Privacy Policy

Earning and keeping your trust has been at the core of our business for over 40 years. Service Payment Plan, Inc. ("SPP," "we," or "us") respects your privacy and is committed to protecting it through our compliance with this policy ("Privacy Policy"). SPP provides zero percent interest payment plans for vehicle service contracts and other protection products. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the websites www.servicepaymentplan.com, www.sppinc.net, www.myspp.com, www.thepowerofzero.com and other websites and online services run by SPP and/or its affiliates (the "Websites"), contact us via mail, email, telephone, fax or instant message, or obtain products or services from us (collectively, the "Services"). This Privacy Policy also explains our practices for collecting, using, maintaining, protecting, and disclosing that information. Depending on how we interact with you, additional privacy or other notices may also govern the handling of your information.

• Residents of Canada should view our Canadian Privacy Policy for information about their privacy rights and choices and additional disclosures.
• For information about how SPP's practices with respect to non-public personal information regulated by the Gramm-Leach-Bliley Act ("GLBA"), please view our Financial Information Privacy Notice .
• Residents of California should also review the Notice to California Residents section of this Privacy Policy.

This policy applies to information we may collect:

• On the Websites;
• In email, text, and other electronic messages between you and the Websites;
• From business partners, such as vehicle retailers (dealers) and service contract administrators; and
• From interactions you have with us offline, such as through a letter or a phone call, in order to provide the Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or our Services. By accessing or using these Websites or obtaining our Services, you agree to this Privacy Policy. This policy may change from time to time (see the Changes to Our Privacy Policy section). Your continued use of the Websites and the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Please note that this Privacy Policy does not apply to any information processed by SPP in its role as service provider to its business partners, who are generally vehicle dealers, dealer management systems, and vehicle service contract administrators. Please consult with the appropriate entity's privacy policy for information on how each entity collects, uses, and discloses personal information. Please note that this Privacy Policy also does not apply to any information collected by any third-party sites to which the Websites may link.

Information We Collect About You and How We Collect It

"Personal Information" includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

We may collect several types of Personal Information from and about users of our Websites and our Services, including:

• Contact information, such as first and last name, postal address, email address, and telephone number.
• Account and profile information, such as account name, and a username or email address in combination with a password or security question and answer that would permit access to an online account, as well as coverage contract identifier assigned to your contract.
• Financial information such as routing number, expiration date, ACH account number, credit card number, or debit card number, date and time of payment, and other applicable payment information.
• Commercial information, including records of personal property and purchasing habits, such as the type of vehicle you have purchased or lease information.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Vehicle information, such as service history information and vehicle identification number (VIN).
• Usage information (details of your visits to the Websites), including referral/requested pages, session IDs, timestamps, and records of time spent on the Websites.
• Technical information, such as browser and operating system types, IP address, unique device identifiers, and other information such as device type.
• Location information, such as rough geolocation through your IP address.

We collect this information:

• Directly from you when you provide it to us by registering for an account with us as either a partner or a customer, filling out forms on our Websites, or by calling or writing us to receive information about the Services.
• Automatically as you navigate through the Websites. Information collected automatically may include usage information and device information collected through cookies.
• From third parties, for example, our business partners such as vehicle service contract providers and vehicle retailers (dealers), such as when they provide Personal Information to us to assist in providing you offers for financing a vehicle service contract. We may also receive information about your purchase, lease, and vehicle service interactions with the dealer.

The technologies we use for automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.
  • We use first party cookies such as session and security management cookies, to assist in the functionality of our Websites, to improve our Websites, to recognize you when you return to the Websites or the Services and to remember information you have already provided or your preferences, and to provide a secure browsing experience during your use of the Websites and Services.
• You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.

We may tie non-personal information collected automatically to Personal Information about you that we collect from other sources or that you provide to us.

Financial Information

For more information on how we collect, use, share, and protect nonpublic personal financial information you may provide us, please refer to our Financial Information Privacy Notice .

How We Use Information We Collect

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Websites and their content to you, including to offer and provide our Services.
• To provide you with information, products, or the Services that you request from us, to complete transactions, to take steps to enter into a contract for financing for vehicle service contracts, to send service communications, and for other customer service functions.
• To customize our communications with you and to notify you about changes to our Websites and our Services.
• To improve our Services, including to improve and grow our business, such as by understanding how our Services and Websites are being used and to develop new features, products, or Services, and for internal quality control and training purposes.
• To conduct general business, accounting, record keeping, and legal functions in support of our operations.
• To secure our Website and Services, including to combat spam, malware, malicious activities or other security risks, to improve and enforce our security measures, and to monitor and verify your identity so that unauthorized users do not gain access to your information.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, such as our Terms of Use or for billing and collection.
• To comply with applicable laws and regulations, including but not limited to use in connection with legal claims, compliance, and regulatory or investigative purposes.
• To protect against and identify fraud and other criminal activity.
• For other legitimate business purposes.

How We Share Information

We may disclose and share Personal Information that we collect or you provide as described in this Privacy Policy:

• To contractors, service providers, and other third parties we use to support our business and provide the Services. These third-party service providers have access to your Personal Information solely for the purposes of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.
• To our partners such as financial institutions and payment processors, dealers, and service contract administrators to facilitate offering you the Services.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our contracts and other agreements, including for billing and collection purposes.
• To an actual or potential buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SPP's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by SPP about users of our Websites and our Services is among the assets transferred.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SPP, our customers, or others.

We do not disclose Personal Information to third parties for their own direct marketing purposes.

Choices About How We Use and Disclose Your Information

Cookies and Marketing Opt Out

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Websites may then be inaccessible or not function properly.

You may opt out of receiving promotional or marketing material at any time by contacting help@sppinc.net or by following the opt-out instructions included in the communications you receive.

Residents of California may have additional rights and choices about Personal Information. Please see the Notice to California Residents section below for more information.

Accessing and Correcting Your Information

If you have an account with us, you can review and change your Personal Information by logging into the Websites and visiting your account profile page. We may retain a copy of your old account information as necessary for business and legal purposes.

Notice to California Residents

This Notice to California Residents section provides additional information to California residents pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the "CCPA").

This section applies to "Personal Information" as defined in the CCPA, which excludes personal information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act ("GLBA"). For our practices related to the collection, use, and disclosure of personal information regulated by the GLBA, please see our Financial Information Privacy Notice . Please note that as an entity regulated by the GLBA, the majority of Personal Information that we collect is in the context of providing financial products or services and is therefore outside the scope of the CCPA.

This Notice to California Residents section does not address or apply to our handling of Personal Information that is exempt under the CCPA, nor does it apply to job applicants or current or former employees in the context of our working relationship with them. This section also does not apply to our handling of information when acting as a service provider to our business partners such as dealers, vehicle service contract administrators, and dealer management systems. In those circumstances, the privacy policy of the relevant dealer, vehicle service contract administrator, and dealer management system will apply to your information.

As described more fully in the section Information We Collect About You and How We Collect It, in the past twelve months we have collected Personal Information from you directly either through the Websites (including automatic data collection technologies) or when you contact us offline regarding our Services, automatically as you navigate through the Websites, from third parties such as dealers, dealer management systems, and vehicle service contract administrators, and from our service providers. We use Personal Information as described in the How We Use Information We Collect section and as described in the tables below. We may disclose Personal Information to our service providers for a business purpose as described in our Privacy Policy section How We Share Information and as described in the tables below.

SPP does not collect any "Sensitive Personal Information" as defined in the CCPA as it does not collect or use such information for the purpose of inferring characteristics about a consumer.

Personal Information Category	Business Purpose for Collection and Use	Categories of Personal Information Recipients
Identifiers, such as real name, postal address, unique personal identifier, online identifier, VIN, email address, account name, or other similar identifiers.	Provide and maintain our Websites and Services, facilitate our business and operational purposes in relation to those services, comply with the law, communicate with you, data security incident detection, debugging and repair of technical systems.	Service providers and partners such as vehicle service contract administrators and dealers
Customer Records personal information, which includes a name, address, telephone number, bank account number, credit card number, or any other financial information. Some personal information included in this category may overlap with other categories.	Provide and maintain our Websites and Services, facilitate our business and operational purposes in relation to those services, comply with the law, communicate with you, data security incident detection, debugging and repair of technical systems.	Service providers and partners such as vehicle service contract administrators and dealers
Internet or other similar network activity, such as information on a consumer's interaction with a website, application, or advertisement.	Providing, maintaining, and improving our Websites and Services, maintaining the security and operation of the Websites, troubleshooting and internal analytics and reporting purposes, data security incident detection, debugging and repair of technical systems.	None
Commercial information, such as records of products or services purchased, obtained or considered.	Providing the Services, including maintaining or servicing accounts, processing or fulfilling orders and transactions, processing payments, providing financing.	None
Geolocation data, such as IP address.	Providing and maintaining the Services, facilitate our business and operational purposes in relation to the Services, communicating with you, and protect against and identify fraud as well as other criminal activity, or with your consent.	None

Profiling, Selling, and Targeted Advertising

We do not "sell" or "share" your Personal Information for cross-context or targeted advertising, nor do we use your Personal Information for profiling (as defined under the CCPA) in furtherance of decisions that produce legal or similarly significant effects concerning you.

SPP does not have any actual knowledge that we sold Personal Information of any person under 16 years old or shared such information for targeted advertising.

You may be accessing the Websites via a browser that has a "Do Not Track" setting. Our Websites do not currently respond to such a signal. If you have turned this setting in your browser on, or if you are using a browser with the default setting of "Do Not Track," please be advised that all features of the Websites may not function in such setting. If you wish to opt-out of the collection of tracking information you may do so according to your browser settings; however, please be advised that such an election may limit the functionality of the Websites available to you.

California Privacy Rights

California residents have the following rights, subject to certain exceptions under the law:

• Right to Know and Data Portability. You have the right to know whether we collected, sold, shared, or disclosed your Personal Information for a business purpose, including the specific pieces of Personal Information we have collected about you. When your right to know includes a data portability request, we will provide you a copy of your Personal Information, subject to any legal exceptions.
• Right to Delete. You have the right to request that we delete Personal Information we have collected or maintain about you. This right is subject to certain exceptions, such as when the Personal Information is needed for legal purposes.
• Right to Correct. You have the right to request correction of Personal Information we maintain about you that you believe is incorrect or inaccurate. Please note that we may not be able to alter certain information depending on legal obligations or exceptions.
• Right to learn of direct marketing. California residents can ask once per year if we have shared Personal Information with third parties for their direct marketing purposes. SPP does not share any Personal Information with third parties for direct marketing purposes.
• Right to Opt-out of Sale or Sharing/Targeted Advertising ("Do Not Sell or Share My Personal Information"). You may request to opt out of the "sale" or "sharing" (as defined by the CCPA) of Personal Information, as well as certain types of cross-context behavioral or targeted advertising based on information collected about you on non-affiliated websites or services. However, we do not "sell" or "share" your Personal Information in this manner.
• Right to Limit: you may request to either limit (opt-out of) or require consent to process Sensitive Personal Information. Since SPP does not collect or process your Sensitive Personal Information as defined under the CCPA, this right is not available.
• Non-Discrimination. SPP will not discriminate against you for exercising any of your above rights. We will not deny you goods or services, charge you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties.

To exercise any of these rights please email help@sppinc.net or call us at 1-800-346-5990

Depending on the type of request, we may request information from you in order to confirm or verify your identity. We may do so by asking for additional information to compare against the Personal Information we hold about you, such as email address, phone number, or other contact information we may have on file for you, or if you have an account with us, by asking you to log in to that account. We will only use this additional information to verify your identity or authority to make the request. We may also ask you to provide additional detail or clarify your request to properly understand, evaluate, and respond to it.

You may authorize someone as an agent to submit a rights request on your behalf. You may provide that person with a power of attorney or signed, written permission to submit requests on your behalf, but we will still require you to verify your identity with us directly by one of the methods listed above. We will also require your authorized agent to verify their personal identity via one of the above methods.

Children's Information

Our Websites are not intended for children under 16 years of age and we do not knowingly collect any information from children under the age of 16. By using the Websites, you certify that you are over the age of 16. We reserve the right to delete any information we believe to be in violation of this Privacy Policy.

We Operate in the United States

If you use the Websites outside of the United States or are a resident of a country other than the United States that has laws and policies governing the disclosure and management of your Personal Information, you understand and agree that the information you exchange with the Websites and Services may be maintained on servers located within the United States. By using the Websites and Services, you understand and consent to the collection, storage, processing and transfer of your Personal Information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy. Residents of Canada should consult our Canadian Privacy Policy for additional information.

Data Security

We have implemented reasonable security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, or disclosure. Unfortunately, the transmission of information via the internet is not completely secure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Websites. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

Data Retention

We will retain your Personal Information for as long as your account is active or as needed to provide you with the Services and to maintain a record of your transactions, subject to applicable law. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. To determine the appropriate retention period for Personal Information, we consider our statutory obligations, the amount, nature, and sensitivity of the Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.

Third Party Sites

Some of the functionality of our Websites may be provided by third parties and we may link to other third-party websites that are not controlled by SPP. These third parties are not under our control and SPP is not responsible for their privacy policies or practices. We recommend reviewing the privacy policies of any such third-party websites you visit.

Changes to this Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the primary email address specified in your account or through a notice on the Websites' home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes.