Effective Date: December 12, 2025

Afni, Inc. (“Afni,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Notice explains how we collect, use, disclose, and safeguard your personal data, and outlines privacy rights you may possess under the laws of your state, if applicable.

1. Information We Collect

We may collect the following categories of personal data:

• Identifiers: Real name, postal address, phone number, email address, employer
• Inferences drawn from any of the information to create a profile about a consumer reflecting the consumer’s preferences, predispositions, behavior, attitudes, abilities, and aptitudes.
• Client information: provided to Afni by our client may include but is not limited to name, mailing address, service address, phone number, email address, employment status, Social Security Number, date of birth, vehicle identification number, records of services provided, payment history, insurance information, police records
• Application Information: Education information, prior work experience, work status
• Internet Activity: IP address, browser type, device identifiers, and usage data.
• Sensitive Data: Financial account information, driver’s license number, Social Security Number, and geolocation data

We do not knowingly collect personal data from children under 13 years of age.

2. Sources of Information

• Afni’s clients provide personal identifying information and account details.
• Afni, through skip tracing and our service providers, obtains updated phone numbers, addresses, bankruptcy information, and U.S. service member information.
• Afni may request information directly from you to verify your identity, ensure up to date records, or process payments at your request.

3. How We Use Your Information

We use your personal data for the following purposes:

• To provide and manage our services.
• To communicate with you
• To complete transactions for which the information was originally obtained or otherwise in performance of a contract between you and our client or Afni.
• To comply with legal obligations, exercise legal claims or rights, or defend legal claims.
• To detect and prevent fraud or security incidents.
• For internal analytics and service improvement

We do not use your data for targeted advertising.

3. How We Share Your Information

Based upon the last twelve months:

• We may share your Identifiers with our Service Providers to help manage communications.
• Providers to help process your application.
• We may share your Identifiers and Financial Account information with our Payment Processors to process payments you have authorized.
• If we are servicing your account on behalf of another company (“our Client”) we may share your Identifiers and Sensitive Data with our Client.
• If we are managing a subrogation account, we may share your Identifiers, Client Information, and Sensitive Data with an Attorney to pursue legal action on our client’s behalf as permitted under law and our contract with the client.
• As required by law, through legal process, or to defend against legal action, we may share any information with Law Enforcement, Government Agencies, Courts, Mediators, or Arbitration Bodies.

We do not sell your personal data.

4. Do Not Track

As Afni does not sell your information or use it for targeted advertising. We do not respond to Do Not Track signals.

5. Your Privacy Rights

Depending on your state of residence, the source of your data, and our purpose for obtaining and processing the data, you may have rights in how we handle your data. These most commonly include:

• Right to Access: Request confirmation and access to your personal data.
• Right to Correct: Request correction of inaccuracies in your personal data.
• Right to Delete: Request deletion of your personal data.
• Right to Data Portability: Obtain a copy of your data in a portable format.
• Right to Opt Out: Limit the sharing or processing of certain categories of data.

To exercise your rights, please contact us at Privacyrequests@afni.com or (844)-293-2364.

• Right of Appeal: If we deny your request to exercise your rights, you may appeal by contacting PrivacyRequests@afni.com with the subject line “Privacy Appeal.” We will respond within 45 days.

6. Data Security and Retention

We implement reasonable administrative, technical, and physical safeguards to protect your personal data. We retain your data only as long as necessary for the purposes described in this notice or as otherwise required by law.

• Information related to collections or subrogation accounts, including Identifiers, Client Information, and Sensitive data will be retained for 6 years after the account has been satisfied, returned to client, or otherwise closed.
• Payment information will be retained only as long as necessary to effectuate your payments.
• Call recordings, potentially containing personal or sensitive information, will be retained for 4 years unless specific state law imposes a longer timeframe.
• Video recordings of agents, applicants, and premises will be retained for up to 6 months.

7. Changes to This Notice

We may update this Privacy Notice from time to time. We will notify you of material changes by posting the updated notice on our website and updating the effective date.

8. Contact Us

If you have any questions or concerns about this Privacy Notice or our data practices, please contact:

Mail:

Afni, Inc.

Attn: Privacy Requests

1310 Martin Luther King Drive

Bloomington, IL 61701-1465

Email: Privacyrequests@afni.com

Phone: (844)-293-2364