1. Who We Serve

We work with two types of users:

• Institutions: Banks and lenders using SOLO software.
• End Users: Individuals and businesses who are invited by these institutions to submit information through SOLO.

2. How We Collect Information

We collect personal information in two ways:

2.1 When You Visit Our Website

We may collect:

• Contact information if you fill out a form.
• Usage data via cookies and tracking tools.
• Browser/device info.

2.2 When You Use SOLO Through a Client Invitation

If you’re invited to complete a form or application through SOLO, we may collect data including:

• Name, address, phone number.
• Social Security Number (SSN), Employer ID Number (EIN), or date of birth.
• Employment, income, or financial records.
• Other documents or responses depending on the institution’s request.

We collect only the information that the institution has specified, and we process that data on their behalf.

3. How We Use Your Information

We use your information to:

• Operate and improve our services.
• Present your submitted data back to the requesting institution in a structured, reviewable format.
• Fulfill our obligations under the Fair Credit Reporting Act (FCRA).

We do not make lending, credit, or eligibility decisions based on your data.
SOLO does not engage in automated profiling or decision-making. However, the financial institution that invited you may use the data submitted through SOLO—alongside their own models, rules, or criteria—as part of their evaluation process.

SOLO FINANCE INC. does not disclose nonpublic personal information except for everyday business purposes and as permitted by law.

4. Your Rights as a Data Owner

If your data has been submitted through SOLO, you have rights under the Fair Credit Reporting Act (FCRA), including:

• The right to know what data SOLO holds about you.
• The right to dispute inaccurate or incomplete information.
• The right to add a statement to your file.

To exercise these rights, contact: pass@solo.one

5. How We Protect Your Information

SOLO maintains comprehensive safeguards to protect customer data through multiple layers of security and oversight:

Information Security Program

SOLO FINANCE INC. maintains a comprehensive information security program designed to protect customer information. This program includes administrative, technical, and physical safeguards appropriate to the size and complexity of our operations.

Risk Identification and Assessment

SOLO FINANCE INC. regularly identifies and assesses risks to customer information, including risks in each relevant area of our operations and the operations of our service providers.

Risk Controls

SOLO FINANCE INC. implements safeguards to control the risks identified through our risk assessment process, and regularly assesses the effectiveness of these safeguards.

Risk Testing

SOLO FINANCE INC. regularly tests and monitors the effectiveness of our safeguards, including through vulnerability assessments, penetration testing, and security audits.

Contracts with 3rd Party Service Providers

SOLO FINANCE INC. maintains contracts with third party service providers that require them to maintain appropriate safeguards to protect customer information and limit use of customer data to the purposes for which it was disclosed.

Service Provider Oversight

SOLO FINANCE INC. oversees our service providers through due diligence, contractual requirements, and ongoing monitoring to ensure they maintain appropriate safeguards for customer information.

Employee Training

SOLO FINANCE INC. provides training to all employees on customer privacy rights, data protection requirements, and their responsibilities under this Privacy Policy. Training is provided at hire and annually thereafter.

Acknowledgement

All SOLO FINANCE INC. employees and contractors with access to customer information must sign an acknowledgment confirming they have read, understand, and agree to comply with the SOLO Privacy Policy and Internal Privacy Program.