Privacy Policy

Arcane Pathways LLC, doing business as Arcane Credit ("Arcane Credit," "we," "us," or "our"), values your privacy. This Privacy Policy explains how we collect, use, share, and protect information when you visit or interact with our websites, including arcanecredit.com, and any other web pages or links where this Privacy Policy is posted or where we provide services (collectively, the "Site"), as well as when you use our products and services (the "Services").

This Policy covers information we collect directly from you, information collected automatically when you use the Site, and information we may receive from third parties in connection with the Services we provide. Certain features available through the Arcane Credit app, such as the Credit Builder Account, are provided entirely by third-party partners and are subject to their own privacy policies, terms, and consent flows. By accessing or using the Site or Services, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy is part of the terms and conditions set forth in our Terms of Use, which governs your use of our Services.

1. Information We Collect and Where It Comes From

The types of information we collect depend on how you use the Site and Services. We may collect the following categories:

A. Information you (or your authorized representative) give us

• Contact details: such as your name, mailing address, email address, and phone number.
• Financial details: such as payment card information, bank account information, credit information (such as credit score), and other financial information (such as salary, income, assets, or debts).
• User identifiers: such as screen name, handle, account ID, assigned user ID, customer number, probabilistic identifier, or other user- or account-level ID that can be used to identify a particular user or account.
• Device identifiers: such as the device's advertising identifier, or other device-level ID.
• Identification details: such as your Social Security number, driver's license number, and date of birth. In some situations, we may request images or copies of government-issued ID (for example, a passport or driver's license).
• Employment details: such as employer name, job title, and income-related information.
• Transaction and account activity on the Site: such as information related to purchases, payments, or other actions taken through the Site or Services.
• Anything else you choose to submit: such as information you include in messages, forms, surveys, or other submissions.

Depending on the Service, we may ask you to verify your identity and (with your permission) connect one or more deposit accounts so we can review transaction activity. This helps us identify recurring payments you want reported to one or more consumer reporting agencies.

To connect an account and retrieve account data, we use Plaid Inc. ("Plaid") as a third-party intermediary to collect information directly from the financial institution you choose. By using our Services, you grant Arcane Credit and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your selected financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy. After the connection is established, we may receive and review certain transaction details and provide you with insights or feedback related to the Service.

B. Information collected automatically when you use the Site

• Usage and device data: such as pages viewed, links clicked, referring/exit pages, browser type, device identifiers, operating system, timestamps, and other technical details.
• Approximate location data: such as the city/state/country associated with your IP address.

C. Information you share on social media

If you interact with us through social media, anything you post publicly is generally controlled by the social media platform and may be visible to others. If you choose to provide information to us through our social media pages, we will treat it in line with this Policy — but we strongly recommend you avoid posting sensitive personal information via social media.

D. Information we receive from third parties

We may receive information about you from third parties that help us provide the Services, such as:

• Financial and account-related information: including bank account information obtained through Plaid (when you have authorized the connection).
• Consumer report information: where applicable, information from consumer reporting agencies used in connection with Services involving credit reporting, credit-related insights, or related offerings. You understand that by using our Services, you are providing written instructions in accordance with the Fair Credit Reporting Act ("FCRA") and other applicable law for Arcane Credit to request and receive copies of consumer reports, scores, and other information about you from third parties, including but not limited to Experian, TransUnion, and Equifax. You further understand that your instructions let Arcane Credit obtain such information at any time for as long as you have a registered Arcane Credit account, to use as described in the Terms of Use and in this Privacy Policy.
• Identity and verification data: including information used to confirm your identity and validate information you provide. We use Plaid Identity Verification (IDV) to automatically cross-reference user information against trusted data sources, including credit reporting agencies, DMV records, and voter registration rolls. If automated verification is unsuccessful, you may be required to complete a manual review process (government-issued ID and selfie submission) before accessing the Services.

2. How We Use Information

We use collected information to operate, maintain, and improve the Site and Services, including for the following purposes:

• To provide and administer the Services: This includes setting up and maintaining your account/profile, delivering requested features, and (where applicable and authorized) furnishing certain payment history or repayment information to consumer reporting agencies.
• To support partner-enabled offerings: Some Services may be offered with or through business partners. We may use certain information to enable those partner offerings.
• To communicate with you and provide support: Including responding to requests, sending service messages, troubleshooting, and answering questions.
• For marketing and promotional outreach: We may send communications about updates, new offerings, and promotions. Where available, you can opt out of promotional communications.
• To improve and develop our products: Including analytics, research, and testing to better understand how people use our Site and Services. This may include evaluating trends connected to repayment information processed through our relationships with consumer reporting agencies (where applicable).
• For legal, compliance, and protection purposes: Including meeting legal obligations, enforcing our terms, preventing fraud and misuse, and protecting our rights, users, and business.

3. Automated Processing

To optimize your experience using the Site and Services, we may process your personal information using both automated and manual methods. Automated methods may include the use of identity verification technology through Plaid IDV, which cross-references your information against trusted data sources to verify your identity. This automated processing is used to verify consumer identity during onboarding, prevent fraud and unauthorized account creation, and ensure accuracy of information furnished to consumer reporting agencies. If automated identity verification is unsuccessful, you may be required to complete a manual review process (government-issued ID and selfie submission) before accessing the Services.

4. How Long We Keep Information

We keep personal information for as long as reasonably necessary for business and operational purposes, consistent with our internal retention practices, our agreements with business partners, and applicable laws and regulations.

We may also retain de-identified or non-identifiable information for longer periods (including indefinitely). We may use and share this de-identified information in any lawful manner.

5. When We Share Information

We may disclose your information in the following situations:

• Service providers and vendors: We may share information with third parties that perform services on our behalf (for example, hosting, analytics, customer support tools, communications providers, marketing support, and similar vendors). These providers may be located in the United States or other countries.
• Consumer reporting agencies: If you use Services that involve credit reporting, we may share relevant payment history with one or more consumer reporting agencies. We will obtain your consent before sharing payment history for credit reporting purposes.
• Plaid: We share information with Plaid Inc. in connection with bank account linking, identity verification, and transaction data retrieval. Plaid's use of your information is governed by the Plaid Privacy Policy.
• Business partners: We may share information with partners who offer Arcane Credit products or services directly to you or jointly with us. Certain features available in the app, such as the Credit Builder Account, are provided entirely by third-party partners who collect your information and obtain your consent independently through their own embedded interfaces. Those partners' privacy policies and terms govern their handling of your data.
• Third parties you choose: We may share information with parties you direct us to share with in connection with a Service.
• Your financial institution: We may share information (including information related to your use of the Services) with the financial institution that maintains the account used for payment reporting through our Services.
• Advertising and marketing partners: We may share information with advertising and marketing partners that help promote our offerings.
• Legal and safety reasons: We may disclose information if we believe disclosure is reasonably necessary to: comply with law; respond to lawful requests; support investigations; prevent fraud or abuse; protect the security of the Site; or protect the rights, property, or safety of Arcane Credit, our users, or others. This may include sharing information with law enforcement, regulators, government agencies, or professional advisors (such as attorneys and auditors).
• Business transfers: If we are involved in a merger, acquisition, reorganization, financing, sale of assets, bankruptcy, or similar transaction (including due diligence discussions), information may be disclosed and/or transferred as part of that process.
• Other situations explained at the time of collection: We may also share information as otherwise described when you provide the information or when you use a particular feature.

6. Online Tracking and Similar Technologies

We and our partners may use tools that collect information about how you interact with the Site. This helps with site functionality, analytics, fraud prevention, advertising, and improving the user experience.

These technologies may include:

• Cookies. Cookies are small files stored on your device that help websites function and remember certain information. We may use cookies such as: strictly necessary cookies (required for core Site functions), analytics cookies (to understand how people use the Site), functionality cookies (to remember preferences), and advertising cookies (to deliver relevant ads and measure performance). You can usually control cookies through your browser settings. If you block or delete cookies, some parts of the Site may not work properly.
• Pixels / web beacons. These are small invisible images or code that may help us measure traffic, understand usage, and evaluate campaign performance.
• Activity replay tools. We may use technology that records or reconstructs how users interact with the Site (for example, mouse movements, clicks, scrolling, and form inputs). We use this to improve the Site, fix problems, and support user experience and troubleshooting.
• Analytics tools. We may use analytics services (including tools like Google Analytics) to understand Site usage and engagement, including how users interact with our communications.
• Device and network details. We may collect technical data such as device type, operating system, browser type, and IP address.
• Third-party tracking. Some Site features or content may be provided by third parties. Those third parties may collect information over time and across websites using cookies, pixels, or similar tools. We do not control their tracking methods. If you have questions about a third party's advertising practices, you should contact that provider directly.

7. Information Security

We use administrative, technical, and organizational safeguards designed to protect personal information. These include:

• Encryption: We enable Secure Socket Layer (SSL) technology to create encrypted connections between your device and our servers.
• Access controls: We limit access to personal information to employees, contractors, and service providers on a need-to-know basis.
• Infrastructure security: We use firewalls and other security solutions to protect our servers and safely store your personal information.
• Data destruction: Personal information that we no longer need to retain is securely destroyed by shredding, erasing, or otherwise modifying the information to make it unreadable or indecipherable.

However, no online system can be guaranteed perfectly secure. For that reason, we cannot promise absolute security for information transmitted to us or stored by us. You are responsible for maintaining the confidentiality of your login credentials and taking reasonable precautions when sharing information online.

8. Social Security Number Safeguards

Social Security numbers collected during enrollment are treated as confidential and may only be accessed by and disclosed to our employees and others with a legitimate business need in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to safeguards and must be stored, transmitted, and disposed of in accordance with our internal policies created and maintained to protect confidential information from unlawful disclosure and to limit access. These restrictions apply to all Social Security numbers collected or retained by Arcane Credit and related service providers and vendors.

9. Your Choices and Controls

You have options regarding your personal information:

• Choosing not to provide information: you may decline to provide certain information, but that may limit access to parts of the Site or Services.
• Updating your information: you may ask us to correct or update certain information we maintain about you.
• Revoking connected-account consent: if you authorized access to financial account data through Plaid, you may withdraw that authorization by contacting us at dataprivacy@arcanecredit.com.

Do Not Track

Some browsers offer a "Do Not Track" signal. Because there is no widely adopted standard for how websites must respond to that signal, our Site does not currently respond to "Do Not Track" requests in a uniform way.

Interest-based advertising choices

You may be able to limit certain targeted advertising through industry programs such as the Network Advertising Initiative, the Digital Advertising Alliance, and AppChoices for mobile users. For reference:

• https://thenai.org/about-online-advertising/
• https://digitaladvertisingalliance.org/
• https://youradchoices.com/appchoices

Marketing communications

You can opt out of promotional emails or texts by using the unsubscribe or opt-out instructions included in those messages, or by contacting us at dataprivacy@arcanecredit.com. Even if you opt out of marketing, we may still send non-promotional messages (such as account notices, security alerts, or service updates). Opt-out requests may take a reasonable period to process.

10. Data Deletion Requests

You may request deletion of your personal data at any time through either of the following methods:

• In the app: Log in and navigate to More Tab > Legal & Privacy > Request Personal Data Deletion.
• By email: Send your request to dataprivacy@arcanecredit.com. Include your full name, date of birth, and the email address associated with your Arcane Credit account.

Once your request is submitted, we will email you with an update and any applicable next steps.

Important: Deleting your data will terminate your Arcane Credit membership. We may not be able to process a deletion request if you maintain any active Arcane Credit accounts, including a Credit Builder (BuildCredit) account or a Rent & Bill Reporting subscription.

Please note that removing the Arcane Credit app or any other Arcane Credit mobile application from your device will not cancel your account(s) or delete your data. You must submit a deletion request through the methods described above.

We may retain certain information after a deletion request where required by law or regulation, including records necessary for compliance with the Fair Credit Reporting Act, Regulation E, or other applicable legal obligations. Please note that a deletion request submitted to Arcane Credit does not affect data independently collected and held by third-party partners (such as the Credit Builder Account provider) through their own embedded interfaces — you may need to contact those partners directly.

11. California Residents — CCPA Notice

This section applies to residents of California and supplements the information in this Privacy Policy, as required by the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA").

Categories of Personal Information Collected

In the preceding 12 months, we may have collected the following categories of personal information (as defined by the CCPA):

Sources of Personal Information

We collect personal information from the following sources: directly from you, automatically when you use the Site, from Plaid (bank account linking and identity verification), from consumer reporting agencies, and from analytics and advertising partners.

Business or Commercial Purpose for Collection

We collect personal information for the purposes described in Section 2 of this Privacy Policy, including providing and administering Services, communicating with you, improving our products, marketing, and legal compliance.

Sale and Sharing of Personal Information

Arcane Credit does not sell your personal information as defined under the CCPA. We may share personal information with advertising and analytics partners for purposes that may be considered "sharing" under the CCPA. You have the right to opt out of such sharing.

Your Rights Under the CCPA

If you are a California resident, you have the following rights:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share your information.
• Right to Delete: You may request that we delete your personal information, subject to certain exceptions (such as information required for legal compliance or to complete a transaction you requested). See Section 10 for how to submit a deletion request.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt Out of Sharing: You may opt out of the sharing of your personal information for cross-context behavioral advertising purposes.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. We will not deny you Services, charge you different prices, or provide a different level of quality because you exercised your rights.

How to Exercise Your Rights

To submit a request to know, delete, or correct your personal information, contact us at dataprivacy@arcanecredit.com or submit a request through the app (More Tab > Legal & Privacy). We will verify your identity before processing your request. You may also designate an authorized agent to submit a request on your behalf, provided you supply written authorization and we can verify your identity.

We will respond to verifiable consumer requests within 45 days of receipt. If we need additional time, we will notify you of the extension and the reason for it.

California Shine the Light

Under California Civil Code Section 1798.83, California residents may request information regarding how we share certain categories of personal information with third parties for their direct marketing purposes. To make such a request, contact us at dataprivacy@arcanecredit.com.

12. Consent to Transfer Information to the United States

The Site and Services are operated in the United States and are intended for users located in the United States. If you are located outside of the United States, please note that information we collect, including personal information, will be transferred to and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States. By using the Site or Services or providing us with any information, you consent to the transfer, processing, and storage of your information in the United States.

13. Third-Party Sites and Links

The Site may contain links to websites or services operated by others. This Privacy Policy does not apply to third-party practices. We encourage you to read the privacy policies of any third-party site before providing information to them.

14. Children's Privacy

Our Site and Services are intended for adults and are not directed to individuals under 18. We do not knowingly collect personal information from anyone under 18. If we learn we have collected personal information from a minor, we will take steps to delete it. If you believe a minor has provided us personal information, please contact us at dataprivacy@arcanecredit.com.

15. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. We will take any steps required by applicable law to notify you of material changes, by sending a notice to the email address associated with your account or by placing a prominent notice on the Site. The "Last Updated" date at the top indicates when this Policy was most recently changed. If you continue using the Site or Services after updates are posted, you are agreeing to the revised Policy.

16. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

Email: dataprivacy@arcanecredit.com

Mail: Arcane Pathways LLC, Attn: Privacy, 3651 Lindell Rd Ste D314, Las Vegas, NV 89103

Customer Support: support@arcanecredit.com