Privacy Policy

Privacy Policy

Last updated: March 20, 2026

This Privacy Policy describes how and why Unsettled d/b/a D&A Services, LLC (“Unsettled”, “we,” “us,” or “our”) might collect, store, use, and/or share your information when you use Unsettled’s services or visit our website. Definitions of terms used in this policy are the same as are found in our Terms of Service. If at any time you have questions about this policy please contact us at compliance@unsettled.com. If you do not agree with our policy or practices, please discontinue use of our services.

Unsettled provides a platform designed to facilitate collection strategies between subscribers and financial institutions in their personal financial network and empower consumers to make personal financial decisions (collectively, the “Service”). Unsettled follows this Privacy Policy according to the applicable law in the places in which we operate.

Our Service is not intended for children or anyone under the age of 18. Unsettled does not knowingly collect personal information from anyone under the age of 18. If you have reason to believe that a child has provided personal information to us please contact us at compliance@unsettled.com.

We do not, and without your consent will not sell, lease, or rent your information to third parties for monetary or other valuable consideration.

1. What Information Do We Collect?

We collect information that you voluntarily provide to us when you register for our services, express an interest in obtaining information about us or our services, when you actively participate in the use of those services, or otherwise access Unsettled’s platform.

Personal Information Provided by You

The personal information we collect may include:

• Company information
• Names
• Phone numbers
• Email addresses
• Physical addresses
• Date of birth
• Usernames and passwords that you create
• Contact preferences and authentication data

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Financial data
• Credit worthiness data
• Social security numbers
• Government identification information

Payment Information

We may collect data necessary to allow you to process payments through Unsettled’s third-party payment service providers, PayScout (https://payscout.com/privacy-policy/). All payment data is handled and stored by PayScout and you should review their privacy policies before using their services.

Information Automatically Collected

When you visit, use, or interact with the Service, we may receive certain information about your visit, use, or interactions. In particular, the following information may be automatically logged in our systems:

• Log data: Your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Service.
• Cookies: Please see the “Cookies” section below.
• Device information: Name of the device, operating system, and browser you are using.
• Usage Information: Types of content you view or engage with, features you use, and the time, frequency, and duration of your activities.

Cookies

We use essential cookies to operate and administer our Service, gather usage data, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. Some cookies expire after a certain amount of time or upon logging out (session cookies); others survive after your browser is closed until a defined expiration date (persistent cookies).

Online Tracking and Do Not Track Signals

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you. You may opt out of receiving this advertising by visiting https://app.retention.com/optout. On most web browsers, you can find the Do-Not-Track (“DNT”) feature or setting in the “help” section of the toolbar. Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Service.

2. How Do We Process Your Information?

Consistent with applicable law and choices and controls that may be available to you, we may use all or some of the personal information we collect from you for purposes including the following:

• To personalize your experience
• To provide and facilitate your engagement with the Service, including account creation, verifying your identity, facilitating communications, and facilitating payments between you and third-party financial institutions
• To respond to your inquiries, comments, feedback, or questions
• To send administrative information to you regarding the Service and changes to our terms, conditions, and policies
• To analyze how you interact with our Service
• To maintain and improve the content and functionality of the Service
• To develop new products and services
• To prevent fraud, criminal activity, or misuse of our Service
• To comply with our legal obligations and legal process and to protect our rights, privacy, safety, or property

Aggregated, Anonymized, and Pseudonymized Information

We may collect or generate aggregated, anonymized, and/or pseudonymized personal information and use the information to analyze the effectiveness of our Service, to improve and add features to our Service, and for any other lawful purpose. We may also share such information with our business partners and other third parties.

3. With Whom Do We Share Your Information?

Our platform is designed to facilitate communications between Unsettled subscribers and financial institutions. In certain circumstances we may share your personal information with third parties, subject to applicable laws, as set forth below:

• Vendors and Service Providers: To assist us in meeting business operations needs, we may share personal information with vendors and service providers including providers of hosting services, cloud services, email communication software, payment processors, banking and financial service providers, customer relationship management services, and web analytics services.
• Companies You Select: If you direct us to share your personal information with another company, we will share your personal information and once shared it will be subject to the privacy policies and practices of those other companies.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend our rights or property, prevent fraud, act in urgent circumstances to protect personal safety, or protect against legal liability.
• Affiliates: We may share personal information with our affiliates. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

4. How Long Do We Keep Your Information?

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is longer. Whenever your personal information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the security and privacy of your personal information.

5. How Do We Keep Your Information Safe?

You use the Service at your own risk. We implement reasonable technical, administrative, and organizational measures designed to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service or third-party websites.

6. Do US Residents Have Rights Regarding Their Personal Information?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to know or request access to and receive details about the personal information we maintain about you and how we have processed it. You may have the right to correct inaccuracies, get a copy of, or delete your personal information. Unsettled will not discriminate against you for exercising your rights.

California Residents

You may have the right to opt-out of the “sale” or sharing of your personal information. You can opt-out by:

• Accessing your Cookie consent settings as described above
• By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA

You should know that we have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. California consumers may make requests to access, correct, or delete pursuant to their rights under the CCPA by contacting us at compliance@unsettled.com.

Virginia Residents

In addition to the rights described above, you also have the right to opt-out from the processing of your personal information for profiling purposes. You also have the right to opt out of targeted advertising and selling; however, as noted above, Unsettled does not participate in the selling of your personal information. If we refuse to take action on a request, you may appeal our decision by emailing compliance@unsettled.com. We will respond to your appeal within 60 days. If we deny your appeal, you have the right to contact the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

7. How Can You Exercise Your Rights?

You control the data you provide to Unsettled. You can access it anytime to make corrections, deletions, provide or revoke consent for certain services and uses of your data. In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our Service, those features may be unavailable to you. You can also contact us at contact@unsettled.com to ask any questions, make recommendations, or seek assistance in updating or correcting your personal information.

Under certain US laws, you can designate an authorized agent to make data requests on your behalf. We may deny a request from an authorized agent that does not submit adequate proof of your authorization for them to act on your behalf.

Upon receipt of your request, we will need to verify your identity to determine you are the same person about whom we have information in our systems. If we cannot verify your identity with the information provided, we may ask for additional information or deny the request for security and fraud-prevention. You can appeal our decision to decline your request by contacting compliance@unsettled.com.

8. Changes to This Privacy Policy

The Service and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page noting the revision date, unless another type of notice is required by the applicable law. Your continued use of our Service after we post an updated Privacy Policy shall be regarded as your consent to revisions to our Privacy Policy and practices related to it.