ONLINE PRIVACY POLICY AGREEMENT

Effective Date:  January 1, 2026

This website privacy policy (“Privacy Policy”) applies to Xactus, LLC, its respective owners, operators, and employees (“Xactus”, “we”, “us”, or “our”) and describes how we collect, use, disclose, and protect personal information, and outlines your rights under applicable U.S. state and federal privacy laws.

This Privacy Policy applies to all current or former User information collected by or provided to us.  This Privacy Policy also applies to the following websites owned and operated by Xactus, as well as any other websites or online services where this Privacy Policy is posted (“Sites”):

• Xactus.com

Xactus is the controller of data provided to, collected by, or processed in connection with your use of our Sites (“User”).  Using the Sites constitutes your User acceptance and agreement to the terms contained in this Privacy Policy. If you do not agree with the terms set forth in this Privacy Policy, please discontinue using the Sites immediately.

This Privacy Policy does not apply to third-party websites, and we do not accept responsibility for your use of any third-party websites, even if we provide a link on the Sites to such third-party websites. We encourage you to review the privacy policies of any third party prior to disclosing information to that party.

NOTICE OF COLLECTION

The purpose of this Privacy Policy is to notify Users of the following: what information we collect, why we collect User data, how we use it and disclose it with third parties, how we store and protect it, and the choices you have regarding our collection, use, and disclosure of this information.

1. Applicability and Legal Exemptions

We operate as a business-to-business (“B2B”) service provider offering consumer reporting, verification, and identity services governed by the Fair Credit Reporting Act (“FCRA”) and the Gramm-Leach Bliley Act (“GLBA"), as well as public records data services and real property data products to our B2B clients.

Under Cal Civ. Code § 1798.145 and equivalent provisions in other state privacy laws, this notice does not apply to:

• Personal information processed under the FCRA.
• Data processed in accordance with the GLBA.
• Publicly available information.

These exemptions apply to the majority of our services (including real property data) provided by us under contract to our B2B clients.  We do not sell services to non B2B consumers.

2. Information we Collect for Business or Commercial Purposes

For activities not covered by exemptions, we may collect:

• Identifiers – Name, business contact info, IP address, User device information
• Professional/Employment Information – Job title, company
• Internet/Network Activity – Portal access logs
• Commercial Info – Transaction records
• Geolocation – Approximate region

3. Sources of Information we Collect for Business or Commercial Purposes

We may collect information from the following categories:

• Directly from you
• Advertising networks
• Internet service providers
• Data analytics providers
• Government entities
• Operating systems and platforms
• Social networks
• Data brokers

4. Online Information we Collect for Business or Commercial Purposes

Our Sites may use tracking technologies (such as cookies, pixels, web beacons, and device identifiers) to collect limited technical information about Users’ interactions with our websites. This may include IP address, browser type, operating system, Internet Service Provider (ISP), date and time of visit, and clickstream data.

We use this information solely to:

• Operate and improve the performance of our Sites,
• Measure and analyze traffic and usage patterns, and
• Tailor content and communications related to our own products and services.

We work with trusted third-party service providers to support these functions, including platforms such as Google Analytics, Google Ads, and Fullstory. These vendors act as service providers under applicable U.S. state privacy laws and are bound by written agreements that limit their use of personal information to services performed solely on our behalf. They are prohibited from using this information for their own purposes, including cross-context behavioral advertising. We may use these tools to deliver ads to you about our own products and services, but only in a context that does not involve selling or sharing your personal information under applicable U.S. state privacy laws.

We do not sell or share personal information collected via cookies or online tracking technologies, and we do not allow third parties to use such data to advertise products or services of other companies.

You can manage cookie preferences through your browser settings or via opt-out tools provided by our service providers. To opt out of interest-based advertising or data collection by our analytics vendors, you may visit:

• Google Ads Settings – Manage how Google uses your info for personalized ads
• Google Analytics Opt-Out – Prevent Google Analytics from collecting data
• Fullstory Opt-Out – Disable Fullstory session tracking
• Digital Advertising Alliance (DAA) – Opt out of interest-based advertising from participating companies
• Network Advertising Initiative (NAI) – Opt out of targeted advertising by NAI members

5. Business or Commercial Purpose of Information we Collect

We use information to:

• Deliver services and information under contract
• Comply with legal and regulatory obligations
• Prevent fraud, misuse, or security threats
• Operate and audit our websites and internal systems
• Marketing and Advertising as described in Section 6 below

We may also use User’s personal information to perform services on behalf of the business, 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 on behalf of the business. 

6. Marketing and Advertising to Businesses

We may use information we collect to deliver advertising and marketing communications and other information regarding our products, service and promotions or to administer promotions or to deliver newsletters, receipt messages, e-mails, mobile messages and special offers, including:

• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a User’s current interaction with us, provided that the User’s personal information is not disclosed to another third party and is not used to build a profile about the User or otherwise alter the User’s experience outside the current interaction with us; or
• Providing advertising and marketing services, except for cross-context behavioral advertising, to a User.

If at any time the User would like to unsubscribe from receiving future emails, detailed unsubscribe instructions can be found at the bottom of each email, or the User may contact us at:

Email: [email protected]

Attention Name: Legal Department

Mailing Address: 370 Reed Road, Suite 100, Broomall, Pennsylvania 19008

Telephone Number: 888-212-4200

7. Collection of Personal Information – Past 12 Months

The Notice at Collection Table below applies solely to non-exempt disclosures and solely as those disclosures are made by us in our capacity as the controller.

8. Do Not Track and Universal Opt-Out Disclosures

We do not knowingly sell or share personal information as defined under applicable U.S. state privacy laws.  Because we do not engage in these activities, our website does not respond to browser “Do Not Track” signals or universal opt-out mechanisms such as Global Privacy Control (GPC). If we become aware that personal information has been sold or shared in violation of our policy, we will take prompt steps to remediate the situation.

9. Sensitive Personal Information and Consent

We do not use or disclose sensitive personal information about you except for purposes specified under California Consumer Privacy Act (Cal Civ. Code § 1798.100 et seq) (“CCPA”) and equivalent provisions in other state privacy laws.

We do not process sensitive personal information for purposes requiring opt-in consent under U.S. state privacy laws. We have no actual knowledge that we have sold any personal information of any consumer under 16 years of age

Any sensitive personal information we collect or disclose is used solely under FCRA, GLBA, public records, or other applicable exemptions contained in U.S. state privacy laws.

10. Children’s Privacy

Our Sites are not intended or designed to be used by persons under the age of eighteen (18). We do not collect personal information from any person that we know to be under the age of thirteen (13). Guardians of minor children, however, may contact us if you believe your child has provided us with personal information without your consent.

11. Consumer Rights and Choices

For data not covered by exemptions, you may have the right to:

• Know/Access your personal information
• Correct inaccuracies to your personal information
• Delete your personal information
• Limit the use and disclosure of your sensitive personal information
• Port your personal information
• Appeal any denial of a request of any of these rights
• Equal Treatment without discrimination for making such a request or appeal

If you are a resident of California, you may visit this website to learn more about these rights under the CCPA:  https://privacy.ca.gov/

For more information about your rights under the FCRA please see Section 19 below.

12. Submitting a Request

If your information has been requested by or processed on behalf of one of our clients we are a “service provider” and if you wish to exercise any rights you may have about this type of information, please note that the respective client is deemed the “controller” under applicable U.S. state privacy laws, responsible for the information concerned, and that you should make your request to the applicable client directly.

If Xactus is the controller (not acting as a service provider):

Email: [email protected]

Attention Name: Legal Department

Mailing Address: Xactus, LLC, 360 Reed Road, Suite 100, Broomall, Pennsylvania 19008

Telephone Number: 888-212-4200

Reasonable verification will be required.  We may require you to provide certain personal information to process and/or verify your request, including your name or email address, so we can match that information against our business records to authenticate your identity.  Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent and send it to us.

13. Appeals

To exercise your right to appeal a denial of a privacy rights request, contact us using the same method.  We will respond as required by law.

14. Data Retention

We retain data for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

15. Security measures

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized use, access, alteration, destruction, or disclosure.

16. Updates to This Policy

We may revise this Privacy Policy from time to time. Unless otherwise stated, any modifications to this Privacy Policy will go into immediate effect after they have been posted, as indicated by the Effective Date above. You are responsible for checking this Privacy Policy when you visit our Sites to review the current Privacy Policy. If you do not agree with the current Privacy Policy at the time of your use, you should cease use of the Sites immediately

We review and update this Privacy Policy at least once every 12 months, or as required by changes in the law or our business practices.

17. Notice to EU Data Subjects

We do not offer services to or monitor individuals located in the European Union.

18. Accessibility of This Privacy Policy

Xactus is committed to ensuring that our privacy policy and related notices are accessible to all individuals, including those with disabilities. If you require this notice or any related information in an alternative format please contact us and we will make reasonable efforts to provide the requested information in a format that meets your needs.

To receive this notice in an alternative format please contact:

Email: [email protected]

Attention Name: Legal Department

Mailing Address: Xactus, LLC, 360 Reed Road, Suite 100, Broomall, Pennsylvania 19008

Telephone Number: 888-212-4200

19. Notice to Consumers Regarding FCRA Rights and Reinvestigation Requests

We are a Consumer Reporting Agency as defined in the FCRA.

The FCRA provides consumers with a separate set of rights located at https://files.consumerfinance.gov/f/documents/bcfp_consumer-rights-summary_2018-09.pdf, many of which are similar to those rights outlined in Section 11 above

If you believe a consumer report we have provided about you contains inaccurate or incomplete information, please visit: https://xactus.com/help-support/consumer-disputes/

20. Artificial Intelligence; Automated Decision Making

The tools we use on our Sites, including analytics and advertising tools, may incorporate artificial intelligence or machine learning functionality that does not result in automated decision making that produces legal or similarly significant effects on individuals.

Our clients may have access to third-party automated decision tools, including tools that may incorporate artificial intelligence or machine learning functionality.  These tools are supplied by independent providers and are not developed, owned, or controlled by Xactus, its parent companies, or its affiliates.  Clients are solely responsible for their utilization of such tools.  Their purpose is solely to support human decision-making, and they are not intended to replace human decision-making for decisions that produce legal or similarly significant effects made by our clients in their provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services. 

21. Questions about this Policy:

To contact us for more information about this Privacy Policy:

Email: [email protected]

Attention Name: Legal Department

Mailing Address: 370 Reed Road, Suite 100, Broomall, Pennsylvania 19008

Telephone Number: 888-212-4200