Privacy Policy

1. Key Terms

"Consumer Report" means any consumer report, credit report, credit score, credit file, identity report, fraud-prevention report, background or verification report, or similar information obtained from a consumer reporting agency or other lawful source for a purpose permitted by applicable law.

"Financing Partner" means any bank, credit union, finance company, leasing company, lender, lessor, mortgage company, broker, dealer, investor, funding source, institutional capital provider, marketplace participant, affiliate, assignee, servicer, administrator, service provider, or other entity that evaluates, facilitates, purchases, services, funds, offers, or provides financial products or services through or in connection with the Platform.

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household, including information treated as personal data or personal information under applicable privacy laws.

2. Information We Collect

We may collect Personal Information that you provide directly, information generated through your use of the Platform, and information received from service providers, Financing Partners, or other lawful sources. Depending on how you use the Platform, this may include:

• Identifiers and contact information, such as name, email, phone number, address, date of birth, account credentials, preferred language, and communication preferences.
• Identity and compliance information, such as government identification, passport or driver license information, proof of address, beneficial ownership or source-of-funds information where applicable, KYC/AML information, sanctions-screening results, and fraud-prevention information.
• Financial, application, property, and vehicle information, such as employment status, income, assets, liabilities, housing costs, desired financing amount, lease or mortgage preferences, property or vehicle details, uploaded documents, and related information you submit to explore opportunities or request Services.
• Technical and usage information, such as IP address, device identifiers, browser type, operating system, app activity, log data, pages viewed, referral source, approximate location derived from IP address, and interactions with Platform features.
• Communications information, such as messages, call notes, support requests, email interactions, SMS opt-in or opt-out records, consent records, and user feedback.
• Inferences and analytics, such as eligibility indicators, product interest, internal segmentation, risk or fraud flags, usage patterns, and insights created from the information described above.

We do not knowingly collect information from individuals under 18, and the Platform is not intended for minors.

3. Consumer Reports and Credit Information

Account registration, browsing, or submitting preliminary information does not authorize us to obtain a Consumer Report. If you choose to apply, prequalify, check eligibility, or otherwise request a financing or leasing opportunity that requires a Consumer Report, we will present a separate Consumer Credit Report Authorization. If you provide that authorization, the collection and use of Consumer Reports will be governed by that authorization, the Fair Credit Reporting Act where applicable, and other applicable law.

4. How We Use Information

We use Personal Information for business, operational, compliance, security, and user-requested purposes, including to:

• create, maintain, authenticate, secure, and administer your account;
• provide, operate, personalize, improve, and develop the Platform and Services;
• facilitate evaluation of residential, automotive, leasing, mortgage, credit, financing, servicing, referral, marketplace, or related opportunities;
• prepare, process, support, refer, administer, service, or facilitate applications, inquiries, transactions, or relationships you request;
• verify identity, detect fraud, conduct KYC/AML, sanctions, OFAC, and similar compliance reviews where appropriate;
• communicate about account, security, transactional, operational, legal, customer-support, and application-related matters;
• send optional marketing communications according to your preferences and applicable law;
• perform analytics, testing, auditing, product development, business planning, benchmarking, machine learning, and statistical analysis;
• enforce our agreements, protect our rights and property, resolve disputes, respond to legal process, and comply with law.

We may use aggregated, anonymized, or de-identified information for analytics, research, product development, artificial intelligence, machine learning, benchmarking, reporting, and other lawful business purposes, provided the information is not reasonably used to identify you.

5. How We Disclose Information

We do not sell Personal Information for money. We may disclose Personal Information as reasonably needed to operate Tamarindo and provide the Services, including to:

• affiliates and related entities that help operate or support the Platform;
• service providers that host, secure, analyze, operate, support, or improve the Platform;
• identity verification, fraud-prevention, compliance, payment, document-processing, analytics, communications, and customer-support vendors;
• Financing Partners when you request or authorize a transaction, application, eligibility review, referral, financing, lease, mortgage, servicing, administration, or related Service;
• professional advisors, banks, auditors, insurers, payment processors, legal counsel, accountants, and compliance consultants;
• government authorities, regulators, law enforcement, courts, credit bureaus, or other parties when required or permitted by law;
• successors or prospective successors in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction.

We require service providers to use Personal Information only for authorized purposes and to maintain appropriate confidentiality and security obligations. Financing Partners may also process information under their own legal obligations, privacy policies, and agreements.

6. Cookies, Analytics, and Similar Technologies

We may use cookies, pixels, SDKs, device identifiers, log files, and similar technologies to operate the Platform, maintain sessions, authenticate users, remember preferences, measure performance, prevent fraud, analyze usage, improve Services, and support advertising or marketing where permitted. You may adjust browser or device settings, but some Platform features may not work properly without these technologies.

7. Marketing and Communications Choices

Marketing is optional. You may choose whether to receive marketing emails, SMS/text messages, push notifications, or similar communications. You may withdraw marketing consent at any time by using unsubscribe tools, replying STOP to eligible SMS messages, adjusting account settings, or contacting us. Even if you opt out of marketing, we may still send non-marketing messages, including verification codes, security alerts, account notices, customer-support messages, application updates, transactional notices, and legal notices.

8. Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, destruction, loss, or misuse. These safeguards may include encryption in transit, restricted access controls, authentication measures, logging, monitoring, vendor diligence, employee confidentiality obligations, and incident-response procedures. No system is perfect, and we cannot guarantee absolute security.

9. Data Retention

We retain Personal Information for as long as reasonably necessary to provide the Platform and Services, administer accounts, evaluate or support requested opportunities, satisfy legal, regulatory, tax, accounting, fraud-prevention, dispute-resolution, and audit obligations, and enforce agreements. Our general retention approach is:

• account and profile information: during the account term and for a reasonable period thereafter;
• application, identity, compliance, financial, property, vehicle, and eligibility information: for the period needed for legal, regulatory, audit, business-record, fraud-prevention, and dispute-resolution purposes;
• communications and support records: for a reasonable period to manage support, quality control, disputes, and compliance;
• technical logs and analytics: for a limited period appropriate to security, performance, fraud prevention, and product improvement;
• marketing preferences and consent records: as long as needed to honor preferences and demonstrate compliance.

When information is no longer needed, we will delete, de-identify, aggregate, or securely archive it in accordance with our retention practices and applicable law.

10. Your Privacy Rights

Depending on where you live and subject to applicable exceptions, you may have rights to request access to, correction of, deletion of, or a portable copy of certain Personal Information; to withdraw certain consents; to opt out of certain marketing; to object to or restrict certain processing; and to appeal a denied request where required by law. We may verify your identity before responding. Requests may be submitted to privacy@tamarindocredit.com.

11. U.S. State Privacy Notice

Residents of states with comprehensive privacy laws may have additional rights, which may include the right to know or access Personal Information, correct inaccurate information, delete information, obtain a portable copy, opt out of the sale of Personal Information, opt out of certain targeted advertising, opt out of certain profiling that produces legal or similarly significant effects, limit certain uses of sensitive Personal Information, and not be discriminated against for exercising privacy rights.

For purposes of applicable state privacy laws, we do not sell Personal Information for money. If our use of analytics or advertising technologies is considered a "sale," "share," targeted advertising, or similar disclosure under applicable law, we will provide any required opt-out mechanism. We process sensitive Personal Information only as reasonably necessary to provide Services, verify identity, prevent fraud, comply with law, maintain security, or support user-requested activities.

12. Colombian and International Users

If you are located in Colombia or provide Colombian personal data, we will process such data in accordance with applicable Colombian data protection principles, including legality, purpose limitation, freedom, truthfulness or quality, transparency, restricted access and circulation, security, and confidentiality. Subject to legal and contractual limitations, you may have rights to know, update, rectify, request proof of authorization, be informed about use, submit complaints to the Superintendence of Industry and Commerce where applicable, revoke authorization, and request deletion.

If you use the Platform from outside the United States, you understand that Personal Information may be processed in the United States and other jurisdictions where we, our affiliates, service providers, or Financing Partners operate. Those jurisdictions may have different data protection rules than your country. Where required, we will use appropriate safeguards or legal mechanisms for cross-border transfers.

13. Third-Party Links and Services

The Platform may link to or interact with third-party websites, services, lenders, lessors, dealers, brokers, identity verification tools, payment tools, or other resources. We are not responsible for the privacy practices of third parties. Their use of information is governed by their own policies and agreements.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the Platform, by email, or by other legally sufficient means. The updated policy will be effective as of the date stated above unless otherwise required by law.

15. Contact Us

Questions, requests, or complaints regarding this Privacy Policy or our privacy practices may be directed to:

Tamarindo Credit LLC, Attn: Privacy Officer

59 Hazelnis Drive, Loch Sheldrake, NY 12759

privacy@tamarindocredit.com · +1 (212) 555-0142