KTR values your patronage and protecting your confidential information is a priority. Our policies and procedures reinforce the fact that we strongly believe in protecting the confidentiality and security of the information we collect about you as a customer, potential customer or former customer. We have adopted the following policies and procedures to safeguard the personal information about you in our possession.

Introduction

This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.

Our Privacy Pledge

• We do not sell or rent customer information.
• We share customer information with certain employees and with companies providing services on our behalf in order to service your needs.
• Our policy is to require all employees and companies providing services on our behalf to keep customer information confidential.
• Our privacy policy applies to potential customers as well as current and former customers.

Safeguarding Personal Information

• We have adopted policies and procedures designed to protect your personal information from unauthorized use or disclosure.
• We have implemented physical, electronic and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access. These include among other things, procedures for controlling access to customer files, building security programs and information technology security measures such as the use of passwords, firewalls, virus prevention and use detection software.
• We continue to assess new technology as it becomes available and to upgrade our physical and electronic security systems as appropriate.
• Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing or developing our products or services.
• Our policy, which governs the conduct of all of our employees, requires all employees to safeguard personal information about the consumers and customers we serve or have served in the past.

KTR Security Policy

KTR takes strong steps to safeguard your personal and sensitive information through industry standard physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls and servers with tested operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Information We Collect About You

We collect information about you to help us serve your financial needs, to provide you with quality products and services and to fulfill legal and regulatory requirements. We consider non-public information about you in our possession to be personal information, even if you cease to be a customer. The personal information we collect about you may include among other things:

• Identifying information, such as your name, age, address, phone number and social security number
• Employment information
• Financial information such as your income, assets and liabilities, as well as information about your savings, investments, insurance and business.

KTR does not alter its behavior or change its services upon receiving Do Not Track requests.

Typically, we collect this information on applications and other forms you complete, through conversations you may have with our loan originators and processors, with our other representatives, and in some cases, over our website. We may also collect information from a wide range of other sources in order to process and/or underwrite your loan. These sources may include among others, employers, attorneys, banks, title insurers, insurance companies and credit reporting agencies.

We will use this information to pull a credit report from a credit bureau to determine your credit worthiness as well as to help our underwriters to assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during the lending process such as:

• Enabling our financial services partners to implement automatic payments and funds transfer
• Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
• Implementing collection activities as needed
• Maintaining regular communications with you as may be necessary to execute loan application, loan agreement and certain stipulations such as identity verification, income verification and employment verification

In addition, we gather names and email addresses of people who contact us through our website with questions about our company or lending operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people.

Lastly, we (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website, as discussed further below.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Communications from Our Site

When you submit an application and/or create a profile on our site you will receive emails that confirm specific actions you requested.

Links to Third Party Websites

KTR is not responsible for the information practices employed by sites linked to or from our website.

Notifications

KTR will send you email notifications from time to time.

Sharing Information With Companies That Provide Services For Us

We do not share phone numbers with third parties for marketing or promotional purposes.

Web-related Information Collection

We use web beacons or pixel tags in conjunction with cookies.

California Do Not Track Notice

Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals.

California

Other important information for California residents.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights.

Link to Other Sites

We may offer links to partner’s sites.

Session time-outs

We employ session time-outs to protect your account.

Passwords

At a minimum, we require the use of both numbers and letters in your password.

What you can do

You can take several precautions to protect the security of your computer and personal information.

Non Sharing Clause

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

Changes To Our Privacy Policy

We may make changes to our privacy policy in the future.

Contacting Us

If you have any questions about this privacy policy, please call us at (651) 492-1402.