BeMaLoans Inc.

PRIVACY POLICY

Effective Date: [INSERT DATE]

Last Updated: [INSERT DATE]

BeMaLoans Inc. | State of Utah, USA | support@bemaloans.io

This Privacy Policy describes how BeMaLoans Inc. ("BeMaLoans," "we," "us," or "our") collects, uses, shares, and protects your personal information when you visit our website, use our mobile application, or apply for or receive a personal loan from us. Please read this policy carefully. By submitting an application or using our services, you agree to the practices described in this Privacy Policy.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

When you apply for a loan or create an account, we collect:

- Full legal name, date of birth, and Social Security Number (last 4 digits or full, as required for identity and MLA verification)

- Contact information: mailing address, email address, and mobile phone number

- Employment information: employer name, job title, income type, and length of employment

- Financial information: monthly net income, monthly rent or mortgage, pay frequency, and bank account details

- Government-issued photo identification (front and back)

- Proof of residency documents (utility bill or bank statement, if required)

- Loan request details: requested amount, term, and loan purpose

1.2 Information Collected Automatically

When you access our website or application, we may automatically collect:

- IP address and approximate geolocation

- Browser type, operating system, and device identifiers

- Pages visited, time spent, and clickstream data

- Referring URLs and search terms

1.3 Information from Third Parties

With your explicit consent, we collect information from the following third-party sources:

- Stripe Financial Connections: We use Stripe to verify your bank account, confirm your identity, and analyze your transaction history to assess your ability to repay.

- Identity verification providers: To verify your government-issued ID and confirm your identity in compliance with applicable law.

- Military status verification: We verify your status under the Military Lending Act (MLA) through the official U.S. Department of Defense MLA database (DMDC).

- Credit bureaus and alternative data providers: We may obtain credit-related information from consumer reporting agencies for the purpose of evaluating your creditworthiness.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

- To process and evaluate your loan application and determine your eligibility

- To verify your identity, age, residency (Utah), and military status

- To assess your ability to repay a loan (underwriting and DTI calculation)

- To disburse approved loan funds via ACH transfer to your verified bank account

- To collect scheduled loan repayments via ACH debit in accordance with your signed loan agreement

- To communicate with you about your application, account, payments, and customer service inquiries

- To send legally required disclosures, loan documents, and notices electronically

- To detect and prevent fraud, identity theft, and other illegal activity

- To comply with applicable federal and Utah state laws and regulations, including TILA, MLA, E-SIGN Act, and the Utah Consumer Credit Code

- To improve our website, application, and services

3. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties for their own marketing purposes. We may share your information in the following limited circumstances:

3.1 Service Providers

We share your information with trusted service providers, including:

- Stripe — bank account verification and payment processing

- Identity verification providers — ID document verification

- Zoho Sign — electronic signature and document delivery

- Twilio Inc. — SMS verification and communications

- Mercury Bank — ACH payment processing and disbursement

- Make.com — workflow automation

- Google LLC — data storage (Google Drive, Google Workspace)

3.2 Legal and Regulatory Disclosure

We may disclose your information when required by law, including to:

- The Utah Department of Financial Institutions (UDFI)

- The Consumer Financial Protection Bureau (CFPB)

- Federal or state law enforcement agencies

3.3 Business Transfers

In the event of a merger, acquisition, or sale of our business, your personal information may be transferred as part of that transaction.

4. DATA RETENTION

We retain your personal information as follows:

- Loan application data: minimum 5 years from the date of application

- Signed loan agreements and ACH authorization forms: minimum 5 years from loan payoff

- MLA verification records: retained with timestamp for regulatory audit purposes

- Identity verification documents: retained as required by applicable AML and KYC regulations

5. DATA SECURITY

We implement industry-standard technical and organizational measures to protect your personal information, including:

- 256-bit SSL/TLS encryption for all data transmitted to and from our website

- Encrypted storage of sensitive data (SSN, bank account details)

- Access controls limiting employee access on a need-to-know basis

- Regular security assessments and monitoring

6. YOUR RIGHTS AND CHOICES

6.1 Access and Correction

You have the right to access the personal information we hold about you and to request corrections. Contact us at support@bemaloans.io.

6.2 Opt-Out of Marketing Communications

You may opt out of receiving marketing emails at any time by clicking "Unsubscribe" in any marketing email or contacting us at support@bemaloans.io.

6.3 Withdrawal of Consent

Where we process your information based on your consent, you may withdraw that consent at any time. However, withdrawal may affect our ability to process your loan application.

7. COOKIES AND TRACKING TECHNOLOGIES

Our website may use cookies and similar tracking technologies to enhance your experience and prevent fraud. You can control cookie settings through your browser preferences.

8. CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 21. We do not knowingly collect personal information from anyone under 21.

9. THIRD-PARTY LINKS

Our website may contain links to third-party websites. This Privacy Policy does not apply to those sites. We are not responsible for the privacy practices of third-party websites.

10. MILITARY LENDING ACT (MLA) COMPLIANCE

BeMaLoans Inc. complies with the Military Lending Act (MLA), 10 U.S.C. § 987. We verify each applicant's military status through the U.S. Department of Defense MLA database (DMDC) at the time of application and again prior to loan consummation. At this time, BeMaLoans Inc. does not offer credit products to active-duty service members or their covered dependents as defined under the MLA.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email or by posting a prominent notice on our website at least 30 days before the changes take effect.

12. CONTACT US

BeMaLoans Inc.

[Street Address]

[City], Utah [ZIP]

Email: support@bemaloans.io

Phone: [INSERT PHONE NUMBER]

Website: www.bemaloans.io

For complaints regarding our privacy practices, you may also contact the Utah Department of Financial Institutions (UDFI) at https://dfi.utah.gov or the Consumer Financial Protection Bureau (CFPB) at https://www.consumerfinance.gov.

BeMaLoans Inc. | Utah Consumer Lending License No. [INSERT] | support@bemaloans.io