Privacy Policy

Effective Date: June 1st, 2026

1. Scope

Welcome to Improve Solutions, LLC, doing business as Impruve Finance (“Impruve,” “we,” “us,” or “our”). This Privacy Policy describes how we collect, use, disclose, and protect personal information when you access our website, apply for financing, use our software platforms, or otherwise interact with our digital services (collectively, the “Services”).

Who this covers. This Policy applies to all users of our Services, including (1) individuals who seek or hold consumer financing through our platform (“Consumers”) and (2) merchants, contractors, and business partners who use our software or financing solutions (“Businesses”).

Bank partner relationship. Impruve operates both as a state-licensed consumer lender and as a technology platform. From time to time we may facilitate loans that are originated by one or more Bank-as-a-Service (BaaS) partner banks. If your loan is originated by a partner bank, your information is also subject to that bank’s privacy notice and to the federal Gramm-Leach-Bliley Act (GLBA). We are not an FDIC-insured bank, and we do not offer deposit accounts, checking accounts, or investment products.

2. Our GLBA Notice and This Policy

If you apply for or obtain a financing product primarily for personal, family, or household purposes, our collection, use, and sharing of your nonpublic personal financial information (“NPI”) is governed by the GLBA. For complete details on how we share your financial information and the federal rights you have to limit certain sharing, please review our standalone GLBA Privacy Notice.

Because federal law governs the financial information we collect to underwrite, originate, or service your loan, certain state privacy rights (such as the right to delete) generally do not apply to that core financial information for the duration of required retention periods. Where a state privacy law conflicts with the GLBA as to that financial data, the GLBA controls.

3. Personal Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”), including the following categories:

•    Identifiers: real name, alias, postal address, unique and online identifiers, IP address, email address, account name, Social Security number, driver’s license number, or similar identifiers.

•    Customer records (financial information): signature, telephone number, employment history, bank account and routing numbers, income-verification details, and loan payment history.

•    Commercial information: project or purchase details, merchant invoices, borrowing history, and financing products considered or obtained.

•    Internet or network activity: browsing and search history, session logs, device type, operating system, and interactions with our website, application, and digital advertisements.

•    Geolocation data: approximate physical location derived from your IP address or mobile device settings.

•    Professional or employment information: current or past employment, income details, and business documentation (for Business users).

•    Sensitive personal information: Social Security number, driver’s license or state identification number, and account log-in credentials in combination with passwords.

Personal Information does not include publicly available information from government records or de-identified or aggregated information.

4. Sources of Personal Information

•    Directly from you: when you complete an application, create an account, or contact support.

•    From Businesses and merchants: when a merchant or contractor initiates a financing request on your behalf through our point-of-sale software.

•    Automatically: through cookies, web beacons, pixels, and similar technologies when you use our website or open our emails.

•    Third-party providers: consumer reporting agencies (e.g., TransUnion, Experian, Equifax) for underwriting, identity-verification vendors for KYC/AML, and financial-data aggregators. If you link a bank account to verify income (e.g., via Plaid), that data is also handled under the provider’s own privacy policy.

•    Marketing partners: lead-generation networks and affiliate marketers who direct you to our Services.

5. How We Use Information

•    Providing the Services: to process applications, underwrite credit, originate and fund loans, and process repayments.

•    Platform operations: to give Businesses access to project pipelines, financing status, software tools, and payout routing.

•    Security and fraud prevention: to verify identity, authenticate logins, and detect and prevent fraudulent or malicious activity.

•    Marketing and advertising: to deliver and measure advertising for our own lending products and to optimize acquisition. We do not use your financial NPI for non-affiliate marketing (see Section 6).

•    Communication: to send transactional alerts, legal disclosures, repayment reminders, and service responses.

•    Product development: to debug, improve, and develop platform features.

•    Legal compliance: to comply with applicable lending, AML, and other laws and to respond to lawful requests.

6. How We Disclose Personal Information

To operate our business and to support the contractors and merchants who offer our financing, we disclose Personal Information to the categories of recipients below. We do not sell your sensitive financial information — such as your Social Security number, account or routing numbers, income, or credit-report data. You can limit certain marketing-related sharing as described in Section 8.

To operate our business, we disclose Personal Information to the following categories of recipients:

•    Partner banks: identifiers, financial information, and sensitive Personal Information, for the express purpose of underwriting and originating your loan.

•    Service providers: vendors that provide credit reporting, payment processing (ACH/card), identity verification, IT and cloud hosting, and customer support. These providers are contractually bound to use the data only for the services we engage and are prohibited from using it for their own marketing.

•    Businesses and merchants (servicing): if your loan is tied to a specific merchant or contractor, we disclose your application or loan status (e.g., approved, denied, funded) and relevant transaction details to facilitate and service your project or purchase and to oversee that partner’s performance.

•    Contractor partners (marketing): we may share limited information — your name, postal address, email, phone number, the general category of your project or purchase, and the associated contractor — with contractor partners so they can market their own home-improvement products and services to you, and in some cases jointly market with us. We do not share your sensitive financial information for this purpose. One contractor partner holds an ownership interest in Impruve and may be treated as an affiliate; where that applies, your right to limit marketing by that partner is provided under the Fair Credit Reporting Act. You may opt out of this sharing at any time (see Section 8).

•    Advertising networks: certain online identifiers and network-activity data, to deliver and measure advertising (see Sections 7 and 9). You may opt out.

•    Legal and regulatory: to comply with law, respond to subpoenas or regulatory inquiries, cooperate with our partner banks’ examiners, and protect against fraud or harm, as permitted by Regulation P (12 CFR 1016.14–1016.15).

•    Corporate transactions: to an acquirer or successor in a merger, acquisition, financing, or bankruptcy.

Mobile opt-in. We do not share your text-messaging consent (your mobile opt-in) with third parties or affiliates for their own marketing; see Section 15 (Text Messaging).

7. Cookies and Tracking Technologies

•    Essential cookies: required for the website to function, such as maintaining your logged-in session.

•    Analytics and advertising cookies: third-party trackers (e.g., Google Analytics, Meta Pixel) that help us understand site usage and serve you Impruve advertising on other sites and platforms.

“Sharing” under state law. Under laws such as the CCPA/CPRA, our use of third-party advertising cookies may constitute “sharing” or “selling” of personal information for cross-context behavioral advertising. You have the right to opt out (see Section 8).

Global Privacy Control. We honor the Global Privacy Control (GPC) browser signal as a valid opt-out where required by state law. Because there is no industry consensus on “Do Not Track” signals, we do not separately respond to them.

8. Your Privacy Rights and Choices

Depending on your state of residence (including California, Virginia, Colorado, Connecticut, Utah, and Texas), you may have the following rights, subject to the GLBA exemption described in Section 2:

•    Opt out of sale/sharing: direct us not to “sell” or “share” your information for targeted advertising via the “Do Not Sell or Share My Personal Information” link in our website footer or by enabling GPC.

•    Opt out of contractor marketing: direct us not to share your information with contractor partners for their own marketing or for joint marketing, and — for any affiliated contractor — not to use shared information to market to you. Submit your request through the methods in “How to Submit a Request” below or the opt-out link in our website footer.

•    Know / access: request the categories and specific pieces of Personal Information we have collected about you.

•    Delete: request deletion of your Personal Information. We cannot delete information tied to an active or past loan or otherwise required to be retained until the applicable retention period expires, and we will explain the statutory reason when we deny a request on this basis.

•    Correct: request correction of materially inaccurate Personal Information that we maintain.

•    Limit sensitive information: direct us to limit use of your Social Security number or identification to the purposes necessary to provide the Services.

•    Non-discrimination: we will not deny Services or charge different rates because you exercised a privacy right.

How to Submit a Request

Submit any request — including an opt-out of “sale” or “sharing” — through our privacy portal at www.impruvefinance.com/privacy-request, by email at privacy@impruvefinance.com, or by phone at 1-800-[TBD]. We will acknowledge and respond to verifiable requests within 45 calendar days (extendable once, as permitted by law). To protect your data, we verify your identity by matching the information in your request against our records; an authorized agent may submit a request on your behalf with proof of authorization.

9. Artificial Intelligence and Machine Learning

We may use artificial intelligence (AI) and machine-learning tools to support limited operations, including enhancing platform security and detecting anomalous logins, assisting identity verification and fraud detection, and optimizing marketing and internal workflows.

Impruve does not use AI to make final credit decisions. Our underwriting models are governed by our internal Model Risk Management program and comply with the Fair Credit Reporting Act (FCRA) and the Equal Credit Opportunity Act (ECOA), including adverse-action notice requirements.

10. Data Retention

We retain Personal Information only as long as reasonably necessary for the purposes in this Policy, unless a longer period is required by law.

•    Applications and originations: federal and state laws (such as ECOA and the Bank Secrecy Act) require us to retain application data, credit reports, and transaction records for a minimum of five (5) to ten (10) years, even if your application is denied or your loan is paid off.

•    Marketing and network activity: cookie and marketing analytics are generally retained for up to 24 months.

When information is no longer necessary or legally required, we securely destroy or irreversibly de-identify it.

11. How We Protect Your Information

We maintain physical, electronic, and procedural safeguards designed to protect Personal Information from unauthorized access, loss, misuse, or alteration. These include encryption of sensitive data in transit and at rest, multi-factor authentication for account and administrative access, role-based access controls limiting data to personnel with a legitimate business need, and regular third-party security audits and penetration testing. No method of transmission or storage is 100% secure.

12. International Data Transfers

Impruve is based in the United States, and our Services are intended for U.S. residents and Businesses. Some service providers may process data outside the United States. By using the Services, you consent to the transfer, storage, and processing of your information in the United States and other jurisdictions whose data-protection laws may differ from those of your home state.

13. Children’s Privacy

Our Services are intended only for individuals 18 years of age or older with the legal capacity to enter into a binding financial agreement. We do not knowingly collect Personal Information from minors, and consistent with the Children’s Online Privacy Protection Act (COPPA) we do not knowingly collect information from children under 13. If we learn we have collected such information, we will delete it promptly.

14. State-Specific Disclosures

California and Vermont. For NPI, we limit sharing with non-affiliated companies except as permitted by law or as described in our GLBA Privacy Notice, and we do not share creditworthiness information with affiliates absent authorization.

Other states. Residents of states with comprehensive privacy laws may exercise the rights in Section 8 to the extent the information is not exempt under the GLBA. State-specific metrics and addenda, where required, are published in our privacy portal.

15. Text Messaging (SMS) and Mobile Opt-In

When you apply for financing through Impruve Finance, you may receive text messages from us at the mobile number you provide.

•    Messages we send: (1) a one-time secure link or passcode to start or resume the application you requested, sent to fulfill that request; and (2) only if you opt in, recurring updates about your application and the servicing of your account. These are account and transactional messages, not marketing.

•    Consent: you ask us to text you a one-time secure application link by requesting the application verbally at the point of sale through a participating contractor; we send that single link to fulfill your request, and you may instead choose email delivery. Separately and optionally, you consent to recurring text updates about your application and account only by checking the dedicated, optional SMS box in the application — not by submitting the application and not by agreeing to our Terms. This recurring-text consent is not required to apply for, obtain, or service a loan, and you may decline or reply STOP at any time and still use the Services.

•    Not a condition of credit or service: you are not required to agree to receive any marketing or recurring account/application texts as a condition of applying for, obtaining, or servicing a loan or using our Services.

•    Frequency and charges: message frequency varies with your application and account activity, and message and data rates may apply.

•    Opt out and help: reply STOP to any message to stop; reply HELP, or contact us using Section 17, for help.

•    Marketing texts: promotional texts are separate and optional, are not a condition of applying for or receiving credit, and you may opt out at any time by replying Stop or by contacting us using Section 17, for help.

•    Mobile opt-in is not shared for others' marketing: we do not sell or share your text-messaging consent (your mobile opt-in) with third parties or affiliates for their own marketing. Where we share your contact information with contractor partners for their marketing (Section 6, subject to your opt-out), any such partner must obtain its own consent before texting you.

16. Changes to This Privacy Policy

We may amend this Policy at any time. For material changes — particularly to our use of AI, cookies, or data sharing — we will post the updated Policy and update the Effective Date above, and where required we will provide advance notice and an opportunity to opt out before new sharing takes effect. Your continued use of the Services after the posted Effective Date constitutes acceptance of the revised Policy.

17. Contact Us

Improve Solutions, LLC (d/b/a Impruve Finance)

·   privacy@impruvefinance.com  
·   www.impruvefinance.com/privacy-request  
·   1-800-[TBD]  
·   [Mailing address TBD]