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Privacy Policy

padgettleessummit.com ("we," "our," "us") provides this Privacy Policy to describe how we collect, use, disclose, and protect Personal Information when you visit our website.

We encourage you to read this Privacy Policy and to use it to help you make informed decisions.

We revise this Privacy Policy from time to time to reflect changes to our business, Services, or applicable laws. If a revised version requires notice in accordance with applicable law, we will provide advance notice by posting on this page; otherwise, the revised Privacy Policy will be effective as of the published effective date.

HOW THIS POLICY APPLIES

This Policy has two parts so you can clearly see which rules apply to which data uses:

Part A — GLBA/FCRA ("GLBA Track")
Applies to nonpublic personal information (NPI) collected in connection with your loan offer request, and to any credit information we obtain with your written instructions (e.g., a soft credit inquiry) to evaluate you for alternative financial solutions.
Part B — State Privacy Laws ("State Track")
Applies only to NPI processed on this site that is not subject to GLBA/FCRA—for example, site telemetry, or advertising/analytics outside of the GLBA context.

If information you submit relates to a financial-product request, GLBA controls even if the same identifiers also appear in other contexts.

PART A — GLBA/FCRA PRIVACY NOTICE

PRIVACY POLICY
FACTS	WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Identifiers and contact information (e.g., name, email, phone numbers, address). • Application/request information (e.g., date of birth, military and employment status, employer and job title, time at job and address, income and pay details, requested amount and purpose, whether you own a car or home, mortgage status, self-reported credit score or debt amount, best time to call). • Sensitive identifiers (e.g., Social Security number; driver's license number and issuing state). • Financial account information (e.g., bank name, routing and account number, account type, time with bank, direct deposit status). • Transaction and experience information related to your request and interactions with us (e.g., submission dates, servicing and customer support records, survey responses). • Credit information (e.g., results of a soft inquiry obtained with your written instructions; not shared with third parties; participating lenders may obtain credit reports directly from consumer reporting agencies). • Technical and security data used to protect and process your request (e.g., IP address and device/user-agent, cookies/session identifiers used for fraud prevention, authentication, and consent logging; not used for cross-context behavioral advertising).
How?	All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons we choose to share; and whether you can limit this sharing.
SHARING YOUR PERSONAL INFORMATION
Reasons We Can Share Your Personal Information				Do We Share?	Can You Limit Sharing?
For our everyday business purposes — to process your request, verify identity, prevent fraud, evaluate eligibility, and route/transmit your information (including via a lender "ping" process) to participating Lenders/Networks or Third-party Marketers - personal-finance-related service providers at your direction				Yes	No
For our everyday business purposes — information about your creditworthiness (e.g., enabling an FCRA-permitted soft inquiry pursuant to your written instructions; Lenders obtain reports directly from CRAs)				Yes	No
For our marketing purposes — to market our own websites and Services to you (e.g., to bring you back to complete your request)				Yes	No (communications preferences/TCPA & CAN-SPAM still apply)
For joint marketing with other financial companies				No	We don't share
For our affiliates' everyday business purposes — information about transactions and experiences				No	We don't share
For our affiliates' everyday business purposes — information about your creditworthiness				No	We don't share
For our affiliates to market to you				No	We don't share
For nonaffiliates to market to you				Yes	Yes (consent/direction exception applies)*
*Clarification about exception: When Lenders/Networks contact you about the credit you asked us to match you for, that disclosure occurs to effect, administer, or enforce your requested transaction and/or at your direction. It is not a "nonaffiliate marketing" share. Non-selected recipients in the ping process are contractually prohibited from contacting you and must not retain your information. We disclose your information to Lenders/Networks and Third-party Marketers at your direction (consent), so they can contact you about their products. We retain records of your direction.
To Limit Our Sharing			Email [email protected] with subject "GLBA opt-out" and include your name, email, and phone number used on your request. What this does: Your choice limits our sharing of your nonpublic personal information with non-affiliated third parties so they can market their own products to you. What it doesn't limit: This choice does not limit disclosures needed to evaluate, effect, administer, or enforce your current request (including lender "ping" eligibility checks), disclosures to our service providers/contractors acting on our behalf. Duration & scope: Your choice remains in effect until you tell us otherwise. We will apply it as soon as reasonably practicable and include your preference when we share leads. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions?			Email us at [email protected]
Sharing Your Sensitive Personal Information
We share Sensitive Personal Information only with our Marketing Partners when necessary to assist you in finding a loan, when required by law, or with your explicit consent. The non-exhaustive list of Marketing Partners is available.
Definitions
Affiliates	Companies related by common ownership or control. They are non-financial companies.
Non Affiliates	Companies not related by common ownership or control. They can be financial and non-financial companies (see categories below).
Third-party Marketers	Non-affiliated providers or promoters of personal-finance products/services (and their intermediaries), including credit, banking/fintech, credit-monitoring/builder/education or repair, and debt-management/relief offerings.
Lenders/Networks	Non-affiliated lenders, together with their intermediaries (including agents, aggregators, brokers, lead networks, and marketplaces) and service providers acting on their behalf.
Marketing Partners	Lenders/Networks and Third-party Marketers
Categories of Non-Affiliates We Share Information With
Lenders/Networks Third-Party Marketers Service Providers (Cloud storage and hosting providers (e.g. AWS), Email/SMS delivery providers, Consumer Reporting Agencies (CRAs) or facilitators, advertising platforms).
WHO WE ARE
Who is providing this notice?		This notice is provided by padgettleessummit.com, the entity responsible for collecting and processing your personal information as you interact with our platform.
WHAT WE DO
How We Protect Your Information		We employ industry-standard security measures, including: Secure transmission of credit data under § 1016.30(b) (GLBA Safeguards (encryption). Firewalls and secure data storage. Restricted access to sensitive information. Multi-factor authentication Regular security assessments Breach response plans Controlled data sharing: We ensure that any transfer of data to our partners is limited to specified purposes and governed by agreements that include strict security and confidentiality obligations. However, no method of transmission over the Internet is 100% secure.
How Do We Collect Your Personal Information?		We collect your personal information when you: Submit an inquiry on our platform or on our affiliates' websites. Interact with our website, including browsing, filling out forms, answering surveys. Communicate with us. We also collect your personal information from others, such as credit bureaus, affiliates, or other companies as permitted.
Why Can't You Limit All Sharing?		Under applicable laws you can't limit sharing personal information for business purposes, such as but not limited to: processing your request to connect you with a lender, preventing fraud, etc. You may limit our sharing with non-affiliated marketers for their own offers – see State Track for additional opt-outs that do not apply to GLBA data.
OTHER IMPORTANT INFORMATION
We do not sell or share personal information collected on this loan offer inquiry page for cross-context behavioral advertising, and we do not use targeted advertising on this page. Limited hashed identifier uploads to advertising platforms are conducted outside the loan form context and are covered under Part B. When we process information in connection with a financial product or service, it is governed by GLBA/FCRA. Accordingly, state-law rights (e.g., "Do Not Sell/Share," limit Sensitive PI, GPC/UOOM) do not apply to these processings.

PART B — STATE PRIVACY NOTICE

NOTICE AT COLLECTION

Scope. This Notice at Collection summarizes what personal information we collect at or before the point of collection, the purposes for which we use it, how long we retain it, and whether we sell or share it (as those terms are defined by applicable U.S. state privacy laws). It should be read together with our full Policy referenced below.

Categories & Purposes. We collect the categories of personal information listed in Personal Information We Collect (table below) and use them for the purposes shown there—providing services and processing requests, matching you with personal-finance-related service providers, security, identification, communication, and compliance with law. See Personal Information We Collect for category-by-category details.

Reuse of Information. In connection with the purposes described above, we may use information you previously provided to us or to our Marketing Partners requesting a loan offer to evaluate and personalize which solutions we show you. We may also securely retain your prior request and, when you return to our site within a reasonable period, use your previously provided information to help you quickly obtain updated offers without requiring you to re-enter the same information, unless you choose to stop this feature. We treat all such reused information as GLBA "nonpublic personal information." State-law rights do not apply to this reuse. See Part A.

Selling/Sharing. We sell certain personal information (for example, lead information) to our Marketing Partners so they can contact you about their products or services. You can exercise your right to opt out of sale/sharing at any time via Your Privacy Choices (Do Not Sell/Share). See Information Sold to or Shared with Third Parties for categories and recipients. We do not sell or share Personal Information for cross-context behavioral advertising.

Use/Disclosure of Sensitive Personal Information. We use or disclose Sensitive PI (e.g., SSN, driver's license) only as necessary to provide requested services, verify identity, ensure security, and comply with law. You may Limit the Use of My Sensitive PI as provided in the Your Rights section.

Retention. We retain personal information only as long as needed for the purposes described above or as required by law.

Your Choices & Rights. You may access, delete, correct, opt out of sale/sharing, limit Sensitive PI, and appeal as described in Your Rights and How to Exercise Your Rights (Your Privacy Choices).

PERSONAL INFORMATION WE COLLECT

In the 12 months we have collected (either directly through this Site or from our other sites) the following categories of personal information:

State-Law Sell/Share Table (Non-GLBA PI)

Category (collected on this site)	Examples	Sources	Purpose	Shared with
Identifiers	Phone, email	From you on this site	Identification, to contact about offers from Marketing Partners, Communication	Third-Party Marketers (Non-GLBA Uses) Service Providers
Internet / Network Activity	Cookies/pixels/SDKs, pages viewed, referrers/UTM, approximate IP-based location	Automatically via our systems when you visit the site	To create, manage, and optimize advertising audiences on platforms such as Meta and TikTok	Advertising Platforms
Communications & Consent Records	TCPA/email consents, "Do Not Sell/Share", unsubscribe logs	An explicit form submit	To comply with applicable laws	Third-Party Marketers (Non-GLBA Uses) Service Providers

Personal information excludes publicly available data and data that has been de-identified or aggregated so it can't reasonably identify you. We use de-identified, aggregated data to analyze and improve our services.

INFORMATION SOLD TO OR SHARED WITH THIRD PARTIES

Consent-Based Disclosures. By providing your consent, you authorize us to sell and share the personal information you provide with Marketing Partners so we can help you find a personal finance related product or service that could be relevant to you.

In the past 12 months, the following categories of personal information were sold or shared with the following categories of third parties:

Shared With (Category of Third Party)	Categories of Personal Information Sold/Shared
Third-Party Marketers (Non-GLBA Uses)	Identifiers, Commercial, Internet / Network Activity, Inferences (from this site), Geolocation (approx.), Consent Records

We only sell or share your information:

For the purposes you authorize,
Subject to contractual obligations that restrict the recipient from using the information for unauthorized purposes.

You may withdraw your authorization or opt out of future sales or sharing at any time by visiting: Do Not Sell or Share My Personal Information (GLBA exclusions apply).

The non-exhaustive list of Marketing Partners is available.

Note: We do not sell or share PI for cross-context behavioral advertising.

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the past 12 months as of the day of this Policy, we have disclosed personal information to the following categories of service providers for the business purposes listed below. These service providers do not use personal information for their own purposes; they only process it to provide tools and services to us.

Categories of Service Providers	Business Purpose for Disclosure	Categories of Personal Information
Cloud Storage and Hosting Providers (e.g. AWS)	Securely storing and managing data	All categories of Personal Information
Email/SMS Delivery Providers	Transactional and marketing communications	Identifiers
Consumer Reporting Agencies (CRAs) or facilitators	Obtain consumer report information to verify identity, assess eligibility, and determine which services/offers you may qualify for from participating Marketing Partners	Identifiers
Advertising Platforms	To create, manage, and optimize advertising audiences on platforms such as Meta and TikTok	Identifiers, Internet or Other Electronic Network Activity (hashed only)

USE OR DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

We do not collect, use, sell, share, or disclose Sensitive Personal Information in this State-Privacy Track. We also do not use Sensitive Personal Information to infer characteristics about you or for targeted advertising.

DO NOT TRACK

We do not engage in tracking individuals across third-party websites or online services, so our Site does not respond to "Do Not Track" browser settings or signals.

YOUR RIGHTS

You have the following rights as a consumer:

Right	Description
Right to Know / Access	You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, including the sources, purposes for collection, categories of third parties with whom we share it, and whether it was sold or shared.
Right to Delete	You can request that we delete personal information we have collected from you. We will comply unless there is a legal or business reason to retain it, such as completing a transaction, detecting security incidents, or complying with legal obligations.
Right to Correct	You have the right to request that we correct any inaccurate personal information we maintain about you, and we will use commercially reasonable efforts to do so upon verification of your identity.
Right to Data Portability	You have the right to obtain and reuse your personal information for your own purposes. We will provide your information in a structured, commonly used, and machine-readable format upon request.
Right to Opt-Out of Sale/Sharing	You may opt out of the sale or sharing of your personal information, including sharing for targeted advertising purposes.
Right to Opt-Out of Automated Decision-Making	In states like Colorado, Connecticut, and Virginia, you may opt out of profiling and automated decision-making that produces legal or similarly significant effects.
Right to Limit Use of Sensitive PI	You may request that we limit the use or disclosure of your sensitive personal information (e.g., account log-in) unless it's strictly necessary to provide the requested services.
Right to Non-Discrimination	You have the right not to be discriminated against for exercising your privacy rights. This means we won't deny services, charge different prices, or provide a lower level of service based solely on your privacy choices.
Right to Appeal	If we deny your request to access, delete, or correct your information, you can appeal the decision. We will provide clear instructions on how to submit an appeal and respond within the time period required by law.
Right to Lodge Complaint	If you believe your data privacy rights have been violated, you may file a complaint with your local data protection authority or relevant regulatory body.

HOW TO EXERCISE YOUR RIGHTS

To request access, correction, or deletion of your personal information; or to limit use of sensitive PI, please email us at [email protected] and include your name.

To appeal our denial of your request, email us at with the subject line: "Appeal of Privacy Rights Request."

We may ask for your contact details (such as name, address, phone number, and email) to confirm your identity. Verification may involve logging into your account and confirming a one-time passcode, or answering a few questions to help us verify who you are. We use this information only to process your request securely.

If you are making a request on someone else's behalf, you'll need to provide your own contact details, complete a certification form, and include information about the individual you represent.

To file a complaint, contact your state attorney general or data protection authority if you believe your rights have been violated.

CHILDREN'S PRIVACY

Our services are not intended for children under the age of 18. We do not knowingly collect, use, sell, or share the personal information of individuals under 16 years of age. If we learn that we have inadvertently collected personal information from a person under 16, we will delete that information as quickly as possible.

If you are a parent or legal guardian and believe that your child under the age of 16 has provided us with personal information, please contact us at [email protected] and we will take appropriate steps to remove such data from our records.

RETENTION PERIOD DISCLOSURE

We retain personal information only as long as necessary to fulfill the purposes outlined in this policy, or as required by law. Retention periods vary depending on the type of data and our legal or operational obligations.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies ("Cookies") for lawful purposes, including to track lead generation activities, remember your choices and preferences, improve your user experience, and analyze traffic to our Site. Certain Cookies are also used for security, fraud prevention, and to help us measure the effectiveness of our marketing.

Cookies are small text files stored on your browser or device by websites you visit. Some Cookies are set by us (first-party Cookies) and others by third parties (third-party Cookies).

For questions or concerns about our Privacy Policy and information practices, please contact us at [email protected].