Privacy Policy and Data Authorization

Scope and acceptance

This Privacy Policy and Data Authorization (“Privacy Policy”) describes how ON-Time Prop Pay LLC, doing business as Easy Impound (“Easy Impound,” “Company,” “we,” “us,” or “our”) collects, uses, protects, and discloses personal information obtained through the Easy Impound platform and related services.

This Privacy Policy applies to all individuals who access or use the Easy Impound platform or enroll in services associated with the Sponsor Bank Property Payment Program.

By accessing the Easy Impound platform or enrolling in the program, the user (“Customer,” “you,” or “your”) acknowledges and agrees to the terms of this Privacy Policy.

1. Information we collect

Easy Impound may collect, receive, and process certain personal and non-personal information necessary to provide services, operate the platform, and comply with applicable legal and regulatory requirements. Information may be provided directly by the Customer, or may be received from the Customer’s lender, mortgage servicer, loan officer, insurance carrier, or from public records and authorized third-party data providers, including in cases where such information is received prior to the Customer creating an account on the platform.

1.1 Personal Identifying Information

We may collect personal identifying information including but not limited to:

• Full legal name
• Residential or mailing address
• Telephone number
• Email address
• Date of birth
• Social Security number
• Government-issued identification numbers
• Driver’s license or state identification information

This information may be provided directly by the Customer or obtained through authorized identity verification providers.

1.2 Property Information

Easy Impound may collect information relating to real property associated with a Customer’s participation in the program, including:

• Property address and legal description
• Assessor parcel numbers
• Property tax records and payment information
• Publicly available property data
• Property characteristics relevant to insurance underwriting (such as construction type, year built, square footage, roof type, and protection class)

1.3 Insurance Information

Easy Impound collects, receives, and maintains property insurance information in connection with administering the Program and, where the Customer has opted in, providing Insurance Marketplace services (described in Section 4A). Insurance information may be obtained directly from the Customer, from the Customer’s insurance carrier, agent, or broker, from the Customer’s mortgage servicer or lender, or from authorized third-party data providers. Insurance information collected may include, but is not limited to:

• Insurance carrier information
• Policy numbers
• Coverage verification
• Policy expiration information
• Insurance agent and broker contact information
• Mortgagee, lienholder, and loss-payee designations
• Premium amounts, billing schedules, and payment due dates
• Policy declarations pages and policy endorsements
• Coverage types, coverage limits, and deductibles
• Insurance billing, invoice, and payment history information
• Policy renewal, cancellation, lapse, and reinstatement notices
• Escrow setup and disbursement instructions provided by the carrier
• Prior insurance history and proof of prior coverage
• Property characteristics relevant to underwriting (such as construction type, year built, and protection class) where shared by the carrier
• Other insurance-related information reasonably necessary to administer the Program

1.4 Financial Information

Financial information may be collected to facilitate payment services administered by Sponsor Bank, including:

• Bank account numbers
• Routing numbers
• Payment authorization records
• Transaction history
• Payment processing information

Easy Impound does not hold customer deposits. Financial transactions associated with the program are conducted through Sponsor Bank.

1.5 Demographic and Verification Information

To support identity verification, fraud prevention, and regulatory compliance, we may collect or obtain additional information including:

• Employment information
• Income indicators
• Public records
• Credit verification data
• Device identifiers and technical data

1.6 Cookies, Tracking Technologies, and Automatically Collected Information

When you access the Easy Impound platform or website, we may automatically collect certain information through cookies, web beacons, pixels, and similar tracking technologies, including:

• IP address and approximate geolocation
• Browser type and version
• Device type and operating system
• Pages visited, time spent on pages, and clickstream data
• Referring URL
• Unique device identifiers

We may use third-party analytics providers, including Google Analytics, to help us understand how users interact with the platform. These providers may use cookies and similar technologies to collect and analyze usage information on our behalf.

We use the following categories of cookies:

• Essential cookies: Required for the platform to function and cannot be disabled.
• Analytics cookies: Help us understand how users interact with the platform so we can improve it.
• Functional cookies: Enable enhanced functionality and personalization.

You may manage or disable non-essential cookies through your browser settings. Disabling certain cookies may affect platform functionality.

Do Not Track Signals. Some web browsers transmit “Do Not Track” signals. At this time, Easy Impound does not respond to “Do Not Track” signals or similar mechanisms. We will update this disclosure if our practices change.

2. Methods of information collection

Information may be collected through various methods including:

• Customer registration and enrollment forms
• Platform activity and usage
• Electronic payment authorizations
• Customer support interactions
• Public records databases
• Identity verification services
• Financial institution integrations
• Regulatory compliance providers
• Insurance carriers, agents, brokers, and insurance data providers
• Mortgage servicers, lenders, and loan officers
• Cookies, web beacons, pixels, and similar tracking technologies
• Third-party analytics providers

Easy Impound may receive Customer information from lenders, mortgage servicers, or loan officers before the Customer creates an account on the platform, in order to facilitate enrollment of the Customer’s property in the Program.

3. Purposes for which information is used

Collected information may be used for legitimate business purposes including but not limited to:

Identity Verification

To confirm the identity of Customers and prevent unauthorized account access.

Fraud Prevention

To detect, prevent, and investigate fraud, abuse, or other security risks.

Program Administration

To administer the Sponsor Bank Property Payment Program.

Regulatory Compliance

To comply with applicable financial laws, banking regulations, and regulatory requirements.

Payment Processing

To facilitate authorized payment transactions administered by Sponsor Bank.

Insurance Premium Administration

To verify, monitor, and maintain Customer property insurance coverage; to obtain premium amounts, billing schedules, and renewal information from insurance carriers, agents, and brokers; to schedule and remit insurance premium payments on the Customer’s behalf through Sponsor Bank; and to coordinate insurance escrow and disbursement activity in connection with the Program.

Insurance Monitoring and Marketplace Services

To monitor Customer property insurance coverage and premium levels; to identify potential cost-saving opportunities; and, where the Customer has opted in to the Insurance Marketplace, to share limited Customer data with participating insurance providers for the purpose of generating competing insurance quotes for the Customer’s review (see Section 4A).

Permitted Use of Funds

Customer funds deposited into the Program are to be used exclusively for the payment of property taxes and property insurance premiums. Funds may not be used for any other purpose. A Customer may access their funds at any time by canceling participation in the Program. Upon cancellation, the Customer’s funds will be returned within seven (7) to fourteen (14) business days.

Platform Operation

To operate, maintain, and improve the Easy Impound platform.

Customer Support

To respond to inquiries and resolve account or service issues.

Risk Management

To monitor platform activity and manage operational or financial risks.

4. Disclosure and sharing of information

Easy Impound may share Customer information where necessary to operate the platform or comply with applicable law. Information may be disclosed to:

Banking Partners

Including Sponsor Bank, which provides financial services associated with the Easy Impound program. The current Sponsor Bank for the Program is OMB Bank, located at 3570 S. National Avenue, Springfield, MO 65807. References to “Sponsor Bank” throughout this Privacy Policy refer to OMB Bank, or to any successor or replacement sponsor bank engaged by Easy Impound from time to time.

Payment Processing Providers

Entities responsible for processing authorized financial transactions.

Identity Verification Providers

Third-party services used for identity verification, Know Your Customer (KYC) onboarding, government-issued identification verification, Office of Foreign Assets Control (OFAC) screening, sanctions and watchlist screening, politically exposed persons (PEP) screening, adverse media screening, and fraud detection. Easy Impound’s identity verification provider is Persona Identities, Inc. (“Persona”).

Transaction Monitoring and AML Providers

Third-party services used for ongoing transaction monitoring, anti-money laundering (AML) screening, ongoing sanctions and watchlist monitoring, suspicious activity detection, and Bank Secrecy Act (BSA) compliance support. Easy Impound’s transaction monitoring and AML provider is IVXS UK Limited, doing business as ComplyAdvantage (“ComplyAdvantage”).

Insurance Carriers, Agents, and Brokers

Property insurance carriers, agencies, brokers, and insurance data providers, for purposes of obtaining and confirming policy and premium information, scheduling and remitting premium payments, coordinating policy renewals, and otherwise administering insurance-related obligations under the Program. Easy Impound may also share information with the Customer’s mortgage servicer or lender where reasonably necessary to administer the Program.

Regulatory Authorities

Government agencies, regulators, or law enforcement authorities where disclosure is required by law.

Service Providers

Third-party vendors providing services necessary to operate the platform, including:

• Data hosting providers
• Cybersecurity services
• Compliance monitoring providers
• Technology infrastructure providers

All service providers are contractually obligated to maintain confidentiality and appropriate security standards.

4A. Insurance Marketplace services

Overview. Easy Impound may offer an Insurance Marketplace feature that allows Customers to receive and compare competing property insurance quotes from multiple participating insurance providers through the Easy Impound platform. The Insurance Marketplace uses insurance and property data already collected through the Program to help Customers identify potential cost savings on their property insurance.

Opt-In Participation. Participation in the Insurance Marketplace is entirely voluntary and requires the Customer’s affirmative opt-in consent. Customers will not be enrolled in the Insurance Marketplace automatically. A separate, clearly labeled consent will be presented within the platform at the time the Customer elects to activate the Insurance Marketplace feature. The Customer’s decision to opt in or opt out of the Insurance Marketplace will not affect the Customer’s access to or participation in the core Program services (property tax and insurance payment administration).

Data Shared with Participating Insurance Providers. When a Customer opts in to the Insurance Marketplace, Easy Impound will share a limited set of Customer information (“Marketplace Data”) with participating insurance providers solely for the purpose of enabling those providers to generate insurance quotes for the Customer. Marketplace Data may include:

• Property address and location information
• Property characteristics (such as construction type, year built, square footage, roof type, and protection class)
• Current insurance coverage types, coverage limits, and deductibles
• Current premium amounts
• Policy expiration and renewal dates
• Mortgagee and loss-payee designations

Marketplace Data does not include the Customer’s Social Security number, bank account numbers, routing numbers, financial account credentials, or payment card information.

Restrictions on Participating Insurance Providers. Each participating insurance provider is contractually required to use Marketplace Data solely for the purpose of generating and presenting an insurance quote to the Customer through the Easy Impound platform. Participating providers may not use Marketplace Data for unrelated marketing, resell or further distribute Customer data, or retain Marketplace Data beyond the period reasonably necessary to generate a quote, unless the Customer independently enters into a direct relationship with that provider.

List of Participating Providers. A current list of participating insurance providers is available on the Easy Impound platform and will be provided to the Customer upon request.

Opt-Out and Withdrawal. A Customer may opt out of the Insurance Marketplace at any time through their account settings on the platform. Upon opt-out, Easy Impound will cease sharing the Customer’s Marketplace Data with participating insurance providers. Opt-out will not affect any quotes already generated or any relationship the Customer has independently established with a participating provider.

Compensation Disclosure. Easy Impound may receive referral fees, commissions, or other compensation from participating insurance providers when a Customer receives or accepts a quote through the Insurance Marketplace. Such compensation does not increase the cost to the Customer. Easy Impound will disclose the existence of such compensation arrangements on the platform.

No Endorsement; No Insurance Advice. Easy Impound does not endorse, recommend, or guarantee any insurance product, provider, or quote presented through the Insurance Marketplace. Easy Impound is a technology platform that facilitates comparison; Easy Impound does not act as an insurance agent, broker, or advisor. Quotes presented through the Insurance Marketplace are provided by the participating insurance providers and are subject to each provider’s underwriting criteria and terms. Customers should review all quotes and coverage terms carefully and consult with a licensed insurance professional before making coverage decisions.

5. Regulatory compliance use

Customer information may be used by Easy Impound and Sponsor Bank to comply with applicable regulatory requirements including:

• Know Your Customer (KYC) obligations
• Anti-Money Laundering (AML) regulations
• Bank Secrecy Act (BSA) compliance
• Office of Foreign Assets Control (OFAC) screening

Customers acknowledge that the collection and verification of personal information may be required to maintain participation in the program.

6. Data security

Easy Impound maintains commercially reasonable administrative, technical, and physical safeguards designed to protect Customer information from unauthorized access, misuse, alteration, or disclosure.

Security measures may include:

• Encryption technologies (including encryption of data in transit and at rest)
• Restricted data access controls
• Secure data storage practices
• Network security monitoring
• Regular security assessments and vulnerability testing

Despite these safeguards, no system can guarantee absolute security, and Customers acknowledge that internet-based data transmission carries inherent risk.

Data Breach Notification. In the event of a data breach that compromises the security or integrity of Customer personal information, Easy Impound will notify affected Customers in accordance with applicable state and federal data breach notification laws. Where required by law, Easy Impound will provide such notification within the timeframes prescribed by the applicable jurisdiction.

7. Data retention

Easy Impound retains Customer information for the duration of the Customer’s active account and participation in the Program, plus a minimum of five (5) years following account closure or the end of the Customer’s participation, in order to comply with applicable legal, regulatory, and financial record-keeping requirements, including Bank Secrecy Act (BSA) and anti-money laundering (AML) retention obligations.

Certain categories of information may be retained for longer periods where required by applicable law, regulatory guidance, or the terms of the Sponsor Bank Account Agreement.

Following the applicable retention period, Customer information will be securely deleted or de-identified in accordance with Easy Impound’s data retention and disposal procedures, unless retention is required by law or legal proceedings.

8. Data aggregation and anonymization

Easy Impound may create aggregated, anonymized, or de-identified data derived from Customer information.

Such data will not identify individual Customers and may be used for purposes including:

• Platform analytics
• Service improvement
• Statistical reporting
• Investor or partner reporting
• Product development

Aggregated or anonymized information may be shared with business partners, service providers, or investors.

9. State privacy rights

9.1 California (CCPA / CPRA)

Residents of California have certain rights regarding their personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

Subject to applicable legal limitations, California residents may have the right to:

• Request disclosure of the categories and specific pieces of personal information collected
• Request deletion of personal information
• Request correction of inaccurate personal information
• Request information regarding categories of sources, purposes of collection, and categories of third parties with whom information is shared
• Opt out of the “sale” or “sharing” of personal information, as those terms are defined under CPRA
• Designate an authorized agent to submit privacy requests on the Customer’s behalf

Sale and Sharing of Personal Information. Easy Impound does not sell personal information as that term is defined under the CCPA/CPRA. Easy Impound does not share personal information for cross-context behavioral advertising. Where a Customer opts in to the Insurance Marketplace (Section 4A), limited Marketplace Data is shared with participating insurance providers solely for the purpose of generating insurance quotes at the Customer’s request; this sharing is based on the Customer’s affirmative opt-in consent and is not a “sale” or “sharing” for cross-context behavioral advertising.

Categories of Personal Information Collected

For purposes of CCPA/CPRA compliance, Easy Impound collects the following categories of personal information:

• Identifiers (name, address, email, phone, SSN, driver’s license number)
• Financial information (bank account numbers, routing numbers, payment records)
• Commercial information (transaction history, property records, insurance policy details)
• Internet or electronic network activity (IP address, browser type, platform usage data, cookies)
• Geolocation data (approximate location derived from IP address)
• Professional or employment-related information (where collected for verification)
• Sensitive personal information (Social Security number, government ID, financial account credentials)

Authorized Agent Requests

California residents may designate an authorized agent to submit privacy requests on their behalf. To submit a request through an authorized agent, the agent must provide a written authorization signed by the Customer, or a power of attorney, and Easy Impound may require the Customer to verify their identity directly.

9.2 Additional State Privacy Laws

Residents of states with applicable consumer privacy laws, including but not limited to Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon, Montana, and other jurisdictions that have enacted or may enact consumer data privacy legislation, may have additional rights regarding their personal information, including rights to access, correct, delete, and obtain a copy of personal data, and the right to opt out of certain processing activities.

To exercise rights under any applicable state privacy law, Customers may contact Easy Impound using the contact information provided in Section 16 of this Privacy Policy. Easy Impound will respond to verified requests in accordance with the applicable law.

Easy Impound will not discriminate against individuals for exercising applicable privacy rights.

Certain information may be retained where required for legal, regulatory, or financial compliance purposes.

10. Children’s privacy

The Easy Impound platform is not directed to, and is not intended for use by, children under the age of thirteen (13). Easy Impound does not knowingly collect personal information from children under 13. If Easy Impound becomes aware that it has collected personal information from a child under 13, Easy Impound will take steps to delete such information promptly. If you believe that a child under 13 has provided personal information to Easy Impound, please contact us at the address provided in Section 16.

11. Limitation of liability for third-party services

Easy Impound may utilize third-party service providers, banking partners, and technology vendors in connection with the operation of the platform.

While Easy Impound requires such providers to implement reasonable data security measures, Easy Impound cannot guarantee the security practices of third-party systems.

To the maximum extent permitted by law, Easy Impound shall not be responsible or liable for damages resulting from:

• Security breaches involving third-party service providers
• Unauthorized access to data stored by third parties
• Failures of third-party technology infrastructure

Customers acknowledge that participation in the platform may involve transmission of data through third-party systems.

12. Law enforcement and regulatory disclosures

Easy Impound may disclose Customer information where required or permitted by law in response to:

• Subpoenas
• Court orders
• Regulatory requests
• Government investigations
• Law enforcement inquiries

Easy Impound may also disclose information where reasonably necessary to:

• Comply with legal obligations
• Protect the rights or safety of Easy Impound, its customers, or third parties
• Prevent fraud or financial crime
• Cooperate with financial institution regulatory authorities

To the extent permitted by law, Easy Impound may disclose such information without prior notice to the Customer.

13. Customer consent and authorization

By using the Easy Impound platform and enrolling in the Sponsor Bank Property Payment Program, the Customer expressly authorizes Easy Impound to:

• Collect personal information
• Store personal information
• Process personal information
• Disclose personal information as described in this Privacy Policy

Customer further authorizes Easy Impound to share such information with Sponsor Bank and authorized service providers for purposes related to program administration, payment processing, fraud prevention, and regulatory compliance.

Customer additionally authorizes Easy Impound, and any service provider acting on its behalf, to request, receive, access, and exchange insurance-related information concerning the Customer’s property with the Customer’s insurance carrier, insurance agent, insurance broker, mortgage servicer, lender, and any authorized insurance data provider. Such information may include policy details, premium amounts, billing and payment schedules, declarations pages, renewal and cancellation notices, mortgagee and loss-payee designations, and other information reasonably necessary for Easy Impound to verify coverage and to schedule, remit, or coordinate property insurance premium payments through Sponsor Bank. This authorization shall remain in effect for the duration of the Customer’s participation in the Program and may be revoked by the Customer at any time by canceling participation in the Program in accordance with the cancellation procedures described herein.

Insurance Marketplace Authorization. Authorization to share Marketplace Data with participating insurance providers pursuant to Section 4A is provided through a separate opt-in consent at the time the Customer activates the Insurance Marketplace feature. This authorization is independent of the general Program authorization described above and may be revoked at any time through the Customer’s account settings without affecting the Customer’s participation in the core Program.

14. Electronic consent and signatures

Customer acknowledges and agrees that:

• Disclosures may be provided electronically
• Consent may be provided electronically
• Electronic acceptance constitutes legally binding authorization

Electronic signatures and electronic records shall have the same legal effect as physical signatures under applicable law, including the Electronic Signatures in Global and National Commerce Act (E-SIGN Act) and the Uniform Electronic Transactions Act (UETA).

15. International data transfers

Easy Impound operates in the United States and primarily stores Customer data within the United States. However, certain third-party service providers, sub-processors, or technology vendors used by Easy Impound may process or store data in locations outside the United States. Where Customer data is transferred to or processed in a jurisdiction outside the United States, Easy Impound requires such providers to maintain data protection standards consistent with this Privacy Policy and applicable law.

16. Third-party links and services

The Easy Impound platform may contain links to third-party websites, services, or applications, including the Sponsor Bank’s website, government tax authority portals, and insurance carrier websites. Easy Impound is not responsible for the privacy practices, content, or security of any third-party website or service. Customers are encouraged to review the privacy policies of any third-party website they visit.

17. Policy modifications

Easy Impound reserves the right to modify or update this Privacy Policy from time to time. Material modifications will be communicated to the Customer by email, in-platform notification, or updated posting on the platform, with at least thirty (30) days’ advance notice before the changes take effect, except where a shorter period is required by law.

Continued use of the platform following the effective date of any modification constitutes acceptance of the updated Privacy Policy. If the Customer does not agree to a modification, the Customer’s sole remedy is to cancel their account.

18. Contact information

Questions, requests, or complaints regarding this Privacy Policy, or requests to exercise privacy rights under applicable law, may be directed to: