Spark Revenue
Privacy Policy

This Privacy Policy describes the collection and use of information by Spark Revenue (together with its affiliated companies, "Spark") in connection with its operation of the Web site located at getcreditamerica.com (the "Site"), including all content, information, and functionality available through the Site, and when you otherwise interact with us regarding our products, services, or offerings (collectively, referred to as the "Services"). Spark takes its obligations regarding privacy very seriously, and it wants to ensure users are fully informed about the Information they are providing to it. By using our Services, including the Site, you acknowledge the terms of this Privacy Policy as they may be amended from time to time.

Types of Personal Data Collected by Spark

We treat any data that identifies, or reasonably can be linked to, an individual consumer as "Personal Data." Data that has been de-identified or aggregated so that it cannot reasonably be linked to an individual consumer is not Personal Data, and we may use that data for any purpose. Personal Data also does not include publicly available information, such as information that is lawfully made available through federal, state, or local government records. We may use de-identified, aggregated, or publicly available data, for any purpose. We do not attempt to re-identify de-identified data unless we have been given consent to maintain and use the data in identifiable form.

Spark may collect the following types of Personal Data:

• Identifying Information - such as name, mailing address, phone numbers, and email addresses.
• Internet or Similar Network Activity - such as your activity related to your interaction on our Site, as well as your interaction with our advertising and other communications, which may include your IP address and browsing activity.
• Commercial Information - such as information relating to your purchases and services, including your purchasing or consuming histories or tendencies.
• Professional or employment-related information
• Demographic Information – such as age or birthday, gender, salary range, marital status, occupation, or personal and online interests.
• Inferences drawn from other personal information, such as profiles reflecting your preferences, characteristics, predispositions, attitudes and aptitudes.

How We Obtain Your Personal Data

We obtain your Personal Data in the following ways:

• From You: We obtain most of the Personal Data that we collect about you from you when you interact with our Site, including when you contact and communicate with us via forms or surveys contained on our Site.
• From Our Partners: We may obtain Personal Data about you from our service providers or other partners, including marketing partners while assisting us to providing you with our Site or Services. We also may utilize third party companies that utilize technology to independently document users' consent provided on our Site signifying agreement to be contacted by us or our partners. For more information about the data use and collection policies of these companies, please see the following privacy policies: (a) ActiveProspect, or (b) Jornaya. In addition, we may enter into list management agreements in which Personal Data may be shared with us to conduct advertising or marketing.

How We Use Personal Data

Spark may use Information collected in connection with the Site in the following ways:

• Provide Our Products and Services: We use Personal Data to furnish our Services, including to process and fulfill your selection or purchase of our Services and to improve the quality, safety and security of our Site and the Services.
• Communicate with You: We use Personal Data to respond to communications, contact you about your transactions, promote our Services, provide other relevant information, and request information or feedback.
• Personalize Your Experience: We utilize Personal Data regarding your use of our Services to personalize and enhance your experiences.
• Internal Research: We use Personal Data to conduct internal research to develop, improve or repair our products, services or technology.
• Security or Fraud Prevention: We use Personal Data to: (1) prevent, detect, protect against, or respond to security incidents, fraud or malicious or deceptive practices, or other illegal activity, (2) preserve the integrity or security of systems, and (3) investigate, prepare for, establish or defend legal claims.
• Legal Compliance: We may use Personal Data to comply with applicable law or to comply with a lawful governmental request.

Use of Cookies

Like most commercial websites, we analyze how visitors use our website and portals with "cookie" technology. A cookie is a small text file that is placed on your computer when you access our website and allows us to recognize you each time you visit the website. We may use cookies and similar technologies such as pixels to: (1) enhance and personalize your experience on our Sites; (2) monitor and analyze website usage and performance; and (3) improve our Sites, Services, and advertising. We may combine cookie data with other information we collect about you or that we receive from third parties.

If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser's help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features on our website. Please note that browser-management tools for cookies are outside of our control, and we cannot guarantee their effectiveness.

Retention

We will retain your Personal Data only for as long as necessary to fulfill the business and commercial purpose(s) for which we obtained the information or as otherwise required by law. Also, please see below regarding consumer rights that may be applicable in your jurisdiction.

We do not use or disclose sensitive personal information, as defined by the California Consumer Privacy Act ("CCPA"), for purposes that would require a consumer to exercise a right to limit under the CCPA.

Our Sharing of Personal Data with Third Parties

• Legal Affiliates: We may share Personal Data with our subsidiaries and legal affiliates.
• Service Providers: We engage third parties to act as our service providers and perform certain tasks on our behalf in connection with our Site and Services. The tasks performed by service providers include: (1) processing and storing Personal Data; (2) assisting with marketing communications and advertising; (3) customer service assistance; and (4) providing technology services, including assisting with our Site. We may share all of types of Personal Data that we collect that are described above with service providers. We encourage service providers to take reasonable steps to ensure that they keep Personal Data confidential and only utilize Personal Data as permitted.
• Partners: We may partner with third parties to provide services and other offerings. For example, we may share your Personal Data with business partners related to content on our Site to provide you with information about products, services and special offers that may interest you. When you use our Site, we may share Personal Data with partners who match the information you share with online and offline marketing databases and those of its advertising partners for the purpose of enabling interest-based content and advertising by third parties unaffiliated with our Site.
• Other Legal Purposes: We also may share Personal Data: (1) with your consent; (2) to respond to subpoenas, court orders, or other legal process or otherwise as required or allowed by law or the competent governmental or judicial authorities; (3) to cooperate with law enforcement, government or regulatory entities, and safety or investigation authorities; (4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or other illegal activities or to establish or preserve a legal claim or defense; (5) to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or other illegal activity, or preserve the integrity or security of systems; (6) to investigate, establish, exercise, prepare for, or defend legal claims; or (7) as part of a corporate restructuring, sale of assets, merger or divestiture.

Security of Your Personal Data

We use commercially reasonable administrative, technical and physical safeguards to protect Personal Data, considering the nature of the Personal Data and the threats posed. However, there is security risk inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Data.

Third Party Websites and Applications

Our Site may contain links to websites or applications hosted by third parties. This Privacy Policy only applies to websites and applications within our control and does not apply to any third-party sources. Any data collected through third party websites or applications is subject to the privacy practices of the third party, and you should review the privacy policies of these third parties prior to sharing any data.

Your Rights and Choices

Depending on your jurisdiction, you may have specific rights regarding their personal information. This section describes rights that may be available to you and explains how to exercise those rights.

Right to Know About Personal Data

You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Data. Once we receive your request and verify your identity, we will disclose to you: (1) the categories of Personal Data we collected about you; (2) the categories of sources for the Personal Data; (3) our business or commercial purpose for collecting or disclosing that Personal Data; (4) the categories of third parties with whom we shared that Personal Data; and (5) the specific pieces of Personal Data we collected about you in the preceding 12 months.

Right to Deletion

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will permanently delete (and direct our service providers to delete) your Personal Data from our records, unless a legal exception to deletion applies.

Right to Correct Personal Data

You have the right to request that we correct inaccurate Personal Data that we maintain about you.

Right to Opt-Out of the Sale or Sharing of Your Personal Data for Targeted Advertising

You have the right to opt out of the sharing of your Personal Data for targeted advertising. As noted above, we engage in personalized or targeted advertising using third-party cookies or pixels. In connection with such advertising, we may share the following categories of Personal Data with marketing partners: (a) identifying information, (b) device information, such as unique advertising identifiers and cookies, and IP address; (c) demographic information, (d) commercial information, (e) location information, such as city; and (f) inference data. We do not otherwise sell your Personal Data, and we have no actual knowledge of selling or sharing personal information of minors under 16 years of age to non-affiliated third parties without affirmative consent.

Additionally, if you enable a browser-based opt-out preference signal, such as Global Privacy Control, in certain jurisdictions, upon receipt or detection, we will make reasonable efforts to treat the signal as a valid request to opt out of the sharing of Personal Data for targeted advertising pursuant to applicable law.

Exercising Your Rights

To exercise the above rights, please submit a verifiable consumer request to us by either:

• By emailing us at info@sparkrevenue.com; or
• Visiting https://docs.corepassage.com/ccparequest.aspx to fill out a request form.

Authorizing an Agent

You may designate an authorized agent to submit your consumer request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.

Verifying Your Request

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify your identity or authority to make the request.

To verify your identity, we ask that you provide us with the following information when you submit your request: (1) first name, (2) last name, and (3) phone number or email. We will use the above information to verify your identity. Depending on your type of request or the information requested by you, we may require additional information to verify your identity and fulfill your request.

Appeal

If we deny your request, you may have the right to appeal our decision.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights.

Cross-Border Data Transfers

We may process Personal Data both inside and outside the United States. When appropriate, we execute EU and UK Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the EU and the UK and make transfers of personal data from those jurisdictions to the United States and other countries that lack adequacy determinations. Please contact us as detailed in the "Contact Us" section below for more information. In addition, we may transfer your Personal Data if one of the legal exceptions for such transfer can be invoked, such as with your consent or in execution of an agreement you have with us.

Personal Data Concerning Children

We do not knowingly collect Personal Data from individuals under the age of 16, unless the Personal Data is submitted with verifiable parental consent. Our website, portals, and applications are not intended for anyone under the age of 16, and no one under the age of 16 may provide information on the website, portals, or applications.

Updates to the Privacy Policy

We may update this Privacy Policy periodically as we offer new products and services, and as our business, technology, and laws change. You can determine when this Privacy Policy was last revised by referring to the "Last updated" reference below. Any changes will become effective upon posting of the revised Privacy Policy. If we make material changes to the policy, we will provide notice to you of the changes as required by applicable law.

Contact Information

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

Email: info@sparkrevenue.com
Postal Address: Spark Revenue
Attn: Privacy Compliance Officer
425 W Colonial Dr Ste 303
Orlando, FL 32804

Last Updated: January 27, 2026