AKOUBACREDIT PRIVACY POLICY

Last Updated: February 27, 2015
AKOUBACREDIT , its subsidiaries and affiliates (collectively, “Company”, “we”, “our”, or “us”) recognizes the importance of privacy and personal information. This Privacy Policy (the “Policy”) highlights how Company manages your personal information and safeguards your privacy. This Policy applies to the Site(s) and such other mobile applications, websites, domains and sub-domains and services, however accessed and/or used, whether via personal computers, mobile devices or otherwise, as well as mobile applications, interactive features and downloads that the Company owns, operates, and makes available through its websites and mobile applications (collectively, the “Site(s)”). This includes interactive features or materials and mobile applications that by their nature interact with The Site(s) and post this Privacy Policy. This Privacy Policy only covers the Site(s) and does not cover any information otherwise collected by us (such as, without limitation) in the “real world” [offline] or at any other web site whether or not owned by us. You may be asked to provide your personal information any time you are in contact with Company. The Site(s) are intended for a general audience aged eighteen (18) years and older. If you are under the age of 18, you are prohibited from using the Site(s). Any personal or other information we collect that can be used to uniquely identify or contact a single person is personal identifying information (“PII”). Protecting your PII is a core value at Company and this Privacy Policy is designed to tell you in plain language how and what kinds of information we collect (public and PII), how the Company, itself and through third party services, uses “tracking” technology during your visits to the Site(s), how the Company uses the information it collects, and how we protect that information. If you have any questions about this Privacy Policy, please contact hello@akoubacredit.com. In addition to this Privacy Policy, users of the Site(s) must comply with the Site(s)’ Terms of Use (“TOU”). There is additional and important information contained in the TOU.

FOR PURPOSES OF CLARITY:

Among the products and/or services that Company offers on the Site(s) are software and/or services used for loan and credit management. While the software and/or services may allow the purchaser/user to manage and store personal information, this Privacy Policy applies only to the Site(s) and NOT TO ANY THIRD PARTY SITE USING COMPANY SOFTWARE AND/OR SERVICES. THOSE WHO DO PURCHASE SOFTWARE OR SERVICES FROM COMPANY ARE REQUIRED UNDER THE TOU AND/OR THE APPLICABLE TERMS OF SALE TO ONLY USE THE SOFTWARE OR SERVICES IN CONFORMITY WITH ALL APPLICABLE LAWS, INCLUDING PRIVACY LAWS, AND TO POST THEIR OWN PRIVACY POLICY AS MAY BE REQUIRED BY LAW IN CONNECTION WITH THEIR USE OF THE SOFTWARE/SERVICES. How this Privacy Policy Affects You Purpose: The purpose of this Privacy Policy is to clearly and concisely inform users of and visitors to (“you” or “your”) the Site(s) of: (1) the information that we collect through the Site(s); (2) how we use that information; (3) how we protect that information; (4) what, if any, information we may share and with whom; (5) and how you can review your Personally Identifiable Information (“PII”) collected through the Site(s) and request modifications and corrections. Please take a moment to read this Privacy Policy to learn how we handle your personal information. In addition, this Privacy Policy clearly explains the steps that you should take if you desire to opt-out of our personal information collection process and how to review and request modification of your personal information that the Company may have collected.

INFORMATION WE COLLECT

Information You Provide Directly to Us: (1) you may be asked to directly provide the Company with certain categories of personal information/PII (e.g., your full name, gender, geographic location [for example, shipping and billing addresses if you are engaging in transactions], e-mail address, telephone contact, a “password” [see below], etc.). You may also choose to share additional personal financial and account information or on sign-up forms or certain pages within the Site(s). We reserve the right to collect information through, without limitation, account registration forms, e-mail newsletter sign-ups, and information that you provide to us directly via the Site(s) and mobile applications; (2) Statistical information is the type of personal information, provided directly or indirectly, that may be collected from you at any time when you are in contact with the Site(s) or mobile applications but is not used in connection with your PII; (3) We do collect your credit card information or other financial information (such as financial account information for a loan or credit transaction) to enable you to make a loan or credit application through the Site(s) or mobile applications. Additionally, if you make a loan or credit application through the Site(s), you may be asked to agree to additional terms. Your credit card and financial information will be used solely for processing your loan or credit transactions that you authorize. We utilize SSL protocol in connection with the collection of such information. Information We May Collect during Your Visit to The Site(s) or Mobile Applications: When you contact the Site(s) or mobile applications, the Company and its third party service providers may also collect your usage information. This usage information may be collected through automated or passive means and may include a variety of technologies that collect information whenever you come into contact with the Site(s) or mobile applications. For example, these technologies record and collect your browser information, the “click-through URL” that linked you to the Site(s) or mobile applications, your usage information about pages and/or features that you visited, the date and time of your contact, and other similar information. We may also collect your internet protocol (“IP”) address or other automatically assigned identifiers that allow us to identify the device or mechanism through which you contact the Site(s) or mobile applications. We treat device and mechanism identifiers, as well as your usage information, to be the type of personal information that may be collected from you at any time when you are in contact with the Site(s) or mobile applications. We may also use this personal information in order to remember you and your preferences. We do not link aggregate data with PII. How We Collect Your Personal Information: During your visit to the Site(s) or mobile applications, we may use the following technologies, without limitation, to collect your personal information: (1) cookies; (2) Flash cookies; (3) small graphic images or web beacons; (4) embedded script; and (5) similar technologies. Cookies are data files placed on the device that is used to access a website. A Flash cookie is a data file placed on a device via a third party plug-in (which may be built into your device or downloaded to your device). Small graphic images or web beacons, other web programming code that may be invisible to you, may be included on the Site(s), mobile applications, and in Company e-mail messages. Web beacons may be used to count the number of users accessing the Site(s) and mobile applications, monitor how users navigate our website(s) and mobile applications, and count the number of e-mails that were sent and actually opened or the number of particular articles or links that were actually viewed. An embedded script is programming code that is designed to collect information about your interactions with the Site(s) or mobile applications (e.g., a link that you click on). We utilize both Session and persistent cookies. A session cookie is a code temporarily “dropped” in your browser through which you access the Site(s) and mobile applications from our web server or a third party service provider, and is only active while you are in contact with the Site(s). This code is deactivated or deleted thereafter. A persistent cookie remains after the session is terminated. We use information collected to: (1) allow for better site functionality while you are visiting the Site(s); (2) provide you with information about services and products that we think may be of interest to you; and (3) to collect aggregate (non-personalized) data. We may, from time to time, supplement the information that we collect about you online with outside records from third parties in order to enhance our ability to serve you, as well as offer opportunities to purchase loan or credit products or services that we believe may be of interest to you. We will apply this Privacy Policy to all collected personal information and may combine your collected personal information to serve our needs in any way, unless we have disclosed otherwise. If you send a third party a communication from the Site(s) or mobile applications, such as sending a friend our loans or credit Service(s) information, we may use this information on a one-time basis to facilitate the communication. We will not use it for any other marketing purpose, unless we obtain consent from that third party.

HOW WE USE YOUR PERSONAL INFORMATION

We may use the information that we collect about you to accomplish any of the following: (1) provide you with information, services, or process your loand or credit transactions that you have requested or agreed to receive, including sending electronic information on loans or credit services, or providing you with special offers or promotional materials on behalf of the Company or third parties; (2) enable you to participate in a variety of the features on the Site(s) and mobile applications, such as online loan or credit information from third party providers; (3) process your registration with the Site(s) and mobile applications, including verifying that your e-mail address is active and valid; (4) improve and customize your experience when you contact the Site(s) and mobile applications; (5) contact you regarding your use of the Site(s) and mobile applications and, in our discretion, changes to the Site(s) and mobile applications or the policies that apply to both; (6) comply with court orders, valid subpoenas, and/or other applicable laws and regulations; (7) for our business purposes; and (8) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy. If you provide comments or commentary or other materials to the Site(s) or mobile applications, we may use these comments and materials as provided (or in a reasonably similar manner), which may include your full name and other information as further set forth in our TOU.

INFORMATION WE MAY SHARE

Information We May Share with Third Parties: We may share information that we do not consider to be personal information, such as aggregated user statistics, with third parties. We do not share your personal information with third parties for marketing purposes unless you consent to such sharing at the time you provide such information. We may share the information we have collected about you, including your personal information, as disclosed at the time you provide your information and as described in this Privacy Policy or to secure third party lenders for your loan or credit application. If you agree (or do not decline) to receive information or marketing materials from third parties, your personal information may be disclosed to such third parties and all information disclosed (by you or by the Company) will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of third parties. You should therefore review the privacy policies and practices of such third parties prior to agreeing to receive such information from third parties. If you later decide that you do not want to receive communications from a third party, you will need to contact that third party directly. We may use third party vendors such as lenders to perform certain services on behalf of the Company, such as hosting the Site(s) and mobile applications, designing and/or operating website features, tracking website analytics, enabling you to purchase any loan or credit products and/or services, and allowing us to send you e-mail newsletters or perform other administrative services. We may provide third parties with access to your information, including your personal information, to carry out the loan or credit services that these parties are performing for you or for us. Access to certain areas of the Site(s) and mobile applications may be provided to you in association with third parties and may require you to disclose personal information in order to register for and access loan or credit products and/or services. Such co-branded areas will identify the third party associates. If you elect to register for loan or credit products and/or services at co-branded areas you may be providing your information to both us and the third party associates. Further, if you sign-in to a co-branded area with a username and password obtained on the Site(s) and mobile applications, your personal information may be disclosed to the identified third party associates for that co-branded area and will be subject to the third party associates’ privacy policies. Legal or Administrative Purposes: We may transfer and disclose your information, including your personal information, to third parties for the following purposes: (1) in the event that we are required to respond to subpoenas or other legal process or if in our good faith opinion such disclosure is required by law; (2) at the request of governmental authorities conducting an investigation; (3) to protect or defend the Terms of Use or other policies applicable to the Site(s) and mobile applications; or (4) to protect the personal safety, rights, property or security of any individual. We may also use IP address or other information collected to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you. Business Transfer: We may share your personal information with our subsidiaries and affiliates for internal purposes. We also reserve the right to disclose and transfer all information related to the Site(s) and mobile applications, including, without limitation, your personal, demographic, and usage information for the following purposes: (1) to a subsequent owner, co-owner, or operator of the Site(s) and mobile applications or an applicable database, or (2) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process.

THIRD PARTY CONTENT AND LINKS

The Site(s) and mobile applications may contain content provided by third parties. Those third parties may collect information about your website usage, including information specific to your mobile device or computer (e.g., IP address) when pages from the Site(s) and mobile applications are served to your web browser. Further, when you click on a third party link from the Site(s) and mobile applications (including, without limitation, banner advertisements), that link will take you to a website(s) controlled and operated by third parties that the Company does not control. When you click on a third party link, you will be subject to that third party’s terms and privacy policy. Please review the privacy policy of all third party website(s) that you contact prior to sharing your personal information with such websites. Third Party Advertisements and/or Analytics: The Site(s) and mobile applications may serve third party advertisements and may use third party analytics service providers to provide us with statistical information about your use of the Site(s) and mobile applications. These third parties display advertisement banners based on an analytics of the statistical data regarding your visits to the Site(s) or mobile applications in order to tailor advertisements that may interest you. These third parties typically install cookies or other tracking technologies to monitor and record certain behavioral statistics that assist with targeted advertising practices. This Privacy Policy does not cover the methodologies used by third parties. If you check on a banner advertisement that re-directs you from a Company website or mobile application, you will be subject to that third party’s terms and privacy policy. Please review the privacy policy of all third party website(s) that you contact prior to sharing your personal information with such websites. We are not responsible for the content or practices of any third party advertiser.

SECURITY

Protection of Your Personal Information: The Company employs reasonable efforts to protect the personal information that you share when you contact the Site(s) or mobile applications as required by applicable law under a SSL Lock. However, note that it is not possible to secure all transmissions made over the internet or through other content/information sharing devices. WE DO NOT WARRANT OR REPRESENT THAT WE CAN GUARANTY THE SECURITY OF ANY INFORMATION THAT YOU TRANSMIT TO US WHEN YOU USE COMPANY WEBSITES AND MOBILE APPLICATIONS. YOU PROVIDE SUCH PERSONAL INFORMATION AT YOUR OWN RISK. In the event of a data or security breach that may compromise your personal information, the Company will make commercially reasonable efforts to notify you and/or the requisite governmental or other regulatory agency promptly and as required by law. Children under the Age of 13: The Site(s) and mobile applications are intended for the general audience over the age of 18. We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected the personal information of a child under the age of 13 we will take steps to delete the information as soon as possible. Your Ability to Review your personal information and Request Changes Changes to Your Personal Information and Preferences: You are solely responsible for the accuracy and content of any personal information that is submitted to The Site(s) and mobile applications (or which may be collected by the Company pursuant to this Privacy Policy). You have the right to review the personal information that we have collected from you. After you review such information, if you decide to change the personal information that we have on file for you, send your request to the Company by e-mail PRIVACY @AKOUBACREDIT.COM] or U.S. mail (ATTN: Privacy Policy, AKOUBACREDIT at 910 W Van Buren Chicago IL 60607. To change the types of communication that you receive from the Company or how you receive such communications, simply cancel or modify your communication preferences by following the instructions in the e-mail or communication that you received or by logging into your account with any of the Site(s) or mobile applications and changing your communication preferences. If you are Outside of the United States The Site(s) and mobile applications are located in the United States. If you are located outside of the United States, please be aware that the information we collect will be transferred, stored, and processed in the United States. When you contact The Site(s) and mobile applications, you are automatically consenting to our standard practice of processing, storing, and transferring your personal information within the United States. Note that data protection and privacy laws are different in every country. You are responsible for learning the data protection and online privacy laws of your own country. Information that you provide may be transferred or accessed by the Company’s affiliates around the world and may be processed by foreign affiliates that operate under foreign online privacy laws. The Company abides by the “safe harbor” frameworks set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information collected by organizations in the European Economic Area and Switzerland. For more information, contact the U.S. Department of Commerce Safe Harbor Program. When you contact The Site(s) or mobile applications you consent to the transfer and storage of your personal information in the manners described in this Privacy Policy.

CHOICE OF LAW

Unless the Parties agree otherwise, in the event that the Agreement to Arbitrate above is found not to apply to either Party or to a particular claim or dispute, either as a result or a decision by the arbitrator or a court order, the Parties agree that any Claim must be resolved exclusively in the Circuit Court of Cook County, Illinois and you irrevocably consent to exclusive jurisdiction and venue in such courts

CHANGES TO THIS PRIVACY POLICY

The Company reserves the right to change this Privacy Policy as it deems reasonable and appropriate without notice to you. Any changes to this Privacy Policy are effective as soon as such changes are posted to The Site(s) or mobile applications. However, the Company will not use your personal information in a manner that is materially different from what was stated in this Privacy Policy at the time that you contacted The Site(s) or mobile applications. The date of the most recent changes to this policy is listed at the beginning of this document. The Company encourages you to verify the date that this Privacy Policy was last updated whenever you contact The Site(s) or mobile applications to determine whether or not changes were made. The Company may, from time to time, post notices on The Site(s) or mobile applications if the Company believes, in its sole discretion, that it has made material changes to this Privacy Policy.