Purpose Account by Resolution Industry Trust Company

Comprehensive Privacy Policy

Your privacy is important to us. This Privacy Policy explains how we collect, use, and share personal information when you:

If you are a current or former job applicant, employee, or contractor, this Privacy Policy does not apply to you. Your privacy rights in those roles are covered by a different policy.

FACTS — What does Purpose Account 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.

What? The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and income, account balances and payment history, credit history and credit scores, employment information and assets.

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 Purpose Account chooses to share; and whether you can limit this sharing.

Information We Collect

Information You Provide

  • Application information (name, address, Social Security number, income, debts)
  • Account documentation and signed agreements
  • Communication preferences and contact information
  • Bank account information for payment processing

Information We Collect Automatically

  • Transaction records and payment history
  • Account balance and settlement activity
  • Login activity and system usage
  • Device and browser information for security

Information From Other Sources

  • Credit reports from credit reporting agencies
  • Bank account verification from third-party services
  • Information from Debt Resolution Company regarding your program
  • Public records as permitted by law

How We Use Your Information

For Our Everyday Business Purposes

  • Process your payments and maintain your account
  • Respond to court orders and legal investigations
  • Report to credit bureaus and regulatory authorities
  • Verify your identity and prevent fraud

For Our Marketing Purposes

  • Send information about our services and programs
  • Communicate program updates and account notifications

For Joint Marketing With Other Financial Companies

We do not share for joint marketing purposes.

Information Sharing

We May Share Information

  • With Debt Resolution Company — Account activity, payment status, and program progress to facilitate debt resolution services.
  • With Service Providers — Third-party vendors who assist with account management, payment processing, and customer service under strict confidentiality agreements.
  • With our Bank Partner — Account information necessary to maintain your FDIC insured special purpose account.
  • With Credit Reporting Agencies — Payment history and account status as required for accurate credit reporting.
  • As Required by Law — Court orders, legal investigations, regulatory examinations, and compliance requirements.
  • With Your Permission — When you authorize us to share your data with other companies or individuals.
  • Business Transfers — If we are involved in a merger, sale, or financing, your information may be transferred as part of that process.

We Do NOT Share Information

  • For marketing purposes by other companies
  • For other companies to market to you
  • With affiliates for marketing purposes

We have not sold personal information for any monetary value in the past 12 months and do not "share" personal information as defined by the Delaware Personal Data Privacy Act.

Your Privacy Rights

You Have the Right To

  • Access your personal information in our files
  • Request correction of inaccurate information
  • Opt out of marketing communications
  • Request deletion of information (subject to legal and regulatory requirements)
  • Receive your personal data in a portable format (right to portability)
  • Instruct us not to sell or share your personal data
  • Limit how we use your sensitive personal information
  • File a complaint with regulatory authorities

State-Specific Additional Rights

Depending on your state of residence, you may have additional privacy rights:

  • California (CCPA): Request details about third parties with whom we have shared personal information and limit use and disclosure of sensitive personal information.
  • Oregon (OCPA): Rights under the Oregon Consumer Privacy Act.
  • Nevada: Opt out of the sale of your personal information.

Contact our Privacy Officer for detailed information on exercising these rights.

Managing Your Preferences

  • Email: Opt out of marketing emails by clicking the unsubscribe link or contacting us directly.
  • Text and SMS: Opt out of receiving text messages by following instructions in the message or contacting us.
  • Cookies: Manage cookie settings through your browser.

Cookies and Tracking Technologies

Cookies

When visiting our website, we may create and send your browser cookies that may be stored on your device. We use cookies to provide a consistent experience throughout the pages and services you may use. You have the ability to decline cookies through your browser settings. Choosing to do so may impact your experience with our website.

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Device Reputation

To protect both you and us, we use services provided by our partners to help decide whether to accept transactions from personal computers, mobile phones, or other devices. These services check whether these devices have been identified with fraudulent or abusive transactions in the past, such as reported instances of identity theft, account takeovers, or malware attacks. For these purposes, a cookie file, flash storage token, beacon, tag, script, or other code file may be placed on your device to identify it in the future when you visit our website. On connection with our site or service, we will transmit that device identification code to the third party's server, along with data concerning certain technical attributes of your device such as the model, operating system, browser version, and IP address, all used to confirm device identification. The third party's server returns a response recommending that transactions be accepted or denied. If you set your browser or device to reject these cookies or tokens, you may not be able to conclude some transactions through our website.

Tracking Services

Our analytics partners use technologies such as cookies, beacons, tags, and scripts to analyze trends, administer the site, track users' movements around the site, and gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these partners on an individual as well as aggregated basis. Please note that our system may not respond to Do Not Track requests or headers from some or all browsers.

Data Security

Physical Safeguards

  • Secure facilities with restricted access
  • Locked storage for physical documents
  • Employee access controls and monitoring

Electronic Safeguards

  • 256-bit SSL encryption for all data transmission
  • Multi-factor authentication requirements
  • Regular security audits and vulnerability testing
  • Secure data centers with 24/7 monitoring

Procedural Safeguards

  • Employee background checks and privacy training
  • Regular security awareness programs
  • Incident response procedures
  • Data retention and disposal policies

Privacy Contact Information

Privacy Officer

Purpose Account — Privacy Office

  • Email: privacy@purposeaccount.com
  • Phone: 1-800-000-0000

Regulatory Contacts

  • Consumer Financial Protection Bureau: consumerfinance.gov
  • Federal Trade Commission: consumer.ftc.gov

Data Retention

We retain your personal information for as long as necessary to:

  • Provide services under your agreements
  • Comply with legal and regulatory requirements (minimum 7 years)
  • Resolve disputes and enforce agreements
  • Protect against fraud and security threats

Policy Updates

We may update this privacy policy annually or when required by regulatory changes. Material changes will be communicated via:

  • Written notice to your address on file
  • Email notification to your registered email
  • Prominent notice in your account portal

Third-Party Links

Our website may contain links to third-party sites. This privacy policy does not apply to those sites. Please review their privacy policies before providing personal information.

Important Disclosures

  • FDIC Insurance: Your special purpose account with our bank partner is FDIC insured up to applicable limits.
  • Program Duration: Debt resolution programs typically last 24–48 months. Individual results may vary.
  • Credit Impact: Debt resolution may impact your credit score. Consult with Debt Resolution Company for specific guidance.
  • Tax Implications: Settled debt may have tax consequences. Consult a tax professional for advice specific to your situation.

© 2026 Resolution Industry Trust Company. All rights reserved.