present you with appropriate commercial financing options.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with are as follows:

• Lending partners and financial institutions
• Credit bureaus and reporting agencies
• Underwriting and risk assessment services
• Finance & Accounting Tools
• Sales & Marketing Tools
• Customer Relationship Management systems

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice and to comply with applicable laws and regulations.

We will only keep your personal and business information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). For financing applications and transactions, this typically includes retention periods required by federal and state lending regulations, which may be up to seven years after the conclusion of our business relationship.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We maintain physical, electronic, and procedural safeguards that comply with federal standards to protect your personal and business information.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• Encryption of sensitive data both in transit and at rest
• Access controls and authentication procedures
• Regular security assessments and audits
• Employee training on data protection and privacy
• Physical security measures for our facilities

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to individuals under 18 years of age.

We do not knowingly collect, solicit data from, or market to individuals under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from individuals under age 18, please contact us at info@shift4funding.com

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you have rights to manage your personal information, including opting out of marketing communications, including SMS.

Managing Your Information and Choices

Depending on the applicable data protection laws in your country, province, or state of residence, you may have the following rights:

• Withdrawing your consent: If we rely on your consent to process your personal information, you have the right to withdraw it at any time. You can do this by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. Please note that this won't affect the lawfulness of the processing before withdrawal, nor processing based on other lawful grounds.
• Opting out of marketing and promotional communications: You can unsubscribe from our marketing emails at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and provision of our financing services, to respond to respond to service requests, or for other non-marketing purposes.
• SMS Messaging:
  • We will not share your mobile information with third parties or affiliates for marketing or promotional purposes without your explicit consent.
  • Information sharing with subcontractors in support services, such as customer service related to your financing, is permitted.
  • These provisions exclude text messaging originator opt-in data and consent; this information will not be shared with any other third parties.
• Other Rights: You may also have rights to review, change, or request deletion of your personal information. To exercise these rights, please contact us as detailed in the "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" section. These rights may be limited by applicable law.

If you have questions or comments about your privacy rights, please email us at Info@shift4funding.com.

8. GRAMM-LEACH-BLILEY ACT (GLBA) PRIVACY NOTICE

In Short: As a financial services provider, we comply with the Gramm-Leach-Bliley Act (GLBA) regarding the collection, use, and protection of your nonpublic personal information.

The GLBA requires us to explain to you how we collect, share, and protect your personal information. This section serves as our notice in compliance with the GLBA.

Information We Collect

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms, such as your name, address, social security number, assets, and income
• Information about your transactions with us, our affiliates, or others, such as your account balance, payment history, and credit card usage
• Information we receive from credit reporting agencies, such as your credit history and creditworthiness
• Information we receive from others involved in your financial services, such as lenders or tax preparers

Information We Disclose

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. We may disclose all of the information we collect, as described above, to companies that perform marketing or other services on our behalf or to other financial institutions with whom we have joint marketing agreements. We may also disclose information about you to our affiliates to provide you with information about their products and services.

Your Right to Opt Out

If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may contact us using the information provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below.

Security Procedures

We restrict access to nonpublic personal information about you to those 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.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have certain rights regarding your personal information.

State-Specific Privacy Rights

Depending on your state of residence, you may have rights to:

• Request access to and details about the personal information we maintain about you
• Request correction of inaccurate personal information
• Request a copy of your personal information
• Request deletion of your personal information
• Withdraw consent to our processing of your personal information
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

We have collected the following categories of personal information in the past twelve (12) months:

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and regulations.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at: info@shift4funding.com, by phone at 213.207.6602

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on applicable laws and regulations, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at info@shift4funding.com.

Please note that we may not be able to delete certain information that is necessary for us to:

• Complete the transaction for which the personal information was collected
• Provide a product or service requested by you
• Perform a contract between us and you
• Detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity
• Comply with a legal obligation, such as retaining records required by law
• Make other lawful uses of that information that are compatible with the context in which you provided it