Effective date: March 9, 2018

CAMM Financial (“CAMM” or “we”) respect your privacy and are committed to protecting your personally identifiable information (“PII”) that may be collected through your use of our website or mobile application (together, “Site”) or in applying for a Loan or receiving any of our Loan products through your selling Dealer or our online services (“Services”). This privacy policy (“Policy”) describes how we collect and use your PII and how you can control that use. Please read this Policy carefully. By using our Site or Services, you agree to our collection, use, and sharing of your PII as described in this Policy.

Information that We Collect

Through your use of our Site and Services, we may collect PII, which is information that identifies an individual or relates to an identifiable individual. PII may include, but is not limited to, your first and last name, physical address, Social Security number, date of birth, and checking account information. We collect the following types of information:

Information Provided by You

If you express interest in one of our Services, we will collect certain PII from you, including contact information (such as name and email), which we will use to contact you. We may request additional PII that is necessary to process any application submitted by you or Dealer, such as your physical address, Social Security number, mobile phone number, date of birth, bank account information and numbers, employment and income information. Additionally, we may collect PII to verify your identity, for security-related purposes, or other administrative purposes or Patriot Act or out of wallet questions. In order to provide Services to you, our Lenders or Assigns, we may on occasion supplement the PII you submit to us with information from third-party sources, such as consumer report information.

If you contact us, tell us your story, or otherwise provide us with information about yourself, we will maintain records of your correspondence. This may include any of your questions, comments, or suggestions. You may also provide us with the email addresses of your contacts and include a personal message to your contacts if you choose to participate in our referral program.

Account and Transaction Information

We collect information about your use of our Services. For example, in processing a payment with you, such information would include your name, amount of payment, and your bank account information, including account numbers, routing numbers, debit card numbers and similar information. Other information that we collect includes your transaction history, payment history, and account balance. We also collect tokens from online services and payment systems.

Device and Usage Information

We may automatically collect the following types of information as you use our Site and Services.

• Usage Information: We collect certain information automatically through your use of the Site, such as which of our web pages you access, the frequency of access, and what you click on while on our Site and submission of Credit Authorization through our online forms.
• Device Information: We may collect information about the device you are using such as: hardware model, operating system, application version number, browser, and IP addresses.

Cookies and Other Tracking Technologies

A cookie is a small text file that is stored on a user's computer for record-keeping purposes.

• We do not use cookies.

We may use a software technology called tracking pixels (a.k.a. web beacons or clear gifs) that help us better manage content on our Site by informing us what content is most effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, tracking pixels are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

Aggregate Information

Statistical or aggregated information does not directly identify a specific person, but it may be derived from your PII. For example, we may aggregate PII to calculate the percentage of users in a particular ZIP code.

Third Party Data Collection

Some content or applications on the Site may be provided by third parties, including advertisers, ad networks and servers, analytics companies, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your PII or they may collect information, including PII, about your online activities over time and across different websites and other online services.

How We Use and Share Information

We use PII we collect in the following ways:

• Process Transactions: We use PII to provide our Services, including to, process Credit Applications, consider loan applications, facilitate loans and process Credit Bureau pulls.
• Communicate: We use PII to communicate with you about our Site, application submission and Loan Services. We will only use the information that you provide for the purpose for which you provided it to us.
• Site Maintenance: We analyze how our users interact with our Site and Services in order to maintain and improve our Site and Services. We also use information that we collect to diagnose any problems with our Site or Services to improve the user experience.

We reserve the right to share information, including PII, with third parties, Lenders or assigns, as described below:

• Service Providers: We may share information with service providers that help us perform functions and process your applications for consideration of Loans.
• Assigns: We may share information with a Lenders, Finance Companies, Dealers or Affiliates to determine qualifications to be considered for a Loan.
• To Prevent Harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
• As Required by Law: We will share information where we are legally required to do so, such as in response to court orders or legal process, to establish, protect, or exercise our legal rights, to defend against legal claims or demands, or to comply with requirements of mandatory applicable law.
• With your Consent: We may request your permission to share your PII for a specific purpose. We will notify you and request consent before you provide the PII or before the PII you have already provided is shared for such purpose.
• Texas, Ohio and ALL USA Residents: We will share your information with the lender and or Dealer with whom you apply or obtain a loan via our Site using our Services.

Correction

If your PII changes, or if you no longer desire our service, you may correct or update your PII by contacting us at: secure@cammfinancial.com.

Security

The security of your PII is important to us. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your PII. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. If you have any questions about the security on our Site, you can contact us at: secure@cammfinancial.com.

Other Websites

The Site may contain links to or links from third party sites that are not owned or controlled by CAMM. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to review the privacy policies of these third party sites before you disclose your PII.

Browser Do Not Track

The Site is not currently configured to respond to Do Not Track signals.

Children's Privacy

Our Site and Services are not intended for use by children. We do not knowingly collect personal information from children under the age of 13 years. If we become aware that a child under 13 has opened an account or otherwise provided us with PII, we take steps to terminate the child's account and delete such PII.

Applicable Law

This is a United States-based Site that is subject to United States law. This Site is controlled, operated, and administered by CAMM from its offices within the United States of America. This Policy is provided in accordance with and subject to applicable U.S. law. If you are accessing this Site from a location outside the United States, you hereby agree that your use of this Site and our collection and use of your PII is subject to this Policy.

Updates to this Policy

We reserve the right to modify this Policy at any time, so please review it frequently. If we decide to make material changes to this Policy, we will post those changes to this Site in a manner that we deem is appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You agree to these future updates by continuing to use our Site or Services after they have been posted. You can always obtain a copy of the most updated Policy by emailing: secure@cammfinancial.com.

CAMM Financial Website Terms and Conditions

CAMM is dedicated to promoting a world of transparency & complete disclosure in the financial services industry.

Rev. December, 2017

What Does CAMM Do with Your Personal Information?

Why? Lenders and Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What? The types of personal information we collect and share depend on the product or service you have with us. This information may include:

• Personal Information which includes
• Social Security number and income
• Account balances and payment history
• Credit history and credit score
• Dealer/Vehicle Purchasing Information

How? All Lenders and financial companies need to share customers' personal information to run their everyday business and to make Credit Decisions. In the section below, we list the reasons Lenders and financial companies can share their customers' personal information; the reason CAMM chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does CAMM share-YES. Can you limit this sharing-NO. For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus, or extension of Credit. For our marketing purposes—
to offer our products and services to you For our affiliates' everyday business purposes—
information about your transactions and experiences

Does CAMM share-YES. Can you limit this sharing-YES. For our affiliates' everyday business purposes—
information about your creditworthiness for our affiliates to market to you

Does CAMM share-NO. Can you limit this sharing-YES. For non-affiliates to market to you

To Limit our Sharing

Email us at: secure@cammfinancial.com
Please Note:
If you are a new customer, we can begin sharing 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as disclosed in this notice.

However, you can contact us any time to limit our sharing.

Questions?
Please email us at: secure@cammfinancial.com or visit www.cammfinancial.com.

Who we are

Who is providing this notice?
CAMM Financial

What we do

How does CAMM protect my personal information?
To protect your personal information from unauthorized access and use, we use securities measures that comply with federal law. These measures include computer safeguards, website encryption and secured files and buildings.

How does CAMM collect my personal information?

We collect your personal information, for example, when you:

• Submit application for consideration-electronically or by facsimile
• Dealer submits your application on your behalf with proper authority

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for Lender and/or affiliates' everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates
Companies related by assigning ownership or control. They can be financial and non-financial companies.

Our affiliates include:

• Lenders and Finance Companies

Companies not related by association. They can be financial and non financial companies.

Non-affiliates
CAMM does not share personal information with non affiliates so they can market to you.

Joint marketing

A formal agreement between non affiliated financial companies that together market financial products or services to you.
CAMM does not jointly market.

Other important information

We share information that we collect with Lenders and/or affiliates when a customer consents to such sharing or the information is released in connection with a written agreement, online application submission or form for the sole purpose of providing products or services covered by such written agreement. We will not share information with affiliates when given notice and an opportunity to opt out, the customer directs us not to share.

Please read this information carefully and print a copy and/or retain this information for future reference. Introduction. You are submitting a request to be connected with one of our third party lenders or lending partners or Assigns. In order to offer you a loan, the third party lenders or lending partners and CAMM need your consent to use and accept electronic signatures, records, and disclosures ("E-Consent"). This form notifies you of your rights when receiving electronic disclosures, notices, and information. By submitting an application or form and using the CAMM submit button assenting to our terms, you acknowledge that you received this E-Consent and that you consent to conduct transactions using electronic signatures, electronic disclosures, electronic records, and electronic contract documents ("Disclosures").

Option for Paper or Non-Electronic Records.

You may request any Disclosures in paper copy by contacting the third party lender or lending partner directly. They will provide paper copies to you. Some may charge for these copies and some may not. The lenders or lending partners will retain all Disclosures as applicable law requires.

Scope of Consent.

This E-Consent applies to all interactions online concerning you and the third party lender or lending partner and includes those interactions engaged in on any mobile device, including phones, smart-phones, and tablets. By exercising this E-Consent, the third party lender or lending partner may process your information and interact during all online interactions with you electronically or by mail. They may also send you notices electronically related to its interactions and transactions. Disclosures may be provided online at our or third party lenders' or lending partners' websites, and may be provided by e-mail.

Consenting to Do Business Electronically.

Before you decide to do business electronically with the third party lenders or lending partners, you should consider whether you have the required hardware and software capabilities described below.

Hardware and Software Requirements.

To access and retain the Disclosures electronically, you will need to use the following computer software and hardware: A PC or MAC compatible computer or other device capable of accessing the Internet, access to an e-mail account, and an Internet Browser software program that supports at least 128 bit encryption, such as Microsoft® Internet Explorer, Chrome® or Mozilla Firefox®. To read some documents, you may need a PDF file reader like Adobe® Acrobat Reader X®. You will need a printer or a long-term storage device, such as your computer's disk drive, to retain a copy of the Disclosures for future reference. You may send any questions regarding the hardware and software requirements directly to the third party lenders or lending partners.

Withdrawing Consent.

Your E-Consent for our connecting service and for our third party lenders' or lending partners' consideration of your connecting request cannot be withdrawn because it is a one-time transaction. If you are connected with one or more third party lenders or lending partners, you are free to withdraw your E-Consent with them at any time and at no charge. However, if you withdraw this E-Consent before receiving credit, you may be prevented from obtaining credit from the lender or lending partner. Contact the third party lender or lending partner directly if you wish to withdraw this E-consent. If you decide to withdraw this E-Consent, the legal effectiveness, validity, and enforceability of prior electronic Disclosures will not be affected.

Change to Your Contact Information.

You should keep third party lenders or lending partners informed of any change in your electronic address or mailing address. You may update such information by logging into their website or by sending them a written update by mail.

We form strategic alliances with Credit Unions and Regional Banks that want to instantly expand into or even streamline their existing indirect lending program in specific Dealer or Consumer markets to generate quality loan volume that they want while reducing acquisition costs, mitigating compliance and greatly increasing Look to Book ratios by utilizing our Inclusive Loan Administration Program.

Our Loan Administration Program is the most efficient method between the Consumer and Dealer to deliver our Institutional Clients a complete and compliant Loan Package that funds quickly without all the internal delinquencies of normal Indirect Programs.