Evolve Bank and Trust Privacy Notice

Sharing & Disclosure · Context

The sharing table reports reasons, Evolve's practice and limitability

Evolve says all financial companies need to share members' personal information to run everyday business. It then presents a table listing the reasons a financial company can share, whether Evolve chooses to share for that reason, and whether the consumer can limit that sharing.

Supporting quotations

| How? | All financial companies need to share members’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ or members’ personal information; the reasons Evolve Bank & Trust chooses to share; and whether you can limit this sharing. |

Qualifications & exceptions

• The table reports Evolve's stated choices for the listed reasons; the notice does not describe every operational sharing arrangement.

Sharing & Disclosure · Company practice

Everyday business sharing cannot be limited

Evolve answers "YES" to sharing for its everyday business purposes and "NO" to whether the consumer can limit it. The row gives processing transactions, maintaining accounts, responding to court orders and legal investigations, and reporting to credit bureaus as examples.

Supporting quotations

| Reasons we can share your personal information Does Evolve Bank & Trust share? Can you limit this sharing? For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus YES NO |

Qualifications & exceptions

• The examples follow "such as" and are not exhaustive.
• The stored text flattens the first row's cells ("YES NO"); the table header orders the answers as "Does Evolve Bank & Trust share?" then "Can you limit this sharing?", and the parallel rows preserve those two columns.

Not stated here

• The notice does not identify every recipient or legal process covered by this everyday-business reason.

Sharing & Disclosure · Company practice

Evolve shares for its own marketing, and consumers cannot limit it

Evolve answers "YES" to sharing personal information for its marketing purposes, described as offering its products and services, and "NO" to whether consumers can limit that sharing.

Supporting quotations

| For our marketing purposes – to offer our products and services to you | YES | NO |

Qualifications & exceptions

• The notice does not identify the marketing recipients or the channels used.

Not stated here

• Whether the marketing row covers affiliates, service providers or other third parties is not specified in the row.

Sharing & Disclosure · Company practice

Evolve shares for joint marketing, and consumers cannot limit it

Evolve answers "YES" to sharing for joint marketing with other financial companies and "NO" to whether consumers can limit it. The notice defines joint marketing separately as a formal agreement between nonaffiliated financial companies that together market financial products or services.

Supporting quotations

| For joint marketing with other financial companies | YES | NO |

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Qualifications & exceptions

• The notice does not name its joint marketing partners.

Sharing & Disclosure · Company practice

Affiliates receive transaction and experience data without a limit

Evolve answers "YES" to sharing information about the consumer's transactions and experiences with affiliates for the affiliates' everyday business purposes, and "NO" to whether the consumer can limit that sharing.

Supporting quotations

| For our affiliates’ everyday business purposes – information about your transactions and experiences | YES | NO |

Qualifications & exceptions

• This row covers transaction and experience information; the following row addresses creditworthiness separately.

Sharing & Disclosure · Company practice

Evolve says it does not share creditworthiness data with affiliates

For affiliates' everyday business purposes involving information about the consumer's creditworthiness, the notice answers "NO" to sharing; the row's limit column reads "We don't share" rather than offering a limit.

Supporting quotations

| For our affiliates’ everyday business purposes – information about your creditworthiness | NO | We don’t share |

Qualifications & exceptions

• This is one of the three categories the notice later says federal law lets consumers limit, but Evolve states it does not share for this purpose.

Not stated here

• The notice does not say whether this practice could change or whether a consumer can request a limit in advance.

Sharing & Disclosure · Company practice

Evolve says it does not share for affiliates' marketing

The notice answers "NO" to sharing personal information for affiliates to market to the consumer; its limit column reads "We don't share" rather than offering a limit.

Supporting quotations

| For our affiliates to market to you | NO | We don’t share |

Qualifications & exceptions

• This is one of the three categories the notice later says federal law lets consumers limit; Evolve states it does not share for it.

Not stated here

• The notice does not state whether affiliates may market to a consumer through other data sources.

Sharing & Disclosure · Company practice

Evolve says it does not share for nonaffiliates' marketing

The notice answers "NO" to sharing personal information for nonaffiliates to market to the consumer; its limit column reads "We don't share" rather than offering a limit.

Supporting quotations

| For nonaffiliates to market to you | NO | We don’t share |

Qualifications & exceptions

• This is one of the three categories the notice later says federal law lets consumers limit; Evolve states it does not share for it.

Sharing & Disclosure · Context

Nonaffiliates cover a wide range of possible recipients

Nonaffiliates are companies not related by common ownership or control, whether financial or nonfinancial. The notice says nonaffiliates it shares with can include insurance companies, service providers, co-branded partners, retailers, data processors, membership clubs, companies engaged in selling consumer products and services, financial services companies, banks and mortgage servicing companies.

Supporting quotations

| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. ■ Nonaffiliates we share with can include insurance companies, service providers, co-branded partners, retailers, data processors, membership clubs, companies engaged in selling of consumer products and services, financial services companies, banks, and mortgage servicing companies. |

Qualifications & exceptions

• The recipient list follows "can include" and is not a statement that Evolve shares with every listed category.

Not stated here

• The notice does not name specific nonaffiliates or give a purpose for each category.

Sharing & Disclosure · Context

Joint marketing requires a formal agreement between financial companies

The notice defines joint marketing as a formal agreement between nonaffiliated financial companies that together market financial products or services to the consumer. It says its joint marketing partners include financial services companies and other financial institutions.

Supporting quotations

| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. ■ Our joint marketing partners include companies such as financial services companies and other financial institutions. . |

Qualifications & exceptions

• The description of partners uses "include companies such as", so the list is illustrative.

Not stated here

• The notice does not identify any joint marketing partner by name.

Sharing & Disclosure · Restriction or exception

Vermont mailing addresses receive automatic sharing limits

For accounts with a Vermont mailing address, the notice says the account is automatically treated as if the consumer had limited the sharing described on page 1. Evolve says it will not share information about the consumer with nonaffiliated third parties, except as permitted by law.

Supporting quotations

VT: Accounts with a Vermont mailing address are automatically treated as if they have limited the sharing described on page 1 and we will not share information about you with nonaffiliated third parties, except as permitted by law.

Qualifications & exceptions

• The rule is keyed to a Vermont mailing address on the account.
• The non-sharing commitment is qualified by "except as permitted by law", whose scope the notice does not detail.

Not stated here

• The notice does not explain what is permitted by law or whether the automatic treatment can be changed.

Sharing & Disclosure · Restriction or exception

California law restricts nonaffiliate and intra-company sharing

Under California law, the notice says Evolve will not share information it collects about the consumer with nonaffiliated third parties except as permitted by law. It gives consent, servicing accounts and providing rewards or benefits as examples of permitted sharing, and says it will limit sharing among its companies to the extent California law requires.

Supporting quotations

CA: Under California law, we will not share information we collect about you with nonaffiliated third parties, except as permitted by law. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent required by California law.

Qualifications & exceptions

• The examples of permitted sharing follow "For example" and are not exhaustive.
• The intra-company limit is expressly tied to "the extent required by California law".

Not stated here

• The notice does not spell out the scope of "as permitted by law" or the specific California requirements.