FCRA & Permissible Use Notice

Sovetta Technologies LLC Version 1.1 — Effective July 3, 2026

This Notice governs any use of the Sovetta Platform in connection with consumer reports and consumer report information — including the personal credit report of any business owner, principal, member, or guarantor — under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. ("FCRA"). It is incorporated into the Terms of Service and must be accepted by every Authorized User. Capitalized terms not defined here have the meanings in the Terms of Service.

Why this document exists. Even in commercial financing, a credit report on an individual owner or guarantor is a consumer report, and federal law strictly limits who may obtain and use it, and for what purpose. Your organization — not Sovetta — procures those reports and owns those legal duties. This Notice records the certifications that make your use of the Platform lawful.

1. Sovetta's Role — Not a Consumer Reporting Agency

1.1 Sovetta processes documents and data solely as a service provider and technology agent of Customer, at Customer's direction, for Customer's own use.

1.2 Sovetta is not a consumer reporting agency ("CRA") or a reseller of consumer reports as those terms are defined in FCRA §§ 603(f) and 603(u). Sovetta does not assemble or evaluate consumer credit information for the purpose of furnishing consumer reports to third parties, and no Output of the Platform is a "consumer report."

1.3 Single-organization furnishing rule. Analysis derived from a consumer report is returned exclusively to the Customer organization that procured that report, and to no other person or organization. The Platform is designed to suppress consumer-report-derived content from any view available to a different organization, and you must never attempt to access consumer-report-derived analysis belonging to another organization.

1.4 Sovetta does not obtain consumer reports from any consumer reporting agency on Customer's behalf. Customer (or its authorized agent under its own bureau agreements) procures all consumer reports it submits to the Platform.

2. Your Continuing Certifications

By accepting this Notice and by each submission of a consumer report or consumer report information to the Platform, Customer and the accepting Authorized User represent, warrant, and certify, on a continuing basis, that:

Lawful procurement. The report was obtained directly from a consumer reporting agency or authorized reseller under Customer's (or its principal's) own agreement with that agency, in compliance with that agreement.
Permissible purpose. At the time of procurement, Customer had — and continues to have — a permissible purpose under FCRA § 604 (15 U.S.C. § 1681b), specifically one or both of:

the written instructions of the consumer (a signed credit-pull authorization from the owner/guarantor, typically contained in the financing application); and/or
a credit transaction initiated by the consumer in connection with which the consumer is or may become personally obligated (e.g., as owner or personal guarantor of the merchant applicant).

Single purpose use. The report and all Output derived from it will be used solely for that certified permissible purpose — evaluating the commercial financing transaction for which it was procured — and for no other purpose.
Prohibited uses. The report and Output derived from it will not be used for: employment purposes (FCRA § 604(b)); tenancy screening; insurance underwriting; any eligibility determination other than the certified financing transaction; locating individuals; marketing; or any unlawful discrimination.
No redistribution. Neither the report nor any consumer-report-derived Output will be shared with, resold to, or made accessible to any third party — including any other customer of Sovetta, any other funding company, or any merchant — except as required by law.
User obligations retained. Customer is solely responsible for all obligations of a "user" of consumer reports, including adverse action notices under FCRA § 615 (15 U.S.C. § 1681m) and, where applicable, risk-based pricing notices, and for its obligations under the Equal Credit Opportunity Act and Regulation B, including commercial adverse-action notification duties.
Seat flow-down. Each Authorized User granted access under Customer's account — including sales representatives and independent sales organization (ISO) personnel — accesses consumer report information only as Customer's agent for the same certified permissible purpose, and Customer remains fully responsible for each Authorized User's compliance.
Data disposal. Customer complies with the FTC Disposal Rule (16 C.F.R. Part 682) with respect to consumer report information in its possession.

3. What the Platform Does with Credit Data

3.1 When Customer submits a credit report, the Platform parses it, extracts structured fields, evaluates Customer-configured screening rules, and returns the analysis to Customer's seat(s). This processing is performed as Customer's agent, and the result is part of Customer's own use of the report it procured.

3.2 The Platform's screening outcomes (including any credit-risk rule result) are inputs to Customer's decision, not decisions. Customer must ensure meaningful human review of any decision to deny, price, or condition financing, and is responsible for the content and delivery of any explanation, reason codes, or notices required by law.

3.3 Consumer report information is retained, protected, and disposed of as described in the Data Processing & Security Statement.

4. Violations

4.1 Immediate termination. Any use of the Platform in violation of this Notice is grounds for immediate suspension or termination of the seat and, where appropriate, the Customer account.

4.2 Legal exposure. FCRA violations carry federal civil liability (including statutory and punitive damages under 15 U.S.C. §§ 1681n–1681o), regulatory enforcement, and in the case of knowingly obtaining a consumer report under false pretenses, criminal penalties (15 U.S.C. § 1681q). Customer's indemnification obligations under the Terms of Service expressly cover claims arising from Customer's or its Authorized Users' procurement or use of consumer reports.

4.3 Reporting misuse. If you become aware of any actual or suspected misuse of consumer report information in connection with the Platform, report it promptly to [email protected].

5. Acknowledgment

By accepting this Notice you acknowledge that you have read it, that you understand a consumer report may be obtained and used only for the certified purposes above, and that you make the certifications in Section 2 personally and on behalf of the Customer organization for which your seat was provisioned.

Questions: [email protected] Sovetta Technologies LLC