Privacy Policy

Financial Privacy Notice

Rev. May 2025

Facts

WHAT DOES GLOW FINANCIAL SERVICES INC. (“GLOW FINANCIAL SERVICES”) DO WITH YOUR PERSONAL INFORMATION?

Why?

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 can include:

• Social security number and income
• checking account information and payment history
• credit history and credit scores

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Glow Financial Services choose to share; and whether you can limit this sharing.

Reasons we can share your personal information
Does Glow Financial Services share?
Can you limit this sharing?

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

Yes
No

For our marketing purposes -
To offer our products and services to you

Yes
No

For joint marketing with other financial companies

No
We don’t share

For our affiliates’ everyday business purposes –
Information about your transactions and experiences

Yes
No

For our affiliates’ everyday business purposes -
Information about your creditworthiness

No
We don’t share

For our affiliates to market to you

No
We don’t share

For nonaffiliates to market to you

No
We don’t share
Questions?
Call (844) 216-1729 or go to www.us.glowcustomerhub.com

Who we are

Who is providing this notice?
Glow Financial Services Inc. (“Glow Financial Services”)

What we do

How does Glow Financial Services protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Glow Financial Services collect my information?
We collect your personal information, for example, when you

• Apply for financing or open an account
• Give us your income information or use your debit card
• Give us your contact information

We also collect your personal information from others, such as credit bureaus or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only

• Sharing for affiliates’ everyday business purposes –information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include financial companies, such as Glow Financial Services Limited, and nonfinancial companies, such as GFS Technologies Limited.

Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Glow Financial Services does not share with nonaffiliates so they can market to you.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Glow Financial Services doesn’t jointly market.
Texas Residents: For questions or complaints about this loan, contact Glow Financial Services Inc. at (844) 216-1729. The lender is licensed and examined under Texas law by the Office of Consumer Credit Commissioner (OCCC), a state agency. If a complaint or question cannot be resolved by contacting the lender, consumers can contact the OCCC to file a complaint or ask a general credit-related question. OCCC address: 2601 N. Lamar Blvd., Austin, Texas 78705.
Phone: (800) 538-1579. Fax: (512) 936-7610. Website: occc.texas.gov. E-mail: consumer.complaints@occc.texas.gov.

Privacy Policy & General Notice

Effective as of February 4, 2025

      Glow Financial Services Inc. (the “Company,” “Glow,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal information and ensuring that we handle personal data in accordance with the applicable data protection laws.

      This Privacy Policy & General Notice (“Privacy Policy”) explains how we collect, use, and disclose personal information about you when you interact with Glow in varying capacities, including when you visit our websites (collectively referred to as “Website”), explore or request our financial products and services in relation to products you may purchase from merchants that partner with Glow, use our borrower portal, or otherwise interact with us or use our services.

      The financial products and services we provide to consumers and customers are subject to other privacy policies and notices that are separate from or supplement this Privacy Policy. If you request or obtain financial products or services from or through us for personal, family, or household purposes, please refer to the financial privacy notice for more information about how we collect, share, and protect your personal information.

      If you are a resident of California and certain other states, please refer to the State Privacy Notice at Collection provided with this Privacy Policy for more information about how we collect, use, and share information within the scope of these state data protection laws.

      Please read this Privacy Policy carefully to understand our policies and practices. We may update this Privacy Policy from time to time, as explained below in the Changes to our Privacy Policy section.

      Our Information Collection Practices

      • In your interactions with us, and as you explore, apply for, or use our services, we may collect certain types of personal information directly from you, such as:
      1. Personal Identifiers: Name, postal address, email address, internet protocol (IP) address, Social Security number, driver’s license number, passport number, information needed to establish a Glow account or provide services (such as username and password), and other similar identifiers;
      2. Records and Financial Information: Telephone number, signature, deposit account number, debit card number, state identification card number, employment status, loan repayment history if you use our services, other financial information, and the personal information referenced above;
      3. Demographic Information: Age, military status, demographic information incidentally included with documentation you provide to use our services (such as a driver’s license or other information submitted for identity verification or fraud prevention purposes);
      4. Commercial Information: Shopping or purchase activity on sites of merchants that partner with Glow to provide financial services;
      5. Biometric Information: When you apply to use our financial services, upon your consent, we may collect a photograph or video of your face and photo identification to verify your identity and validate your request for financial products or services, which some jurisdictions may consider biometric information;
      6. Internet or Network or Device Activity: Interactions with our Website, portal, or online service application, location information (such as IP address), statistics regarding how pages are loaded or viewed, device type, software used, and other related information;
      7. Geolocation Data: IP address-based geolocation data;
      8. Sensory Data: Call recordings when you talk to customer service;
      9. Professional or Employment-related Data: Employment status, self-reported annual income;
      10. Sensitive Personal Information: Some of the personal information listed above is considered sensitive personal information, such as Social Security number, driver’s license, identification, or passport number, demographic information, biometric data used for the purposes of identifying you, and account log-in, financial account, or payment card information in combination with access password or other credential.
      • We may also obtain the above categories of personal information from other sources, such as merchants that partner with us, our service providers (including fraud prevention and identity verification service companies), payment card networks and their participants and service providers, consumer reporting agencies, financial institutions, analytics companies, and other third parties.
      • Some personal information may be collected automatically when you use our customer portal or engage in online browsing on our Website, including preferences, pages visited, and technical information regarding your computer and operating systems, including IP address, domain name, and system configuration and settings.

      The Purpose for Collecting Personal Information

      We may process your personal information for a variety of reasons, including to provide our services, validate your identity, prevent fraud, and comply with the law. In particular, we may use personal information to:

      • Provide the information or the financial products or services you have requested
      • Fulfill obligations to merchants that partner with us to provide financial services to you
      • Provide customer service and support
      • Verify your identity or authorization
      • Give you notices about your account
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Manage and improve the delivery, performance, and security of our service
      • Present our Website and its contents to you
      • Notify you about changes to our Website, products, or service
      • Enforce compliance with any agreements we have with you, including any consents, Website terms of use, and financial service agreements
      • For any other purpose with your consent or as otherwise allowed or required under applicable law

      When We Disclose Personal Information and Why

      We do not sell personal information to third parties or share your personal information for cross context behavioral advertising, including any sensitive personal information. However, we will disclose your personal information to third parties to help us provide services, protect against fraudulent activities, comply with legal obligations, enforce agreements, fulfill the purpose for which you provided it, or for any other purpose disclosed by us when you provide the information. We may also disclose your personal information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others, including exchanging information with other companies and organizations for the purpose of fraud protection and credit risk reduction.

      We may disclose personal information to:

      • Glow affiliates
      • Service providers and consultants
      • Consumer reporting agencies and debt collection agencies
      • Fraud prevention agencies or providers
      • Companies that provide identity verification services
      • Payment card providers and networks
      • Intelligence scanners
      • Legal authorities or as directed by a legal requirement
      • Merchants that partner with Glow to provide financial services
      • Buyers in connection with a business transfer, such as a merger, sale, or transfer of some or all assets

      We may disclose your sensitive personal information as appropriate to carry out legitimate business activities allowed by law.

      How Long We Store Personal Information

      How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for the time required to fulfil the purposes described in this Privacy Policy and our financial privacy notice, unless a longer retention period is permitted or required by law.

      The criteria used to determine our retention period is as follows: personal information for the ongoing relationship between you and Glow is stored for the duration of your and our relationship plus a period of seven years, unless we need to keep it longer, such as in relation: (1) to a legal obligation or compliance with laws to which we are subject; (2) to litigation, investigations, audit and compliance processes; or (3) to protect against legal claims.

      Information that some jurisdictions may consider biometric data, such as a photograph of your face that we may collect if you use our services and we need to verify your identity, will be stored for the time periods above, but no longer than three years.

      How We Protect Personal Information

      The security of your personal information is important to us, and we maintain physical, technical and administrative security standards to protect personal information from loss, misuse, unauthorized access, disclosure, and alteration. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and access controls. Only authorized individuals are allowed access to your personal information. Our service providers and agents are contractually bound to maintain the confidentiality of personal information and they may not use it for any unauthorized purpose. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and verifying that the personal information we maintain about you is accurate and current.

      Biometric Data

      Our identity verification is performed by a third-party service provider.

      The service provider uses your biometric data to check you are a real person, to extract your face from the ID document and to compare that against your selfie to ensure you are the right person, and for anti-fraud purposes. The service provider will store your biometric data as long as needed for the purpose for which it was collected, but no longer than three years.

      The service provider also uses location information from your device for anti-fraud purposes.

      Use of Cookies and Tracking Technologies

      When you use our customer portal or visit our Website, we may use cookies to collect information (such as user preferences, pages visited, and technical information about your computer and operating system). Cookies allow us to recognize whether you have used our portal or visited our Website before, and they allow us to store your preferences and other information. We also use the information to facilitate navigation, display information more effectively, and gather information about the portal and Website to improve their design and functionality.

      If you are concerned about having cookies on your computer or device, you can usually set your browser to refuse all cookies or indicate when a cookie is being set, which will allow you to decide whether to accept it. You can also delete cookies from your computer. If you choose to block or delete cookies, some features of our portal and Website may not function. Some browsers have an optional setting called “Do not Track”(“DNT”) related to advertising and consumer tracking. Glow does not sell your personal information to third parties or share your personal information for cross context behavioral advertising, and we do not respond to DNT settings.

      Third Party Links

      We may provide links to external websites, mobile applications, or third-party services that are not operated by Glow, and plugins from other third parties. These links and plugins are collectively referred to as “Third-Party Sites.” We provide these links and plugins as a service and do not imply any endorsement of them, nor any association with their operators. We are not responsible for the privacy or other policies or practices of those Third-Party Sites or their operators. To learn more about the information collected by Third-Party Sites, please visit their privacy policies.

      Use of Website by Minors

      We do not directly provide services to children. We do not knowingly collect personal information from children under the age of 13 or the relevant minimum age under applicable local law (referred to collectively as a “Minor” or “Minors”). If you are a Minor, please do not provide personal information to Glow through our Website or by any other means. Please contact us if you believe we have mistakenly or unintentionally collected information from or about a Minor. If we have actual knowledge that we have collected personalinformation from a Minor without parental consent, we will promptly delete it, unless we are legally obligatedto retain such data.

      Your Rights

      Under applicable data protection law, you may have certain rights about how your personal information is collected, stored, used, and shared.

      For example, you may have the right to know what personal information we collect about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.

      Subject to certain exceptions, you may have the right to delete personal information that we maintain about you, as well as the right to correct inaccurate personal information. If you are a customer, it is especially important that you keep us informed if your personal contact information changes by contacting us at the email referenced below.

      You also have the right not to receive discriminatory treatment, including not to be retaliated against, for the exercise of your privacy rights under certain, applicable state laws. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights.

      How to exercise your rights

      You can exercise your rights by contacting us at dataprotection@glowgfs.com or by calling (844) 216-1729. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information to fulfill your request.

      To verify your identity, please be prepared to offer the following information: your name, date of birth, and any other information you have previously provided to Glow. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you.We reserve the right to charge a fee where permitted by law (for instance, if your request is manifestly unfounded or excessive).

      You may also be able to designate an authorized agent to make a request regarding these rights on your behalf. If you would like to do so, please have your authorized agent use the contact email or phone number referenced above and state within their request they are your authorized agent. If needed, Glow will inform the authorized agent of any additional verification data needed to process the request at that time.

      We may not always be able to fully address your request (for example, if it would impact the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way\0.

      Our Contact Information

      If you have a question about your personal information or this Privacy Policy, contact us at:

      • Email: dataprotection@glowgfs.com
      • Toll-free telephone number: (844) 216-1729
      • Mailing address: Glow Financial Services Inc., c/o WeWork Brickell City Centre, Suite 500, 78 SW 7th St,Miami, FL 33130

      Changes to Our Privacy Policy

      We may update this Privacy Policy from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page. We encourage you to periodically review this Privacy Policy so that you will be aware of our privacy practices.

      This Privacy Policy was last updated on February 4, 2025.

      State Privacy Notice at Collection

      This Privacy Policy was last updated on February 4, 2025

      This State Privacy Notice at Collection (“Notice”) explains how Glow Financial Services Inc. and its affiliates (the “Company”, “Glow”, “we”, “us” or “our”) collects, uses, discloses, sells, shares, and retains personal information, and it provides information about Glow’s privacy practices as required by the laws of California and certain other US states.

      US state privacy laws do not apply to certain information collected in relation to financial services, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and other state or federal privacy laws. If you request or obtain financial products or services from or through us for personal, family, or household purposes, please refer to the financial privacy notice for more information about how we collect, share, and protect your personal information. This Notice does not apply to information we collect in the context of your interaction with us as a job applicant, employee, contractor, or other role within Glow.

      Under California privacy law, we do not sell or share your personal information, including any sensitive personal information. We also do not sell or share and have no actual knowledge that we have sold or shared any personal information of anyone under 16 years of age.

      For more information about each category of personal information, including retention practices, please see the following sections of the Privacy Policy:

      Categories of Personal Information Collected

      Purpose of Collection and Use

      Categories of Third Parties to Whom Glow Discloses This Personal Information for Business Purposes

      Contact Information and Identifiers

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Provide customer service and support
      • Verify your identity or authorization
      • Give you notices about your account
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Manage and improve the delivery,performance, and security of our services
      • Notify you about changes to our Website,products, or services
      • Enforce compliance with any agreements
      • Glow affiliates
      • Service providers and consultants
      • Credit reporting and debt collection agencies
      • Fraud prevention agencies or providers
      • Companies that provide identity verification
        services
      • Payment card providers and networks
      • Intelligence scanners
      • Legal authorities, or as directed by a legal requirement
      • Merchants who partner with Glow to provide financial services

      Personal information categories listed in the California Customer Records statute (Cal.Civ. Code § 1798.80(e))

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Provide customer service and support
      • Provide customer service and support
      • Verify your identity or authorization
      • Give you notices about your account
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Manage and improve the delivery,performance, and security of our services
      • Notify you about changes to our Website, products, or services
      • Enforce compliance with any agreements
      • Glow affiliates
      • Service providers and consultants
      • Credit reporting and debt collection agencies
      • Fraud prevention agencies or providers
      • Companies that provide identity verification
        services
      • Payment card providers and networks
      • Intelligence scanners
      • Legal authorities, or as directed by a legal requirement
      • Merchants who partner with Glow to provide financial services

      Protected classification characteristics under California or federal law

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Comply with legal requirements
      • Glow affiliates
      • Service providers and consultants
      • Credit reporting and debt collection agencies
      • Fraud prevention agencies or providers
      • Companies that provide identity verification
        services
      • Legal authorities, or as directed by a legal requirement
      • Merchants who partner with Glow to provide financial services

      Commercial information

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Provide customer service and support
      • Give you notices about your account
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Enforce compliance with any agreements
      • Glow affiliates
      • Service providers and consultants
      • Legal authorities, or as directed by a legal requirement
      • Merchants who partner with Glow to provide financial services

      Biometric information

      • Provide information, products, or the financial services that you have requested
      • Provide customer service and support
      • Verify your identity or authorization
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Glow affiliates
      • Service providers and consultants
      • Companies that provide identity verification services
      • Legal authorities, or as directed by a legal
        requirement

      Internet or other similar network usage activity

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Provide customer service and support
      • Manage and improve the delivery, performance, and security of our services
      • Present our Website and its contents to you
      • Enforce compliance with any agreements
      • Glow affiliates
      • Service providers and consultants
      • Credit reporting and debt collection agencies
      • Fraud prevention agencies or providers
      • Companies that provide identity verification
        services
      • Payment card providers and networks
      • Intelligence scanners
      • Legal authorities, or as directed by a legal requirement
      • Merchants who partner with Glow to provide financial services

      Geolocation data

      • Provide information, products, or the financial services that you have requested
      • Provide customer service and support
      • Verify your identity or authorization
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Manage and improve the delivery, performance, and security of our services
      • Present our Website and its contents to you
      • Glow affiliates
      • Service providers and consultants
      • Fraud prevention agencies or providers
      • Companies that provide identity verification services
      • Legal authorities, or as directed by a legal
        requirement

      Sensory data

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Provide customer service and support
      • Manage and improve the delivery, performance, and security of our services
      • Glow affiliates
      • Service providers and consultants

      Professional or employment-related information

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Glow affiliates
      • Service providers and consultants

      Sensitive personal information

      • Provide information, products, or the financial services that you have requested
      • Fulfill obligations to merchants who partner with us to provide financial services to you
      • Provide customer service and support
      • Verify your identity or authorization
      • Prevent fraud and protect against fraudulent activities
      • Comply with legal requirements
      • Enforce compliance with any agreements
      • Glow affiliates
      • Service providers and consultants
      • Credit reporting and debt collection agencies
      • Fraud prevention agencies or providers
      • Companies that provide identity verification
        services
      • Payment card providers and networks
      • Intelligence scanners
      • Legal authorities, or as directed by a legal requirement