Theodore Clarke & Company – Privacy Policy

Effective Date: 9/28/2025

Theodore Clarke & Company, LLC (“TC & Co.,” “we,” “us,” or “our”) is committed to protecting the privacy and security of information entrusted to us. This Privacy Policy is intended to provide a clear and legally enforceable explanation of the categories of information we collect, the purposes for which we use such information, the circumstances under which we disclose it, and the rights available to consumers under applicable federal and state law, including, without limitation, the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, the “CCPA/CPRA”) and the Nevada Privacy Law (NRS 603A).

1. Information We Collect

In the course of providing our services, we may collect personal information, including but not limited to identifiers such as name, address, telephone number, email address, driver’s license number, and Social Security number; financial information such as income, credit history, employment details, and vehicle information; technical information such as
Internet Protocol addresses, device identifiers, and browser data; and information relating to your communications preferences. By providing such information, you consent to its collection and use in accordance with this Privacy Policy.

2. Use of Information

We use personal information for the purpose of processing loan, lease, and insurance applications; administering and improving our platform; verifying identity; preventing fraud; complying with applicable laws and regulations; and communicating with you regarding transactions and services. We may also use your information to send marketing and promotional communications by email, telephone, or mail, subject to your rights to opt out. Notwithstanding the foregoing, text message communications sent directly by TC & Co. shall be used exclusively for purposes of two-factor authentication and account security verification. Under no circumstances will TC & Co. use SMS text messaging for marketing purposes.

3. Disclosure of Information

We may disclose personal information to third parties, including dealers, lenders, and insurance partners, solely as necessary to process and administer applications and transactions initiated by you. We may disclose information to service providers who perform functions on our behalf, including cloud hosting, information technology services, data security, and fraud detection. We may disclose information when required to do so by law, regulation, subpoena, or other legal process. TC & Co. does not sell personal information as defined by applicable law.

4. Rights of California Residents

If you are a resident of California, you have the right under the CCPA/CPRA to request that we disclose the categories and specific pieces of personal information we have collected about you, to request correction or deletion of such information subject to certain exceptions, to request information regarding the categories of personal information
disclosed and the categories of third parties to whom it was disclosed, and to opt out of the sale or sharing of personal information. You further have the right not to be subjected to discriminatory treatment for exercising any of your rights.

5. Rights of Nevada Residents

If you are a resident of Nevada, you have the right under NRS 603A to direct us not to sell your covered information. While TC & Co. does not currently sell covered information, you may nonetheless submit a verified request to opt out of the sale of information.

6. Data Security

We implement and maintain administrative, technical, and physical safeguards designed to ensure the confidentiality, integrity, and availability of personal information. These safeguards include encryption, tokenization, multi-factor authentication, and access controls. Our systems are designed to comply with applicable regulatory standards, including the Payment Card Industry Data Security Standard and the Federal Trade Commission Safeguards Rule. We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy or as otherwise required
by law.

7. Cookies and Tracking Technologies

We use cookies and other tracking technologies for purposes of functionality, analytics, and improvement of the platform. By using our website and platform, you consent to the placement of cookies on your device. You may disable cookies in your browser settings, but doing so may affect your ability to use certain features of our services.

8. Children’s Privacy

Our platform is not directed at children under the age of eighteen, and we do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a minor without verifiable parental consent, we will delete such information promptly.

9. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time. Any material changes will be communicated by posting the revised policy on our website or by providing direct notice to you, as required by law. Continued use of our services following such notice constitutes your acceptance of the revised Privacy Policy.

10. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, you may contact us at:

Theodore Clarke & Company, LLC
141 Duesenberg Dr, Suite 15C
Westlake Village, CA 91362
Email: privacy@theodoreclarkeco.com
Toll-Free Telephone: 866-896-4639