Effective Date: July 18, 2018

Your privacy is very important to us. We want you to understand how we may collect, use, share, and keep information about you and the choices that are available to you. This Privacy Policy describes the types of information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, the steps that we take to safeguard the information and to protect your privacy; and other important privacy terms (as updated from time-to-time, this "Privacy Policy") that apply when you visit the Subtractor website (Subtractor.com, TheSubtractor.com), and any associated or successor websites, products, services or mobile applications (collectively, the "Site").

By using the Site, you are accepting the terms of this Privacy Policy and you are consenting to our collection, use, disclosure and protection of your information as described in this Privacy Policy.

As used throughout this Privacy Policy , the terms (1) "Subtractor," "we," "us" or "our" means Subtractor, Inc. and its successors, agents and assigns worldwide; (2) "you" or "your" means any user of the Site; and (3) "includes" or "including" means "including but not limited to" or "includes but is not limited to."

As you review this Privacy Policy, please remember information you provide to us in connection with the Site may be governed by a separate notice called the Subtractor Privacy Policy. Please refer to that notice for additional information about our privacy practices and your rights.

This Privacy Policy does not address, and we are not responsible for, the personal information collection, use, disclosure or security, or other practices, of any third parties to which the Site may link, which is framed within the Site, or which is otherwise available on or through the Site (including, for example, social media "like," "share," or similar buttons, some of which may collect information from you even when you do not interact with them). Such third parties may also include, for example, lenders, credit card companies and other providers of products and services. Information collected by these third parties is governed by their privacy policies, which we encourage you to review.

The inclusion of a link, button, or similar functionality within the Site does not imply our endorsement of the third party. In addition, we are not responsible for and have no liability for the content, features, products, services, privacy policies or terms of service of any other third party, social media platform, operating system or wireless service provider; or device manufacturer.

We may change this Privacy Policy from time-to-time. If we make changes to this statement, we will update the "Last Modified" date at the top of this page. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise. Your continued use of the Site following the posting of any changes will mean that you accept those changes.

Sources of Personal Information

The personal information we collect about you comes primarily from the information that you provide to us during the course of your relationship with us. We may also collect information about your experiences with us relating to your use of the Site.

When you interact with the Site on a social media platform, we may collect the personal information that you make available to us relating to that platform, including your account ID or username and other information included in your posts. The information available to us through your social account can be selected at the time you link your account.

Finally, information may be collected about you indirectly through monitoring or other means (for example, monitoring emails we send you and information collected through your use of the Site). By communicating with us, you acknowledge that your communication may be monitored or recorded without further notice or warning.

Information That You Provide

When you use the Site, or otherwise interact with us, the typical information we may collect about you may include:

• Your name, address, phone, email and other contact details and similar information;

• Account login credentials;

• Information about subscriptions or other services you receive;

• Social media account ID;

• Other personal information that you disclose as part of any Site enrollment or in other communications with us.

Of course, you are not required to supply any of the personal information that we request. However, your failure to do so may result in your being unable to interact with our Site, or having that interaction with the Site being limited.

Automatically Collected Information

In addition to the information that you provide to us, we collect certain information automatically through your use of the Site or interaction with our advertisements. For example, we may collect data regarding your use of the Site directly or through our service providers using cookies, web beacons, page tags, pixels or similar tools that are set when you visit the Site or when you view an advertisement that we have placed on another site ("Clickstream Data"). Clickstream Data may include computer and connection information such as statistics on your page views, pathways to and from the Site, referral URL, ad data, IP address (which can be used to derive the location of your device), device identifiers, the type of operating system and browser you use, and other device settings. Clickstream Data also may include your browsing history, transaction history, your web log information and other information that may be aggregated and/or de-identified. Clickstream Data helps us suggest products or service offerings that may be of interest to you. This information may be used by us (or third parties on our behalf) for the purposes described in this Privacy Policy or for other business purposes as permitted by law. For more information about how the Site uses cookies, web beacons, page tags, pixels and similar choices and your rights and choices, please see Cookies and Other Tracking Technologies below.

Location Information

We may receive information about your location and your mobile device, including a unique identifier for your device. In addition, in some instances, location information can be derived from your IP address or through your wi-fi connection. We may use your device's physical location to provide you with location-based services and content. You can change whether you share specific geo-location information in your device settings; however, some features in the Site may not function properly without this information.

Use of Your Information

We use your information to provide you with services on our Site and to help us personalize and continually improve the Site, including fulfilling requests for information, analyzing and compiling trends and statistics, and communicating with you.

We may also use your information to:

• Administer, operate and manage your relationship with us. This may include sharing such information internally as well as disclosing it to third parties, as described in this Privacy Policy.

• Mitigate fraud, enhance the security of the Site and manage institutional risk;

• Operate, evaluate and improve our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);

• Contact you through various channels, including mail, text message, and Site messaging including push notifications, and email;

• Provide you with customized information and reports, tailored content and marketing messages, including through push notifications and text messages;

• Support our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements;

• Comply with contractual obligations, relevant industry standards and our policies;

• Improve Site performance and personalize your experience with the Site;

• Notify you about changes to the Site, and policies;

• Perform analytics concerning your use of our Site, including your responses to our emails and the pages and advertisements you view;

• Respond to your requests and otherwise fulfill any purpose for which you provide personal information to us;

• To facilitate social sharing functionality;

• For any other purpose that we disclose at the time you provide, or when we collect, your information; and

• Other purposes permitted by applicable law.

You may stop the receipt of push notifications through your device settings.

In addition to the list above, we may use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.

If you opt to cancel your account or otherwise end your relationship with us, all Subtractor related account data, transaction data associated to your account, and banking connection data you have provided will be permanently deleted immediately following your deletion request.

Disclosures of Your Personal Information to Third Parties

We may share your personal information with third parties as described below. In addition, we may share information that does not specifically and personally identify you, such as aggregated information, device identifiers or other unique identifiers to third parties.

Third-Party Service Providers: We may share your personal information with non-affiliated companies that perform support services for the Site ("Third-Party Service Providers"). We may also share your personal information with other third parties whose products or services you request within the Site, and if so, such third parties may use and disclose your information in accordance with their own privacy policies.

Law Enforcement, Legal Process and Emergency Situations: Your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations. Examples include responding to a subpoena or similar legal process, protecting against fraud and cooperating with law enforcement or regulatory authorities. We may also disclose your information if we believe it is necessary or appropriate to protect our rights, property or safety or the rights, property or safety of our employees, customers or others, or to enforce our contractual rights.

Sale, Assignment or Change of Control: In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities, some of the personal information that we hold may be among the assets or liabilities transferred to a buyer or other successor. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or liabilities or any line of business, change in ownership control or financing transaction.

Cookies and Other Tracking Technologies

Like many online services, we use tracking technologies such as cookies, web beacons and similar technologies. We may also use these technologies to record your preferences, track your use of the Site across multiple devices, measure exposure to our online advertisements, monitor traffic, improve the Site and make the Site easier to use.

We may use and disclose the information described in this section for any purpose, except where we are required to do otherwise under applicable law. If we combine the information described in this section with information that is deemed "personal information" under applicable law, we will treat the combined information as described within this Privacy Policy, for as long as it is combined.

You have choices to limit some tracking mechanisms that collect information when you use the Site. Many web browsers automatically accept cookies, but you can usually modify your browser's setting to decline cookies if you prefer. If you choose to decline cookies, certain features of the Site may not function properly or may not remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that, if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.

For more information about your choices, see Interest-Based Advertising below.

Cookies

Cookies are small text files that may be placed on your device when you use the Site or when you view advertisements that we have placed on other websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. When you quit your browser, some cookies are stored in your computer's memory, while some expire or disappear.

Tags, Pixels, Web Beacons, Clear GIFs

A web beacon, also known as an Internet tag, pixel tag or clear GIF, is typically a one-pixel, transparent image located on a webpage or in an email. These may be used when you are served with advertisements, when you interact with advertisements outside of our online services or when you interact with our communications. They are generally used to transmit information back to a web server.

Interest-Based Advertising

We may use third party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you use other applications and online services, based on information relating to your access to and use of the Site and other apps and online services. To do so, these companies may place or recognize a unique identifier on your device. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device from which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/ and http://optout.networkadvertising.org/ . To opt out in the mobile application, go to www.aboutads.info/appchoices to download the App Choices app.

If you choose to opt-out, a cookie will be placed on your browser or device indicating your decision. This cookie is specific to a particular device and browser, so if you use different browsers or devices, you will need to opt-out on each. In addition, because the opt-out is facilitated via cookies, if you clear your cookies you will need to opt-out again.

Additional Technology

We use Google Analytics, a web analytics service provided by Google, on the Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site's activity and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. The Site does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google's privacy policies. To learn more about Google's partner services and to learn how to opt out of tracking of analytics by Google, click https://www.google.com/policies/privacy/partners/.

Information Security - How We Protect Your Privacy

We employ protections to keep data secure, but no data transmission or storage system can be guaranteed to be 100% secure. We seek to limit access to your personal information to authorized employees, agents, contractors or Third-Party Service Providers. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure while in our possession.

Other Important Information

You must be an individual of at least eighteen (18) years of age and reside in the United States or on a United States military base, or in a United States Territory in order to use the Site. If you do use the Site outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing and storage of your personal information in, the United States and elsewhere. The laws in the United States and these countries regarding personal information may be different from the laws of your state or country.

" Do Not Track" Signals

Your browser or device may include Do Not Track functionality. The Site is not built to respond to Do Not Track signals. That means that, even if your browser is set to "Do Not Track," our information collection and disclosure practices (including the choices that we provide to customers) will continue to operate as described in this Privacy Policy.

Our Contact Information

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@thesubtractor.com, and we will try to resolve your concerns.