For information regarding your personal information and the practices of Beal Bank USA, you may access and download the Bank's Consumer Privacy Notices at the following link:

BEAL BANK USA CONSUMER PRIVACY NOTICE

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This California Privacy Rights Act Policy and Notice (this "Policy") is for California residents ("consumers" or "you") only. This Policy describes the personal information that Beal Bank USA, Beal Service Corporation, MGC Mortgage, Inc., CSG Capital Investments, Inc. d/b/a CSG Investments, Inc., and CLMG Corp. (collectively, "we", "our", or "us") collects in the course of our business operations, your customer relationship with us, and/or through your job application and employment with us. This Policy explains how such information is collected, used, shared, and disclosed; describes rights provided under the California Privacy Rights Act of 2020 (California Civil Code § 1798 et seq.) ("CPRA") to consumers regarding their personal information; and explains how consumers can exercise those rights.

NOTICE AT COLLECTION

What is Personal Information?

We may collect, use, or share your "personal information" (as defined in California Civil Code § 1798.140(v)(1)), including "sensitive personal information" (as defined in California Civil Code § 1798.140(ae)). We do not and will not sell personal information for monetary consideration. "Personal information" is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include: (1) publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience; (2) lawfully obtained, truthful information that is a matter of public concern; and (3) de-identified or aggregate consumer information.

With a limited exception, and as noted in other sections of this Policy, certain personal information is excluded from the CPRA's scope: (a) health or medical information covered by the Health Insurance Portability and Accountability Act ("HIPAA") and the California Confidentiality of Medical Information Act ("CMIA"), clinical trial data, or other qualifying research data; or (b) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA"), California Financial Information Privacy Act ("FIPA"), and the Driver's Privacy Protection Act.

Personal Information We Collect, Use, or Share

The CPRA requires us to disclose certain information regarding our collection, use, and sharing of personal information. The following table outlines the categories of personal information that we have collected about consumers in the last twelve (12) months. For each category, if applicable, we have identified the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, and the categories of third parties and service providers with whom we share personal information.

Where you are a business and the personal information or sensitive personal information relates to your directors, shareholders, beneficial owners, employees, agents, associates, or family members, it is not reasonably practicable for us to provide to them the information set out in this Policy. Accordingly, where appropriate, you are responsible for providing this information to any such person.

Business or commercial purposes are defined as follows:

• Account Services: We use personal information to offer our account services, including:

(1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on the service provider's behalf.

• Security and Fraud Detection: We use personal information for our security and fraud detection services including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.

• Debugging: We use personal information to engage in debugging to identify and repair errors that impair existing intended functionality.

• Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.

• Internal Research: We use personal information for our internal research related to technological development and demonstration.

• Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.

• Legal Obligations: We use personal information to comply with legal obligations.

• Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).

• Merger/Acquisition/Bankruptcy, etc.: We may use your personal information as part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.

• Commercial/Economic Interests: We use personal information to advance our commercial or economic intere

Retention of Personal and Sensitive Personal Information

We will retain your information as identified above, including personal and sensitive information, for each disclosed purpose for a period that is reasonably necessary and proportionate to the stated purpose, or for such period as required by applicable law, regulation, or rule.

We retain personal information for as long as needed or permitted in light of the purposes for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you have an account with us or keep using our products and services);

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); and

• Whether retention is advisable in light of our legal rights (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Disclosing Your Personal Information for a Business or Commercial Purpose

We may disclose your personal information to third parties in order to carry out specific business or commercial purposes. In the preceding twelve (12) months, we have disclosed consumer personal information for business or commercial purposes to our service providers and the following categories of third parties:

• Web and data analytics service providers;

• Financial and payment technology providers;

• Consumer reporting agencies;

• Background check companies;

• Identity verification services; • Asset verification services;

• Security and fraud detection;

• Government entities; and

• Operating systems and platforms.

In the last twelve (12) months, we have disclosed the following categories of personal information (as described in more detail above) for a business or commercial purpose:

• Personal information described in the California Customer Records Statute;

• Characteristics of protected classification under California or federal law;

• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99));

• Internet or other similar network activity; • Identifiers;

• Geolocation data;

• Sensory data;

• Commercial information;

• Professional- or employment- related information; and

• Inferences drawn from other personal information.

Your Rights Under the CPRA

As described in more detail below, the CPRA provides you with certain rights regarding the collection, use, retention, and disclosure of your personal information.

Right to Know

You have the right to request that we provide you with certain information about the personal information we collect, use, or disclose about you, as well as the categories and specific pieces of information that we have collected about you in the twelve (12) months before your submission of a verifiable consumer request. Specifically, you have the right to request the following information:

• The categories of personal information we have collected about you;

• The categories of sources from which we have collected personal information about you;

• Our business or commercial purpose for collecting your personal information;

• Our business or commercial purpose for disclosing the category of personal information about you;

• The specific pieces of personal information we have about you; and

• If we disclosed your personal information for a business or commercial purpose.

A household may request to know aggregate household personal information by submitting a verifiable consumer request. Also, if all consumers in a household jointly request access to specific pieces of information for the household, and we can individually verify all the members of the household, then we will comply with the request.

However, there is certain information that we will not disclose to you. This information includes, but is not limited to, your Social Security number, driver's license number, or other government- issued identification number; financial account number; any health insurance or medical identification number; an account password; or security questions and answers. Also, we will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks.

Right to Correct

You have the right to request that we correct personal information we maintain about you that you believe is inaccurate, taking into account the nature of the personal information and the purposes of the processing of the personal information. We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. We will use commercially reasonable efforts to correct personal information that our review determines is inaccurate.

Right to Delete

In certain circumstances, you have the right to request that we delete any personal information that we have collected from you and maintained about you. We may need to retain some of your information to: complete a transaction, prevent or detect fraud, or comply with a legal obligation. While we may not delete your information, we will always use it for a lawful purpose that aligns with what you would expect given your relationship with us.

Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your personal information from our records, we will also direct any service providers we work with to also delete your personal information from their records.

A household may request the deletion of aggregate household personal information by submitting a verifiable consumer request. If all consumers in a household jointly request deletion of household personal information, and we can individually verify all the members of the household, then we will comply with the request.

Please note that we may deny your deletion request for a number of different reasons, which are identified in the CPRA.

Right to Limit Sensitive Personal Information Use and Disclosure

In certain circumstances, you have the right to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those good or services. This right is not absolute and we have the right to refuse requests, wholly or partly, where exceptions under applicable law apply.

Personal Information Sales for a Business or Commercial Purpose; Right to Opt-Out

We have not sold consumer personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We do not and will not sell your personal information for monetary consideration. We do not offer an opt-out from the sale of personal information because we do not engage in the sale of personal information as contemplated by the CPRA.

We are a financial institution and do not sell the personal information of minors under sixteen (16) years of age.

Right of No Retaliation and Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your privacy rights under the CPRA. For example, unless otherwise permitted by the CPRA, we will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you with a different level or quality of goods or services; or

• Suggest that you will receive a different price or rate for goods or services, or a different level or quality of goods or services.

How to Exercise Your Rights

To exercise your right to know, right to delete, right to limit, or right to correct, please submit a verifiable consumer request to us by either:

• Calling us at 877-879-3650;

• E-mailing us at info@bealbankusa.com; or

• Visiting us in-person at a Beal Bank USA branch.

Whether you are a customer or not, to submit a verifiable consumer request, you may be asked to:

• Provide your name, address, and e-mail address (if you want to receive our response via e-mail);

• Submit additional identifying information; and

• Submit a signed declaration if you request specific personal information or request deletion in certain instances.

Only you (or an authorized agent) may make a verifiable consumer request for your personal information or for deletion of your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Please note that we are only required to respond to your request for access to your personal information twice within a twelve (12)-month period.

How We Verify Your Request

We will verify you as follows:

• If you submit a request to know the categories of personal information, you will need to provide us with your name and address, along with one (1) other additional identifier, which we will attempt to match with your name, address, and that other additional identifier in our system to verify your identity.

• If you submit a request to know specific pieces of personal information, you will need to provide us with your name, address, and two (2) additional identifiers, which we will attempt to match with your name, address, and the additional identifiers in our system to verify your identity. You will also be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose personal information is the subject of the request.

• If you submit a request to delete your personal information, you will need to provide us with your name and address, along with one (1) other additional identifier, which we will attempt to match with your name, address, and that other additional identifier in our system to verify your identity. In certain instances, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose personal information is the subject of the request.

If we suspect fraudulent or malicious activity related to your request, we will not comply with your request until we perform further verification to determine whether your request is authentic and you are the person about whom we have collected the personal information.

We will generally avoid requesting additional information from you to verify you. However, if we cannot verify your identity based on the information we currently maintain, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes. We will delete any new personal information we collect to verify your identity as soon as practical after processing your request unless otherwise required by the CPRA.

Generally, if we are unable to verify your identity, we will inform you of this inability and explain why we were unable to do so.

Our Response to Your Request

Once we receive your verifiable consumer request, we will confirm our receipt of your request within ten (10) business days and provide you with additional information about how we will process the request. Our goal is to respond to your request within forty-five (45) days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to ninety (90) days) to respond to your request, we will provide you with notice and an explanation of the reason(s) that we will take more than forty-five (45) days to respond. For requests to know, any personal information we provide will cover the twelve (12)-month period preceding our receipt of your verifiable consumer request. If we are unable to comply with a given request, we will provide you with a response explaining why we have not taken action on your request and identifying any rights you may have to appeal the decision.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Authorized Agent for Requests

You may designate an authorized agent to make a request on your behalf. If you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request, you must provide the authorized agent with written permission to do so and verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they are authorized to act on your behalf.

Contact Information

If you have any questions or comments regarding this Policy, the ways in which we collect, use, and disclose your personal information as described herein, or how to exercise your rights under the CPRA, please do not hesitate to contact us at:

Phone: 877-879-3650

E-mail: info@bealbankusa.com

Postal Address: 6000 Legacy Drive

Plano, Texas 75024

Attn: CPRA Information Request

Access by Persons with Disabilities

Persons with disabilities who need assistance accessing this Policy may contact us as provided above, by e-mailing ADAsupport@BealService.com, or by calling 1-800-840-7075 or 469-467- 5362. Depending on your individual needs, we will grant reasonable requests to furnish this Policy in an alternative format.

Changes to this Policy

We may change this Policy from time to time. When we do, we will communicate the changes as required by applicable law and by appropriate means, such as by posting the revised Policy on this page with a new "Last Updated" date. Any changes to this Policy will become effective when posted unless indicated otherwise. We encourage you to check this page to review the current Policy in effect.

This Policy was last updated on October 9, 2026.

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