Effective: 01/02/2026

This notice supplements Liberty1 Financial’s Privacy Policy and Privacy Notice, and applies only to California residents. It explains, as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), the categories of personal information we collect, sell, and share, and the rights available to you and how to exercise them. Your use of our website and services is also governed by our Terms & Conditions, which is incorporated into this notice by reference and includes our dispute resolution, arbitration, class action waiver, and jury trial waiver provisions.

1. Key Terms

2. Personal Information We Collect About You

In the preceding 12 months, we have collected the following categories of personal information about our clients and website visitors:

3. How Your Personal Information Is Collected

We collect most of this personal information directly from you: by phone (including a call handled by Libby, our virtual agent, when no representative is available), email, text, or through our website and enrollment forms. We also collect information from:

• Third parties with your consent, such as creditors and lenders you authorize us to contact on your behalf;
• Lending platforms and partners, where you have applied for financing through us;
• Cookies and similar technologies on our website;
• Advertising and analytics platforms, as described in Section 6; and
• Publicly available government records, where relevant to verifying your identity.

4. Why We Use Your Personal Information

We market and advertise unsecured consumer loan matching only. We collect, use, sell, and share personal information for the following business purposes:

• Performing our loan-matching services, including evaluating your eligibility and arranging financing with lending partners; communicating with our lending partners about your account; and servicing your account;
• Matching you with third-party lending partners and platforms so they can evaluate you for financing offers;
• Advertising and marketing our own services, including through the social media and advertising platforms described in Section 6;
• Detecting, preventing, and investigating fraud or security incidents;
• Complying with our legal and regulatory obligations, including recordkeeping required by state lending laws; and
• Performing our contract with you, or taking steps you request before entering into a contract with us.

5. Who We Share Your Personal Information With

In the preceding 12 months, we have disclosed personal information to:

• Third-party lending platforms and partners, including AskEVVO, so they can evaluate you for loan or financing offers (see Section 6: this disclosure is a “sale” under the CCPA because we receive compensation from these partners in connection with successful matches);
• Social media and advertising platforms, to advertise our services and measure the effectiveness of that advertising (see Section 6: this disclosure is a “share” under the CCPA);
• Service providers who perform functions on our behalf, such as payment processing, telephony, e-signature, customer support software, and data hosting, under contracts that restrict their use of your information to providing services to us;
• Government and regulatory agencies, and other parties, when required by law, legal process, or to protect the rights, property, or safety of Liberty1 Financial, our clients, or others; and
• A successor entity, in the event of a merger, acquisition, or sale of assets, subject to confidentiality protections.

6. Categories of Personal Information We Sold or Shared

Sold (to lending partners and platforms, including AskEVVO, in exchange for referral compensation):

• Identifiers (name, contact information, Social Security number, date of birth);
• Financial and commercial information (income, employment, debt, bank account and credit information); and
• Inferences drawn from the above to evaluate eligibility for a loan.

Shared (with Meta, TikTok, LinkedIn, YouTube, and Mobiquity, for cross-context behavioral advertising):

• Identifiers (such as device identifiers or hashed contact information, where used to match you to an advertising audience); and
• Internet or other electronic network activity information (such as browsing activity on our website and interaction with our ads).

7. Categories of Personal Information We Disclosed for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information to service providers for a business purpose (not a sale or share):

• Identifiers;
• Financial and commercial information;
• Internet or other electronic network activity information; and
• Audio information (call recordings), where applicable.

8. How Long Your Personal Information Will Be Kept

We retain your personal information for as long as you have an account or relationship with us, and afterward for no longer than seven years, for purposes that may include:

• Complying with recordkeeping obligations under applicable state lending and consumer-protection laws;
• Responding to any questions, complaints, or claims made by you or on your behalf;
• Establishing, exercising, or defending legal claims; or
• Keeping records required by law.

9. Text Messaging (SMS) Data Practices

If you provide your mobile phone number to enroll in text messages from us, whether on your loan application, through our website, or by texting us directly, we collect that number, together with your name and any other information you provide in that request, as an Identifier described in Section 2 above.

We use this information to send you account-related text messages, such as application status updates and customer support responses, and, only if you separately opt in as described in our Terms & Conditions, marketing text messages about our services. See our Consent for Electronic Communications for the specific terms governing this text-messaging program, including message frequency, applicable message and data rates, and how to opt out.

We do not sell or share your mobile phone number, or your consent to receive text messages from us, with unrelated third parties for their own independent marketing or promotional purposes. We share this information only with the service provider that operates the text-messaging platform we use to deliver messages on our behalf, solely to deliver those messages, and as otherwise described in Section 5 above.

You may exercise your rights over this information, including the rights described in Section 10 below, the same way you would for any other personal information we hold about you.

10. Your Rights Under the CCPA/CPRA

California residents have the following rights, which you may exercise free of charge as described in Section 11:

Right to Know

You have the right to request that we disclose: the categories and specific pieces of personal information we have collected about you; the categories of sources from which it was collected; our business or commercial purpose for collecting, selling, or sharing it; the categories of third parties to whom we disclose it; and the categories of personal information we sold, shared, or disclosed for a business purpose, and to whom.

Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale of your personal information to lending partners and platforms, and out of the sharing of your personal information for cross-context behavioral advertising, as described in Section 6. Once you opt out, we will not sell or share your personal information unless you later provide express authorization to resume.

Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of your sensitive personal information (Section 1) to what is reasonably necessary to perform the services you request, and other purposes permitted by the CCPA/CPRA, such as security, fraud prevention, and legal compliance.

Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to exceptions, for example, where the information is necessary to complete a transaction you requested, detect or respond to security incidents, comply with a legal obligation, or exercise free speech.

Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes of processing.

Right to Non-Discrimination

We will not deny you services, charge you a different price, or provide a different level or quality of service because you exercised any right under the CCPA/CPRA.

Global Privacy Control

If your browser sends an opt-out preference signal, such as the Global Privacy Control, we will treat that signal as a valid request to opt out of the sale and sharing of your personal information for the browser (and, where applicable, the account) that sent it.

11. How to Exercise Your Rights

You may exercise the rights described in Section 10 by:

• Email: [email protected];
• Phone: (800) 216-5772; or
• A designated “Do Not Sell or Share My Personal Information” link, once the built webform is deployed and linked from our website per the drafting note at the top of this document.

To protect your information, we will need to verify your identity before completing most requests. Depending on the request, we may ask you to confirm information already in our records, such as your name, address, and the last four digits of your Social Security number, or a government-issued photo ID. You may also designate an authorized agent to make a request on your behalf; we may require the agent to provide proof of that authorization and may still require you to verify your own identity directly with us.

You may make a request to know or a request for data portability up to twice in a 12-month period. There is no limit on requests to opt out, limit use of sensitive personal information, delete, or correct.

12. Contact Us

Clear Vision Financial LLC, d/b/a Liberty1 Financial

999 E Playa del Norte, Suite 405, Tempe, AZ 85288

(800) 216-5772

[email protected]