Zendable Online Privacy Policy

Effective Date: February 2, 2026

PLEASE READ THIS PRIVACY POLICY CAREFULLY. Your privacy is important to us. Zendable, Inc. and its affiliates (collectively, "Zendable", or "we") provide this Online Privacy Policy to explain how we collect, use, share and protect your personal information in connection with the online services offered at www.zable.com and any of its subdomains, and any other online services offered by us in the United States (the "online services"). This includes the products and services offered via the online services by Zendable, as well as when you interact with us on social media sites and apps, through e-mails or advertisements displayed through online services operated by us or nonaffiliated third parties.

By accessing our online services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information. If you are a California resident, you may have additional rights under the California Consumer Privacy Act, and should review our California Privacy Notice to learn more about your rights. Our social media sites or pages may have additional terms from this Policy about the privacy of your information. Please review the privacy policy for the specific online service you are using for more information.

Since we may change the Zendable Online Privacy Policy, the U.S. Consumer Privacy Notice, or the California Privacy Notice, we recommend that you check the current version available from time to time. If we make changes to any of these, we will update the "Effective Date" at the top of the page.

Information We Collect and How We Collect It

When you visit or use our online services, we may collect personal information from or about you. Personal information is generally information that identifies you or that could be used to identify you.

Personal Information. We collect certain information directly from you when you use our online services, such as when you fill out forms or fields to request a loan offer, or apply for a loan or credit card, or when you seek consumer support. During these interactions, you voluntarily provide us with the following types of personal information so that we can provide our services:

Characteristics of protected class: Age, receipt of public assistance (when disclosed by applicant), and other data and factual information used for self-tests as allowed under 12 CFR 1002.15.
Commercial Information: Our history together, services provided or discussed, payment information such as bank account or wiring instructions, and your credit history, credit scores and other information provided by consumer reporting agencies.
Identifiers: Name, physical address, email, phone number, unique device identifiers, social security number, documents that verify your identity such as your driver's license or passport, and social media handles;
Internet Activity: Browsing history, search history, and Session Replay data (mouse movements, clicks, scrolls, and keystrokes used to debug errors).
Precise Geolocation: Location data within a radius of 1,850 feet, derived from device signals.
Inferences: Profiles reflecting your creditworthiness, psychological trends, and predispositions to tailor marketing offers.
Professional Info: Job title, employer, income, and consumer provided tax returns, W-2, and pay stub (in some instances) to verify credit worthiness.

Sensitive Personal Information. To align with enhanced privacy standards, we explicitly categorize certain data as "Sensitive." This includes:

Biometric Data: Facial recognition data used for identity verification or fraud prevention.
Geolocation: Data derived from your device (GPS, Wi-Fi) to prevent fraud or locate you within a specific radius.
Account information: Your account numbers, and bank account credentials.
Government Identifiers: Social Security, driver's license, or passport number.

Usage Information. When you visit our online services, we may automatically collect certain information about your use of our online services, such as:

Information about your computer, mobile phone or other access device and anonymous information about your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the online services, domain names, landing pages, pages viewed, your use of third-party applications, and other information that assists us in analyzing and improving the online services.
We may collect your location using a cellular network location, Wi-Fi networks, browser services, mobile location services if turned on, or other information you provide.
In addition, we may later associate the usage and other information we collect online with personal information about you.

Additional Sources of Information. We may also collect information about you from additional online and offline third party sources including from co-branded partner sites or commercially available sources, such as credit reporting agencies, with whom you engage. These third-party sources may pass certain information about you and your use of their service to us. This information could include any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review and, if necessary, adjust your privacy settings on third-party websites and services. We may combine this information with the personal and other information we have collected about you under this Privacy Policy.

Why We Collect Information

We use the online information we collect from or about you to:

Provide you with access to the products and services offered;
Provide notices and other information to you about, or in connection with, these products and services, and update you about new features and benefits;
Verify your identity;
Manage your preferences;
Provide customer support, response to your requests and communicate with you;
Use the location of your mobile device for location-based services that you may request;
Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, fulfill legal requirements and enforce our agreements;
Debug to identify and repair errors that impair existing intended functionality;
Provide, maintain, develop and improve our services, your experience, and to protect Zendable and its users;
Improve your experience accessing the products and services offered through the Site by recognizing you as a customer and remembering information you previously provided so that you will not have to re-enter it;
Improve our insights so we can tailor our content and advertising, and provide you with offer recommendations and/or insights that are most relevant to you;
Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies;
For any other purposes that we may specifically disclose at the time you provide or we collect your information;
We may use AI and machine learning tools, including chatbots, to improve customer support, assess fraud risks, and enhance our insights. When you interact with our chatbots, your data is processed to generate automated responses; and
With your consent, Zable may work with a third party, such as Plaid, to access and collect your financial information on our behalf. We use this financial information to process your transactions, to improve and expand our Services, and to determine your financial wellbeing. If you create an account with us, we will use financial information about you to facilitate and service your account. We may also use this information to process your application or transactions and enable payments and fund transfers with financial institutions. In addition, we may use this financial information for creditworthiness if you are a borrower, assess risks related to your transaction, and to help investors determine whether to commit to or purchase your credit product. By providing your financial information or your financial payroll information to the third party, you acknowledge and agree that such information is accessed, collected, or transmitted by the third party in accordance with the privacy policy of the third party. Plaid's privacy policy is available at https://plaid.com/legal.

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.

Disclosure of Information

All financial companies need to share customers' personal information to run their everyday business. Subject to any applicable legal exemptions including the Gramm-Leach Bliley Act, and/or the California Consumer Privacy Act, we may share your personal information, including non-public personal information with:

Service providers who help with parts of our business operations such as fraud prevention, servicing, bill collection, debt collection, marketing and technology services, and product development;
Credit reporting agencies to report account information, at your direction and otherwise as permitted by law;
Debt collection companies that purchase your loan from a Creditor if it has been charged off;
Zendable affiliated websites and businesses in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations;
Other companies to bring you co-branded services, products or programs;
Companies that we plan to merge with or be acquired by, or companies we plan to sell, divest or transfer all or a portion of our products and/or services to, including any back-up service provider or back-up administrator we, or any Creditor engage in the event we stop operating; and
Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our U.S. Consumer Privacy Notice.

We do not "sell" the personal information we collect (and will not sell it in the future without providing a right to opt out). We do allow third parties to collect personal information through our services and share personal information with third parties for the business purposes described above, including without limitation advertising and marketing on our services and elsewhere based on users' online activities over time and across different sites, services, and devices.

If you select a loan offer and/or a credit card offer from one of our partner banks, when you sign your promissory note, your loans may be automatically transferred as follows:

We may purchase your loan from our partner banks.
Investors may purchase your loan directly from us. If that occurs, we provide information about you included in your application, including personally identifiable, financial, and credit information, and your loan terms to these investors and their agents and trustees in advance of their purchase of your loan.
As the servicer of your loan, we will also share information we obtain in servicing your loan, including about your repayments, to investors, who become the Creditor of your loan, any subsequent purchaser of your loan, and each of their agents or trustees.

Zendable will not sell or rent any of your personal information to third parties and will only share your personal information with third parties as described above. We may share identified or aggregated information with third parties to help deliver products, services, and content that are better tailored to the users of our online services and for other purposes. Information that has been identified so that it does not identify a specific user is not considered personal information.

Your Rights

This section discusses U.S. state privacy laws that apply to data we collect about you. Please note, however, that these broadly-applicable privacy laws do not apply to what is referred to as personally identifiable financial information collected by financial institutions (like Zable), because that information is subject to other financial privacy laws (like the Gramm-Leach-Bliley Act (GLBA)). As a result, these laws do not apply to most of the information that Zable collects. The details below only apply to the more limited personal information we collect that is subject to these broadly-applicable U.S. state privacy laws.

State Consumer Privacy Rights

Residents of certain U.S. states have specific rights regarding their personal information collected outside of the GLBA context.

If you are a resident of CA, please see our California Privacy Notice.

If you are a resident of Minnesota, Montana, Oregon, Texas, and Virginia your rights include:

Right to Know/Access: Request confirmation of whether we process your data and access a copy of it.
Right to Correct: Request correction of inaccurate personal information.
Right to Delete: Request deletion of personal information, subject to legal exceptions.
Right to Opt-Out: Opt out of the "sale" of data or "targeted advertising".
Right to Appeal: If we deny your request, you may appeal the decision by contacting us. We will provide a written explanation for any decision.

If you are a resident of Utah:

Right to Know/Access: Request confirmation of whether we process your data and access a copy of it.
Right to Delete: Request deletion of personal information, subject to legal exceptions.

If you are a resident of Vermont:

In accordance with Vermont's Opt-In Requirements, we treat all consumers with a Vermont mailing address as if you have limited our sharing of your information as follows:
- Sharing with Non-affiliates: We will not share your nonpublic personal financial information with nonaffiliated third parties unless you give us your express written or electronic authorization (opt-in).
- Sharing with Affiliates: We will not share information about your creditworthiness with our affiliates for their everyday business purposes unless you provide your prior consent.
- Joint Marketing: We will only disclose your name, contact information, and information about your transactions and experiences (not creditworthiness) for joint marketing purposes with other financial institutions.
Under the Vermont Fair Credit Reporting Act, we are prohibited from obtaining or sharing information about your creditworthiness from a consumer report with any company—including our own affiliates—without first obtaining your direct consent.
Per the Vermont Data Privacy Act (VDPA), effective as of 2025/2026:
- Specific Consent: We must obtain your freely given, specific, and informed consent before processing "sensitive data," which includes your Social Security number and financial account credentials.
- Minimization: We limit our collection of your personal data to what is reasonably necessary to provide the specific credit card product you requested.

Cookies and Other Tracking Technologies

We, or our service providers, and other companies we work with may deploy and use cookies, and other tracking technologies for various purposes, such as fraud prevention and monitoring our advertising and marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services. "Cookies" are small amounts of data a website can send to a visitor's web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our online services over time to customize your experience.

We use common tracking technologies for a variety of reasons such as to:

Recognize new or past customers;
Store your password if you are registered on our online services;
Improve our online services;
Observe your behaviors and browsing activities over time across multiple websites or other platforms; and
Better understand the interests of our customers and our online services visitors.

Most web browsers allow you to adjust your browser settings to decline or delete cookies, but doing so may degrade your experience with our online services. Certain browsers can be set to clear past and reject future tracking tools. If you block tracking tools on your browser, certain features of our Online Services may not work. Additionally, if you block or delete tracking tools, not all of the tracking activities we have described here will stop. Choices you make are both browser and device-specific.

Security

We care about the security of your information and take reasonable measures designed to protect your personal information from unauthorized access and use by maintaining physical, electronic and procedural safeguards in compliance with applicable law. We also take appropriate measures so that personal information can be kept accurate, and up-to-date, which will be in accordance with the applicable security requirements.

Zendable protects your Social Security number, prohibits the unlawful disclosure of Social Security numbers; and limits access to Social Security numbers to employees or others with legitimate business purposes or as described in our Terms. These protections apply to all Social Security numbers collected or retained in any way by Zendable in connection with customer, commercial, or all other relationships. Individuals applying for or obtaining a product or service from us to be used primarily for personal, family or household purposes may obtain more information by reviewing the U.S. Consumer Privacy Notice or California Privacy Notice, as applicable.

You are responsible for controlling access to your account and email communications from us at all times. We also encourage you to keep your password confidential and not have any written or other record of the password that can be accessible by an intruder or third party. We cannot ensure or warrant the security of any information you transmit to us or guarantee that information may not be accessed, disclosed, altered or destroyed.

In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify via email, mail, or telephone those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Retention

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Third Party Websites

Zendable may provide links to websites that are owned or operated by other companies ("third-party websites"). When you use a link online to visit a third-party website, you will be subject to that website's privacy and security practices, which may differ from ours.

You should familiarize yourself with the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website. We are not responsible for the practices employed by any third party website linked to or from our online services.

Your Choices

Access and Correction. We rely on you to update and correct your personal information. Most of our online services allow you to modify or delete your account profile. If our online services do not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information be modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.

You can review and edit some of your personal information at any time by calling us at 1-844-779-2253 for loans Monday through Friday 8 am to 9 pm EST and 1-877-659-2253 for cards 9 am to 6 pm Monday through Friday EST.
Choice for Marketing Materials. If you do not want to receive marketing and sales materials from Zendable by direct mail, telephone or email, please follow the "unsubscribe" instructions provided in those communications or submit a written request to the address listed in the Contact Us section below. We will comply with your request within a reasonable period of time after receiving it or within the time period required by local law.
Other Legal Rights. Subject to the law applicable to our collection of your personal information, you may other have certain rights such as requesting information related to the anonymization, sharing, portability, or deletion of your personal information and individual review of processing decisions. Contact us in writing with requests to exercise such rights at the address listed in the Contact Us section below and we will honor such rights in accordance with applicable law. Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, email address, or details about your last interaction with us. We may also ask you to provide a signed declaration confirming your identity.

California residents covered by the California Consumer Privacy Act may have additional rights. Please see our California Privacy Notice for more information.

Children

Our online services are not directed at children under the age of 13. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as users. If we learn that we have collected personal information from a child under age 13, we will delete that information promptly. If you believe that we might have any information from a child under 13, please contact us at privacy@zable.com.

Contact Us

If you have questions or concerns regarding this policy, you should contact us by emailing us at privacy@zable.com, by calling us at 1-844-779-2253 during our operating hours 8:00 AM EST to 9:00 PM EST or by writing to us via regular mail at Zendable, Inc., 3100 Clarendon Blvd, Suite 200, Arlington, VA 22201.