Credit & Identity Monitoring Services Addendum

This Credit & Identity Monitoring Services Addendum (“Addendum”) supplements and forms part of the Greenlight Terms of Service (the “Terms”) between you and Greenlight Financial Technology, Inc. (“Greenlight”). By enrolling in, accessing, or using any Credit & Identity Monitoring Services, you agree to this Addendum. If there is a conflict between this Addendum and the Terms, this Addendum controls solely with respect to the Credit & Identity Monitoring Services.

1. Scope of credit & identity monitoring services

Greenlight may make available certain credit-related and identity monitoring services, which may include access to credit reports and credit scores, credit monitoring alerts, dark web or identity monitoring alerts, and credit lock and unlock functionality (collectively, the “Credit Services”). Greenlight provides the Credit Services using one or more third-party service providers, including Array, and applicable consumer reporting agencies. Greenlight remains your sole contractual counterparty for purposes of this Addendum and may change or substitute service providers at any time.

2. Informational nature of the credit services

The Credit Services are provided for informational and monitoring purposes only. Greenlight does not provide credit repair services, legal, financial, or identity theft recovery advice, and does not guarantee the prevention of identity theft, fraud, or unauthorized credit activity. Credit scores and reports displayed through the Credit Services may not reflect real-time information, may differ from scores used by lenders, creditors, or insurers, and should not be relied upon as a substitute for obtaining credit directly from lenders or consumer reporting agencies.

3. Non-CRA status; third-party data disclaimer

Greenlight is not a “consumer reporting agency” as defined by the Fair Credit Reporting Act (“FCRA”) and does not assemble, evaluate, or furnish consumer reports. Credit information, alerts, and monitoring data are obtained from consumer reporting agencies and other third parties. Greenlight does not generate or modify consumer report information and does not control the accuracy, completeness, or timeliness of such information. Greenlight is not responsible for inaccurate, incomplete, or delayed data, errors or omissions by consumer reporting agencies, or actions taken by creditors or third parties based on consumer report information.

4. Credit report disputes

Greenlight does not handle disputes regarding the accuracy or completeness of consumer report information. You must submit any disputes directly to the applicable consumer reporting agency in accordance with that agency’s dispute procedures. Greenlight has no obligation to investigate, resolve, or respond to disputes concerning consumer report data.

5. Dark web & identity monitoring limitations

Dark web and identity monitoring services are limited to specific data sources, databases, and marketplaces, may not detect all compromised information, and may identify information that is outdated, incomplete, or already publicly available. Dark web monitoring does not prevent identity theft or fraud and does not remove information from circulation. Greenlight has no obligation to recover compromised information, stop misuse of personal information, or provide identity restoration, remediation, or insurance services.

6. Credit lock and unlock authorization

If you elect to use credit lock or unlock functionality:

7. Authorization

You expressly authorize Greenlight to act as your authorized agent to submit credit lock and unlock requests to applicable consumer reporting agencies at your direction.

8. No guarantee

You acknowledge that lock and unlock requests may be delayed, rejected, or unavailable, that certain creditors or entities may access credit information under applicable legal exceptions, and that Greenlight does not guarantee that a credit lock will prevent fraud or unauthorized credit activity.

9. User responsibility

You are solely responsible for the timing and use of credit lock and unlock requests, any inability to obtain credit due to a locked credit file, and maintaining the security of your account credentials.

10. FCRA authorization; affirmative consent; data sharing

By enrolling in the Credit Services, you provide your written instructions and consent under the Fair Credit Reporting Act (“FCRA”) to Greenlight and its employees, agents, affiliates, contractors, and service providers, including Array, to obtain, access, and monitor your consumer credit reports and related information from one or more consumer reporting agencies on a recurring basis, solely for purposes of verifying your identity, displaying credit data to you, monitoring your credit for changes, preventing fraudulent activity, and providing the Credit Services, including alerts and credit lock and unlock functionality.

You acknowledge that this authorization is provided through an affirmative acceptance mechanism within the Greenlight platform, and that Greenlight may capture, store, and retain records of your consent in accordance with applicable law.

You further expressly consent to Greenlight sharing your personal information and consumer report information with its employees, agents, affiliates, contractors, service providers (including Array), applicable consumer reporting agencies, and other third-party data sources, solely as necessary to provide, support, and administer the Credit Services and as described in Greenlight’s Privacy Policy.

11. No adverse action

Greenlight does not make credit, employment, insurance, or housing decisions based on consumer report information, does not take adverse action as defined under the FCRA, and does not provide adverse action notices. Any adverse action taken by a third party is the responsibility of that third party.

12. No insurance; no recovery obligations

The Credit Services do not include identity theft insurance, fraud reimbursement, legal representation, credit repair, or dispute resolution services. Greenlight has no obligation to reimburse losses or assist with recovery arising from identity theft, fraud, or unauthorized credit activity.

13. Suspension, modification, or termination

Greenlight may modify, suspend, or discontinue any Credit Services at any time, change service providers without notice, or limit availability based on eligibility, geography, regulatory requirements, or data-provider obligations. Greenlight may update disclosures related to the Credit Services from time to time as required by applicable law or by its service providers or data sources, and continued use of the Credit Services constitutes acceptance of such updates.

14. Limitation of liability (credit services only)

To the maximum extent permitted by law, Greenlight shall not be liable for any damages arising out of or related to inaccurate, incomplete, or delayed credit information, failure or delay of monitoring alerts, credit lock or unlock requests or functionality, or identity theft, fraud, or unauthorized account activity. This limitation applies solely to the Credit Services and does not expand liability limitations beyond those set forth in the Terms.

15. Arbitration; governing terms; survival

The Credit Services are part of the Greenlight Services and are subject to the arbitration agreement, class action waiver, and governing law provisions set forth in the Terms. Provisions relating to authorization and consent, disclaimers, limitation of liability, arbitration, and governing law survive termination of your use of the Credit Services.