Effective Date: February 24, 2026
This Privacy Policy (“Policy”) applies to the products, services, and platform (referred to collectively as the “elphi Platform” or “Platform”) owned and operated by elphi, Inc. (“elphi” or “us” or“our” or “we”). For purposes of this Policy, “you” and “your” mean the Platform account creator, authorized signer, authorized representative, delegate, and/or other authorized Platform user, including a co-applicant. This Policy describes and governs the personal information collection, use, and sharing practices of elphi with respect to the Platform. Personal Information, sometimes also known as Personally Identifiable Information or ‘PII’, is information that can be used on its own or with other information to identify, contact, or locate a person or household, or to identify a person or household in context.
Before you use or submit any information on or through the Platform, please carefully review this Policy. By using any part of the Platform, you consent to the collection, use, and disclosure of the information you provide as further outlined in this Policy. We will continue to evaluate this Policy as we update and expand the Platform and our offerings, and we may make changes to the Policy accordingly. Any changes will be incorporated into this Policy and posted on the Platform. Your continued use of the Platform will signify acceptance of the terms of the updated Policy.
What Type of Information Do We Collect?
We collect information in multiple ways, including when you provide information directly to us and when we passively collect information from you, such as from your browser or device.
Information You Provide Directly to Us
We may collect information from you during your use of or access to the Platform, such as when you:
Register for an elphi Platform account;
Enter information in the elphi Platform;
Communicate with us;
or Connect with your third-party accounts to retrieve your information.
For example, we may collect identifying information such as your name, email address, account password, and phone number for creating and authenticating an elphi Platform account. We may also collect third-party account credentials (e.g., your log-in credentials for accessing your bank account or tax return information) , as well as contact, financial, and other information that may be used for the purpose of retrieving information from third-parties. All such information we collect from you through or in connection with the Platform is covered by this Policy.
Certain information we collect, such as financial account information, authentication credentials, and other financial data, may be considered sensitive personal information under applicable law. We use such information only as necessary to provide the Platform and related services and not for marketing or advertising purposes.
Information Collected Passively
• Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices or tablets)you use to access the Platform. As described further below, we may collect and analyze information such as (a) IP addresses (including city and state information), unique device identifiers, IMEI and TCP/IP addresses, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, and the state or country from which you accessed the Platform; and (b) information related to the ways in which you interact with the Platform, such as referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Platform, amount of time spent on particular pages, date and time you used the Platform, frequency of your use of the Platform, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
• Cookies and Other Electronic Technologies
We use cookies, pixels, and similar tracking technologies to improve the Platform, understand user activity, and support marketing and advertising efforts.
These technologies may collect information about your device and browsing activity, including IP address, browser type, pages visited, time spent on pages, referring URLs, and other online activity information.
We may work with third-party service providers and advertising partners that use cookies and similar technologies to collect information about your interactions with our website. These partners may associate your website activity with other personal information they or others have about you, including your email address, for the purpose of providing marketing communications and targeted advertising based on your online activity across websites and devices.
This identity resolution and advertising activity is limited to U.S.-based visitors and is conducted in accordance with applicable U.S. privacy laws. Our service providers are contractually restricted from using the information for purposes other than providing services to us.
You may opt out of this type of advertising by visiting:
https://app.retention.com/optout
You may also control cookies through your browser settings. Please note that disabling cookies may affect certain features of the Platform.
Information from Third Parties
We may also obtain information about you from third parties such as third parties that provide products or services related to the Platform.
How Will elphi Use My Information?
We may use the personal information we collect:
• To process and fulfill a transaction or to provide products or services through or in connection with the Platform
• To administer an elphi website, including troubleshooting, data analysis, testing, and for statistical and survey purposes;
• To send you information about your Platform-related activities;
• To contact you with information or surveys regarding our Platform;
• To process and respond to your inquiries or to request your feedback;
• For internal research and reporting;
• To improve the content and features of the Platform or develop or deliver new products or services;
• To enforce the legal terms that govern your use of the Platform; and
• To monitor trends, marketing and advertising;
We may also use information that we collect on an aggregate or anonymous basis (such that it does not identify any individual or household) for various business purposes, where permissible underapplicable laws and regulations.
How Will elphi Share My Information?
We do not sell Personal Information for monetary consideration. In limited circumstances, we may share certain Personal Information, such as device identifiers and online activity information, with advertising and marketing service providers to assist us in delivering marketing communications and measuring advertising effectiveness. Where required by applicable law, you may have the right to opt out of such sharing.
• Financial Services Providers. We collect information for Financial Services Providers that are evaluating, processing, or funding loan applications or other financial services applications. We may share the information you provide with, and/or make that information available to Financial Services Providers, their successors-in-interest, and other relevant third parties that the Financial Services Provider has authorized to access the information in order to facilitate the loan process or other financial services transaction, and provide related services and products to you. If you are a customer of such a Financial Services Provider and have questions about its privacy practices or you no longer want to be contacted by the Financial Services Provider, please contact the Financial Services Provider directly. The Financial Services Provider’s privacy policy, and not this Policy will apply to the Financial Services Provider’s use of your information, and to the sharing and use of your information to/by others authorized by the Financial Services Provider to obtain your information. elphi is not responsible for the privacy practices of the Financial Services Providers.
• Third party service providers who act on our behalf.
• Data Access Providers and Other Third Parties. If you choose to provide your Third-Party Account Credentials to link with your third-party financial accounts, you grant us and our data access providers the right to retrieve information from the relevant third party on your behalf and transmit such information to the Financial Services Providers. The collection, use, transmission, and storage of this information by our data access providers is governed by the privacy policy of the applicable data access provider. If following the initial retrieval of information from your third-party financial account, you no longer want us or our data access providers to obtain information from such accounts in connection with continued provision of services to you, please see the “What Choices Do I Have” section below. elphi may also share your information with partners of elphi or the Financial Services Provider (e.g., pricing engines, document generation providers).
• Consent. With your consent, we may also share your information with other third parties.
• Other third parties to meet obligations for legal or regulatory compliance; to verify or enforce our terms of use and other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers, employees, or third parties.
How Does elphi Secure My Data?
Safeguarding your Personal Information is our top priority. We have implemented security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, we store usernames, passwords, PINs, and other log-in information in encrypted form. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because despite our efforts, no internet and/or other electronic transmissions can be completely secure.
We recommend that you change your password periodically. You are responsible for maintaining the security of your Platform account username and password. If you believe that your Platform account username and/or password have been stolen or been made known to others, it is your responsibility to immediately contact us at privacy@elphi.io and change your password. We are not responsible if someone else accesses your Platform account through information they have obtained from you.
What Choices Do I Have?
1. Updating and Deleting Your Information. You may be able to add, update, or delete certain information through the Platform. When you update information, however, we may maintain a copy of the unrevised information in our records for legal compliance purposes. Any information that cannot be updated or deleted through the Platform will require you to contact the Financial Services Provider for further assistance. Additionally, to the extent applicable law affords you rights to your personal information, such as access and deletion rights, please reach out to your Financial Services Provider to inquire about your data rights.
2. Account Access for Providing Financial Services. If you no longer want us or our data access providers to obtain information from your financial accounts on behalf of your Financial Service Provider, please email us at privacy@elphi.io.
California Privacy Rights
If you are a California resident, you may have certain rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), including the right to request access to, deletion of, or correction of your Personal Information, and the right to opt out of the sale or sharing of Personal Information, where applicable.To exercise your rights, please contact us at privacy@elphi.io. We will not discriminate against you for exercising your privacy rights.
U.S. State Privacy Rights
Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws. These rights may include the right to access, correct, delete, or opt out of certain processing of Personal Information.To exercise applicable rights, please contact privacy@elphi.io.
What Is elphi’s Policy on Children?
We do not knowingly collect or solicit personal information (as defined by the “Children’s Online Privacy ProtectionAct”) from anyone under the age of 13. If you are under 13, please do not attempt to register for the Platform or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact privacy@elphi.io.
For more information about the Children's Online Privacy Protection Act(COPPA), visit the FTC website: http://www.ftc.gov/.
Retention of Your Information
We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, including to comply with legal, regulatory, tax, accounting, or reporting requirements.
Will elphi Change This Policy?
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of the Platform, or advances in technology. Please check this page periodically for changes. Your continued use of the Platform following the posting of changes to this Policy will mean you accept those changes.
How to contact us?
If you have any questions or concerns regarding our Privacy Policy, please send us a detailed message to privacy@elphi.io and we will try to resolve your concerns.
