Terms & Conditions

Welcome to Surepoint Financial Group Terms and Conditions

Protecting your private information is our priority. This Statement of Privacy applies to https://surepointfinancialgroup.com and Surepoint Financial Group, Inc. and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Surepoint Financial Group, LLC include https://surepointfinancialgroup.com, Surepoint Financial Group, and https://surepointfinancialgroup. The Surepoint Financial Group website is a website description site. By using the Surepoint Financial Group website, you consent to the data practices described in this statement.

1. Terms & Conditions

Terms and Conditions

Agreement between User and Surepoint Financial Group, Inc.(“Surepoint Financial Group”).
Welcome to Surepoint Financial Group, provider of Surepoint Financial Groupmarketing technology. Surepoint Financial Group, LLC operates https://surepointfinancialgroup.com, each with various webpages and is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein (the “Terms”). Your use of https://surepointfinancialgroup.com constitutes your agreement to all such Terms. Please read these terms carefully and keep a copy of them for your reference.
Surepoint Financial Group is a Software-as-a-Service based technology and marketing company. Surepoint Financial Group engages with customers to help them submit consumer loan requests via the Surepoint Financial Group technology.

Privacy

Your use of https://surepointfinancialgroup.com/privacy-policy is subject to Surepoint Financial Group’s Privacy Policy. Please review our Privacy Policy,
which also governs the Sites and informs users of our data collection practices.

Electronic Communications

Visiting https://surepointfinancialgroup.com or sending emails to Surepoint Financial Group constitutes electronic communications. You consent to receive
electronic communications and you agree that all agreements, notices, disclosures and other communications that we provide to you
electronically, via email and on the Site, satisfy any legal requirement that such communications be in writing.

Your Account

If you use this site, you are responsible for maintaining the confidentiality of your account and password and for restricting access to your
computer, and you agree to accept responsibility for all activities that occur under your account or password. You may not assign or
otherwise transfer your account to any other person or entity. You acknowledge that Surepoint Financial Group is not responsible for third party
access to your account that results from theft or misappropriation of your account. Surepoint Financial Group and its associates reserve the right to
refuse or cancel service, terminate accounts, or remove or edit content in our sole discretion.

Children Under Thirteen

Surepoint Financial Group does not knowingly collect, either online or offline, personal information from persons under the age of thirteen. Visitors
under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Company does not knowingly
solicit or collect information from visitors under eighteen (18) years of age. Company encourages parents and guardians to spend time
online with their children and to participate and monitor the interactive activities of their children.

No Unlawful or Prohibited Use/Intellectual Property

You are granted a non-exclusive, non-transferable, revocable license to access and use https://surepointfinancialgroup.com strictly in accordance with
these terms of use. As a condition of your use of the Site, you warrant to Surepoint Financial Group that you will not use the Site for any purpose that
is unlawful or prohibited by these Terms. You may not use the Site in any manner which could damage, disable, overburden, or impair the
Site or interfere with any other party’s use and enjoyment of the Site. You may not obtain or attempt to obtain any materials or information
through any means not intentionally made available or provided for through the Site.

All content included as part of the Service, such as text, graphics, logos, images, as well as the compilation thereof, and any software used on
the Site, is the property of Surepoint Financial Group or its suppliers and protected by copyright and other laws that protect intellectual property and
proprietary rights. You agree to observe and abide by all copyright and other proprietary notices, legends or other restrictions contained in
any such content and will not make any changes thereto.

You will not modify, publish, transmit, reverse engineer, participate in the transfer or sale, create derivative works, or in any way exploit any
of the content, in whole or in part, found on the Site. Surepoint Financial Group content is not for resale. Your use of the Site does not entitle you to
make any unauthorized use of any protected content, and in particular you will not delete or alter any proprietary rights or attribution
notices in any content. You will use protected content solely for your personal use and will make no other use of the content without the
express written permission of Surepoint Financial Group and the copyright owner. You agree that you do not acquire any ownership rights in any
protected content. We do not grant you any licenses, express or implied, to the intellectual property of Surepoint Financial Group or our licensors
except as expressly authorized by these Terms.

International Users

The Service is controlled, operated and administered by Surepoint Financial Group from our offices within the USA. If you access the Service from a
location outside the USA, you are responsible for compliance with all local laws. You agree that you will not use the Surepoint Financial Group Content
accessed through https://surepointfinancialgroup.com in any country or in any manner prohibited by any applicable laws, restrictions or regulations.

Indemnification

You agree to indemnify, defend and hold harmless Surepoint Financial Group, its officers, directors, employees, agents and third parties, for any
losses, costs, liabilities and expenses (including reasonable attorney’s fees) relating to or arising out of your use of or inability to use the
Site or services, any user postings made by you, your violation of any terms of this Agreement or your violation of any rights of a third
party, or your violation of any applicable laws, rules or regulations. Surepoint Financial Group reserves the right, at its own cost, to assume the
exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will fully cooperate with
Surepoint Financial Group in asserting any available defenses.

Arbitration

In the event the parties are not able to resolve any dispute between them arising out of or concerning these Terms and Conditions, or
any provisions hereof, whether in contract, tort, or otherwise at law or in equity for damages or any other relief, then such dispute shall
be resolved only by final and binding arbitration pursuant to the Federal Arbitration Act, conducted by a single neutral arbitrator and
administered by the American Arbitration Association, or a similar arbitration service selected by the parties, in a location mutually
agreed upon by the parties. The arbitrator’s award shall be final, and judgment may be entered upon it in any court having jurisdiction.
In the event that any legal or equitable action, proceeding or arbitration arises out of or concerns these Terms and Conditions, the
prevailing party shall be entitled torecover its costs and reasonable attorney’s fees. The parties agree to arbitrate all disputes and
claims in regard to these Terms and Conditions or any disputes arising as a result of these Terms and Conditions, whether directly or
indirectly, including Tort claims that are a result of these Terms and Conditions. The parties agree that the Federal Arbitration Act
governs the interpretation and enforcement of this provision. The entire dispute, including the scope and enforceability of this arbitration
provision shall be determined by the Arbitrator. This arbitration provision shall survive the termination of these Terms and Conditions.

Class Action Waiver

Any arbitration under these Terms and Conditions will take place on an individual basis; class arbitrations and class/representative/
collective actions are not permitted.
THE PARTIES AGREE THAT A PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY IN EACH’S INDIVIDUAL CAPACITY, AND NOT AS A
PLAINTIFF OR CLASS MEMBER IN ANY PUTATIVE CLASS, COLLECTIVE AND/ OR REPRESENTATIVE PROCEEDING, SUCH AS IN THE FORM
OF A PRIVATE ATTORNEY GENERAL ACTION AGAINST THE OTHER. Further, unless both you and Surepoint Financial Group agree otherwise, the
arbitrator may not consolidate more than one person’s claims and may not otherwise preside over any form of a representative or
class proceeding.

Liability Disclaimer

THE INFORMATION, SOFTWARE, PRODUCTS, AND SERVICES INCLUDED IN OR AVAILABLE THROUGH THE SITE MAY INCLUDE INACCURACIES
OR TYPOGRAPHICAL ERRORS. CHANGES ARE PERIODICALLY ADDED TO THE INFORMATION HEREIN. Surepoint Financial Group, INC ITS SUPPLIERS
MAY MAKE IMPROVEMENTS CHANGES IN THE SITE AT ANY TIME. Surepoint Financial Group, INC ITS SUPPLIERS MAKE NO REPRESENTATIONS ABOUT
THE SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, AND ACCURACY OF THE INFORMATION, SOFTWARE, PRODUCTS, SERVICES AND
RELATED GRAPHICS CONTAINED ON THE SITE FOR ANY PURPOSE. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL SUCH
INFORMATION, SOFTWARE, PRODUCTS, SERVICES AND RELATED GRAPHICS ARE PROVIDED “AS IS” WITHOUT WARRANTY OR CONDITION
OF ANY KIND. Surepoint Financial Group, INC ITS SUPPLIERS HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH REGARD TO THIS
INFORMATION, SOFTWARE, PRODUCTS, SERVICES AND RELATED GRAPHICS, INCLUDING ALL IMPLIED WARRANTIES OR CONDITIONS OF
MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. TO THE MAXIMUM EXTENT PERMITTED BY
APPLICABLE LAW, IN NOEVENT SHALL Surepoint Financial Group, INC ITS SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL,
SPECIAL, CONSEQUENTIAL DAMAGES OR ANY DAMAGES WHATSOEVER INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF USE,
DATA OR PROFITS, ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE USE OR PERFORMANCE OF THE SITE, WITH THE DELAY OR
INABILITY TO USE THE SITE OR RELATED SERVICES, THE PROVISION OF OR FAILURE TO PROVIDE SERVICES, OR FOR ANY INFORMATION,
SOFTWARE, PRODUCTS, SERVICES AND RELATED GRAPHICS OBTAINED THROUGH THE SITE, OR OTHERWISE ARISING OUT OF THE USE OF
THE SITE, WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, EVEN IF Surepoint Financial Group, INC OR ANY OF
ITS SUPPLIERS HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION
OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IF YOU ARE
DISSATISFIED WITH ANY PORTION OF THE SITE, OR WITH ANY OF THESE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO
DISCONTINUE USING THE SITE.

Termination/Access Restriction

Surepoint Financial Group reserves the right, in its sole discretion, to terminate your access to the Site and the related services or any portion thereof
at any time, without notice. To the maximum extent permitted by law, this agreement is governed by the laws of the State of California and
you hereby consent to the exclusive jurisdiction and venue of courts in California in all disputes arising out of or relating to the use of the
Site. Use of the Site is unauthorized in any jurisdiction that does not give effect to all
provisions of these Terms, including, without limitation, this section.

You agree that no joint venture, partnership, employment, or agency relationship exists between you and Surepoint Financial Group as a result of this
agreement or use of the Site. Surepoint Financial Group’s performance of this agreement is subject to existing laws and legal process, and nothing
contained in this agreement is in derogation of Surepoint Financial Group’s right to comply with governmental, court and law enforcement requests
or requirements relating to your use of the Site or information provided to or gathered by Surepoint Financial Group with respect to such use. If any
part of this agreement is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty
disclaimers and liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid,
enforceable provision that most closely matches the intent of the original provision and the remainder of the agreement shall continue in
effect.

Unless otherwise specified herein, this agreement constitutes the entire agreement between the user and Surepoint Financial Group with respect to
the Site and it supersedes all prior or contemporaneous communications and proposals, whether electronic, oral or written, between the
user and Surepoint Financial Group with respect to the Site. A printed version of this agreement and of any notice given in electronic form shall be
admissible in judicial or administrative proceedings based upon or relating to this agreement to the same extent and subject to the same
conditions as other business documents and records originally generated and maintained in printed form. It is the express wish to the
parties that this agreement and all related documents be written in English.

Changes to Terms

Surepoint Financial Group reserves the right, in its sole discretion, to change the Terms under which https://Surepoint Financial Group.com https://Surepoint Financial Group.com is offered. The most current version of the Terms will supersede all previous versions. Surepoint Financial Group encourages you to
periodically review the Terms to stay informed of our updates.

Loan Eligibility Service

In connection with your use of this site, Surepoint Financial Group shares your Personal Information with Monevo Inc to provide the loan eligibility
service and their related tools and services. You acknowledge that by agreeing to this privacy policy you have also read and agree to
Monevo Inc’s Terms of Service, Credit Authorization Agreement, eConsent & Privacy Policy.

Effective Date: 01/01/2020
Last Reviewed on: 03/01/2021

This Privacy Notice for California Residents supplements the information contained in Surepoint Financial Group’s Privacy Policy and applies solely
to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the
California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

A. Information We Collect

Personal information you provide to us. Personal information you may provide to us when you use the service such as:

Contact data, such as your first and last name, email address, residential address and phone number.
Identity data, such as your Social Security number and date of birth.
Credit history and loan data, such as your estimated credit score, vehicle and home ownership status and other information.
Employment data, such as your employment status, employer name, and income
Education data, such as the education level you have obtained.

Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or
as otherwise disclosed at the timeof collection.

Other sources. As part of our service we may receive information from the Partners we connect you with including, but not limited to
status of product acceptance and funding, and loan terms offered and obtained (such as APR, repayment amount, loan amount). As
part of our service we may also receive information from Transunion when we perform a soft credit check including but not limited to
your credit score and profile. We may combine personal information we receive from you with information we obtain from other
sources, such as:

Data providers, such as credit bureaus and information services.
Business partners, third parties, lenders, or affiliates, as well as other information provided to us online or offline by customers or
users of Surepoint Financial Group.us

Automatic Collection. We, our service providers and our third party partners may automatically capture information about you, your
computer or mobile device, and your activity over time on the service and other online services, including:

Online activity data, such as the date and time of your access, visit or use of the service, and information about your activity on a
page or screen.

Device data, such as unique device identifier, media access control address, network information, hardware model, browser type,
screen resolution, IP address as
well as usage and traffic data and information about how the device interacts with the service.

Cookies and Similar Technologies. To assist the services in collecting and storing Non-Personal Information, we may employ a variety
of technologies, including “Cookies,” local browser storage and “Web Beacons”:

Cookies, A “Cookie” is a small amount of data a website may store in your web browser that it can access when you visit it. A cookie
also refers to web-browser- based storage provided by Adobe’s Flash plugin (a “Flash Cookie”). Cookies may contain user preferences,
unique identifiers and other Non-Personal Information. See our Cookie Policy for more information on how cookies are used and
how to manage your preferences.

Web beacons, A “Web Beacon” is a small, usually-transparent image placed on a web page that allows us or our partners to collect
non-Personal Information.

How We Use Your Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following business purposes listed below.

Service delivery We may use your personal information to:

Provide, deliver, and customize your use of the Surepoint Financial Group service;
Connect you with partners, lenders, aggregators, and/or loan originators and send you service-related information;
Communicate with you about the service and to respond to your inquiries, including for Customer support;
Send you important information regarding the services, changes to our terms, conditions, and Policies and/or other administrative
information.
Understand your needs and interests, and personalize your experience with the service and our communications; and
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured
for, or controlled by the business, and to improve,

Research and development. We may use your personal information for research and development purposes, including to perform
research and analysis aimed at improving our products and services. We make personal information into anonymous data by removing
information that makes the data personally identifiable in order to share it with third parties for our lawful business purposes, including
to analyze and improve the service and promote our business.

Marketing and advertising. With your consent, we and our third party advertising partners and business partners may use your personal
information for marketing and advertising purposes:

Direct marketing. We may send you Surepoint Financial Group related or other direct marketing communications as permitted by law. You may
opt-out of our marketing communications from Surepoint Financial Group by Unsubscribing.

Interest-based advertising. We may partner with third-party companies to display ads on the service and other sites. These companies
may use cookies and similar technologies to try to tailor the ads you see online to your interests based on your activity over time
across the service and other sites, or your interaction with our emails. These ads are known as “interest-based advertisements.” For
more information on these advertisements and to manage your preferences, visit our Privacy Portal

Compliance and protection. We may use your personal information to:

Comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government
authorities.
Perform debugging to identify and repair errors that impair existing intended functionality
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
Enforce the Terms of Service; and
Detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible
for that activity.

For other purposes. We may also use your personal information for other purposes described in this Privacy Policy or at the time we
collect the information, as permissible by law. Surepoint Financial Group will not collect additional categories of personal information or use
the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How We Share Your Personal Information.

Surepoint Financial Group may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Advertisers: Third party companies that we use to advertise our services, and/or deliver ads to you and similar users on their platforms or through email marketing
Authorities: Law enforcement, government authorities, privacy parties, and other applicable authorities
Business Partners: Third party companies that we partner with to provide content or services to you or to such business partners. Such as affiliates, data brokers,
and lending partners (please see our Partner List for more information on our network of lending partners)
Internet Cookie Data Recipients
Parent or Subsidiary Organizations
Professional advisors: Such as professional advisors, lawyers, bankers, auditors or insurers
Service providers: Such as credit bureaus and information services.
For other purposes: We may also share your personal information for other purposes described in this Privacy Policy or with your consent

Your Choices

Marketing communications. To opt out of email marketing, email us at info@surepointfinancialgroup.com or submit your email address here. Surepoint Financial Group will comply
with your unsubscribe request within ten days of submission, as required by law. You may continue to receive service-related and other non-marketing emails.
Cookies. See our Cookie Policy for more information on how cookies are used and how to manage your preferences.
Advertising choices. See our Privacy Portal for more information on how to manage your targeted advertising preferences.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. At this time, Surepoint Financial Group.us does
not respond to “do not track” signals that may be sent from your browser.
Declining to provide personal information. If you do not provide certain information that is needed to deliver the Surepoint Financial Group service, we may not be able to
provide you with all or certain features of the service.

Your Rights as a California Resident

As a California resident, you have the rights listed below. These rights are not absolute and subject to certain exceptions; we may decline your request in certain cases
as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with whom we share Personal Information.
Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of
third party recipient.
Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.

Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months. We endeavor to respond to a verifiable
consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) days, we will inform you of the reason and extension period
in writing. If applicable, the response we provide will explain the reasons we cannot comply with a request. We do not charge a fee to process or respond to your
verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made
that decision and provide you with a cost estimate before completing your request.
Deletion. You can ask us to delete the Personal Information that we have collected from you. We endeavor to respond to a verifiable consumer request within forty-
five (45) days of its receipt. If we require more time (up to forty-five (45) days, we will inform you of the reason and extension period in writing. If applicable, the
response we provide will explain the reasons we cannot comply with a request.
Opt-out of sales. If we sell your Personal Information, you can opt-out.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited
increases in the price or decreases in the quality of our service.

How to exercise your rights. You may exercise your California privacy rights described above as follows:

Right to information, access, deletion, and opt out. You can request to exercise your information, access, deletion, and opt out rights by:
Submitting a request through our Privacy Portal
Emailing info@surepointfinancialgroup.com

We reserve the right to confirm your identity and California residency status to process your requests to exercise your information,
access or deletion rights. As part of this process, government identification may be required.

B. Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices
during the 12 months preceding the effective date of this Privacy Policy.

Categories in the chart refer to the categories described above in the general section of this Privacy Policy. If a category of information is not listed within the chart
(such as Biometric Information or Inferences) then those categories of information are not collected by Surepoint Financial Group.

CATEGORY OF PERSONAL INFORMATION (PI) (DEFINITIONS HERE)	PI WE COLLECT	SOURCE OF PI	BUSINESS PURPOSE FOR COLLECTION	CATEGORIES OF THIRD PARTIES TO WHOM WE MAY “DISCLOSE” PI FOR A BUSINESS PURPOSE
Identifiers	Contact data Identity data	You Data providers Business Partners	Service delivery Marketing and advertising Compliance and protection	Advertising partners Authorities Business partners Parent or Subsidiary Organizations Professional advisors Service providers	Business partners
Commercial Information	Credit information and loan data Property data Online activity data	You Data providers Business Partners Automatic collection	Service delivery Research and development Marketing and advertising Compliance and protection	Affiliates Authorities Business Partners Internet Cookie Data Recipients Parent or Subsidiary Organizations Service Providers	Business partners
Financial Information	Credit information and loan data	You Data providers Business Partners	Service delivery Research and development Marketing Compliance and Operations	Authorities Parent or Subsidiary Organizations Partners Professional advisors Service providers	Business partners
Online Identifiers	Contact data Device data Online activity data	You Automatic Collection Business Partners	Service delivery Research and development Marketing and advertising Compliance and protection	Advertising partners Authorities Business partners Business transferees Parent or Subsidiary Organizations Professional advisors Service providers	Business partners
Internet or Network Information	Device data Online activity data	Automatic collection	Service delivery Research and development Marketing and advertising Compliance and protection	Parent or Subsidiary Organizations	None
Professional or Employment Information	Employment data	You	Service delivery Research and development Compliance and protection	Authorities Business partners Parent or Subsidiary Organizations Professional advisors	Business partners
Protected Classification Characteristics	Eligibility data Identity Data	You Data providers Business Partners	Service delivery Compliance and protection	Authorities Business partners Parent or Subsidiary Organizations Professional advisors Service providers	Business partners
Education Information	Education data (highest level of education)	You	Service delivery Research and development Compliance and protection	Authorities Business partners Parent or Subsidiary Organizations Professional advisors	Business partners

Showing 1 to 8 of 8 entries

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our
disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@surepointfinancialgroup.com or write
to us at: 3801 Springhurst Blvd Suite 202, Louisville, KY 40241. Privacy and copyright protection

Protecting your private information is our priority. This Statement of Privacy applies to https://surepointfinancialgroup.com and Surepoint Financial Group, Inc. and governs data collection
and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Surepoint Financial Group, Inc. include https://surepointfinancialgroup.com, Surepoint Financial Group,
Surepoint Financial Group and https://surepointfinancialgroup.com. The Surepoint Financial Group website is a Website description site. By using the Surepoint Financial Group website, you consent to the
data practices described in this statement.

Collection of your Personal Information

In order to better provide you with products and services offered on our Site, Surepoint Financial Group may collect personally identifiable information, such as your:

First and Last Name
Mailing Address
E-mail Address
Phone Number

If you purchase Surepoint Financial Group’s products and services, we collect billing and credit card information. This information is used to complete the purchase transaction.

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us
when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) entering a sweepstakes or
contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit
card or other payment information when ordering and purchasing products and services on our Site. To wit, we will use your information for, but not limited to,
communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the
future.

Use of your Personal Information

Surepoint Financial Group collects and uses your personal information to operate its website(s) and deliver the services you have requested.

Surepoint Financial Group may also use your personally identifiable information to inform you of other products or services available from Surepoint Financial Group and its affiliates.

Sharing Information with Third Parties

Surepoint Financial Group does not sell, rent or lease its customer lists to third parties.

Surepoint Financial Group may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases,
your unique personally identifiable information (e-mail, name, address, telephone number) is transferred to the third party. Surepoint Financial Group may share data with trusted
partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from
using your personal information except to provide these services to Surepoint Financial Group, and they are required to maintain the confidentiality of your information.

Surepoint Financial Group may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a)
conform to the edicts of the law or comply with legal process served on Surepoint Financial Group or the site; (b) protect and defend the rights or property of Surepoint Financial Group;
and/or (c) act under exigent circumstances to protect the personal safety of users of Surepoint Financial Group, or the public.

Tracking User Behavior

Surepoint Financial Group may keep track of the websites and pages our users visit within Surepoint Financial Group, in order to determine what Surepoint Financial Group services are the most
popular. This data is used to deliver customized content and advertising within Surepoint Financial Group to customers whose behavior indicates that they are interested in a
particular subject area.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by Surepoint Financial Group. This information can include: your IP address, browser type,
domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide
general statistics regarding use of the Surepoint Financial Group website.

Use of Cookies

The Surepoint Financial Group website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page
server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the
domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to
a specific page. For example, if you personalize Surepoint Financial Group pages, or register with Surepoint Financial Group site or services, a cookie helps Surepoint Financial Group to recall your
specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on.
When you return to the same Surepoint Financial Group website, the information you previously provided can be retrieved, so you can easily use the Surepoint Financial Group features that
you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if
you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Surepoint Financial Group services or websites you visit.

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users
to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Security of your Personal Information

Surepoint Financial Group secures your personal information from unauthorized access, use, or disclosure. Surepoint Financial Group uses the following methods for this purpose:

SSL Protocol

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets
Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission
over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that:
(a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and
data exchanged between you and us through this Site cannot be guaranteed.

Children Under Thirteen

Surepoint Financial Group does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask
your parent or guardian for permission to use this website.

Opt-Out & Unsubscribe from Third Party Communications

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all
communications from third-party partners of Surepoint Financial Group by contacting us here:

Web page: _________________
Email: Optout@surepointfinancialgroup.com
Phone: _________________

E-mail Communications

From time to time, Surepoint Financial Group may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or
other general communication. In order to improve our Services, we may receive a notification when you open an email from Surepoint Financial Group or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from Surepoint Financial Group, you may opt out of such communications by Customers may
unsubscribe from emails by “replying STOP” or “clicking on the UNSUBSCRIBE button.

External Data Storage Sites

We may store your data on servers provided by third party hosting vendors with whom we have contracted.

Changes to this Statement

Surepoint Financial Group reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information
by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this
page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy
Policy; and (b) agreement to abide and be bound by that Policy.

Loan Eligibility Service

In connection with your use of this site, Surepoint Financial Group shares your Personal Information with Monevo Inc to provide the loan eligibility service and their related tools
and services. You acknowledge that by agreeing to this privacy policy you have also read and agree to Monevo Inc’s Terms of Service, Credit Authorization, Agreement, eConsent & Privacy Policy.

3. Electronic Consent

Please read this information carefully and print a copy and/or retain this information for future
reference.

By utilizing this website and clicking the “submit” button, you are submitting a request to be connected with one of our third-party advertisers or lenders, collectively
“third parties.” In order to attempt to connect you with an entity mentioned above, that may offer you a financial product or service, the third parties need your consent
to use and accept electronic signatures, records, and disclosures (“E-Consent”). This policy notifies you of your rights when receiving electronic disclosures, notices,
information and other forms of communication. By submitting your information on our website, you acknowledge that you have received and reviewed this E-Consent
Policy, and that you consent to conduct transactions using electronic signatures, electronic disclosures, electronic records, and electronic contract documents
(“Disclosures”).

Option for Paper or Non-Electronic Records.

If you are connected with a Lender, and said Lender determines that you are a potential candidate for a financial product or loan, and said Lender offers you an electronic
copy of any pertinent Disclosures related to that loan, you may, at any time, request any Disclosures in paper form by contacting the third party lender directly.
Depending on the specific Disclosure request to the Lender, the Lender may be able to provide these Disclosures to you at no or minimal charge. Each third party shall
retain all Disclosures as required by any applicable laws to the specific transaction.

Scope of Consent.

This E-Consent Policy applies to all interactions online concerning you, and the third party Lender or Advertiser, and includes those interactions engaged in on any
mobile device, including phones, smart-phones, tablets, and any other electronic device that allows the consumer to connect to the Internet. By exercising this E-
Consent, the third party may process your information and interact during all online interactions with you electronically. The third party may also send you notices
electronically related to its interactions and transactions. Disclosures may be provided online at Surepoint Financial Group.com or the third party websites, and may be provided by
e-mail. See above for guidance on how to request paper copies.

Consenting to Do Business Electronically.

Before you decide to do business electronically with the third party advertiser, you should consider whether 1. You wish to conduct business electronically, and 2. You
have the required hardware and software capabilities described below.

Hardware and Software Requirements.

To both access and retain the Disclosures electronically, at a minimum, you will need to use the following computer software and hardware: A PC or MAC compatible
computer or other device capable of accessing the Internet, access to an electronic mail (e-mail) account, and an Internet Browser software program that supports at
least 256-BIT encryption, including but not limited to, Microsoft® Internet Explorer, Google Chrome® or Mozilla Firefox®. To read some documents, you may need a PDF
file reader like Adobe® Acrobat Reader® or Foxit®. You will need a printer or a long-term storage device, such as your computer’s disk drive, to retain a copy of the
Disclosures for future reference. You may send any questions regarding the specific hardware and software requirements directly to the third party lender or advertiser.

Withdrawing Consent.

If you are connected with one or more third-party lenders, you are free to withdraw your E-Consent with those third-parties at any time, and at no charge. However, if
you withdraw this E-Consent before being connected with the third party Lender, you may be prevented from obtaining an offer from the third party as this consent is
required, for this one time transaction, to facilitate the connection and to conduct business. Contact the third-party lender directly if you wish to withdraw this E-
Consent. If you decide to withdraw this E-Consent, the legal effectiveness, validity, and enforceability of prior electronic disclosures will not be affected.

Change to Your Contact Information.

You should keep third party advertisers informed of any change in either your electronic address or physical mailing address. Your lender will have specific instructions
on how to update your contact information, if necessary. Please note that Surepoint Financial Group.com cannot update your information for you.

Your Ability to Access Disclosures.

By clicking and submitting your information, you assent to our terms and conditions. You acknowledge that you can access the disclosures in the designated formats
described above.