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Privacy Policy

Last updated: June 3, 2022

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We respect your privacy and values your trust and confidence. This Privacy Notice (“Privacy Notice”) sets out the types of information that U-Pledge, Inc. dba B Generous (“B Generous”, “we”, “us” and/or “our”) may collect, use, share, transfer, store, or otherwise process when you use its website and other products and services (collectively, the “Service”) and the purposes for which we may use such information. This Privacy Notice does not apply to any website, including third-party websites, that B Generous does not own or control. The website and this Privacy Notice are intended for U.S. residents only. By using the website and Services, you agree to the terms of this Privacy Notice.

In addition, federal privacy laws protect your financial personal information. Please see our Gramm-Leach-Bliley Act Privacy Notice, which is available here, for more information.

1. Personal Information Collected by B Generous

We may collect, use, share, transfer, store, disclose, or otherwise process your Personal Information. “Personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). “Personal Information” does not include: (1) publicly available information, such as information that is lawfully made available from federal, state, or local records, and (2) de-identified, aggregate, or any consumer information that cannot be reasonably linked to you.

In the past 12 months, we have collected the following categories of Personal Information:

  • Personal Identifiers: This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. We use this information to provide you Services, respond to your requests, and send information and advertisements to you. We also use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.
    We also collect payment information when you provide it to us, which may be your credit card number or bank account, when you complete a transaction. We use this information to streamline and facilitate payments and transactions.
  • Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This category is similar to identifiers and may include a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  • Characteristics of Protected Classification under California or Federal Law. This may include age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Commercial Information: This may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements, and offers.
  • Device-Specific Information:
    • This may include information such as hardware model, operating system, unique device identifiers, and mobile network information including telephone number.
    • We may also maintain digital communication logs that track information like your telephone number and other routing information associated with use of service, time and date of calls, duration of calls, SMS routing information, and types of calls.
  • Internet or Other Electronic Network Activity Information: This may include browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement, such as your clicks and how long you are using our website. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tool, and to serve targeted advertisements based on your online activities.
  • Geolocation Data: This may include physical location or movements. As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates). If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.
  • Sensory data. This may include audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or Employment-Related Information: This may include current or past job history or performance evaluations. We use this information to conduct background and other screening activities, and to promote our services to others.
  • Inferences Drawn from Other Personal Information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
  • Additional information as otherwise described to you at the point of collection or pursuant to your consent.

2. How B Generous Collects Your Personal Information

We may collect Personal Information from you or about you in a variety of ways:

  • We may collect Personal Information from you through your online interactions with us, such as visiting our website, using the interactive features on the website, or registering or completing a profile on our website or completing an online application or prequalification submission. Much of the Personal Information we may collect about users is information provided by users themselves.
  • When you are connected to our services via custom applications (“apps”), we may collect device-specific information. Server logs that are maintained by us or by our third-party service providers may contain information about the services that you have used, and may contain device information.
  • Certain services may include a unique application number in connection with the installation of apps. This number and information, including operating system type and app version number, may be sent to our service providers when you install, update, or uninstall apps.
  • We may also collect and process information about your actual location. We may also collect this type of information based on information available via browser and other supporting apps to determine your location based on information collected via Wi-Fi access points, custom sensors, and cell towers.
  • We may also obtain Personal Information about you, such as name, address, previous purchasing and servicing history, from our business partners, based on information that has already been shared with or made available to them.
  • We may also obtain Personal Information about you, such as your payment and account history, and related product and product servicing history, from our service providers, based on information that has already been shared with or made available to them.

In the past 12 months, we may have collected Personal Information from the following categories of sources:

  • The devices you use to access our websites, mobile applications, and online services;
  • Your bank or financial institution;
  • Public sources (i.e., databases);
  • Social Media platforms (such as Facebook and Twitter);
  • Marketing data from third parties;
  • Identify verification and fraud prevention services;
  • Marketing and analytics providers; and
  • Credit Bureaus

3. How B Generous May Use Your Personal Information

We may collect your Personal Information for the following business or commercial purposes:

  • Account Services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on our service provider’s behalf.
  • Security and Fraud Detection, including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
  • Debugging, including identifying and correcting errors to our system and services.
  • Improvement of Products and Services, including to verify, maintain, and improve our products and services.
  • Internal Research, including for our internal research related to technological development and demonstration.
  • To Comply with our Legal Obligations, including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Audits, including to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
  • As part of a Merger/Acquisition/Bankruptcy or Other Transaction.
  • For Advertising or Marketing Purposes, including for use in digital and standard marketing channels, including, without limitation, apps, notifications, text messages, email, and mail to notify users and customers about products and services that B Generous believes may be of interest to you.
  • To Improve User and Customer Experience, including using your device’s IP address or Media Access Control (“MAC”) address to track device-event information to measure the number of users to the different areas of our websites, and to help us make our websites more useful to users. The information we collect may include, for example, system activity, hardware settings, browser type, browser language, the date and time of your request, referral URL, and any crashes.
  • Other Purposes, including:
    • To ensure compliance with our Terms and Conditions.
    • For security, validation, identity verification, suppression, content improvement and feedback purposes.
    • To perform data analysis, audits, fraud monitoring and prevention, new product development, enhancing, improving or modifying our products and services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
    • To protect our operations, our rights, privacy, safety or property, you or others, and to allow us to pursue available remedies or limit the damages that we may sustain.
    • As otherwise permitted by law.

4. How B Generous May Share Personal Information

We are committed to maintaining your trust and we want you to understand when and with whom we may share the Personal Information we collect.

  • Employees, Contractors, and Service Providers. We share your Personal Information with employees, contractors, and service providers, as required to offer the B Generous Services. This includes, but is not limited to, processing transactions, maintaining your account, offering or servicing loans or lines of credit, offering other financial services, complying with audits, and reporting to credit bureaus.
  • Other Third Parties. We may use third parties to provide additional products and services related to our B Generous credit products and services offered through our website. In addition, we may share Personal Information with other third parties, such as co-branding partners, retail outlets, advertising networks, or app developers for our everyday business purposes. We do not share your Personal Information with third parties for their direct marketing purposes.
  • Administrative or Legal Process: We may disclose your information to third parties in order to protect the legal rights, safety, and security of B Generous; enforce our Terms of Use, respond to and resolve claims or complaints; prevent fraud or for risk management purposes; comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required. We also may disclose your Personal Information if the information is part of a purchase, transfer, or sale of services or assets.

In the preceding 12 months, we may have disclosed the following categories of Personal Information for business or commercial purposes to service providers and the following categories of third parties:

  • Personal Identifiers Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law].
  • Personal information described in the California Customer Records Statute to Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
  • Characteristics of Protected Classification under California or Federal Law to Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
  • Commercial information to Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law

In the preceding twelve (12) months, we have not sold any Personal Information. In addition, we do not sell Personal Information, including Personal Information of minors under 16 years of age, and we have no actual knowledge of doing so.

5. Your Privacy Rights

As described in more detail below, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with certain rights regarding the collection, use, sale, and disclosure of their Personal Information. We care deeply about individual privacy rights and, as such, are extending these rights to you regardless of your state of residence. As we noted above, because B Generous does not sell Personal Information, we have not included a description of the right to opt out of the sale of Personal Information. If you have any questions regarding our sharing practices, please email us at privacy@bgenerous.com.

With a limited exception, the rights described below do not apply to certain personal information, including, for example:

Certain personal information covered by or collected under industry-specific federal or state privacy laws including, but not limited to, the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act. For more information, please visit https://bgenerous.com/privacy-policy/ to view our Gramm-Leach-Bliley Act privacy notice.

Personal information you provide us when acting in other capacities, such as a job applicant, employee, independent contractor, or as a representative of another business (such as a service provider, vendor, or other entity that we do business with). For more information on your privacy rights when acting in other capacities, please email us at privacy@bgenerous.com.

The Right to Know About Personal Information Collected, Used, Sold, Shared, or Disclosed

You have the right to request that we provide you with certain information about the Personal Information we collect, use, sell, share, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before you submit a verifiable consumer request. Specifically, you have the right to request the following information:

  • The specific pieces of Personal Information we have about you.
    • The categories of Personal Information we have collected about you, including:
    • The categories of Personal Information we have collected about you in the past 12 months.
    • The categories of sources from which the Personal Information about you was collected.
    • Our business or commercial purpose for collecting your Personal Information.
  • If we shared your Personal Information:
    • The categories of Personal Information that we disclosed about you for a business purpose in the past 12 months and, for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information; and
    • The categories of third parties that we share Personal Information.
  • If we sold your Personal Information, which we do not do:
    • Our business or commercial purpose for selling your Personal Information.
    • The categories of your Personal Information that we have sold about you in the past 12 months and, for each category identified, the categories of third parties to which we sold that particular category of Personal Information.

However, there is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer. However, if we have collected this type of information about you, we will inform you of that fact and provide you with enough information to determine what was collected.

The Right to Request Correction of Inaccuracies in Personal Information

You have the right to request that we correct any inaccuracies in the Personal Information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a correction request and correct inaccuracies in – or, as may be appropriate, delete – your Personal Information from our records, we will also direct any service providers we work with to also correct or delete your Personal Information from their records. If we store any of your Personal Information in our archived or back-up systems, we will correct or delete your information once the systems are accessed, restored, and/or used.

The Right to Request Deletion of Personal Information

You have the right to request that we delete any Personal Information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your Personal Information from our records, we will also direct any service providers we work with to also delete your Personal Information from their records. If we store any of your Personal Information in our archived or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.

Please note that we may deny your deletion request for a number of different reasons, which are identified in California law.

The Right to Nondiscrimination

We will not discriminate against you for exercising any of your privacy rights. For example, unless otherwise permitted by law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with a different level or quality of goods or services.
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer, and you may consent to receive certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. You may revoke your consent to participate or receive such financial incentives at any time.

Exercising Your Privacy Rights

Request to Know, Delete, or Correct Personal Information

Submitting a Verifiable Consumer Request to Know, Correct, or Delete Personal Information

To exercise your Right to Know, Correct, or Delete Personal Information, please submit a verifiable consumer request to us by selecting the PRIVACY REQUEST button at the top of this document and following the instructions provided to complete the B Generous – Right to Know, Delete, and Correct Request Form. Alternatively, you may submit a request by emailing us at privacy@BGenerous.com

To submit a verifiable consumer request, you (or your authorized agent) will be asked to provide:

  • [Your full name]
  • [Your address]
  • [Your email address associated with the request]
  • An additional identifier to help us verify your identity

You may make such a request by providing an authorized agent with written permission to act on your behalf as outlined below. Your agent may be subject to the same verification procedures that we use to verify consumers who do not currently have a relationship with us. Only you or an authorized agent may make a verifiable consumer request. [You may also make a verifiable consumer request on behalf of your minor child.]

Once we receive your verifiable consumer request, we will confirm our receipt of your request within 10 business days and provide you with additional information about how we will process the request.

Verifying Your Identity or Authority

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. We may otherwise limit our response to your request as permitted under applicable law.

Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account and we will also require you to re-authenticate yourself before we disclose your Personal Information. If we suspect fraudulent or malicious activity on or from your account, we will not comply with your request until we perform further verification to determine whether your request is authentic and you are the person about whom we have collected the personal information.

If you submit a request to know specific pieces of Personal Information, delete Personal Information, or correct Personal Information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose Personal Information is the subject of the request. If we are unable to respond to your request for specific pieces of information, we will evaluate your request as if it is a request to know the categories of Personal Information that we have collected about you.

We will try to avoid requesting additional information from you to verify you. However, if we cannot verify your identity based on the information we currently maintain, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes. We will delete any new Personal Information we collect to verify your identity as soon as practical after processing your request unless otherwise required by law.

Generally, if we are unable to verify your identity, we will deny your request and send you a letter explaining why we were unable to verify your identity.

Please note that we are only required to respond to your request for access to your Personal Information twice within a 12-month period.

Responding to Your Request to Know, Delete, or Correct

Our goal is to respond to your request within 45 calendar days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to 90 calendar days) to respond to your request, we will provide you with a notice explaining the reasons that we will take more than 45 calendar days to respond. Any disclosures we provide will cover the 12-month period preceding the date we received your request. If we are unable to comply with a given request, we will provide you with a response explaining why we have not taken action on your request.

Authorized Agent for Requests

You may designate an authorized agent to make a request on your behalf. Unless you have a power of attorney, if you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request, you must provide the authorized agent with signed permission to do so, and verify your own identity directly with us, or directly confirm that you provided the authorized agent with permission to submit the request. We may deny a request from an authorized agent that does not submit proof that they are authorized to act on your behalf.

6. How B Generous Protects Your Personal Information

B Generous uses reasonable measures to safeguard the security and integrity of your Personal Information. We maintain physical, electronic, and procedural safeguards designed to protect Personal Information. We also employ encryption technologies and user authentication procedures that are designed to keep your Personal Information secure. We limit access to Personal Information to authorized personnel, contractors, service providers, and third party vendors who need access to perform their job and are contractually required to keep your information secure.

However, data transmission or storage on the Internet cannot be guaranteed to be always secure, and B Generous does not make such a guarantee. You should take all precautions to safeguard your passwords and any account information that you may have or provide and to employ current virus-scanning or firewall software and other security safeguards. You should also log out of your account and close your browser window. In the event of a data breach, we will provide you with timely notification as required by applicable law.

7. Suspicious Email

It is our policy not to email you or send you electronic communication to request non-public Personal Information or account information, such as username or password. If you receive an unsolicited email or other electronic communication that appears to be from B Generous but you suspect may be from another source and might be fraudulent, please contact us at privacy@bgenerous.com.

8. Social Security Numbers

Social Security numbers are treated as “confidential” and may only be accessed by and disclosed to B Generous employees and others with a legitimate business need in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to safeguards, and must be stored, transmitted, and disposed of in accordance with our internal policies created and maintained to protect confidential information from unlawful disclosure and to limit access. These restrictions apply to all Social Security numbers collected or retained by B Generous and related service providers and third-party vendors.

9. Allowing or Rejecting Cookies and Use of Do Not Track Signals

In addition to the Personal Information described above, B Generous may also collect information that Web browsers may make available depending on their settings. That information may include “cookies”, the user’s IP address and MAC numbers, the number of times a user visits the website, accesses, operating system and browser type, screen resolution, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the website. We use this information for security purposes, to facilitate navigation, to display information more effectively, to personalize/customize your experience while visiting the website, and to recognize your device to allow your use of our online services. We may collect information about the usage of the website in order to continually improve the design and functionality, to monitor responses to our content, and to assist us with resolving questions regarding the website. We or our third-party partners may also use cookies to collect and store other information about your visit to, or use of, our website.

Some browsers may have the option to transmit a “do not track” signal to websites. B Generous and the third parties who assist in operating B Generous’s Services do not respond differently or limit their practices under the terms of this Privacy Notice when you visit the website with a browser that uses a “do not track” signal or similar mechanism.

Generally, we are not able to link “cookie” information to you without additional information. For example, if a visitor to our website enters data into a web-form and submits data to us, the information is paired with the IP address of the computer the visitor is using. This information is shared internally and with our contractors and service providers.

10. Links to Other Websites

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under the contorl of or maintained by B Generous.
Our online service providers or business partners may implement technologies that allow for the collection of Personal Information over time and across websites. We recommend that you review each privacy notice posted on the websites that you visit to better understand privacy practices on those websites.

Links to other websites or online services that are operated and maintained by third parties do not constitute an endorsement by B Generous of those other websites, the content displayed therein, or the person or entities associated therewith. This Privacy Notice does not apply to this third party content. B Generous encourages you to review the privacy policies of these third party websites or services.

11. Children’s Online Privacy

This website and the Services are intended for general audiences and not directed to children under the age of 13. B Generous does not knowingly collect, use, or disclose Personal Information directly from children under the age of 13. If B Generous is made aware we have collected Personal Information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act (“COPPA”), we will delete this information as soon as possible. If you are under the age of 13, you should not use the website or cause your Personal Information to be submitted to the website.

If you become aware that a child has provided us with Personal Information without parental consent, please email us at privacy@bgenerous.com to request immediate deletion of that information.

12. Privacy Notice Updates and Effective Date

We are required by law to update this Privacy Notice at least once each year. This Privacy Notice was last updated on June 20, 2022. We may amend this Privacy Notice at our discretion from time to time. Your continued use of the Services after any modification to the Privacy Notice will constitute your acceptance of the new terms. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. In the event of any update, the revised Privacy Notice will be posted with a new “Last Updated” date. All updates to the Privacy Notice are effective when we post the updates on our website with the new “Last Updated” date.

13. Contact Us

If you have any questions about this Privacy Notice, the ways in which we collect, use, disclose, and sell your Personal Information, or how to exercise your privacy rights or as otherwise provided herein, please do not hesitate to contact us at: at privacy@bgenerous.com

Drake Bank Privacy Notice

FACTS

 What does Drake bank do with your 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 Transaction History
  • Account Balances and Payment History
  • Credit History and Credit Scores

How?

All financial companies need to share customer’s personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons Drake Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Drake Bank 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
YesNo
For our marketing purposes—
to offer our products and services to you
 YesNo
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes—
information about your transactions and experiences
 No We don’t share
For our affiliates’ everyday business purposes—
information about your creditworthiness
 No We don’t share
For nonaffiliates to market to you No We don’t share

To limit our sharing

Email us at: privacy@bgenerous.com

Please note:
If you are a new customer, we can begin sharing your information 1 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

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

Questions?

Email us at: privacy@bgenerous.com

Who We Are

Who is providing this notice?Drake Bank

What We Do

How does Drake Bank 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 Drake Bank
collect my personal information?
We collect your personal information, for example, when you

  • open an account
  • apply for a loan
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.

What happens when I limit sharing for an account I hold jointly with someone else?Your choices will apply to everyone on your account.

Definitions

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

  • Not Applicable
NonaffiliatesCompanies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Not Applicable
Joint marketingA formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • U-Pledge d/b/a B Generous
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