ALFRED™ Privacy Policy

This Privacy Policy explains how ALFRED™ (“ALFRED,” “we,” “our,” or “us”) — a financial decision intelligence platform owned and operated by Fintech Reimagined LLC — collects, uses, shares, and protects information as you engage with the platform.

ALFRED operates through the P3 Framework™ and Readiness Intelligence™ to evaluate readiness signals and support progression toward a Complete Verified File. This Policy covers the information gathered in support of that process, positioned Upstream of the Application™ — before a file ever reaches a lender or CDFI.

Information We Collect

ALFRED collects the following categories of information to deliver readiness guidance and support the Complete Verified File Delivery process:

• Information you provide directly — name, email, business information, readiness assessment responses, uploaded documents, and communications with ALFRED
• Information from authorized third-party providers you choose to connect, including Plaid and other financial or identity verification services
• Technical information such as browser type, device information, IP address, session activity, and platform usage analytics

How We Use Information

Information collected through ALFRED supports the following functions:

• Deliver readiness evaluation and guidance through the P3 Framework™ and Readiness Intelligence™
• Verify submitted information and improve platform functionality
• Support readiness, compliance, verification, and workflow activities across the Entrepreneur, CDFI, and Lender engines
• Maintain platform security and meet applicable legal obligations

Information Sharing

ALFRED does not sell personal information. Information may be shared only in the following circumstances:

• With authorized service providers who support platform operations, under confidentiality obligations
• When required by law, regulation, or valid legal process
• As part of a business transaction, such as a merger, acquisition, or asset sale
• With a CDFI, lender, or capital provider — but only once a Complete Verified File is assembled and you have approved its submission

• Share your data with a lender or CDFI before you reach the Proceed state and approve submission
• Sell or share your data for advertising purposes
• Generate leads from your information outside the ALFRED platform

Data Retention

Information is retained only as long as reasonably necessary to provide ALFRED’s services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the type of information and the purpose for which it was collected.

User Rights

You may request access to, correction of, or deletion of your eligible information, subject to applicable legal requirements. Requests can be submitted using the contact information below, and ALFRED will respond within a reasonable timeframe consistent with applicable law.

Third-Party Services

ALFRED may reference or integrate with third-party services to support identity verification, financial data connection, and readiness evaluation, including:

Additional authorized providers may be added as the platform evolves. Each third-party provider maintains its own privacy practices, and ALFRED encourages you to review them directly.

Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in the platform, applicable law, or operating structure. Continued use of ALFRED following any update constitutes acceptance of the revised Policy. The effective date at the top of this document reflects the most recent revision.