Privacy Policy
Last Updated: July 8, 2024

Sellona, Inc., and its subsidiaries and affiliates (collectively, “Sellona,” “we,” “our,” or “us”) are committed to maintaining your confidence and trust as it relates to the privacy and security of your personal information. This Privacy Policy describes how we use, disclose, and protect the personal information collected:
• through our website, www.Sellona.com, and any other websites or mobile apps where this Privacy Policy is posted or linked (collectively, the “Digital Properties”) and any services available through the Digital Properties;
• in connection with the delivery of our products and services to our customers;
• in connection with our business development and marketing activities; and
• through our other offline and business interactions.

Collectively, we refer to our online and offline interactions with you as the “Services.” In this Privacy Policy, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. Please carefully review this Privacy Policy to learn more about our information handling and privacy practices. If you are a California resident, INSERT for more information about our privacy practices and your rights.

PERSONAL INFORMATION WE COLLECT
Depending on your use of the Services and how you otherwise interact with us, we may collect or obtain information from and about you in several ways, including: (1) directly from you; (2) automatically when you visit and interact with the Digital Properties; and (3) from third parties. Additional details regarding our collection of your personal information are included below.

Information provided by you
When you visit and interact with the Digital Properties or otherwise engage with us, we collect personal information that you share with us. For example, we may collect personal information when you contact us (via phone, web, email, etc.), request that we send you promotional communications or other materials, or otherwise communicate with us.
Depending on the context of your interactions with us and the Services, the categories of personal information that we may collect directly from you include:
• Contact information, including your name, street address, telephone number, and email address.
• Identifying information, including your Sellona account name, Social Security number, Driver’s License, date of birth, and other similar identifiers.
• Correspondence and communications, including recordings of our email and phone conversations with you and any correspondence related to providing you with the Services.
• Preferences, including how frequently you wish to receive marketing and promotional communications from us.
• Other information you choose to provide, including information you include in any webforms that you complete and submit on the Digital Properties and other information that you provide during your interactions with us.
Where applicable, we may indicate whether and why you must provide us with your personal information as well as the consequences of failing to do so. For example, it may be necessary for you to disclose certain personal information in order for us to provide the Services to you.
You may voluntarily provide certain information to us when you interact with an automated assistance chatbot on the Digital Properties, which our service provider enables on our behalf. Note that your conversations with any chatbot present on the Digital Properties may be monitored and recorded and any personal information you provide will be handled by us and our service provider in accordance with this Privacy Policy.
Some personal information that we receive from you may relate to other individuals. You are responsible for obtaining all necessary permissions to provide personal information relating to other individuals to us.
Information collected through automated means
When you visit and interact with the Digital Properties, we (and our service providers, advertisers and partners) may use cookies, pixels, web beacons, software development kits (SDKs), and other similar tracking technologies to collect certain information automatically.
The specific types of information we (and our service providers and partners) may collect include:
● Device information, which includes the Internet Protocol (IP) address and/or other unique identifier(s) assigned to your device; the location of your device; and other information about your browser, device, and operating system.
● Usage information, which includes information about your interaction(s) with the Digital Properties (e.g., the date and time of your visit(s); the area(s) or page(s) that you visit; the amount of time you spend on a page or use the Digital Properties; the domain name from which you accessed the Digital Properties; and other click-stream or usage information).
We (and our service providers and partners) may use cookies or other similar technologies to collect information about your behavior on the Digital Properties (e.g., how you move and scroll through the Digital Properties, your keystrokes, how you interact with webforms, etc.) and the actions that you take upon receipt of an email from us.

Analytics
We use third-party analytics and tracking tools to better understand who is using the Digital Properties, how the Digital Properties are used, and how to improve the effectiveness of the Digital Properties and related content. We may also use the information collected to draw inferences. For example, we use Google Analytics (or similar) to better understand how users interact with the Digital Properties. For information on Google Analytics’ information-handling practices and how you can control the use of information sent to Google, visit https://policies.google.com/technologies/partner-sites. If you wish to prevent your information from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.

Interest-based advertising
We use third-party tools and services to serve interest-based advertisements to you across the internet. These tools may include cookies, pixels, web beacons, and/or other similar tracking technologies that automatically collect, store, and/or transmit certain information about your interaction(s) with the Digital Properties and other websites and mobile apps that you interact with and use across your devices. Our third-party service providers and partners use the collected information to serve advertisements to you and measure the performance of our advertising campaigns. To learn more about your interest-based advertising choices, see the “Your Choices” section below.
You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Refer to your device’s settings or your browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or adjust your tracking preferences. Additional information about cookies, including how to manage them, can be found here: https://allaboutcookies.org/.
Site recording technology
We use third-party site-visit recording technologies to memorialize visits to our Digital Properties. Scripts from these technologies are embedded on our Digital Properties and collect information when you interact with pages where the scripts are present. These technologies collect information such as page URL, mouse movements and clicks, information you input, snapshots of pages you visit, time spent on a page, date and time of various interactions with a page, and HTTP headers from your browser. By visiting our Digital Properties or using our Services, you acknowledge and agree to our use of such site recording technologies and the collection, maintenance, and use of information these technologies collect.

ChatBot Technology
We may use chatbots on certain Digital Properties to help provide customer service and support, including through the use of a virtual assistant. A chatbot is a software application that mimics human conversations in text or voice interactions on our website. It enables the communication between a human and a machine, which can take the form of messages or voice commands. The chatbot is designed to work without the assistance of a human operator. It responds to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts, machine learning, and generative artificial intelligence (“AI”). When asked a question, the chatbot will answer using the knowledge database that is currently available to it. If the conversation introduces a concept the chatbot is not programmed to understand, it will advise of its limitations. The chatbot functionality is limited to Sellona customer service and support inquiries and may not be monitored in real time. If you use our chatbot service, we will collect and maintain any information you provide to us when using the chatbot. You are responsible for the information you share with the chatbot, and we strongly advise you not to input sensitive or personal information, such as financial or account details or other confidential information. We will also create and store a transcript of your chat interaction with us, which will be stored by our third-party service provider. We may use these transcripts and the information you provide for quality control, customer service, fraud prevention, and security.

Information collected from other sources
We may obtain your personal information from other sources, including, for example, credit bureaus, our service providers, our advertisers, our users, our customers, lead generators, social media platforms, Network Partners (as defined below), and other partners.
The information that we receive from other sources may include contact information, demographic information, consumer credit reports, credit scores, credit history, and other consumer reports/credit information, financial information (e.g., information about an account and the terms, amount, usage, or disposition of a loan or other financial product received from a Network Partner), and internet or other electronic network activity information.
We use the personal information that we receive from other sources to help us maintain the accuracy of or supplement the information we collect; personalize your experience with the Services; conduct internal business analysis; and fulfill other business or commercial purposes described in this Privacy Policy.

Combination of information
We may combine personal information that we receive from and about you, including information you provide to us, information we automatically collect through the Digital Properties, and information we receive from third-party sources. Where applicable, we will use, disclose, and protect the combined information for the purposes described in this Privacy Policy.

HOW WE USE PERSONAL INFORMATION
We may use personal information we collect for the following purposes:
● Providing the Services, including to operate, maintain, support, and provide the Services.
● Communicating with you, including to contact you for administrative purposes (e.g., to provide the Services and information that you request or to respond to your comments and questions) or to send you important updates and communications about this Privacy Policy and/or other applicable terms and conditions.
● Sending you marketing and promotional communications, including emails about products or services that we think may interest you. Details on how to exercise your choices with respect to marketing and promotional communications from us can be found in the “Your Choices” section below.
● Personalizing the Services, including to tailor the content we may send or display to you and otherwise personalize your experience with us.
● Engaging in interest-based advertising, including to serve you interest-based advertising on the Digital Properties or on other online services across the devices you may use. Details on how to exercise your choices with respect to interest-based advertising can be found in the “Your Choices” section below.
● Conducting research and analytics to develop and improve the Services, including to analyze usage trends and preferences in order to improve the Services and to develop new products, services, and features.
● Maintaining security and preventing fraud, including to monitor and maintain the security of our systems and networks and to detect, prevent, investigate, and protect you, our business, and others from fraud, unauthorized transactions, and other unlawful or unsafe activity.
● Satisfying our legal obligations, including complying with applicable law and responding to lawful requests and communications from law enforcement authorities and other government officials.
● Supporting our business operations and business transactions, including to administer our general business and other related functions and to carry out sales or other business transactions.
We may also use your personal information as described to you at the point of information collection or with your consent. Additionally, we may use your personal information as we believe necessary or appropriate to protect our rights, privacy, safety, property, and/or those of others.
HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose each category of personal information we collect from and about you with the following categories of recipients:
● Our Affiliates and Subsidiaries. We disclose your personal information to other entities within our family of brands to fulfill any purpose described in this Privacy Policy.
● Network Partners. We may disclose your personal information to Network Partners to provide you with information about financial products and services that may interest you. Note that Network Partners that interact with you may use and/or retain your personal information whether or not you use their services and their handling of your personal information is subject to their privacy policies.
● Financial Companies. We disclose your personal information to other financial companies with whom we engage in joint marketing efforts or who offer financial-related products or services that may be of interest to you.
● Our Business Partners. We disclose your personal information to other companies with whom we partner to provide the Services and carry out other activities described in this Privacy Policy.
● Our Service Providers. We disclose your personal information to third parties that provide business, professional, or technical support services to us and/or administer activities on our behalf.
● Our Analytics Providers. We disclose your personal information to parties that assist us in performing analytics and help us measure the effectiveness of the Services and our marketing and advertising efforts.
● Our Marketing and Advertising Partners. We disclose your personal information to our marketing and advertising partners, including social media networks, third-party advertising networks, and other parties that assist us in serving, measuring the performance of, and optimizing our advertisements.
● Governmental and Public Authorities. We disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a subpoena, court order, investigative demand, request for cooperation from a law enforcement agency, or similar request from a self-regulatory body or government agency.
● Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction as well as in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
● Other Parties. We may disclose your personal information to other parties as we believe necessary or appropriate either to: (1) comply with applicable law; (2) protect our operations and those of our affiliates and subsidiaries; (3) investigate and prevent against fraud and other illegal activity; (4) protect our rights, privacy, safety, property, and/or those of others; or (5) allow us to pursue available remedies or limit damages that we may sustain.
We may disclose your personal information for other reasons described at the time of information collection or prior to disclosing your information. Additionally, we may disclose your personal information with your consent or when you direct us to do so. We may de-identify, anonymize, or aggregate personal information and disclose such information to third parties for various purposes as permitted by law.

YOUR CHOICES
We respect your privacy and provide you with the ability to make certain choices about how we use your personal information, as described below.
• Financial Information: For details regarding our handling of financial information and your choices with respect to such information, review our INSERT
• Marketing and Promotional Communications: You can opt out of receiving marketing and promotional communications from us or manage your preferences at any time through your Sellona profile or by visiting https://www.Sellona.com/publications. You may be able to opt out of receiving marketing and promotional communications from us by following the instructions included in any such communication that you receive from us. Note that even if you opt out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries/requests.
• Cookies: As noted above, we (and our third-party providers and partners) use cookies on the Digital Properties for various purposes, including for analytics and interest-based advertising purposes. You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Refer to your device’s settings or your browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or adjust your tracking preferences. Additional information about cookies, including how to manage and delete them, can be found here: https://allaboutcookies.org/.
• Interest-Based Advertising: We use services provided by Persona, Google, Meta, TikTok, and other similar companies that use tracking technologies to collect from you and across your devices information about your online activities, preferences, and interactions with websites. These services are used to serve targeted advertising to you and to measure performance of our advertising campaigns. For example, these services enable us to retarget you with advertisements based on what you have viewed or engaged with on our Digital Properties while you are using platforms provided by Google, Meta, or TikTok and to measure when you have clicked through to our Digital Properties after seeing an advertisement on those or other platforms. Some websites/platforms and mobile devices allow you to exercise certain choices with respect to interest-based advertising, as described below.
o Web browsers: You may be able to opt out of receiving interest-based advertising using the browser opt-out tools and consumer choice mechanisms provided by interest-based advertising self-regulatory groups by following the links below:
▪ Digital Advertising Alliance (DAA): https://optout.aboutads.info/?c=2&lang=EN
▪ Network Advertising Alliance (NAI): https://optout.networkadvertising.org/?c=1
Note that you will need to opt out separately on all of your browsers and devices, as each opt-out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies, change browsers, or use a different device, any opt-out cookie may no longer work and you will have to opt out again.
o Mobile devices: You have the ability to control whether you see interest-based advertisements on your mobile device in the following ways:
▪ Device Settings: Your device operating system may provide mechanisms that allow you to opt in or opt out of the use of information about your usage of mobile apps to deliver interest-based advertising to your mobile device. For more information, consult your device settings.
▪ AppChoices Tool: The DAA offers a tool for opting out of the collection of cross-app information on a mobile device for interest-based advertising. To exercise your choices with respect to participating companies, you may download the AppChoices tool available here: https://youradchoices.com/appchoices.
o Other choices: The advertising partners that we have listed below may provide you with additional choices with respect to interest-based advertising, including the ability to control your advertising preferences directly through their services. We encourage you to review the privacy policies of the third-party services you use for more information regarding your choices.
▪ Google: https://adssettings.google.com
▪ Meta/Facebook: https://www.facebook.com/about/ads
▪ TikTok: https://support.tiktok.com/en/account-and-privacy
▪ Twitter: https://twitter.com/settings/account/personalization
• Access and Correct Personal Information: Depending on how you have engaged with us and the Services, as well as your state of residence, you may be able to request access to and/or correction of certain personal information that we maintain relating to you. You may also be able to access and correct certain personal information by logging in to the Digital Properties. If you have submitted a loan request through the Services and would like to request access to or correction of certain personal information, contact us using the contact details below. Note that we will only respond to or take action in response to a request to access, correct, or delete personal information to the extent required by law.
o Email: support@Sellona.com
o Mail: Compliance Officer
Sellona, Inc.
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INFORMATION SECURITY
We maintain physical, electronic, and procedural measures designed to safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee your information, searches, or other communications will always remain secure.
INFORMATION RETENTION
We will retain your personal information at least as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to satisfy our legal or reporting requirements, unless a longer retention period is required or allowed under law. We reserve the right to retain your personal information to the extent allowed by applicable law. We also reserve the right to provide access to or delete personal information only to the extent required by applicable law
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information; the potential risk from deletion, unauthorized use, or disclosure of the personal information; the purpose(s) for which we use or may use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.
If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.
THIRD-PARTY SERVICES
The Digital Properties may contain features or links to websites and services provided by third parties, including social media widgets and plugins, which are not governed by this Privacy Policy. Any personal information you provide to the owner or operator of another website or a third-party service is provided directly to the owner or operator and is subject to its privacy policy, even if accessed through the Digital Properties. We encourage you to review all third parties’ privacy policies before providing them with your personal information.
CHILDREN’S PRIVACY
The Services are not intended for or directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18.
SERVICES LIMITED TO THE UNITED STATES
Our Digital Properties are designed to provide services in the United States and are governed by the laws of the United States. All Services may not be available in all U.S. states or territories. We make no representation that our Digital Properties are governed by or operated in accordance with the laws of any other nation or foreign jurisdiction.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our information handling and privacy practices and/or changes in applicable law. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make changes, we will revise the date at the top of this page and, in the case of material changes, we will provide you with additional notice if required by applicable law. Unless otherwise stated, the current version of this Privacy Policy applies to all Digital Properties and all personal information under our control. We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices. By visiting or using our Digital Properties, you agree that any changes to this Privacy Policy shall apply to any personal information we may maintain about you, whether collected before or after such changes.
HOW TO CONTACT US
If you have any questions or comments about this Privacy Policy or our information handling and privacy practices, contact us using the following contact details:
• Email: support@Sellona.com
• Phone:
• Mail: Compliance Officer
Sellona, Inc.
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