Privacy Notice

I. Overview

This Privacy Notice sets forth the information gathering, use, and dissemination practices of Alorica, Inc., any of its subsidiaries including Systems & Services Technologies, Inc., EGS Financial Care, Inc., and any of its products or services offered including PayNow. This Privacy Notice addresses Alorica’s practices regarding information collected directly through or from its website. This Privacy Notice also addresses the information collected from any of our clients’ customers as part of our services offered to our clients, which information is owned and controlled exclusively by Alorica’s clients. This notice does not address or govern any information gathering, use, or dissemination practices related to information collected other than directly through or from its website, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media including but not limited to how Alorica’s clients may share information about its customers directly to Alorica pursuant to contractual obligations.

Alorica collects, uses, and stores information on the domain you use to access its website, the Internet address of the site from which you linked directly to its website, and the date and time of your visit to its website. This information may be used to measure the number of visitors to the various pages on the Alorica website, to help make improvements to the information contained on the site, and to better serve site visitors through special marketing and service programs, among others. Alorica also collects, uses, and stores the email addresses of users that communicate with Alorica via email, information knowingly provided by website users, and information regarding which website pages users’ access. As part of the services Alorica offers to its clients, it collects the

information that you provide to us verbally, in writing, during chat sessions or otherwise transmitted from you (as a customer of Alorica’s client(s) to those clients, via Alorica.

II. What Personal Information Do We Collect?

We may collect information about you when you visit our sites or use any part of the services we offer our clients, including the following:

• Registration and use information, which may include personal data as necessary to offer and fulfill the services you request or are receiving from our clients. Depending on the services you choose, we may require you to provide us with your name, postal address, telephone number, email address, and other identification information to establish or further service an account and also information about the services or products you receive or have received from our clients. We may require you to provide us with additional personal information as necessary.

• Information about you from third-party sources – We may obtain information about you from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law and where you have previously authorized our client to direct us to obtain this information.

• Personal information contained in email sent by individuals may be used by Alorica to answer questions, follow-up on suggestions or complaints, process requests or transactions, or improve the level of service Alorica provides.

III. Why Do We Retain Personal Information?

We retain personal information about you to fulfill our legal or regulatory obligations and for our legitimate business purposes in connection with the services we offer to our clients. We may retain personal information for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. We will continue to use and disclose such personal information in accordance with this Privacy Notice. Please note that Alorica does not unilaterally or jointly with others determine the purposes and the means of the processing of any personal information you provide to our clients, indirectly via the services we offer to those clients.

IV. Do We Share Personal Information?

We only share personal information of our client’s customers with that client in connection with the account you may have with that client and/or as part of the services we offer to that client. Aside from that process, the Privacy Notice provides specific information about the reasons why we share the personal data of certain United States residents with unaffiliated third parties.

Aside from information gathered from our client’s customers, we may share your personal information or other information about you for the following reasons:

• with any company or marketing group internal to Alorica or its affiliates to provide you with the products or services requested. Except as provided below, Alorica does not share any personally identifiable information obtained on its website with or sell information obtained on this website to any company or marketing group external to Alorica and its affiliates.

• with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.

• to another entity with which Alorica enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase,

• to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether pursuant to a subpoena, court order, or other form of legal process,

• to a third party if determined by Alorica in its sole judgment that such disclosure is appropriate to protect the life, health, or property of Alorica or any other person or entity. (The foregoing is not intended to obviate or displace any legal obligations or duties applicable to Alorica.)

• with your consent.

V. Other Important Disclosures

Except as necessary for Alorica to provide the services, information, or products requested, or except for the disclosures identified in the preceding section, the user may opt out of having his or her personally identifiable information disclosed by Alorica to third parties by contacting Alorica via postal mail at: 4315 Pickett Rd, St Joseph, MO 64503

While Alorica may undertake efforts to see that another party to which Alorica shares personal information is under a contractual obligation to use the personal information solely for the purposes for which the information was disclosed by Alorica, Alorica exercises no control over such parties and Alorica is not responsible for their conduct, actions, omissions, or information handling or dissemination practices.

Email posted or sent through this website may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, if you are communicating with Alorica, all correspondence should be sent by U.S. Postal Service. Be sure to include your name, your mailing address, and, if applicable, the account number, creditor name, and creditor account number so that we may process your inquiry and respond promptly. Without complete information,

we will be unable to respond to your request. The address for mailing inquiries is: 4315 Pickett Rd, St Joseph, MO 64503

Alorica has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. Additionally to further safeguard this information, our employees are asked to agree to Alorica’s Standards of Conduct and Work Rules as well as confidentiality agreements and are subject to disciplinary action up to and including termination of employment if they fail to follow signed agreements.

California Consumer Privacy Act Notice

Effective Date: January 1, 2020

This Notice applies solely to customers of our clients who reside in the State of California (“consumers” or “you”) We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Alorica is not a “Business” as defined in the CCPA as it does not alone, or jointly with others, determine the purpose and means of the processing of consumers’ personal information. Nevertheless, Alorica strives to maintain it status as a helpful and informative corporate citizen and hereby provides the following information regarding information it gathers on behalf of its clients. Further, although Alorica is not a “Business” as defined in the CCPA, it will reply to written requests for information in order to maintain transparency and to reply to legitimate requests from California consumers.

Information We Collect for our Clients

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include: Publicly available information from government records; De-identified or aggregated consumer information; Information excluded from the CCPA’s scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data or personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources: directly from you; indirectly from you, our clients, or their agents, for example, through information we collect from our clients in the course of providing services to them; and, directly and indirectly from activity on our website, computers, and phones. For example, from submissions through our website portal or website usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes: to fulfill or meet the reason for which the information is provided, for example, as part of the services that Alorica offers to its clients, when you provide us with personal information as part of a transaction or inquiry, we will use that information to verify identity, retrieve account information, process payment, or respond to your inquiry; to carry out our obligations and enforce our rights arising from any client contracts entered into services; for quality assurance and regulatory compliance; as necessary or appropriate to protect the rights, property or safety of us, our clients or others; to respond to law enforcement requests and as required by applicable law, court order, or governmental regulation; as described to you when collecting your personal information or as otherwise set forth in the CCPA; and to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose only as directed by Alorica’s client in connection with the account you have with that client or to further the services you receive or have received from that client. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties: Our affiliates; Service providers; and Third parties to whom you authorize us to disclose your personal information in connection with employment, products, or services we provide to you. In the preceding twelve (12) months, we have not sold any personal information. Alorica does not sell any personal information for any purpose whatsoever.

Your Rights and Choices

Although Alorica is not a “Business” as defined in the CCPA, it will attempt to provide responses to legitimate and verified written requests for information pursuant to the CCPA. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.

The categories of sources for the personal information we collected about you.

Our business or commercial purpose for collecting or selling that personal information.

The categories of third parties with whom we share that personal information.

The specific pieces of personal information we collected about you (also called a data portability request).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o sales, identifying the personal information categories that each category of recipient purchased; and

o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Please be advised that Alorica will generally deny a request to delete information if you are a current customer of one of Alorica’s clients or if you are a former customer of one of Alorica’s clients due to compliance with a legal obligation or to make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Emailing us at CCPArequest@alorica.com or calling us at 1-888-206-3725. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and (ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically determined by the method of submitting the verifiable consumer request. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Discrimination

The California Consumer Privacy Act prohibits us from discriminating against you in any way should you exercise any of the rights set forth above.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this notice, we will notify you through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by sending a verifiable consumer request to us by either: emailing us at CCPArequest@alorica.com, or calling us at 1-888-206-3725.