Privacy Policy

1. Information We Collect

1.1 Personal Identifying Information

• Full name
• Mailing address
• Email address
• Phone number
• Date of birth (when required for identity verification)

1.2 Financial Information

Because we provide financial consulting services, we collect nonpublic personal financial information, including:

• Total unsecured debt amount and types of debt (credit cards, medical, personal loans, etc.)
• Names of creditors and approximate account balances
• Monthly income and employment status
• Monthly expenses and budget information
• Description of financial hardship or circumstances
• Credit profile information (self-reported or with your consent from a credit bureau)

1.3 Automatically Collected Information

• IP address and approximate location
• Browser type and version
• Pages visited and time spent on the website
• Referring URLs
• Device type and operating system
• Cookie and tracking technology data (see Section 6)

2. How We Use Your Information

We use the information we collect for the following purposes:

• To conduct your free financial situation review and consultation
• To analyze your debt profile and identify appropriate debt relief solutions
• To match and refer you to licensed third-party debt relief service providers
• To communicate with you regarding your consultation and follow-up
• To send informational or educational content you have requested
• To comply with legal and regulatory obligations
• To improve our website, services, and user experience
• To protect against fraud and unauthorized activity

We do not use your financial information for marketing unrelated products or services without your express consent.

3. GLBA Financial Privacy Notice

As a financial services company, we are required by the Gramm-Leach-Bliley Act (GLBA) to provide you with this notice regarding how we handle your nonpublic personal financial information.

3.1 Information We May Share

We may share your nonpublic personal financial information with the following categories of third parties:

• Debt relief service providers (debt settlement companies, credit counseling agencies, debt consolidation lenders, bankruptcy attorneys) to whom you are referred as part of our matching service
• Technology and software service providers who assist us in operating our website, CRM, and communications platforms, under confidentiality agreements
• Regulatory authorities and law enforcement, as required by law

3.2 Information We Do NOT Share

We do not sell, rent, or share your nonpublic personal financial information with:

• Unaffiliated third parties for their own independent marketing purposes
• Data brokers or information resellers
• Any party without a legitimate need related to delivering our consulting services to you

3.3 Your Opt-Out Rights

You have the right to opt out of certain information sharing. To exercise your opt-out rights or to request that we not share your information with any category of third party, please contact us using the information in Section 12. We will honor opt-out requests within 30 days.

4. How We Share Your Information

When we refer you to a third-party service provider, we will share the information necessary to initiate your consultation with that provider. This typically includes your name, contact information, and a summary of your debt situation. You will have the opportunity to review and consent to any such referral before your information is shared.

Third-party providers operate under their own privacy policies and agreements. We encourage you to review any provider's privacy policy before enrolling in their program.

We may also disclose your information when required by law, court order, or regulatory authority, or to protect our legal rights.

5. Data Security

We implement industry-standard technical and organizational security measures to protect your personal and financial information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using SSL/TLS technology (256-bit encryption)
• Access controls limiting data access to authorized personnel only
• Secure data storage with regular security reviews
• Employee training on data privacy and security

While we take reasonable precautions, no data transmission over the internet or electronic storage system is completely secure. We cannot guarantee absolute security and encourage you to protect your own information by using strong passwords and secure networks.

6. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to improve functionality, analyze traffic, and personalize your experience. Types of cookies we use include:

• Essential cookies: Required for the website to function properly
• Analytics cookies: Help us understand how visitors use the site (e.g., Google Analytics)
• Marketing cookies: Used to track conversions and improve our advertising (only with your consent)

You can control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

7. Your Privacy Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

• Right to know: Request information about the personal data we have collected about you
• Right to access: Obtain a copy of your personal information
• Right to correction: Request correction of inaccurate information
• Right to deletion: Request deletion of your personal information, subject to legal retention requirements
• Right to opt out: Opt out of data sharing for marketing purposes
• Right to non-discrimination: We will not discriminate against you for exercising your privacy rights

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know the categories of personal information sold and the right to opt out of the sale of personal information. We do not sell personal information.

To exercise any of your rights, contact us at info@thrivecds.com. We will respond within 45 days of receiving a verifiable request.

8. Data Retention

We retain your personal and financial information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Typically, consultation records are retained for a minimum of five (5) years in accordance with applicable financial services record-keeping requirements. After the applicable retention period, we securely destroy or anonymize your information.

9. Children's Privacy

Our website and services are not directed to children under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will promptly delete it.

10. Third-Party Links

Our website may contain links to external websites or third-party service providers. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party site before providing them with your information.

11. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices or applicable law. Any changes will be posted on this page with a revised Effective Date. Your continued use of our website or services following any changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

12. Contact Us

For questions, concerns, or to exercise your privacy rights, please contact us:

64 Squares Consulting LLC d/b/a Thrive Consumer Debt Solutions

25 SE 2nd Avenue, Suite 923, Miami, FL 33131

Phone: (786) 206-7575

Email: info@thrivecds.com

Website: www.thrivecds.com

This Privacy Policy is effective as of April 8, 2026 and supersedes all prior versions. It is not a substitute for individualized legal advice.