Subscriber Service Agreement This Subscriber Service Agreement, together with its associated exhibits (collectively referred to as the "Agreement"), shall become effective as of , and is entered into by and between Soft Pull Solutions LLC (“Provider”), and (“Subscriber”). For the purposes of this Agreement, Soft Pull Solutions and Subscriber shall be referred to collectively as the “Parties” and individually as a “Party”. The Parties hereby agree to the terms set forth below: Soft Pull Solutions offers a range of information and data services, encompassing credit scores, credit reports, credit report-related products, consumer reports, liens and judgments data, bankruptcy information, eviction searches, income estimators, bank verification, business or commercial credit reports, third-party data services, credit report compliance products, and other relevant software services, all individually and collectively referred to as "Information Services." The Subscriber acknowledges and agrees to the terms and conditions set forth in this Agreement. This Agreement applies to all information, software, and services provided by Soft Pull Solutions to the Subscriber, whether or not a specific service type is explicitly referenced. THE SUBSCRIBER AGREES: 1. The Subscriber’s business, as described by its industry and the general nature of its operations, is . 2. Adherence to the Fair Credit Reporting Act, 15 U.S.C. § 1681 et. seq. (“FCRA”), as amended by the Fair and Accurate Credit Transactions Act of 2003 (“FACTA”) and, subsequently, the Americans with Disabilities Act (“ADA”), and other pertinent equal opportunity laws, the Gramm-Leach-Bliley Act of 1999, 15 U.S.C. § 6801 et. seq. (“GLBA”), the Driver’s Privacy Protection Act of 1994, 18 U.S.C. § 2721(b)(3) (“DPPA”), the laws of the relevant state issuing Motor Vehicle Records (“MVR”), the Equal Credit Opportunity Act (“ECOA”), the Truth In Lending Act (“TILA”), and all other local, state, and federal laws governing Information. This includes compliance with the permissions and limitations set forth by Soft Pull Solutions, Consumer Reporting Agencies, and other data provider companies. 3. In the event that: (a) there is a change in the Subscriber’s physical location or ownership; (b) any modifications are made to the information provided in the Subscriber’s Application; or (c) the Subscriber no longer meets the eligibility criteria for receiving Information Services from Soft Pull Solutions, the Subscriber agrees to notify Soft Pull Solutions in writing within ten (10) days of such changes. Updated vetting information may be required, and, if applicable, a new third-party physical inspection may be necessary, with additional fees potentially applying. 4. Solely requesting information for the Subscriber’s exclusive use, as an end-user, with the certification that there is a permissible purpose. Inquiries will be made only for the purpose of, and no other purpose, in connection with a credit or consumer transaction involving the consumer on whom the information is to be furnished. The Subscriber will obtain the consumer’s written authorization for such information requests. 5. Awareness, per the FCRA, that obtaining information on a consumer for a consumer reporting agency under false pretenses is subject to fines or imprisonment. 6. The Subscriber agrees to use the Information Services solely for legitimate business purposes directly related to the operations of the Subscriber’s business. The Subscriber shall not use the Information Services for marketing or solicitation purposes. Soft Pull Solutions reserves the right to suspend or terminate the Subscriber’s service if any improper use is identified or reasonably suspected. 7. The Subscriber acknowledges that access to certain information is subject to restrictions, including a prohibition on the export of such information, related documentation, or technical data outside the fifty (50) states of the United States of America. 8. Awareness of stricter consumer, ADA, and DMV-based statutes in some states (CA, CO, MN, VT, WA, etc.), with compliance being the responsibility of the Subscriber. 9. Employees are prohibited from attempting to use the Information Services to obtain reports on themselves, associates, or any other person, except in the exercise of their official duties. 10. Assurance that if the Subscriber uses driver’s license data, it will comply with the DPPA and GLBA, as well as any similar state or local laws, regulations, rules, or restrictions. 11. The Subscriber acknowledges that if data from the United States Treasury Department’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons list is used, the matching process is based on limited identification information. A match does not automatically confirm that the individual or entity in question is the same as the one listed by OFAC. Any adverse action taken by the Subscriber must be based on a thorough investigation of the individual or entity, and not solely on the OFAC data. 12. Acknowledge that for products and services accessed containing information from the Death Master File (“DMF”) as issued by the Social Security Administration (“SSA”), the User certifies pursuant to § 203 of the Bipartisan Budget Act of 2013 and 15 C.F.R. § 1110.2 and § 1110.102 that: User meets the qualifications of a “Certified Person” and that its access to the DMF is appropriate. In line with its applicable FCRA or GLBA use of Information, the User’s utilization of deceased flags or other indicia within such Information is restricted to legitimate fraud prevention or business purposes, complying with applicable laws, governmental rules, regulations, or fiduciary duty. This includes business purposes as i nterpreted under 15 C.F.R. § 1110.102(a)(1), and the User shall specify the basis for so certifying. The User affirms having systems, facilities, and procedures in place to safeguard the accessed DMF i nformation and experience in maintaining the confidentiality, security, and appropriate use of the accessed DMF information, similar to the requirements of § 6103(p)(4) of the Internal Revenue Code of 1986. The User agrees to satisfy the requirements of § 6103(p)(4) as if such applies to the User. Additionally, the User shall not disclose information derived from the DMF to the consumer or any third party unless clearly required by applicable law. Failure to comply with the provisions above may subject the User to penalties under 15 C.F.R. § 1110.200 of $1,000 for each disclosure or use, up to a maximum of $250,000 in penalties per calendar year. The User also commits not to take any adverse action against any consumer without further investigation to verify the information from the deceased flags or other indicia. 13. Subscriber acknowledges that the Military Lending Act, 10 U.S.C. § 987 (“MLA”), protects Department of Defense (“DOD”) “Covered Borrower(s)” (as defined in 32 C.F.R. § 232.3(g)(1)), including “Service Members” and certain “dependents,” from certain high-cost “consumer credit” products (as defined in the MLA). The DOD Covered Borrower data provided to the User from or through Soft Pull Solutions originates from the Defense Manpower Data Center (“DMDC”) directly from the DOD or from a DOD approved Repository. MLA data and reports obtained from or through Soft Pull Solutions shall be used by the User with a “permissible purpose” in accordance with the FCRA, only for its own internal one-time use. It should not be used in connection with, in whole or in part, underwriting of insurance, initiating preapproved offers of credit, establishing profiles, reports, or any other documentation on individuals for marketing, or any purpose other than making a determination of consumer status as a Covered Borrower, as required of “creditors” for credit “transactions” subject to and as defined in the MLA. Without using a Social Security Number in the query, neither the DMDC, the Repositories, nor Soft Pull Solutions can authoritatively assert that the individual identified in the data and report is the same individual that your query refers to; name and data of birth alone do not uniquely identify an individual. Refer to the MLA and consult with your attorney for more details prior to use. 14. Subscriber assures that, except as expressly permitted by the FCRA, the User shall not use any medical information contained in a consumer report in connection with any determination of the consumer’s eligibility or continued eligibility for credit or for any purpose other than for use: (i) in connection with an insurance transaction with the affirmative consent of the consumer who is the subject of the report; (ii) in connection with a credit transaction involving the extension of credit to, or the review or collection of an account of the consumer, where the medical information to be furnished is relevant to process or effect the transaction, and the consumer has provided specific written consent for the furnishing of the report that describes in clear and conspicuous language the use for which the medical information will be furnished; (iii) for employment purposes, where the medical information to be furnished is relevant to process or effect the transaction, and the consumer has provided specific written consent for the furnishing of the report that describes in clear and conspicuous language the use for which the medical information will be furnished; or (iv) with the consumer’s consent. 15. The Subscriber acknowledges that certain commercial Repository Data may contain consumer credit information, which may only be used in connection with a current or prospective commercial (i.e., nonpersonal, non-family, and non-household) credit or financial transaction involving the business inquired upon or the individual for whom such Information is sought. This applies only if the individual is the proprietor of an unincorporated business, a general partner in a partnership, a guarantor of the business’s obligations who has provided a written guaranty, or has given explicit written consent for the provision of such Information. Such data shall not be used for determining an individual's eligibility for personal credit, insurance for personal, family, or household purposes, or employment. 16. If Subscriber is provided access to MVRD from Soft Pull Solutions, without limiting Subscriber’s obligations to comply with all state and federal laws governing the use of MVRD, the following restrictions apply: (a) Subscriber shall not use any MVRD provided by Soft Pull Solutions, or portions of information contained therein, to create or update a file that Subscriber uses to develop its own source of driving history information; (b) Subscriber shall complete any state forms that Soft Pull Solutions is legally or contractually bound to obtain from Subscriber before providing Subscriber with MVRD; and (c) Soft Pull Solutions (and/or third-party vendors) may conduct reasonable and periodic audits of Subscriber’s use of MVRD, and Subscriber must be able to substantiate the reason for each MVRD order as a result of an audit request. 17. A third-party inspection may be required to ensure FCRA compliance by verifying the legitimacy of the subscriber's business and its adherence to FCRA requirements. Soft Pull Solutions will notify the subscriber if an inspection is necessary and will coordinate with the inspection company. The subscriber is responsible for paying Soft Pull Solutions, as applicable, in accordance with the Fee Schedule outlined in Document Ref: 5NQMD-FUXFT-2WMQX-PXU6S Page 3 of 9, before Soft Pull Solutions grants access to data information and services. 18. Soft Pull Solutions, with reasonable notice, reserves the right to review the Subscriber’s procedures related to this Agreement to ensure their effectiveness in preventing improper use and verifying compliance. The Subscriber agrees to fully cooperate with any such audits and implement any changes reasonably requested by Soft Pull Solutions to safeguard against unauthorized access. 19. Before granting access to the Information Services, the Subscriber is responsible for informing and training its employees regarding their obligations under this Agreement. 20. Subscriber certifies that all personnel with access to Experian data shall complete annual security awareness training. Subscriber shall retain documentation of such training and make it available to Soft Pull Solutions and/or Experian upon request. 21. Subscriber acknowledges that Public Record Information provided to User from or through Soft Pull Solutions is derived solely from public records, which may not be 100 percent (100%) accurate or complete. The User should consult state and federal laws, including the FCRA, before using Public Record Information in making business decisions based on the results. Neither Soft Pull Solutions nor the data Repositories, or other vendors or suppliers, are liable for claims or damages arising from the use of Public Record Information, beyond the cost of the particular search performed and report obtained by the User. Due to potential misidentifications when relying solely on name and other identifiers, the review and use of Public Record Information should be exercised with extreme care. It is recommended that the User obtain the original public record document from the relevant jurisdiction for legal proceedings rather than using Public Record Information contained herein. 22. The Subscriber assumes the responsibility for the final verification of the consumer’s identity. 23. The Subscriber commits to implementing and maintaining an extensive information security program to ensure the security of the information provided by Soft Pull Solutions and protect against any threats or hazards, including unauthorized access. Subscriber shall maintain a written information security policy that reflects controls aligned with recognized industry standards, such as ISO/IEC 27002 or equivalent. Subscriber agrees to make this policy available for audit or review upon request by Soft Pull Solutions or its data providers. 24. The Subscriber agrees to hold in strict confidence the consumer report received and not to sell, transfer, or distribute a copy to any other party, except as authorized or required by law. However, this restriction does not prevent the Subscriber from discussing with the subject of the information report, who is the subject of an adverse action, the content of the report as it relates to the reason(s) for the adverse action. 25. The Subscriber agrees to maintain the strict confidentiality of its designated User ID, Password, and Subcodes. Any loss, theft, disclosure, or unauthorized use of these credentials must be reported to Soft Pull Solutions immediately. Until Soft Pull Solutions confirms the deactivation of the User ID, Password, and/or Subcodes, the Subscriber remains responsible for any and all fees, as well as any consequences arising from misuse. 26. Subscriber agrees to notify Soft Pull Solutions and Experian in writing of any confirmed unauthorized access, data breach, or other security incident involving Experian data or systems within 24 hours of confirmation. Subscriber shall provide sufficient detail of the incident, mitigation steps taken, and any ongoing risk. 27. The Subscriber acknowledges, unless otherwise permitted by Soft Pull Solutions or applicable law, that its business does not sell information directly to consumers and is not involved in credit repair, process serving, dance studios, spiritual, tattoo, health or book clubs, adult entertainment, dating services, massage businesses, child location services, pawn shops, or time shares. 28. The Subscriber agrees to place all devices used to obtain information and all electronic and hard-copy information and applications with transaction details in a secure location within its facility for a minimum of five (5) years. This ensures unauthorized access is prevented, and devices and locations are password-protected and locked after normal business hours. 29. The Subscriber agrees not to mention Soft Pull Solutions or reference its use of the Information Services in any advertisements, marketing materials, or press releases without the express written consent of Soft Pull Solutions. 30. The Subscriber agrees not to replicate, reproduce, reverse engineer, or otherwise transfer Soft Pull Solutions' services for any commercial purposes. Soft Pull Solutions and/or its third- party providers retain all rights, title, and interest in the Information Services, as well as the data and information they provide, under applicable contractual, trade secret, and related laws. The Subscriber shall use such materials in accordance with the terms and conditions of this Agreement and promptly notify Soft Pull Solutions of any actual or potential infringement of its rights. Soft Pull Solutions or its data provider shall own the Subscriber’s search inquiry data used to access the Information Services and may use such data for any lawful purpose in accordance with applicable federal, state, and local laws, rules, and regulations. 31. The Subscriber agrees to pay the full amount due upon receipt of the invoice for services rendered during the previous monthly period, in accordance with the current Soft Pull Solutions Fee Schedule. All payments are due within 15 days from the invoice date. Past due amounts will accrue interest at a rate of 1.5% per month, and a late fee of $25.00 will be applied to any payment with an invoice amount with a total amount due of less than $300, and a $50 late fee will be charged for invoices totaling $300 or more. not received by the specified due date. If an unpaid balance exceeds 60 days, Soft Pull Solutions reserves the right to suspend the Subscriber's access until the outstanding balance is paid in full. In the event that collection efforts are required, the Subscriber will be responsible for all associated costs, including attorney fees. 32. The User agrees to pay Soft Pull Solutions directly for all applicable Fees due for services rendered by Soft Pull Solutions to the User under this Agreement. This includes fees for Set- Up, Access, Onboarding, Monthly, Site Inspection, Training, Testing, Credentialing, Certification, Annual, Transactions, Bureau Products, Repository Data, Data, Reports, Information, Products, Searches, Additional Data, Additional Products, Modules, and any other then current, amended, or additional fees, plus taxes, as outlined in the attached Fee Schedule. Payment should be made in one of the two manners specified in the Fee Schedule, and by initialing in the Fee Schedule, the authorized account holder explicitly agrees to such method and to provide all necessary information and documentation for prompt payment. 33. This Agreement shall remain in effect for a minimum period of three months from the effective date. After this initial term, the Agreement will automatically renew for successive one- month periods unless Soft Pull Solutions receives written notice of termination at least sixty (60) days prior to the end of the current term. However, Soft Pull Solutions or the CRAs may terminate this Agreement immediately, with just cause, including but not limited to delinquency, violation of the terms of this Agreement, or legal requirements, at their discretion. 34. Soft Pull Solutions reserves the right to modify the Fee Schedule by providing the Subscriber with thirty (30) days' written notice. 35. Termination of this Agreement shall not relieve the Subscriber of the obligation to pay Soft Pull Solutions in full for any fees, late charges, attorney fees, or collection costs incurred up to and including the date of termination. 36. Soft Pull Solutions shall retain audit rights, as well as the right to use and ownership of the Subscriber’s search inquiry data. Additionally, the data security provisions of this Agreement will survive its termination. The governing law provisions shall also remain in effect following the termination of the Subscriber’s license to use Soft Pull Solutions Information Services. 37. Soft Pull Solutions will make reasonable, good-faith efforts to obtain credit and consumer information and provide Information Services from sources considered reliable. However, Soft Pull Solutions does not guarantee the accuracy of the information provided. Under no circumstances shall the CRAs or Soft Pull Solutions be held liable for any loss or injury incurred by the Subscriber resulting from the provision of such information. The Subscriber agrees to indemnify, defend, and hold harmless the CRAs, Soft Pull Solutions, and their respective affiliates, officers, directors, employees, agents, suppliers, and third-party contractors from any claims, losses, damages, or liabilities arising from any alleged failure or breach by the Subscriber to fulfill its obligations under this Agreement. 38. The Information Services are provided to the Subscriber "As-Is", without any warranty, express or implied, including but not limited to any warranties of merchantability or fitness for a particular purpose. Soft Pull Solutions does not guarantee uninterrupted access to the Information Services or that the Services will be free from defects, computer viruses, or other issues that may result in the loss of information or damage to the Subscriber's computer software or equipment. 39. The Subscriber acknowledges reviewing the "Notice to Users of Consumer Reports: Obligations of Users Under the FCRA" as required by the FCRA, which can be viewed and printed at the Website. 40. The Subscriber acknowledges reviewing the “Terms of Services”, otherwise known as “Terms and Conditions” 41. The Subscriber acknowledges reviewing the “end user agreement”, “permissible purpose form” “FICO Scoring Certifications”, “Vantage Scoring Requirements”, and“death master file” 42. The Subscriber agrees to obtain in advance and retain on file appropriate application, release, consent, and/or authorization forms ("Forms") from any credit applicant, job applicant, or other individual on whom Information in Repositories accessed through Soft Pull Solutions is sought. It will disclose to such individuals, as required by law, that credit and/or other Information will be sought. The Subscriber will provide consumers with answers about their own credit report when credit is denied, terminated, or changed based on Information secured through Repositories availed by Soft Pull Solutions, resulting in "adverse action" as defined in FCRA. The Subscriber will advise applicants and follow procedures regarding Repository mandates on consumer inquiries or complaints. 43. The Subscriber agrees to retain Forms for five (5) years in all cases where credit is extended or an application approved, and in any case where credit is declined or an application declined. It will make such Forms available to Soft Pull Solutions upon reasonable notice for occasions where confirmation or audit is required, either by consumers, the Repositories, or by Soft Pull Solutions. 44. The Subscriber agrees to take all reasonable precautions to ensure that information regarding individuals (including scores) is disclosed internally only to those employees whose duties are directly related to the legitimate business purpose for which the information was requested. 45. The Subscriber understands that a soft pull is for pre-qualification purposes only and shall not be used to make a lending decision. 46. The Subscriber acknowledges that Soft Pull Solutions and its employees are not authorized to provide opinions regarding the information contained in a consumer report. All actions or decisions must be made in accordance with the Subscriber’s established user policies and procedures. 47. Soft Pull Solutions cannot and will not provide legal advice. 48. None of the Parties shall, at any time, represent that it is the authorized agent or representative of the other. 49. Notwithstanding any provisions to the contrary in this Agreement, no Party shall be liable for damages resulting from delays in performance caused by factors beyond its control and without fault on its part. Such factors include, but are not limited to, interruptions in telecommunications or network services provided by third parties, credit bureau outages, acts of God, war, government actions, vandalism, terrorism, fires, floods, epidemics, strikes, or labor disputes. Delays caused by subcontractors or suppliers shall not be covered by this provision. 50. This Agreement, along with its exhibits, represents the complete and exclusive understanding between the Parties regarding the subject matter hereof and supersedes all prior agreements, discussions, or understandings, whether written or oral, between the Parties. 51. Nothing in this Agreement shall be construed as making Soft Pull Solutions a consumer credit reporting agency for purposes of the Fair Credit Reporting Act and companion state statutes. 52. Each Party may have access to confidential information of the other Party (“Disclosing Party”) related to its business, including but not limited to financial data, strategies, processes, trade secrets, inventions, ideas, technical information, computer programs, algorithms, and other proprietary information (whether written or oral). In the case of Soft Pull Solutions, this includes product details, pricing information, data, processes contained within the Information Services, and other business-related information ("Confidential Information"). Confidential Information does not include information that: (i) becomes publicly known through no fault or improper action of the Receiving Party; (ii) was in the Receiving Party’s possession prior to disclosure by the Disclosing Party; (iii) is lawfully disclosed to the Receiving Party by a third party without breach of any confidentiality obligations; (iv) is independently developed by the Receiving Party without reference to or use of the Disclosing Party’s Confidential Information. Each Receiving Party agrees not to disclose any Confidential Information, or information derived from it, to any third party. The Receiving Party shall protect the confidentiality of the Confidential Information with at least the same level of care it uses to protect its own confidential information and trade secrets, but in no event less than a reasonable standard of care. Notwithstanding the foregoing, the Receiving Party may disclose Confidential Information if required by subpoena, court order, or other governmental authority. In such cases, the Receiving Party shall promptly notify the Disclosing Party in writing to provide an opportunity for the Disclosing Party to seek a protective order or other remedy at its own cost and expense. Any Confidential Information disclosed under such circumstances shall still be subject to the confidentiality terms outlined in this Agreement. The confidentiality obligations under this Agreement will remain in effect for the duration of the Agreement and for a period of five (5) years thereafter. However, with respect to trade secrets, these obligations will continue as long as the information remains a trade secret. 53. This Agreement shall be interpreted and governed by the laws of the State of California, without regard to its conflict of laws principles. The Subscriber irrevocably consents to the exclusive jurisdiction and venue of the federal and state courts located in Kern County, California, for any disputes arising in connection with this Agreement. If any provision of this Agreement is found to be illegal, invalid, or unenforceable by a court or other competent authority, the legality, validity, and enforceability of the remaining provisions will not be affected. The illegal, invalid, or unenforceable provision will be deemed severed from this Agreement and will not affect the remaining terms. 54. Soft Pull Solutions reserves the right to amend this Agreement and the Fee Schedule, and the Subscriber agrees to comply with changes to the Information Services usage requirements and other provisions of this Agreement as Soft Pull Solutions shall make from time to time via written notice to the Subscriber. Soft Pull Solutions may impose restrictions and/or prohibitions on the Subscriber’s use of the Information Services or certain data as a result of a modification in policy, a modification of thirdparty agreements, a modification in industry standards, a security change, or a change in law or regulation, or the interpretation thereof. This Agreement is complete and may not be altered or amended unless in writing. This Agreement shall not be binding on either Party until it is accepted by Soft Pull Solutions. 55. As necessary, in accordance with FCRA, FACTA, GLBA, DPPA, MVR, ECOA, TILA, and other local, state, and federal laws, as well as Credit Bureau, Data Repository, and Soft Pull Solutions policies, the Subscriber agrees to undergo compliance certification, credentialing, employee FCRA training and testing, an on-site inspection at its business premises (“Site Inspection”), criminal, consumer credit, and other background checks on the Subscriber’s business and principal (owner or officer). This is often performed by ComplyTraq, LLC, or another selected inspection company, to determine and review credit, history, procedures, processes, and the need for accessing, using, storing, and/or distributing Information, security practices, and other protective measures in place. This ensures initial compliance with the terms hereof, as well as periodically for reassurance thereafter. 56. The Subscriber certifies that they have read and fully understand the terms of this Agreement and Fee Schedule and that the undersigned agrees to these terms on behalf of their business. The undersigned further represents that they are authorized to execute this Agreement on behalf of the indicated party. The Parties acknowledge that this Agreement, along with the Recitals, Fee Schedule, and any other attached exhibits, may be executed in multiple counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument. Facsimile signatures shall be considered legal, valid, and binding. 57. This Agreement, including the Recitals, Fee Schedule, Confirmation of Documents, and any exhibits attached hereto, constitutes the entire understanding between Soft Pull Solutions and the Subscriber regarding the subject matter hereof. It supersedes all prior or contemporaneous agreements, communications, and understandings, whether written or oral, between the Parties related to the same subject matter. There are no warranties, representations, or agreements between the Parties reg