Consumer Privacy Policy

Effective date: August 3, 2026

1. Our Role and Your Consent

Thrive Financial LLC (“Thrive,” “We,” “Us,” or “Our”) is a financial technology company, bank service provider, and a loan servicer. Thrive is not a bank or a lender. We facilitate the origination of home improvement loans and other financial products for our partner banks and service those loans on behalf of the banks and subsequent investors. By using our online loan application platform, you agree to the collection, use, and sharing of your information as described in this Policy.

2. Information We Collect

We collect “Nonpublic Personal Information” (NPI) to evaluate your eligibility for credit and to service your account. This includes:

Application Data: Name, address, income, and employment details.
Credit Information: Information from consumer reporting agencies regarding your creditworthiness and history.
Transactional Data: Account balances, payment history, and details regarding your home improvement project.
Technical Data: IP address, browser type, device identifiers, and platform interaction collected via cookies.

3. Sensitive Personal Information

In addition to general NPI, we collect and process “Sensitive Personal Information” as defined by state privacy laws. This includes:

Government Identifiers: Social Security numbers, driver’s license numbers, or state identification numbers.
Financial Account Access: Credentials allowing access to an account (where provided for income verification).

Use and Limitation: We collect this information strictly to verify your identity (KYC), prevent fraud, and perform credit underwriting. We do not use or disclose sensitive personal information for purposes other than to provide the services you have requested. We do not “sell” or “share” SPI for cross-context behavioral advertising.

4. How We Share Your Information

Federal law gives you the right to limit some, but not all, sharing. The table below explains our practices:

Reasons we can share your personal information	Does Thrive share?	Can you limit this sharing?
Everyday Business Purposes: Processing transactions, maintaining accounts, responding to court orders, or reporting to credit bureaus.	Yes	No
Marketing Purposes: To offer our products and services to you.	Yes	No
Joint Marketing with other financial companies.	No	We don’t share
Affiliates’ Everyday Business Purposes: Information about your transactions and experiences.	Yes	No
Affiliates’ Everyday Business Purposes: Information about your creditworthiness.	No	We don’t share
Nonaffiliates to market to you.	No	We don’t share

5. Automated Decision-Making Technology

Thrive uses automated processes, including algorithms and credit scoring models, to assist in evaluating your loan application and detecting potential fraud. These automated tools process the information you provide and data from credit bureaus to determine eligibility and pricing.

Human Oversight: While decisions are primarily automated to ensure efficiency and consistency, our credit and fraud teams perform periodic manual reviews to verify system accuracy.

Right to Appeal: If your application is denied based on an automated decision, you have the right to request a manual review of your application by contacting us at 1-844-223-9711 or email us at privacy@partnerwiththrive.com.

6. Record Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

Service Delivery: For the duration of your active loan and servicing relationship.
Legal Compliance: To comply with federal and state laws, such as the Bank Secrecy Act, which requires retention of certain records for at least five (5) years.
Dispute Resolution: To resolve disputes, enforce our agreements, and protect our legal rights.

When information is no longer required, we securely delete or anonymize it in accordance with our internal data destruction policies.

7. Children’s Privacy (COPPA)

Our services are directed to adults aged 18 and older. Thrive does not knowingly collect personal information from individuals under the age of 13, in compliance with the Children’s Online Privacy Protection Act (COPPA).

Verification: We verify the age of all applicants through the collection of government identifiers (e.g., SSN and Date of Birth) during the loan application process.

Teen Privacy: We do not knowingly collect, sell, or share personal information from consumers between the ages of 13 and 17 without affirmative authorization where required by state law.

8. Fair Credit Reporting Act (FCRA) Disclosures

The FCRA gives you specific rights regarding how your information is shared among related companies (affiliates). Our practices are as follows:

Experience Information: Federal law allows us to share information with our affiliates about our own internal “transactions and experiences” with you (such as your payment history or account balances). You may not opt out of this sharing.

Creditworthiness Information: Thrive does not share “creditworthiness” information (such as your credit scores or information from your credit report) with our affiliates for their own business purposes or for making eligibility decisions. Because we do not share this information, no opt-out is required.

9. Third-Party Product Marketing

Thrive may occasionally notify you regarding financial products offered by third parties. We maintain a strict non-sharing policy for these offers:

Thrive does not provide your personal information to these third-party companies.
If you choose to explore such an offer, you will be directed to the third party’s website, and any information you provide is given directly to them.

10. Mobile Privacy & SMS Guarantee

To ensure your mobile data remains secure and private under telephony carrier standards (A2P 10DLC):

Direct-Only Messaging: We do not share mobile contact information with third parties or affiliates for marketing or promotional purposes.
Restricted Usage: Information may be shared with subcontractors in support services, such as customer service, to assist in managing your account.
Opt-In Exclusion: All other data categories in this Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

11. Communications and TCPA Support

By providing your number, you consent to receive transactional texts/calls (automated or otherwise) necessary to process your application and service your loan. You may opt out of transactional texts/calls for servicing messages at any time by replying “STOP” to any text message or clicking “Unsubscribe” in any email. You must opt-in to receive marketing texts/calls.

12. State-Specific Rights (California and Others)

Residents of California, Virginia, Colorado, Connecticut, Utah, and Texas may have specific rights, including the Right to Know/Access, Right to Correct, and Right to Delete. Thrive does not sell your personal information or share it for cross-context behavioral advertising.

13. Legal Disclosures & Security

We comply with the Right to Financial Privacy Act (RFPA), requiring proper legal process (subpoenas/warrants) before releasing records to federal authorities. We maintain physical, electronic, and procedural safeguards that comply with federal standards to protect your NPI.

14. Contact Us

To exercise your rights or ask questions, please contact our Compliance Team:

Email: privacy@partnerwiththrive.com
Phone: 1-844-223-9711
Mail: Thrive Financial, LLC, Attn: Compliance Officer, PO Box 5033, Fredericksburg, VA 22403-5033