Upon enrollment, the participant is entered into a credit builder program that simulates a fixed-term installment account. No funds are transferred or disbursed to the participant, and no savings account is opened or funded. The program is designed to help build positive credit history through regular monthly service fee payments that may be reported to one or more credit bureaus.

The first payment will be due approximately 30 days after enrollment, and subsequent payments will recur monthly on the same day. If the billing date falls on a weekend or holiday, payment will be processed on the next business day.

By enrolling in the program, participants authorize Primeak to debit their bank account or card on file for the service fee each month. Participants may update their payment method at any time or cancel service before the next billing cycle. Authorization remains in effect until canceled.

Participants agree to pay a flat monthly service fee of $ for up to 12 months. The total cost of participation is $.00 if all 12 monthly payments are made.

Each monthly payment of $ consists entirely of a service fee. There is no principal, no interest, and no loan balance associated with this program.

Payments not received within 10 calendar days of the scheduled billing date may be considered late. Primeak reserves the right to assess a $25.00 late fee and suspend credit reporting for accounts that become past due.

As this program does not involve a loan or accruing interest, participants may cancel or complete the program early without penalty. There is no "payoff" or principal balance.

The participant affirms they are legally authorized to enroll in this program and to enter into this agreement.

The participant understands this is not a loan and that no money will be disbursed or deposited on their behalf. This agreement constitutes a binding service subscription for credit-building purposes only.

The participant certifies that the information provided during enrollment is accurate and agrees to notify Primeak of any change in contact or billing information within 30 days.

Participants may make monthly service payments using any of the following approved methods:

• Automatic debit (ACH) from a linked bank account
• Debit or credit card via the Primeak customer portal
• Other methods approved by Primeak in writing

All payments will be applied to the participant's service account. As this is not a loan, no portion of any payment will be applied to principal or interest.

Partial payments may be accepted at Primeak's discretion. However, only full and timely payments may be eligible for credit reporting.

By enrolling, participants authorize Primeak to initiate recurring electronic debits from their designated payment method in the amount of $ per month, unless canceled in advance. This authorization remains valid until the program is canceled or completed.

Participants agree to maintain current billing, address, and contact information with Primeak. Any changes must be reported within 30 days. Primeak may communicate program updates, payment notices, or account activity via email or other secure electronic means.

By enrolling, the participant agrees to:

• Make full and timely payments each month
• Maintain accurate and updated contact information
• Use this program in good faith to build a positive credit history
• Promptly respond to Primeak communications, including verification or dispute inquiries
• Understand that non-payment or cancellation may result in discontinued credit reporting

This Agreement becomes effective upon enrollment and payment of the first monthly service fee by the participant. The intended program term is 12 months, but the participant may cancel at any time.

Participants may cancel the program at any time before their next billing date. No penalties apply. Past payments are non-refundable.

Primeak reserves the right to suspend or cancel a participant's enrollment for non-payment, fraud, misuse of the program, or any violation of the terms of this Agreement. If cancellation occurs due to non-payment, credit reporting may be paused or discontinued.

This program does not include a loan or disbursed funds. Upon cancellation, there is no principal balance or payoff amount due. Credit reporting will cease after cancellation is processed.

This document represents the entire agreement between the participant and Primeak regarding participation in the Credit Builder Program. No verbal or written representations outside of this document shall alter the terms herein unless amended in writing by Primeak.

Primeak may modify this Agreement from time to time. Any changes will be communicated to participants by email or through the customer portal. Continued participation after such notice constitutes acceptance of the updated terms.

All communications related to this Agreement may be sent via email, SMS, or through the secure customer portal. Participants are responsible for maintaining up-to-date contact information.

This Agreement remains in effect for as long as the participant is enrolled in the Credit Builder Program and has an active account in good standing. Either party may terminate this Agreement at any time, for any reason, with written notice or through the customer portal.

There is no penalty for cancellation. Once canceled, no future payments will be processed and credit reporting will cease.

This Privacy Policy is designed to comply with comprehensive federal regulations governing financial services:

• Fair Credit Reporting Act (FCRA) - 15 U.S.C. § 1681 et seq.
• Truth in Lending Act (TILA) - 15 U.S.C. § 1601 et seq.
• Equal Credit Opportunity Act (ECOA) - 15 U.S.C. § 1691 et seq.
• Gramm-Leach-Bliley Act (GLBA) - 15 U.S.C. § 6801 et seq.
• Fair Debt Collection Practices Act (FDCPA) - 15 U.S.C. § 1692 et seq.
• Electronic Fund Transfer Act (EFTA) - 15 U.S.C. § 1693 et seq.
• Telephone Consumer Protection Act (TCPA) - 47 U.S.C. § 227
• CAN-SPAM Act - 15 U.S.C. § 7701 et seq.

Our operations comply with comprehensive California privacy and financial services regulations:

• California Consumer Privacy Act (CCPA) - Cal. Civ. Code § 1798.100 et seq.
• California Privacy Rights Act (CPRA) - Amendment to CCPA effective 2023
• California Financing Law (CFL) - Cal. Fin. Code § 22000 et seq.
• Rosenthal Fair Debt Collection Practices Act - Cal. Civ. Code § 1788 et seq.
• California Unruh Civil Rights Act - Cal. Civ. Code § 51 et seq.
• California "Shine the Light" Law - Cal. Civ. Code § 1798.83
• Song-Beverly Credit Card Act - Cal. Civ. Code § 1747 et seq.

• Real name, alias, postal address, unique personal identifier
• Online identifier, Internet Protocol address, email address
• Account name, Social Security number, driver's license number
• Passport number, state identification card number
• Insurance policy number, bank account number, credit card number
• Debit card number, or any other financial account number

• Name, signature, Social Security number, physical characteristics
• Address, telephone number, passport number, driver's license
• Insurance policy number, education, employment, employment history
• Bank account number, credit card number, debit card number
• Any other financial information, medical information, or health insurance information

• Age (40 years or older) - for ECOA compliance only
• Race, color, religion, national origin - prohibited under ECOA except for monitoring
• Sex (including gender identity, gender expression, pregnancy)
• Marital status - limited collection for joint applications
• Military or veteran status

• Records of personal property, products or services purchased
• Loan agreements, promissory notes, security agreements
• Payment history, account balances, transaction records
• Collection accounts, charge-off information, bankruptcy records
• Credit applications, credit reports, credit scores

• Online Applications: Loan applications and account portals
• Paper Applications: Physical forms and documents
• Telephone Applications: Phone-based applications and customer service calls
• In-Person Meetings: Direct document collection and consultations
• Mobile Applications: Digital platforms and mobile apps

• TransUnion LLC - Credit monitoring services
• Experian Information Solutions - Credit verification and reporting
• Equifax Inc. - Credit bureau services and identity verification
• LexisNexis Risk Solutions - Identity verification, fraud detection
• LocatePlus Holdings Corp. - Skip tracing, address verification
• Plaid Inc. - Bank account verification, transaction history
• Stripe Inc. - Payment processing, ACH services

• Social Security Administration - SSN verification
• Internal Revenue Service - Tax lien and levy information
• Bankruptcy Courts - Chapter 7, 11, 13 filing records
• Federal Regulatory Databases - NMLS Consumer Access
• California Secretary of State - Business entity records
• County Recorders - Property ownership, liens, judgments
• Department of Motor Vehicles - Vehicle registration, liens

• Loan Origination and Underwriting: Credit evaluation, income verification, capacity assessment
• Account Management and Servicing: Payment processing, account maintenance, customer communications
• Collections and Recovery: First-party collections on our loans and third-party debt collection
• Credit Reporting: Monthly reporting cycles to TransUnion, Experian, Equifax
• Fraud Prevention and Security: Identity verification, transaction monitoring, risk scoring
• Regulatory Compliance: DFPI reporting, NMLS updates, federal compliance

• Customer Service: Inquiry resolution, dispute handling, account assistance
• Marketing: Service notifications, product offerings, educational content
• Analytics: Portfolio performance, risk assessment, operational efficiency

• TransUnion LLC - Credit reporting, monitoring, verification services
• Experian Information Solutions - Credit bureau services, identity verification
• Equifax Inc. - Credit reporting, fraud prevention, data analytics
• LexisNexis Risk Solutions - Identity verification, fraud detection, compliance screening
• Plaid Inc. - Bank account verification, financial data aggregation
• Stripe Inc. - Payment processing, ACH transfers, merchant services

• DocuSign Inc. - Electronic signature services, document management
• Salesforce Inc. - Customer relationship management, data processing
• Amazon Web Services - Cloud hosting, data storage, security services

• Licensed auto dealers for vehicle financing origination
• Bank and credit union partners for loan referrals and participation
• Alternative lenders for declined application referrals

• Data in Transit: TLS 1.3 minimum encryption for all communications
• Data at Rest: AES-256 encryption for stored personal information
• Key Management: Hardware security modules (HSM) for cryptographic keys
• Access Controls: Multi-factor authentication required for all system access
• Network Security: Next-generation firewall with intrusion detection

• Privacy Officer: Designated privacy leadership and accountability
• Employee Training: Annual privacy training mandatory for all employees
• Incident Response: Comprehensive breach notification and response procedures
• Vendor Management: Data protection obligations in all vendor agreements

• Application Data: 25 months minimum (FCRA § 1681m), 3 years per CFL § 22451
• Approved Loans: Life of loan plus 3 years after final payment
• Payment History: 7 years for tax and accounting purposes
• Service Call Recordings: 3 years for quality assurance and training
• Regulatory Records: 5 years following examination completion