Privacy Policy

For additional Privacy Notices, please see “State Privacy Protections” below.

We value your privacy and take safeguarding your personal information seriously. In this Privacy Policy (“Policy”), we describe the information we collect, how we use it, and when and with whom we share it. This Policy applies to Ben Miller Loans, Barrett Financial Group, L.L.C., the ARIVE platform, including any subsequent version or upgrades (the “Platform”), and all websites, mobile applications, and other online services (collectively, the “Service”) operated by Wizni, Inc. and its wholly-owned subsidiaries, including Arive, LLC (collectively, “ARIVE”, “we”, “us”, or “our”).

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This Policy covers information you provide or share with us, as well as with mortgage brokers, lenders, and other authorized users of the Platform who are involved in assisting you with your loan application or with any other mortgage-related services. This Policy describes our practices regarding the information we collect, and we encourage you to review the separate privacy policies and practices of your mortgage broker, lender, and any other parties you work with.

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By accessing or using the Service, you agree to the practices described in this Policy. IF YOU DO NOT AGREE TO THE PRACTICES DESCRIBED IN THIS POLICY, YOU MUST NOT ACCESS OR USE THE SERVICE.

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If you are a Platform user, ARIVE provides the Platform to you, mortgage lenders, brokers, third-party service providers, and non-affiliated third parties, to create a seamless and efficient mortgage lending experience. When you apply, the information we collect helps such parties to assist you in evaluating your mortgage loan options and processing your loan application. The relevant parties are responsible for treating your personal information in accordance with all applicable federal and state privacy-related laws and regulations, including, as applicable to the relevant party, the federal Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.) and related regulations. ARIVE is not a lender or broker, and all loan decisions, pre-qualifications, rate locks, deposits or refunds, evaluations of creditworthiness, and other commitments regarding a loan are made only by your lender or broker.

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State Privacy Protections

Users may be subject to different or broader protection standards, as required by state laws, such as rights to know the personal information we collect, to correct or delete certain information, or to opt out of the sale or sharing of certain personal information. Residents of California are encouraged to review the

California Privacy Notice

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INFORMATION WE COLLECT

How we collect and store information depends on how you access and use the Platform. We collect information in multiple ways including when you provide information directly to us, when you permit third parties to provide information to us, and when we passively collect information from you, such as information collected from your browser or device. Details regarding the types of information collected are provided below in this Policy or by specific prompts or explanations prior to the collection.

Information we collect may be about you or about others who may be involved in your mortgage loan process (such as a client, co-applicant, or other party who will hold title on the property to be financed). You are responsible for any information you provide to us, and by providing such information you hereby confirm that such information is either your own information or that you have the third party’s consent to provide such information.

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Unless otherwise specified, all information that we collect is mandatory for the Service you have requested, and failure to provide the information may make it impossible for us to provide the Service. In cases where information is not mandatory, you are free to not provide such information. Unless otherwise specified, use of any cookies or other tracking tools is required for the functionality of the Service.

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Information You Provide Directly to Us

We may collect information from you during your use or access of the Platform, including:

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- When you register for an Account;

- When you participate in polls or surveys;

- When you enroll for electronic newsletters;

- When you request a quote or other information;

- When you are directed by a lender or broker to use the Platform to submit a loan application;

- When you submit or respond to a quote;

- When you fill out any forms;

- When you register for other mortgage related services offered through a third-party;

- When you interact with customer service representatives by phone, email, or chat;

- When you transmit content on the Platform;

- When you download or use one of our mobile applications; or

- When you otherwise communicate with us or other parties through the Platform.

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The information you provide to us depends on how you use or access the Platform. When you request customer service, you acknowledge and agree that we may record and retain information you provide to our representatives without separate notice to you, to the extent permitted by applicable law. For example, we may keep a record of email messages you send, and may record calls or chat sessions for quality monitoring or record-keeping purposes.

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Information you provide to us may include: (a) name; (b) social security number; (c) email address; (d) home or business telephone number; (e) home, business or mailing address; (f) demographic information (e.g., gender, age, political preference, education, race or ethnic origin, and other information relevant to user surveys and/or offers); (g) date of birth; (h) insurance information; (i) photographs; (j) information about your mortgage loan, request or needs; (k) Americans with Disabilities Act compliant audio files; (l) information relating to the property securing the loan, such as the address and valuation information; (m) account password; (n) billing information, (o) information you provide through customer support communications, (p) in certain circumstances, such as when you apply for a loan on the Platform, employment history, tax returns, education, information to verify your identity, and financial information related to income, account balances, and creditworthiness; and/or (q) any other content you include in communications with other parties through the Platform or communications with us.

When you are asked to provide personal information, you can decline. If you choose not to provide the requested information, you may not be able to proceed with your mortgage loan application and certain features of the Platform may not be accessible or available to you.

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Information from Third Parties

We may collect information through non-affiliated third parties. For example, we may make it possible for you to access the Platform through your lender, a mortgage broker, or a social networking account. If you access the Platform through one of these parties, you may allow us to have access to certain information in your user profiles. This may include your name, profile picture, gender, networks, user IDs, list of friends or connections, location, date of birth, email address, photos, videos, people you follow and/or who follow you, and/or your posts or “likes.” We may use this information for Platform analytics, to assist in determining relevant advertising (both on and off the Platform), to evaluate the success of our advertising campaigns, and as otherwise described in this Policy. Such parties may have their own privacy policies for handling your information and we encourage you to review such policies separately.

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We also collect information through certain non-affiliated third parties. For example, in order to assist with your loan application, your broker or lender may request that we collect supplemental information from third parties, such as your credit history from a credit bureau, or information to verify your identity or trustworthiness, or for other fraud or safety protection purposes.

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We may also collect information about communications between you and your mortgage lender, broker, or other third-party service provider involved in the mortgage process, for our billing purposes and to enforce the

Terms of Use

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We may communicate with you, our lending partners, your broker and the broker community, other partners, and third-party service providers in a variety of different ways, including by email, voicemail, mail, text and SMS messaging, and in person. As part of this process, we may receive and store data about these communications, including the date and time of the message, your phone number, and the content of the message.

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Information That is Passively or Automatically Collected

Device/Usage Information.

We and our third-party service providers, which include lender and broker partner networks and sites, ad networks and analytics companies, use beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Platform. As described further below, we may collect and analyze information including (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Platform. We may use this information for Platform analytics (including to determine Platform use and performance), to assist in determining relevant advertising (both on and off the Platform), to evaluate the success of our advertising campaigns, and as otherwise described in this Policy.

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Location Information.

When you use the Platform, we may collect general location information from you (such as IP address). If you install our mobile app, we may ask you to grant us access to your mobile device’s geolocation data. If you grant such permission, we may collect information about your precise geolocation, and we may use that information to improve the Platform, including providing you with location-based features (e.g., for identification of professional services available near you). To deliver customized content and advertising, we may share your location information with our agents, vendors, or advertisers. If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device. If you disable certain functions, you may be unable to use certain parts of the Platform.

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Cookies and Other Electronic Technologies.

We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, provide training and customer support, and improve the Platform. These technologies, for example, may allow us to tailor the Platform to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about Platform usage. We may also record sessions or track user interaction with Platform pages using document object models or similar technology. We may also use certain of these technologies to deliver advertisements through the Platform that may interest you. We and our third-party service providers also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

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You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Platform, because it may not function properly. As we adopt additional technologies, we may also gather additional information through other methods and will update this Policy accordingly.

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You can learn more about our use of cookies and opt out of optional cookies, if any, by clicking on

Manage Cookies

at any time.

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HOW WE USE THE INFORMATION WE COLLECT

We may use, process, or share your information for some or all of the following reasons:

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- For the purposes for which you provided it;

- To process your loan application;

- To allow lenders to underwrite your loan application;

- To verify the accuracy of information provided on your loan application such as address, employer, bank account information, and credit history;

- To enable you to use the services available through the Platform, including registering you for our services and verifying your identity and authority to use our services;

- For customer support and to respond to your inquiries;

- For internal record-keeping purposes;

- To administer surveys, sweepstakes, promotions, or contests;

- To track fees and process billing and payments including sharing with third-party payment gateways and payment service providers in connection with the Platform;

- To improve and maintain the Platform and for product development;

- To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing;

- To periodically send promotional emails, in-application messages, telephone or text messages regarding Platform features, improvements, new products and special offers, or other information that may interest you;

- To contact you by telephone or text message regarding certain services or information you have requested;

- For our market research purposes, including the customization of the Platform according to your interests;

- To inform our integrated lenders regarding Platform usage, analytics of their approved brokers’ usage, and about potential brokers who may be interested in their mortgage-related products and services;

- For other research and analytical purposes;

- To detect any malicious or fraudulent activity; and

- To resolve disputes, to protect ourselves and other users of the Platform, to respond to enforcement requests, and to enforce any legal terms that govern your use of the Platform.

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We may combine information that we collect from you through the Platform with information that we obtain from third parties, and information derived from any other products or services we provide.

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We may aggregate and/or de-identify information collected through the Platform. We may use de-identified or aggregated data for any purpose, including for research and marketing purposes and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

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We may, either directly or through third-party service providers, review, scan, or analyze your communications with other users on the Platform or off the Platform (if we track these communications) for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes, as well as to debug, improve and expand product offerings.

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TO WHOM WE DISCLOSE YOUR INFORMATION

Sale of Personal Information.

We do not sell your personal information for money and do not act as a data broker. However, we may share or disclose some personal information as described below, which in some cases may be deemed “selling” under various state laws, even if we receive no money. For additional state-specific privacy information, see the links to specific state Privacy Notices under “State Privacy Protections” near the beginning of this Policy.

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Sharing or Disclosure of Personal Information.

In order to carry out the business or commercial purposes for our use or processing of personal information described above, we may disclose your personal information to: (i) our directly-affiliated companies, (ii) third-party suppliers or professional service providers, and (iii) federal and state governmental authorities or agencies as required.

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Third-party suppliers or professional service providers to whom we disclose information may include: (i) data providers, credit reporting agencies, title insurance companies, customer relationship management providers, consumer insight providers; (ii) lead aggregators, marketing providers, advertising and brand providers, publishers, social media and online sources; (iii) sales agents, brokers, lenders; (iv) background check companies, recruitment agencies, insurance and benefits providers, employees, contractors, job applicants; (v) technology providers, communications companies, document management vendors; (vi) cloud storage providers, payment processors, web analytics, hosting, email distribution, help desk and similar providers; (vii) service providers who assist us in providing our Service and fulfilling our obligations to you and other parties (such as real estate appraisers, auditors, law firms or trustees); and (viii) other similar third parties.

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SOCIAL MEDIA AND THIRD-PARTY WEBSITE PRIVACY CONSIDERATIONS

From time to time, we may provide the ability to connect to our Platform through social media or through other parties’ websites or your login credentials with such parties. Your activity on third-party websites or applications is governed by their respective security and privacy policies. We encourage you to review their policies before using their websites or applications to learn how they may collect, use, and share your information.

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If you connect to the Platform via a social media or third-party website, some of your information may be visible to others. For example, when you create an account with us, you must provide us with your name. If you create an account with us through a social media platform, the Platform may use the name associated with your social media account. In that case, your name and certain linked content and activity may be visible to other users with whom you have interacted.

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ONLINE ANALYTICS AND TAILORED ADVERTISING

Analytics

We may use third-party web analytics services on the Platform, such as Google Analytics or similar services. These service providers use the types of technology described in the Information That Is Passively or Automatically Collected section above to help us analyze how you use the Platform, including by noting the third-party website from which you arrive. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on. We do not now, but however reserve the right to use Google Analytics or similar services for certain purposes related to advertising, as described in the following section.

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Tailored Loan Product Advertising

Third parties whose products or services are accessible or marketed via the Platform may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Platform in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to the Platform. From time to time we may allow ad networks and ad providers to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Platform. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Platform by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.

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It is also possible that when using a mobile application, you may also receive tailored in-application advertising content. Each operating system (e.g., iOS for Apple devices, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to opt-out of the delivery of tailored in-application marketing content. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt out of tailored in-application advertising.

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DO NOT TRACK DISCLOSURE

Certain laws require us to let you know how we respond to web browser Do Not Track (DNT) signals. We do not currently recognize or respond to browser-initiated DNT signals. To determine whether any of the third-party services handle DNT signals, please read their privacy policies.

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PRIVACY OF MINORS

The Platform and related services are not designed for minors under 18. Only persons 18 years of age or older may use the Platform and if you are under 18 you must not use our Service. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete the personal information to the extent required by the Children’s Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy.

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SECURITY AND PROCESSING OF INFORMATION

We employ reasonable security procedures and practices as required by law to protect your personal information from unauthorized or illegal access, destruction, use, modification, or disclosure. No security measures, however, are 100% failsafe. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or communications will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. We are not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

We may process your information when reasonably necessary: (i) to provide the Service, (ii) to comply with legal obligations to which we are subject, (iii) to carry out our other legitimate business purposes, (iv) to fulfill contractual obligations to you or another third party, or (v) as otherwise agreed by you or to which you have provided your consent.

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More information about the use of information is described in “How We Use the Information We Collect” above.

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Location of Processing and Access to Information

The Platform application and data are hosted with facilities based in the United States, following organizational procedures related to the purposes of such application and data. Information is processed at our facilities and at any other location where the parties involved in data processing are located. Depending on your location, our use of and processing of information may involve transferring your information to a country other than your own. For more information, see “Consent to Transfer” below. We employ encryption technology when handling data, both in transit and at rest. In some cases, your information may be accessible to our personnel involved with the operation and use of the Service, including for administrative, sales, legal, and support purposes. In addition, information may be accessible, to the extent required to provide the Service, by hosting providers, data processers, communications providers, or other technical service providers engaged by us from time to time. A list of such parties may be requested by contacting us.

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RETENTION OF PERSONAL INFORMATION

We will retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected and to fulfill our legitimate business interests. In doing so, we will consider the type of products and services requested by or provided to you, the nature and length of our relationship with you or the business entity you are associated with, and mandatory retention periods under applicable law. For example, under federal and state laws, information relating to a loan application will generally be stored in our Platform by your broker or lender for a minimum of 3 years, and up to 7 years. We will also retain your information, including after your relationship with us ends, as long as necessary to enforce or comply with our legal or contractual rights and obligations, to resolve disputes and defend claims, and to reserve our legal rights.

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EXTERNAL RESOURCES

The Platform may contain links to, or information about, other websites or resources over which we do not have any control. Such links do not constitute an endorsement by ARIVE of those external websites. All third-party service providers in the mortgage lending process are responsible for their own compliance requirements. You acknowledge that we are providing such information and links to you only as a convenience, and further agree that we are not responsible for the content of such external websites or the protection and privacy of information you provide while visiting such external websites.

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YOUR RIGHT TO UPDATE, DELETE, AND CORRECT YOUR INFORMATION AND CERTAIN

OPT-OUT RIGHTS

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You may review, correct and delete certain information about you by logging in to the Platform and navigating to your Preferences page. You must promptly update your account information if it changes or is inaccurate. You should understand, however, that once you transmit certain information through the Platform, you may not be able to change or remove it. Once we have deactivated or removed your account, you acknowledge that we will not be responsible to you for retaining information related to your account. For more information about retention of your information, see “Retention of Personal Information” above.

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Residents of certain states may have additional rights to review, correct and delete personal information, as well as to opt out of certain activities relating to the sale, sharing or disclosure of personal information. For more information, see the links to specific state Privacy Notices under “State Privacy Protections” near the beginning

of this Policy.

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You may exercise your rights by following the instructions under the relevant state Privacy Notice, or by contacting us at the address below.

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CHANGES TO THIS POLICY

This Policy is current as of the date set forth below, but is subject to change at any time, in our sole discretion. If we make changes to this Policy, we will post an updated Policy and revise the Effective Date. In our sole discretion, we may also send you a message or otherwise notify you when you are logged into your account. We encourage you to review this Policy regularly for any changes. Your continued use of our website or Service following the posting of changes constitutes your acceptance of such changes.

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CONSENT TO TRANSFER

The Platform application and data are hosted with facilities based in the United States, so your personal information will be processed by us in the United States. We provide customer support from both within and outside of the United States, and you agree that our personnel, wherever located, may access your data to the limited extent and for a limited time reasonably necessary to fulfill your and your client’s customer support requests. In addition, if you create an account with the Platform as a visitor from outside the United States, by using the Platform, you are consenting to the practices described in this Policy and agree to have your personal information transferred to and processed in the United States, which may not offer a level of protection equivalent to that required in the European Union or certain other countries, and to the processing of that information as described in this Policy.

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DEFINITIONS

The words “include,” “includes” and “including” shall mean without limitation, and any listing thereafter is not exhaustive.

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CONTACT US

If you have any questions about this Policy or our privacy practices, you may contact us by email at

[email protected]

or by mail at Arive, LLC, c/o Wizni, Inc., 5000 Executive Parkway, Suite 312, San Ramon CA 94583.

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Effective Date: June 29, 2023