Privacy

Your privacy is important to Upgrade and its bank partners.

Privacy Policy

Last Updated / Effective Date: April 8, 2026

Scope and Purpose of this Privacy Policy

Protecting your privacy is important to Upgrade, Inc. This Privacy Policy describes how we collect, use, disclose, process, and delete personal information; what rights and choices you may have with respect to your personal information; how you may contact us, and how we protect your personal information. Please read this Privacy Policy before using the Site.

Information Upgrade Collects About You

The information that we collect depends on the context of your interactions with us. The sub-sections below describe the information we collect about you and how we collect it.

A. Information You Provide Directly to Us

We collect the following information directly from you when you use our Site and/or Services:

• Personal Information: Name, address, email, phone number, Social Security number, date of birth, account log in, password, Upgrade card number, loan ID, government ID, selfie, geolocation, and IP address;
• Payment Information: Information about your payments, loan terms, and transaction history;
• Employment Information: Information about your employment, start date, work phone, salary, paystub, and annual income;
• Company Information: Information about your company, company name, location, and your percentage of ownership;
• Bank Information: Your bank information, including your bank name, account number, and routing number; and debit and credit card details;
• Verification Information: Information for verification (fraud) checks;
• Biometric Information: Information for verification of your identity;
• Sensitive Personal Information: Social Security number, driver’s license, state identification card, or passport number;
• Other information that you voluntarily provide to us related to the Services or when we provide you with customer support.

B. Information We Receive from Third Parties

We receive the following information about you from third parties:

• Credit reporting agencies: Information such as your name, address, Social Security number, credit score;
• Affiliates and business partners: We may receive your personal information from our affiliates and businesses we partner with;
• Service providers: We may also receive your personal information from service providers;
• Banking and Financial Institutions: When you link your bank account for services, we may receive financial information associated with those accounts.

C. Information We Collect Automatically

We may collect certain information automatically when you use our Site, such as your Internet Protocol (IP) address, user settings, and other unique identifiers. We may also automatically collect information regarding your use of our Site.

D. Deidentified Information

We may generate deidentified information from the personal information that we collect about you.

How Upgrade Uses Information

We limit our use of your personal information to business and commercial purposes:

• Provide and Improve our Site and Services
• Facilitate your loan or account with bank or lending partner(s)
• Communicate with you about our Services
• Send and improve marketing communications
• Provide customer support
• Provide and improve necessary functionality
• Promote the security of our Site and Services
• Legal, regulatory, safety, and compliance purposes

Upgrade may collect or use personal information for the purpose of training large language models.

Information Upgrade Discloses

Upgrade may disclose your information to provide products and Services to you. We may disclose your information with the following third parties in certain instances:

• Contractors, service providers, and other third parties we use to support our business;
• Affiliated financial institutions;
• Nonaffiliated financial institutions;
• Credit reporting agencies;
• Law enforcement or other government officials;
• Third parties when we have a legitimate business purpose; or
• Others with your consent or authorization.

Third-Party Websites

This Site may contain links to other websites operated by third parties. Upgrade does not endorse the content of these third-party websites.

How Upgrade Protects Your Personal Information

Our goal is to protect the security of your information. We have implemented technical, organizational, and physical measures to protect against loss or unauthorized access, disclosure, alteration, or destruction of your information.

Additional Steps You Should Take to Ensure the Security of Your Information

Upgrade encourages you to take steps to secure your information. You should not include any personal identifying information in your account ID and should choose a unique password that is difficult for others to guess.

Children’s Privacy

This Site is not intended for children or minors under the age of 18. We do not knowingly collect personal information from children under the age of 13.

How to Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@upgrade.com.

State Privacy Disclosures

Certain state residents may have privacy rights regarding your personal information, as described below:

• Request Confirmation
• Access Request
• Request to Correct
• Request to Delete
• Request List of Specific Third Parties
• Request List of Third Parties to which Personal Information is Sold
• Request to Opt-Out
• Revoke Consent
• Appeal
• Discrimination

California Notice at Collection

This notice for California residents supplements the information provided in the rest of this Privacy Policy. We collect personal information about prospective, current, and former Upgrade customers.

• Identifiers such as name, address, phone number, email address;
• Characteristics of protected classifications under California or federal law;
• Commercial information;
• Biometric information;
• Certain geolocation data;
• Professional or employment-related information.

Upgrade does not “sell” any personal information we collect but may “share” your personal information for advertising purposes.

Federal Privacy Notices

The following U.S. federal privacy notices of Upgrade and its bank and lending partners apply to personal information of applicants, borrowers, and/or users of Services offered by Upgrade.

• Upgrade GLBA Privacy Notice
• Flex Pay GLBA Privacy Notice
• Celtic Bank GLBA Privacy Notice
• Cross River Bank Privacy Notice
• Blue Ridge Bank, N.A. Privacy Notice