California Consumer Privacy Policy 

Last Updated: July 18, 2025

This Privacy Policy for California Residents supplements the information found in Triad Financial Services’ Online Privacy Notice and applies solely to all visitors, users and others who reside in the state of California (“consumers” or “you”).   Triad Financial Services adopts this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Consumer Privacy Rights Act (CCPA), along with subsequent clarifying CCPA legislation and implementing regulations. Any terms defined in the CCPA have the same meaning when used in this Notice.

Notice at Collection

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”).   Personal Information does not include:

• Publicly available information from government records.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope:
  • Personal Information covered by certain sector-specific privacy laws including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Because we are subject to the laws and regulations above, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our Privacy Policy.

Your Personal Information

In the past 12 months, we have not sold the Personal Information, or the sensitive information we collect. We also have not shared your Personal Information, or sensitive personal information that we collect with third parties for cross-context behavioral advertising in the past 12 months.   We do not sell or share the personal information of minors under 16 years of age.

In particular, we have collected the following categories of Personal Information and sensitive information listed in the tables below in the past 12 months.

Data Retention

We store your Personal Information for different lengths of time depending on the category or personal information and the purposes for its collection and use. We will retain your data for as long as needed, or permitted, based on the reason why we obtained it. We will not retain Personal Information for longer than is reasonably necessary for any disclosed purposes. This means we may retain your Personal Information even after you close your account with us. Some information may be deleted automatically based on specific schedules, such as financial information. Other information (e.g., account information), may be retained for longer periods of time. We may further retain information for business practices based on our legitimate business interests or legal purposes, such as network improvement, fraud prevention, record-keeping, or enforcing our legal rights or defending legal claims.

When deciding how long to keep your information, we consider criteria such as:

• The duration, and nature, of any relationship with you or service that we have provided to you.
• Whether we are subject to any legal obligations (e.g., laws that require us to keep transaction records for a certain period of time before we can delete them).
• Whether we have taken any legal positions (e.g., in connection with any statutes of limitations or in response to any legal hold or regulatory requests).

Rather than delete your data, we may de-identify it by removing identifying details.

We specifically collect the following categories of sensitive personal information: (1) Social security, driver’s license, state identification card, or passport number; (2) Usernames, account numbers, or card numbers combined with required access/security code or password; and (3) Racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs or union membership.

Business/Commercial Purpose for Collection

All the information that Triad Financial Services collects from consumers is collected in connection with the following business purposes:

• For everyday business purposes, such as to process your transactions and maintain your accounts.
• To present our website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it, including to process any application that you may submit.
• To carry our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
• To notify you about changes to our website or any products or services we offer or provide through it.
• In any way we may describe when you provide the information.
• For any other purpose with your consent.

Triad Financial Services does not use any other methods to collect Personal Information or for other purposes.

Categories of Sources

We obtain the categories of Personal Information listed above from the following sources:

• Directly from you. For example, from forms you complete, mortgage applications, or products and services you purchase.
• Indirectly from you. For example, through information we collect from you in the course of providing services to you.
• Directly and indirectly from activity on our website (https://www.triadfs.com/). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, credit reporting agencies, appraisers and other service providers.

We also collect demographic information. Demographic information is all other information such as gender, zip code, or any information that is not tied to your personal information. In addition, we may receive information about you from other online or offline sources, including third parties from whom we validate consumer self-reported information, and verify information we already have about you. This helps us to update, expand and analyze our records and provide products and services that may be of interest to you.

Disclosure and Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a rate quote or ask a question about our products or services, we will use that personal information to respond to your inquiry.
• To provide, support, personalize and develop our website, products and services.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
• To respond to audits or state or federal examination by our regulators.
• To perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose your Personal Information to a service provider or contractor for a business purpose, subject to your right to opt-out of those. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract or as otherwise permitted by you. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We disclose your personal information for a business purpose with the following categories of third parties:

• Service providers
• Contractors
• Government entities
• Credit Reporting Agencies
• Attorneys
• Courts of Law
• Law Enforcement
• Successors in interest or assigns
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we and/or third parties provide to you.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know – Access to Specific Information and Data Portability

Unless your Personal Information is excluded from the scope of the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request we will disclose to you:

• The categories of Personal Information that we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information
• The specific pieces of Personal Information we collected about you (also called a data portability request).

If we disclosed your Personal Information for a business purpose, we will identify the categories of third parties to whom we disclosed your personal information, along with the categories of personal information we disclose to third parties.

Right to Delete

Unless your Personal Information is excluded from the scope of the CCPA, you have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the Personal Information is necessary for us or our services providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provide.

Right to Correct Inaccuracies

You have the right to request that we correct inaccurate information that we have about you.

Exercising Access, Data Portability, Deletion, and Correction Rights

To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (800) 522-2013
• Emailing at compliance@triadfs.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Pursuant to the CCPA, only a natural person or a business entity that a customer has authorized to act on their behalf may act as an authorized agent. When you use an authorized agent to submit a request to delete, request to correct, or a request to know, we may require that you or the authorized agent provide proof that you gave the agent signed permission to submit the request. We may also require the consumer to do either of the following: (1) Verify their own identity directly with the business; or (2) Directly confirm with the business that they provided the authorized agent permission to submit the request.

You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.

Response Timing and Format.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not.

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Provide you a different level of quality of goods or services
• Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

Right to Limit and Disclosure of Sensitive Personal Information

Under the CCPA regulations, a business is only required to provide a right to limit the use and disclosure of sensitive personal information when such use does not fall within the list of exemptions outlined in the CCPA regulations under Cal. Code Regs. tit. 11 § 7027, subsection (m). We do not use or disclose sensitive personal information for purposes other than those specified in § 7027, subsection (m).

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Phone: (800) 522-2013
• Email: compliance@triadfs.com
• Postal Address:

Triad Financial Services, Inc

Attn: Legal Department

13901 South Sutton Park Drive, Suite 300

Jacksonville, FL 32224