Phoenix Financial — Privacy and Safeguards Notice

Effective July 2026

Introduction

Thank you for visiting a website (including its mobile device-ready version) of Phoenix Financial (“Phoenix Financial,” “we,” “our,” or “us”). In this Privacy Policy, we refer to our websites as our “Websites.” We hope that you find our Websites to be a useful part of your experience with us. Please note that this Privacy Policy describes our overall privacy practices for our Websites. This policy also applies to information collected from customers and applicants at our offices and through our payment portal.

Phoenix Financial is committed to respecting the privacy rights of our customers and all visitors to our Websites. We are publishing this policy to advise you what information Phoenix Financial may collect, how Phoenix Financial may use that information, and how your information is protected.

Phoenix Financial is an automotive finance company located in Odessa, Texas. This Privacy Policy applies to information collected through our Websites, our physical office locations, and our online payment portal. Because Phoenix Financial is engaged in financial activities, including consumer lending and loan servicing, this Privacy Policy should be read together with our Financial Privacy Notice, which describes how we handle your nonpublic personal financial information under applicable federal law.

Acceptance of Privacy Policy

As a condition to using the Websites, we require your approval to collect the data described below. By visiting any of our Websites, you agree that Phoenix Financial may collect and use this information as stated in this Privacy Policy. Do not use the site if you do not accept the terms of this Privacy Policy.

Updating Our Privacy Policy

Phoenix Financial reserves the right to make changes to this Privacy Policy at any time. We will post those changes to this page so that users are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We will use, share, and disclose all information in accordance with the privacy policy in effect at the time the information was collected.

After we make any change to the Privacy Policy, we will post the updated version on the Website. Your continued use of the site following the posting of such modifications will mean that you accept the amended Privacy Policy.

How We Collect Information

We collect information in a number of different ways:

Basic Web Information

We may collect information associated with your IP address, such as the time and date of a visit, the originating domain name, the browser type, the web address of the site from which you were linked (if any), and the particular pages or products viewed on the Websites.

Passive Information

We also may collect information from you passively. Phoenix Financial may use a variety of technologies including cookies. A cookie is a piece of data stored on your device containing information about you. Usage of a cookie is in no way linked to personal information until you provide that information (see below). If you reject or delete a cookie, you may still use our site; however, you may be limited in some areas. We may also use tracking pixels, web beacons, and similar technologies to collect information about your interactions with our Websites and our advertising.

Voluntarily Provided Information

We collect certain information that users voluntarily provide to us via the site, at our offices, through our online payment portal, or in other correspondence. For example, we collect the email addresses of those who contact us by email. When you submit a financing application or inquiry, make a payment, or otherwise engage with our services, we may collect your full name, phone number, email address, mailing address, date of birth, and other information you choose to provide. We use that information to serve you, to process your account, to improve the content of our Websites, and to contact you for marketing and account-related purposes.

Because Phoenix Financial is engaged in consumer lending and loan servicing, personal information you provide in connection with a financing application or account is subject to separate handling under federal law, as described in our Financial Privacy Notice. Please note that communications with us, including telephone calls, may be monitored or recorded for identity-verification, quality-assurance, training, security, and compliance purposes, as permitted by applicable law.

Information Received from Others

Phoenix Financial may receive information about you from others in connection with your financing application or account. For example, we may receive information from consumer reporting agencies, credit bureaus, employers, insurance agencies, automobile dealerships, and other financial institutions, such as your credit history, creditworthiness, employment history, insurance coverage, and vehicle information.

Mobile Websites

When you use our mobile device-ready website, we may collect additional information about you that is specific to your mobile device, such as device type and mobile advertising identifiers.

How We Combine Information

We may combine information that we have collected offline with information we collect online. We may combine information we collect passively with information you provide to us. We may combine information about our transactions and experiences with you with other information we have collected. We may also combine previously anonymous information, such as IP addresses, with other information we have collected in order to identify an individual.

How We Use Collected Information

We use the information we collect to operate our Websites, to respond to your requests, and to manage your relationship with Phoenix Financial. For example, we use the information to process financing applications and payments; to manage and service your account; to communicate with you about your account, required notices, and important updates; and to improve our Websites. We may also use information for marketing purposes, such as informing you about our financing products and services. We use your information to verify your identity, assess creditworthiness, and determine eligibility for financing.

We do not engage in automated profiling in furtherance of decisions that produce legal or similarly significant effects on you.

Use of Third-Party Services

We may use third-party services in order to better understand our users’ needs and optimize their experience. These third parties may use cookies and other technologies to collect user feedback on issues affecting website usage, such as how long users spend on certain pages and what links are clicked. A user’s IP address, device type, country location, and other similar information may be collected by the third party and stored in an anonymized profile. Any third party we use to collect this kind of data is subject to contractual confidentiality restrictions that prohibit the use or sale of data collected on our behalf for their own independent purposes.

Sharing

Phoenix Financial does not rent or sell your personal information to any unaffiliated third party for their own marketing purposes, and we do not sell personal information in exchange for money. Please note, however, that some state privacy laws define “sale” or “sharing” broadly enough to include the use of cookies, pixels, and similar technologies that make information available to advertising partners for targeted (cross-context behavioral) advertising. To the extent our use of these technologies is considered a “sale” or “sharing” under applicable law, you may opt out as described in the “Cookies and Online Tracking” and “State Privacy Rights” sections of this Privacy Policy. We share information with third parties in accordance with applicable law, including:

With Affiliates. We may share information among Phoenix Financial and its affiliated companies, which may include affiliated automotive dealerships.

With Service Providers. We will share information with third parties who perform services on our behalf. For example, we share information with vendors who send emails for us, operate our websites, or run a promotion. The information we share may include location information.

With Loan Servicers and Collection Agencies. In the course of servicing your account, we may share information with third parties who assist in loan servicing, payment processing, debt collection, and related activities, subject to applicable law and our Financial Privacy Notice.

To Comply with Law or Protect Phoenix Financial’s Interests. We will share information if we believe we are required to do so by law or to protect our interests. For example, we will share information to respond to a court order, subpoena, or government agency request, or when we are investigating potential fraud.

With Successors. We may share information with any successor to all or part of our business, such as in connection with a merger, acquisition, sale of assets, or similar transaction.

Social Media

We maintain a presence on several social networking platforms, such as Facebook and Instagram, and we may incorporate third-party social networking features onto our Websites. Through these platforms and features, we may receive information about you, and this Privacy Policy applies to that information as well. Third-party social networking platforms have their own privacy policies that explain how those platforms will use and protect your information. Information about your activities on our Websites may be published to your social network in accordance with your privacy settings within your social networking accounts.

Cookies and Online Tracking

Our Websites use cookies and similar tracking technologies to enhance your experience. You can set your browser to notify you before accepting cookies or to refuse cookies entirely. If you refuse cookies, you may still use our site, but you may be limited in some areas. We currently do not respond to browser “Do Not Track” signals, as there is no universally accepted standard for such signals.

Where required by applicable law, we recognize and honor universal opt-out preference signals, such as the Global Privacy Control (GPC). If your browser or browser extension transmits a legally recognized opt-out preference signal, we will treat it as a valid request to opt out of targeted advertising and of any “sale” or “sharing” of personal information for the browser or device from which the signal is sent, to the extent required by the law of your state of residence.

Phoenix Financial may use online advertising networks to serve ads on third-party websites. You can opt out of receiving targeted ads from many websites by using the opt-out tools available through the Digital Advertising Alliance (www.aboutads.info) or the Network Advertising Initiative (www.networkadvertising.org). Please note that even if you opt out, you may still receive online advertising —- the ads will simply not be based on your online preferences or behavior.

Security

We take commercially reasonable steps to protect the information we collect online. When we transfer and receive certain types of sensitive information, such as financial information, we redirect visitors to a secure server using industry-standard encryption. Once information has been received by us, we use security procedures and policies commensurate with industry standards —- including those required under the FTC Safeguards Rule —- to safeguard against loss, theft, unauthorized access, destruction, use, modification, and disclosure. However, no security system is impenetrable, and we cannot guarantee the absolute security of our databases or that information you transmit to us will not be intercepted. We will make all legally required disclosures of any breach of the security, confidentiality, or integrity of your information in the manner and within the time periods required by applicable law.

In accordance with the FTC’s Red Flags Rule (16 C.F.R. Part 681), Phoenix Financial maintains a written Identity Theft Prevention Program designed to detect, prevent, and mitigate identity theft in connection with the opening of new covered accounts and the maintenance of existing covered accounts. This program is part of our broader commitment to protecting your personal information throughout your relationship with us.

Data Retention

We retain personal information only for as long as it is necessary and relevant for the purposes described in this Privacy Policy, taking into account the nature and sensitivity of the information; our legal, regulatory, tax, and accounting obligations, including federal and state record-retention requirements applicable to consumer lending and loan servicing; the need to establish or defend legal claims; and applicable statutes of limitations. Records relating to financing applications, loan accounts, payments, and collections may be retained for extended periods where required by law. When personal information is no longer needed for these purposes, we take reasonable steps to securely delete, de-identify, or aggregate it in accordance with applicable law.

Links to Other Sites

Our Websites contain links to other sites. Please be aware that Phoenix Financial is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personal information. This Privacy Policy applies solely to information collected by the Phoenix Financial Websites. Links from our Websites do not imply that Phoenix Financial sponsors or endorses those other sites or any products or services described there.

Children

Phoenix Financial does not knowingly allow anyone under the age of 13 to participate in any services offered on our Websites that require the submission of personal information. If we learn that a user is under 13 and has submitted personal information to us, we will delete that information as promptly as possible. If you believe a child under 13 has provided us with personal information, please contact us using the information in the “How to Contact Us” section below.

State Privacy Rights

Phoenix Financial’s primary operations are in Texas. The Texas Data Privacy and Security Act (TDPSA) provides Texas residents with certain rights regarding their personal information, including the right to know whether we process their personal data, the right to access that data, the right to correct inaccuracies, the right to delete personal data, the right to obtain a copy of their personal data in a portable format, and the right to opt out of the processing of their personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

Phoenix Financial also serves customers in neighboring states and beyond. Residents of California (under the CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other states that have enacted comprehensive privacy laws may also have rights similar to those described above with respect to their personal information. We will honor such rights to the extent required by the law of each consumer’s state of residence.

California residents may also have additional rights under California law, including the right to opt out of the “sale” or “sharing” of personal information for cross-context behavioral advertising and the right to limit the use of sensitive personal information.

In addition, Nevada law requires website operators to provide Nevada residents with a way to opt out of the sale of certain covered information. As noted in this Privacy Policy, we do not sell personal information.

Important limitation: Because Phoenix Financial is a financial institution engaged in consumer lending and loan servicing, much of the personal information we collect and process is subject to the Gramm-Leach-Bliley Act (GLBA) and/or the Fair Credit Reporting Act (FCRA). State consumer privacy laws, including the TDPSA and the CCPA/CPRA, generally exempt personal information collected, processed, sold, or disclosed subject to the GLBA or FCRA. As a result, the state privacy rights described in this section may not apply to information relating to your financing application, loan account, payment history, or credit report, and we may be legally required to retain such information even if you request its deletion. Requests relating to that information are governed by the GLBA, the FCRA, and our Financial Privacy Notice.

To exercise any of the rights described above, please contact us as specified below. We may need to verify your identity before processing your request in order to protect against unauthorized disclosure or deletion of personal information. We will respond to verifiable requests within the time frames required by applicable law. You may also designate an authorized agent to submit a request on your behalf.

If we decline to take action on your request, we will notify you of our decision and the reasons for it. You have the right to appeal our decision by contacting us using the information in the “How to Contact Us” section below and referencing your original request. We will respond to your appeal within the time frame required by applicable law; for Texas residents, we will inform you in writing of any action taken or not taken in response to your appeal within 60 days of receipt, along with a written explanation of the reasons for our decision. If your appeal is denied, you may contact the attorney general of your state of residence to submit a complaint. Texas residents may contact the Office of the Texas Attorney General at www.texasattorneygeneral.gov.

Opting Out of Communications

If you wish to stop receiving email communications from us, you may “unsubscribe” using the link at the bottom of any email you receive from us. To stop text communications, reply to the text with the word “STOP.” If you wish to be placed on our postal mailing “Do Not Contact” list, please contact us using the information below and provide the name and address as listed on the mailing. You may also control ads appearing on your browser or mobile device by adjusting your settings or using third-party ad blocking tools. Please note that opting out of marketing communications does not affect transactional, account-servicing, or legally required communications, such as payment reminders, billing statements, privacy notices, collection communications, and other notices relating to your account, which we may continue to send as permitted by applicable law.

Corporate Transfers

In connection with a corporate merger, acquisition, divestiture, asset sale, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, we may sell, transfer, assign, share, or otherwise engage in a transaction that involves some or all of our assets, including your personal information.

Compliance with Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties that we, in our reasonable discretion, believe necessary or appropriate to respond to claims and legal process (including subpoenas and court orders), to protect our rights or those of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be, or that may pose a risk of being, illegal, unethical, or subject to legal action.

Financial Privacy Notice

Phoenix Financial is engaged in consumer lending and loan servicing and is subject to the Gramm-Leach-Bliley Act (GLBA). Personal information you provide in connection with a financing application, loan account, or payment is subject to separate handling under federal law. Phoenix Financial provides a separate Financial Privacy Notice to customers in connection with such financial transactions, as required by the Gramm-Leach-Bliley Act. Please review that notice for information about how we handle your nonpublic personal financial information.

Credit Reporting

Phoenix Financial may furnish information about your account, including your payment history, to consumer reporting agencies. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. If you believe that information we have furnished to a consumer reporting agency is inaccurate or incomplete, you may submit a dispute directly to the consumer reporting agency or to us in writing using the contact information in the “How to Contact Us” section below. Disputes concerning consumer report information, and any adverse action taken in connection with a credit application, are governed by the Fair Credit Reporting Act rather than by the state privacy rights described in this Privacy Policy.

Disclaimer and Limitation of Liability

The information within this site is provided “as is.” No warranty is expressed or implied to the fullest extent permissible by applicable law. Phoenix Financial and any of its providers of information do not warrant error-free or uninterrupted service of this site. This site, and the information provided herein, may contain inaccuracies and typographical errors. Phoenix Financial does not warrant the accuracy or completeness of this site or the information provided here. You acknowledge that any reliance on any advice, opinion, statement, or other information will be at your sole risk.

The Websites and the information contained on them are protected by copyright, trademark, and other intellectual property laws under U.S. and international law. Unauthorized reproduction, distribution, or use of content from our Websites is prohibited.

How to Contact Us

If you have any questions or concerns regarding this Privacy Policy, wish to exercise your privacy rights, or need to report a privacy issue, please contact us by:

Email: legal@teamsewell.com

Phone: 432.580.7335

Mail: Sewell Family of Companies, Inc. (and its related entities), Attn: Privacy Officer, P.O. Box 3432, Odessa, TX 79760

Website: www.phoenixfinancial.com

We will make every effort to promptly respond to your inquiry. Residents of states with applicable privacy laws who wish to exercise their rights may use any of the contact methods above.