PRIVACY POLICY

Last updated on April 2, 2025

Thank you for choosing to be part of our community at Ownwell, Inc. (“Ownwell”, “Company”, “we”, “us”, or “our”). We are committed to protecting your Personal Information (defined below) and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your Personal Information, please visit our help center.

When you visit our website ownwell.com (“Site”), and use our services, you trust us with your Personal Information. We take your privacy very seriously. In this Privacy Policy (“Privacy Policy”), we seek to explain to you in the clearest way possible what Personal Information we collect, how we use it and what rights you have in relation to it. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Site and our Services (defined below).

This Privacy Policy is incorporated into and forms a part of our Terms of Service (“Terms”), together with all other terms and policies linked or otherwise referenced within the Terms or our Privacy Policy. This Privacy Policy applies to Personal Information collected through our Site and/or any related services, sales, marketing, or events (we refer to them collectively in this Privacy Policy as the "Services"). Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your Personal Information with us. Our Site contains links to other websites. Our Privacy Policy applies only to our Site. If you click on a link to a third-party website, you should read their privacy policy.

By signing up for our Services or taking other affirmative actions to indicate your consent to this Privacy Policy on our Site, you expressly consent to the information handling practices described in this Privacy Policy, including the deployment of cookies, pixels, and similar third-party tracking technologies for the purposes described herein. Further, you acknowledge and confirm that you have permission to provide us with all Personal Information that we process in connection with your use of the Services. If you do not agree with this Privacy Policy or our Terms, please do not access, use, or otherwise sign up for our Services.

As used in this Privacy Policy, "Personal Information" means information that can be used to identify you, the processing of which is subject to applicable data privacy laws such as State Privacy Laws (defined below). The term Personal Information can include information such as your name and e-mail address, and it can also include indirect identifiers such as your IP address or device identifier. Personal Information does not include aggregate information, which is data we collect about the use of our Services or categories of such users which does not identify you.

From time to time, we may also share certain information from customers of Ownwell in our capacity as a financial institution subject to the Gramm-Leach-Bliley Act (“GLBA”) with certain non-affiliated third parties for marketing purposes. The terms on which we share such information are set out in our GLBA Privacy Notice, available here, and are incorporated into this Privacy Policy by reference.

Certain jurisdictions require that we provide additional information regarding our privacy practices and your privacy rights. If you are a resident of a U.S. state that has enacted consumer data privacy legislation which applies to Ownwell, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia (each an “Applicable State” and collectively “Applicable States”), you may be entitled to additional rights regarding your Personal Information. For more information, please refer to the section titled “WHAT DATA PRIVACY LAWS APPLY TO OWNWELL?” below.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information you disclose to us

In Short: We collect Personal Information that you provide to us.

We collect Personal Information that you voluntarily provide to us when expressing an interest in obtaining information about us or our Services, when participating in activities within the Services or otherwise contacting us.

The Personal Information that we collect depends on the context of your interactions with us, the Services, and the choices you make within the Services and features you use. The types of Personal Information we collect may include the following:

Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; email addresses; phone numbers; current and former address; and other similar data.

Personal Information Provided by You. We collect financial information such as credit card number, purchase history, invoices, and other similar data. Additionally, you may be required to provide additional information for certain services:

• Bill Negotiation Services: You must provide us with the following information: the account holder’s name, your name and relationship to the account holder (if different), and your respective addresses, phone numbers and email addresses, the name of the service provider , the applicable account number, password, pin number, or other security credentials to access the account, and any other specific information your Provider may require for us to make changes to your account.
• Mortgage Services: You will be required to provide information about your property, including but not limited to purchase date, purchase price, loan term, mortgage payment status, interest rate on loan, any extra contribution to principal.
• Insurance Services: You will be required to provide us with the following information: your current provider, current deductible, current premium, as well as your date of birth and your marriage status. Additionally, you will be asked for consent to run credit history checks with third parties.

Payment Data. If you make a purchase on our site, we collect data necessary to process your payment, such as your payment instrument number (i.e., a credit card number, mobile banking account number, etc.), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their Privacy Policy here.

All Personal Information that you provide to us must be true, complete, and accurate. You must notify us of any changes to such Personal Information.

Information automatically collected

In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our website.

We automatically collect certain information when you visit, use or navigate the Services. This information is not considered “Personal Information” and does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily used for functionality purposes, to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Online Identifiers. We collect cookie identifiers, or others such as the ones used for analytics and marketing; tools and protocols, such as IP (Internet Protocol) addresses; device's geolocation; applications; devices; and other similar data.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources may include: social media profile information, marketing leads, search results and links, including paid listings (such as sponsored links).

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, and compliance with any legal obligations.

We use Personal Information collected via our Services for a variety of business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, to enter into or perform our services within our contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and login process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and login process for the performance of the contract.
• To send you marketing and promotional communications. We and/or our third- party marketing partners may use the Personal Information you share with us for marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing communications at any time.
• To send administrative information to you. We may use your Personal Information to send you product, service and new feature information, or information related to changes in our terms, conditions, or policies.
• To post testimonials. We sometimes highlight testimonials you have submitted to us about our Services, which may include Personal Information, such as your name or city. We will request your consent prior to posting a testimonial that includes your Personal Information. You may update or delete your testimonial here: contact us and be sure to include your name, testimonial location, and any other relevant contact information.
• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and then to measure its effectiveness.
• Request Feedback. We may use your information to request your feedback about your experience with the use of our Services.
• To enforce our terms, conditions, and policies for business purposes, legal and contractual reasons.
• To respond to legal requests or to prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.
• To deliver services to the user. We may use your information to provide you with any requested services.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and trouble shoot any issues you may encounter with the use of our Services.
• Carry out any other purpose for which the information was collected and to which you consented.
• For other Business Purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, and determining the effectiveness of our promotional campaigns. We may also use your information to evaluate and improve our Services, products, marketing, and the overall user experience. We may use and store some of this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personally identifiable information.

Emails: We only send e-mails to persons who have provided their email directly to us and who have consented to receive communications from us. If you do not wish to receive e-mails from Ownwell, you may opt out by contacting us at hello@ownwell.com, or by clicking the “unsubscribe” link at the bottom of our marketing communications. Please note that even if you opt out of receiving marketing e-mails from Ownwell, you may still receive relationship e-mails from us, including responses to e-mails that you sent to us prior to opting out, notices of updates or changes to our policies and procedures, or other messages relating to your account or your use of the Services.

Phone Calls and Text Messages: When you provide your phone number to us through a web form, verbally, or other medium, you consent receive phone calls and text messages from us, and other parties acting on our behalf, at the phone number you provide to us, even if you are on a federal or state do-not-call registry. We use the Personal Information from you for the purpose of sending you requested communications. We do not sell, rent, or share Personal Information from your consent to receive communications from us with third parties for their direct marketing purposes. The information is only used by us for the purposes set out in this Privacy Policy and by our service providers to send the requested communications. The texts and calls may be automated, contain transactional, including collections, information or marketing and promotional material. While message frequency varies, we will not send you more than fifteen messages per week unless otherwise requested by you. Standard message and data rates may apply. You are responsible for any charges from your mobile carrier and any delays or errors in SMS delivery caused by a mobile carrier or third party service provider. Your consent to receive text messages is not a condition to purchase. You may opt out of receiving text messages at any time by contacting us at hello@ownwell.com, or replying STOP, END, CANCEL, or QUIT to any text message that you receive.

We share some or all of your Personal Information with third parties such as service providers for the business purposes listed above, to the extent permitted by applicable laws. We require that our service providers and contractors refrain from combining the Personal Information of opted-out consumers that such service provider or contractor receives from us with any Personal Information that the service provider or contractor obtains in any other manner, as required by law.

3. WILL WE SHARE YOUR INFORMATION?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your or our rights, and to fulfill business obligations. We may share your Personal Information with third parties as described below for the purposes described in this Privacy Policy:

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us, or on our behalf, and require access to such information to do that work. Examples include but are not limited to payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which allows them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity.
• Business Transfers. We may share or transfer your information in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may allow third-party advertising companies to display ads when you visit the Services. These companies may use information about your visits to our Site and other websites that are contained in web cookies and other tracking technologies to provide advertisements about goods and services of interest to you. Additionally, we may share your Personal Information with our joint marketing partners to provide marketing or advertising that we believe will interest you with your consent.
• Legal Compliance. We may share your Personal Information in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/. Alternately, to exercise your rights to opt out of interest-based advertising under certain data privacy laws, please see the section titled “HOW CAN YOU OPT OUT OF THE SALE OF YOUR PERSONAL INFORMATION OR EXERCISE YOUR OTHER RIGHTS AS A CONSUMER?” below.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as is legitimately necessary.

We will only keep your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, our service agreement, any other agreement, or when it is otherwise required or permitted by law (such as reporting for tax, accounting, or other legal purposes).

When we have no ongoing, legitimate business purpose to process your Personal Information, we will either delete or anonymize it; or, if this is not possible (for example, if your Personal Information has been stored in backup archives), then we will continue to securely store your Personal Information, but isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your Personal Information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we process. However, please keep in mind that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Services is at your own risk. You should only access our Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using our Services, you represent that you are at least 18 years of age, or that you are the parent or guardian of such a person and consent to that person’s use of the Services. If we learn that Personal Information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we have collected from any person under 18 years of age, please contact us.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: Our Site honors Global Privacy Control signals.

Some web browsers, mobile operating systems, and mobile applications include a Do- Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference to prevent data about your online browsing activities from being monitored or collected. No uniform technology standard for recognizing and implementing DNT signals has been adopted. Our Site honors Global Privacy Control signals as a valid request to opt- out of the sharing of information linked to your browser or device that you used to access our Site. Please be aware, however, that opt-out preference tools are limited to the browser or device you are using. Your browser may save some information in its cookies or cache to maintain your privacy preferences, and if you clear cookies, you may remove your opt-out preference and be required to opt-out again.

9. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we update this policy as necessary to stay compliant with relevant laws and to reflect changes in our own policies.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last updated on” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. However, we encourage you to periodically review this Privacy Policy to remain up to date on how we are protecting your information.

10. WHAT DATA PRIVACY LAWS APPLY TO OWNWELL?

In Short: State Privacy Laws apply to Ownwell.

As of the “Last Updated” date indicated on this page, Ownwell is subject to the consumer data privacy laws of the Applicable States but is not subject to the General Data Protection Regulation of the EU or the UK. Note, however, that we are located in the United States and transfer your Personal Information for processing in the United States. We make such transfers in the absence of an adequacy decision because they are necessary for the performance of a contract with you, with your consent, or otherwise as permitted by applicable laws. By submitting your Personal Information for processing by our Services, you consent to the transfer of your Personal Information to and from the U.S. from and to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services on the terms described in this Privacy Policy.

The consumer data privacy laws in the Applicable States (referred collectively as “State Privacy Laws”) provide residents of the Applicable States (“Consumers”) with additional rights described in this section.

Ownwell collects and uses the following categories of Personal Information and shares them with the third parties described below:

We do not collect, use, or disclose sensitive Personal Information unless it is specifically submitted by you. To the extent that you submit any sensitive Personal Information for our collection, our use of such sensitive information will be limited to that use which is necessary to provide our Services to you and/or for the uses to which you have consented.

Subject to certain limitations, Consumers have the right to (1) confirm whether we are processing your Personal Information, and to request to know more about the categories and specific pieces of Personal Information we collect, use, and disclose, including by obtaining copies of the Personal Information that we have collected, (2) request deletion of your Personal Information, (3) request correction of your Personal Information, and (4) not be discriminated against for exercising these rights. For more information, please refer to the section titled “HOW CAN YOU OPT OUT OF THE SALE OF YOUR PERSONAL INFORMATION OR EXERCISE YOUR OTHER RIGHTS AS A CONSUMER?” below.

11. DOES OWNWELL SELL YOUR PERSONAL INFORMATION?

In Short: Yes, our sharing of Personal Information in connection with referral services you have requested and for Targeted Advertising (defined below) may be considered selling of Personal Information under State Privacy Laws.

We disclose Personal Information to third parties such as referral partners, joint marketing partners, and other nonaffiliated third parties in exchange for valuable consideration in connection with providing referral services that you have requested. For example, if you subscribe to our insurance services, we will leverage third-party insurance brokers to run comparable insurance policies and rates across alternative insurance providers, and send you communications regarding deals and other opportunities offered by such insurance providers.

State Privacy Laws require that we notify you if we use your Personal Information for Targeted Advertising. “Targeted Advertising” means displaying advertisements to you where the advertisement is selected based on Personal Information obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests. We disclose Personal Information to third parties for cross-context behavioral advertising, or Targeted Advertising. For more information, please refer to the “CCPA Notice of Sales of Personal Information” section below.

CCPA Notice of Sales of Personal Information

For purposes of the CCPA, “sale” means scenarios in which we have disclosed Personal Information to third parties in exchange for valuable consideration, while “sharing” means we have disclosed Personal Information to a third party for cross- context behavioral advertising. The CCPA categorizes “sharing” as a form of “sale”.

In the preceding 12 months, we have “sold” or “shared” the following categories of Personal Information with the following categories of third parties:

See the “HOW CAN YOU OPT OUT OF THE SALE OF YOUR PERSONAL INFORMATION OR EXERCISE YOUR OTHER RIGHTS AS A CONSUMER?” section below to learn how to opt out of these activities.

California Notice of Financial Incentive

California’s privacy laws require that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of Personal Information, which it defines as a “financial incentive.” We offer promotions and incentives to prospective and current customers of Ownwell. For example, users may provide us their Personal Information (e.g., email address) to be eligible to receive product incentives or participate in promotions. Under the CCPA, our product incentives or promotions to Consumers may be considered financial incentives provided in exchange for the collection and retention of Personal Information. The types of Personal Information that we receive in exchange for your participation depends on various factors -- including, for example, the extent to which you take advantage of our offerings -- but is roughly equivalent to the value of the product incentive or promotion offered. There is no obligation to opt in to such offerings, and California Consumers may opt out at any time. The details of each program are contained in each such offering.

12. HOW CAN YOU OPT OUT OF THE SALE OF YOUR PERSONAL INFORMATION OR EXERCISE YOUR OTHER RIGHTS AS A CONSUMER?

You may request to exercise your rights under State Privacy Laws by contacting us using the information at the bottom of the page. Additionally, you may opt out of the sale or sharing of your Personal Information at any time by clicking on this link.

We will verify your request by asking you to provide information related to your recent interactions with us, such as your name, email address, phone number and mailing address. We will address all verifiable consumer requests within the time periods required by law. If we require more time, we will inform you of the reason and extension period in writing. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We may request specific information from you to help us confirm your identity and complete your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information related to your request to enable us to process your request more efficiently. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We reserve the right to refuse to fulfill any consumer rights requests for data that is not required to be provided under applicable laws.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

If we deny your request, you may appeal our decision by contacting us using the contact information at the bottom of the form. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact us here or by email to: hello@ownwell.com