PRIVACY POLICY

Effective Date: August 23, 2026

Last Updated: August 23, 2026

Dunigan Investment Group ("DIG," "Dunigan Investment Group," "we," "our," or "us") respects the privacy of our customers, prospective customers, website visitors, contest entrants, program participants, and other individuals who provide information to us.

We understand that individuals may provide Dunigan Investment Group with personal, financial, credit-related, identification, and other sensitive information. Protecting that information is important to us.

This Privacy Policy explains:

What information we may collect
Why we collect it
How we may use it
When limited disclosures may occur
How we protect sensitive information
How long information may be retained
How marketing communications are handled
The privacy choices available to individuals
How individuals may contact us concerning their information

By using a Dunigan Investment Group website, submitting information to DIG, entering a DIG promotion or contest, requesting information, or becoming a DIG customer or program participant, you acknowledge the practices described in this Privacy Policy.

1. OUR PRIVACY COMMITMENT

Dunigan Investment Group collects personal information for legitimate business purposes connected with Dunigan Investment Group and the services, programs, promotions, communications, and activities we provide.

Dunigan Investment Group does not sell, rent, trade, or give personal information to unrelated third parties for their own independent marketing or commercial purposes.

We do not operate as a data broker.

We do not collect personal information for the purpose of creating consumer lists to sell to unrelated companies.

We do not provide customer, applicant, entrant, or program-participant information to unrelated businesses so that those businesses can independently market their products or services to those individuals.

Personal information is used for Dunigan Investment Group business purposes and may only be disclosed in the limited circumstances described in this Privacy Policy.

2. INFORMATION WE MAY COLLECT

The information we collect depends upon how an individual interacts with Dunigan Investment Group.

We may collect the following categories of information.

A. Personal Identification Information

This may include:

First and last name;
Mailing address;
Residential address;
City;
State;
ZIP Code;
Email address;
Telephone number;
Date of birth or age when necessary;
Government-issued identification information; and
Other information necessary to identify or communicate with an individual.

3. CONTEST AND PROMOTIONAL ENTRY INFORMATION

Individuals participating in promotions such as The Dunigan 5 Credit Comeback Giveaway may provide information including:

Name;
Email address;
Mobile telephone number;
Residential address;
City and state;
Age or confirmation of age eligibility;
Credit-related goals;
Personal statements;
Information regarding credit challenges;
Video submissions;
Photographs;
Testimonials;
Contest answers;
Application responses; and
Other information voluntarily submitted as part of an application.

Submitted video, media, and testimonial materials may be used in accordance with the separate media consent and applicable Official Rules associated with the promotion.

4. SENSITIVE PERSONAL INFORMATION

Individuals selected for certain DIG programs or individuals receiving credit-related services may be required to provide more sensitive information.

This may include:

A copy of a driver's license or government-issued identification;
A copy of a Social Security card;
Social Security number or portions of a Social Security number when reasonably required;
Utility bills or other proof-of-address documents;
Consumer credit-report information;
Credit-account information;
Information appearing on consumer credit reports;
Collection-account information;
Creditor information;
Payment-history information;
Credit utilization information;
Consumer reporting agency information;
Documents relating to disputed credit information; and
Other information reasonably necessary to provide requested credit-related services.

DIG treats this category of information with increased sensitivity.

Sensitive personal information is collected only when reasonably necessary for legitimate business, verification, legal, compliance, or service-related purposes.

5. CREDIT-REPORT AND CREDIT-RELATED INFORMATION

When an individual becomes a customer or authorized program participant, DIG may receive or review consumer credit information when legally permitted and when authorized by the individual.

This may include information from:

Equifax;
Experian;
TransUnion;
Other consumer reporting agencies;
Credit-monitoring platforms;
SmartCredit;
Creditors;
Collection companies;
Data furnishers; and
Other authorized sources relevant to the services requested.

Credit-related information will be used for legitimate purposes associated with evaluating, administering, educating, monitoring, or performing authorized credit-related services.

6. INFORMATION WE COLLECT AUTOMATICALLY

When an individual visits a DIG website, certain technical information may be collected automatically by the website or the technology used to operate it.

This may include:

Internet Protocol ("IP") address;
Browser type;
Device type;
Operating system;
Pages visited;
Date and time of visit;
Referring website or source;
Website interactions;
General geographic information derived from an IP address;
Cookie identifiers; and
Similar technical information.

This information may be used for:

Website operation;
Website security;
Fraud prevention;
Troubleshooting;
Performance analysis;
Understanding website usage;
Improving our websites and services; and
Maintaining the reliability of our systems.

7. COOKIES AND SIMILAR TECHNOLOGIES

DIG websites may use cookies and similar technologies to support website functionality, security, preferences, analytics, and performance.

Cookies may allow a website to remember certain information about a user's visit.

Depending upon the technology used on a particular DIG website, cookies may be used to:

Keep the website functioning properly;
Remember user preferences;
Understand how visitors interact with the website;
Detect abuse or suspicious activity;
Improve site performance; and
Measure website effectiveness.

Users may be able to adjust cookie settings through their web browser or through any cookie-preference controls provided on the applicable website.

Disabling certain cookies may affect website functionality.

8. HOW DUNIGAN INVESTMENT GROUP USES PERSONAL INFORMATION

DIG may use personal information for legitimate business purposes including:

Providing requested services;
Responding to inquiries;
Processing applications;
Administering contests and promotions;
Evaluating contest submissions;
Determining eligibility;
Communicating with entrants;
Selecting and verifying potential winners;
Providing credit-repair and credit-education services;
Reviewing credit information;
Preparing authorized disputes or communications;
Monitoring credit-related progress;
Developing personalized credit strategies;
Providing educational information;
Maintaining customer records;
Providing customer support;
Scheduling appointments;
Conducting account reviews;
Preventing fraud;
Verifying identity;
Maintaining website and system security;
Improving DIG services;
Maintaining legally required records;
Complying with applicable laws and regulations;
Protecting DIG's legal rights;
Responding to legal requests;
Providing company updates;
Sending educational information;
Providing credit tips and strategies;
Informing individuals about future DIG programs;
Informing individuals about future contests or giveaways;
Sending promotional communications where permitted;
Providing information about DIG products and services; and
Carrying out other legitimate Dunigan Investment Group business activities consistent with this Privacy Policy.

9. THE DUNIGAN 5 AND FUTURE COMMUNICATIONS

Individuals who submit information in connection with The Dunigan 5 Credit Comeback Giveaway understand that their contact information may continue to be maintained by Dunigan Investment Group after the Contest ends.

This includes individuals who are not selected as winners.

Where permitted by applicable law, DIG may use submitted contact information to provide future:

Credit-repair education;
Credit-building information;
Credit tips;
Financial-education materials;
Credit-report information;
Educational newsletters;
Future promotions;
Future giveaways;
Special offers;
Information regarding DIG programs or services;
Educational events;
Webinars;
Company announcements; and
Other DIG-related information.

Where separate affirmative consent is legally required for a particular communication method, such as certain promotional text messages or automated calls, DIG will seek that consent separately.

Individuals may opt out of promotional communications as described in this Privacy Policy.

10. EMAIL COMMUNICATIONS

DIG may use an email address provided by an individual for:

Requested communications;
Contest administration;
Customer-service communications;
Account communications;
Educational information;
Credit-related tips;
Newsletters;
Company updates;
Promotional information; and
Other communications permitted by applicable law.

Promotional emails will include an appropriate method for unsubscribing from future promotional email communications.

Unsubscribing from promotional emails does not prevent DIG from sending communications that are reasonably necessary to administer an existing account, service, transaction, contest entry, or other legitimate relationship.

11. TEXT MESSAGES AND TELEPHONE COMMUNICATIONS

DIG may use telephone numbers provided by individuals for legitimate customer-service, contest, appointment, verification, or account-related communications.

Where required by applicable law, DIG will obtain separate affirmative consent before sending certain promotional text messages, automated marketing calls, prerecorded calls, or similar marketing communications.

Individuals who consent to promotional text messages may withdraw that consent using available opt-out methods, including replying STOP where supported.

Message and data rates may apply.

Message frequency may vary.

Choosing not to consent to optional marketing text messages will not, by itself, prevent an individual from entering The Dunigan 5 or negatively affect an otherwise valid contest entry.

12. WE DO NOT SELL PERSONAL INFORMATION

Dunigan Investment Group does not sell personal information for money.

DIG does not rent personal information.

DIG does not trade personal information.

DIG does not provide personal information to unrelated third parties for those parties to create their own independent marketing lists.

DIG does not allow unrelated third parties to purchase access to our customer, applicant, entrant, or program-participant databases.

As of the Effective Date of this Privacy Policy, DIG does not intentionally sell or share personal information for cross-context behavioral advertising as those terms may be defined by applicable state privacy laws.

If DIG's practices materially change in the future, this Privacy Policy will be updated and any notice, choice, or consent required by applicable law will be provided.

13. LIMITED DISCLOSURE TO SERVICE PROVIDERS

Although DIG does not sell or give personal information to unrelated companies for their own purposes, certain businesses may need limited access to information in order to perform services for Dunigan Investment Group.

These companies may include providers of:

Website hosting;
Customer relationship management ("CRM") systems;
Email services;
SMS/text-message services;
Telephone systems;
Secure document storage;
Cloud hosting;
Cybersecurity services;
Data backup;
Appointment scheduling;
Electronic signatures;
Payment processing;
Accounting;
Professional consulting;
Information technology support; and
Similar operational services.

These companies are permitted to access information only as reasonably necessary to provide services to DIG and are not authorized by DIG to use DIG customer information for their own independent marketing purposes.

Where appropriate, DIG expects service providers that handle personal information to maintain appropriate confidentiality and security protections.

14. DISCLOSURES NECESSARY TO PROVIDE CREDIT-RELATED SERVICES

When an individual authorizes DIG to provide credit-related services, information may need to be communicated to or received from organizations involved in the consumer credit-reporting process.

Depending upon the service being performed, this may include:

Consumer reporting agencies;
Credit bureaus;
Creditors;
Collection agencies;
Data furnishers;
Credit-monitoring providers;
Attorneys or professional advisers where authorized;
Government agencies; and
Other organizations reasonably necessary to perform authorized services.

These disclosures are made for the purpose of providing or supporting the services requested by the customer and are not the sale of customer information for unrelated marketing purposes.

15. SMARTCREDIT AND OTHER THIRD-PARTY SERVICES

DIG may work with or rely upon third-party platforms such as SmartCredit to obtain authorized access to credit-report information.

SmartCredit and other independent third-party services maintain their own privacy policies, terms, security practices, and data-handling procedures.

DIG does not control the independent privacy practices of those third parties.

Individuals should review the applicable privacy policies and terms of third-party services before creating or maintaining accounts with them.

16. LEGAL AND SAFETY DISCLOSURES

DIG may disclose information when we reasonably believe disclosure is necessary to:

Comply with federal, state, or local law;
Comply with a subpoena, court order, warrant, or other lawful legal process;
Respond to a lawful request from a government agency;
Investigate suspected fraud;
Prevent identity theft;
Protect the rights, property, security, or safety of DIG;
Protect the safety of customers or other individuals;
Investigate violations of agreements or policies;
Establish, exercise, or defend legal claims; or
Fulfill another legal obligation.

DIG will not voluntarily disclose sensitive personal information to unrelated third parties merely because they request it.

17. BUSINESS TRANSFERS

If Dunigan Investment Group is involved in a merger, acquisition, restructuring, financing transaction, sale of substantially all business assets, or similar legitimate corporate transaction, personal information may be transferred as part of that transaction where permitted by law.

Any successor receiving such information will be expected to handle the information consistently with applicable privacy obligations.

This type of organizational transfer is not intended to constitute the sale of personal information as a standalone consumer-data product.

18. DATA SECURITY

DIG takes the protection of personal information seriously.

We use reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information against:

Unauthorized access;
Unauthorized disclosure;
Loss;
Misuse;
Alteration;
Destruction;
Fraud; and
Other unauthorized activity.

Depending upon the information and systems involved, safeguards may include:

Access controls;
Password protection;
Authentication controls;
Secure storage;
Encryption or protected transmission methods where appropriate;
Restricted employee or contractor access;
Confidentiality requirements;
Secure document-handling procedures;
System monitoring;
Data backups;
Security updates;
Vendor-management procedures; and
Other reasonable security measures.

Access to sensitive personal information should be limited to individuals who have a legitimate business need to access it.

19. NO SECURITY SYSTEM IS ABSOLUTE

Although DIG takes reasonable steps to protect personal information, no website, electronic system, network, database, cloud platform, or transmission method can be guaranteed to be completely secure.

DIG therefore cannot guarantee absolute security.

Individuals should also take reasonable steps to protect their own information, including protecting passwords and avoiding sending sensitive documents through unsecured or public communication channels.

20. SENSITIVE DOCUMENT HANDLING

Documents such as:

Social Security cards;
Government-issued identification;
Utility bills;
Consumer credit reports;
Credit-account documentation; and
Other sensitive personal records

should be submitted only through the secure method designated by Dunigan Investment Group.

Individuals should not publicly post sensitive documents on social media, include them in Dunigan 5 entry videos, or transmit them through unauthorized public channels.

DIG will not intentionally publish Social Security numbers, full financial-account numbers, passwords, SmartCredit passwords, or similar authentication information.

21. DATA MINIMIZATION

DIG seeks to collect and maintain only information that is reasonably useful or necessary for legitimate business, service, legal, verification, security, promotional, or operational purposes.

We do not intentionally collect sensitive personal information merely for the sake of collecting it.

Whenever reasonably possible, DIG will avoid requesting unnecessary sensitive information.

22. DATA RETENTION

DIG may retain personal information for as long as reasonably necessary to:

Administer a contest or promotion;
Provide requested services;
Maintain customer records;
Maintain contest-entry records;
Document consent;
Process communications;
Resolve disputes;
Prevent fraud;
Maintain security;
Enforce agreements;
Comply with legal, tax, accounting, regulatory, or recordkeeping obligations; and
Protect DIG's legitimate business interests.

The amount of time information is retained may vary depending upon the type of information and the reason it was collected.

Sensitive information should not be retained longer than reasonably necessary when there is no continuing legitimate or legal reason to retain it.

When appropriate, information may be securely deleted, destroyed, anonymized, or de-identified.

23. DATA BREACHES AND SECURITY INCIDENTS

If DIG becomes aware of a security incident involving personal information, DIG will investigate and respond as appropriate.

Where notification is required by applicable law, affected individuals and appropriate governmental authorities will be notified in accordance with applicable legal requirements.

DIG may also take reasonable steps to:

Contain the incident;
Investigate what occurred;
Reduce further risk;
Restore system security; and
Prevent similar incidents where reasonably possible.

24. EMPLOYEE AND CONTRACTOR ACCESS

DIG employees, independent contractors, and authorized representatives may access personal information only when such access is reasonably related to their job duties or responsibilities.

Individuals with access to sensitive information are expected to maintain confidentiality and comply with applicable DIG information-security requirements.

Access should be limited to the minimum reasonably necessary for the person's assigned responsibilities.

25. USER PRIVACY RIGHTS

Depending upon an individual's state of residence and the privacy laws applicable to DIG, an individual may have certain rights concerning personal information.

These rights may include the right to request:

Confirmation of whether DIG maintains certain personal information;
Access to personal information;
Correction of inaccurate information;
Deletion of certain information;
Information regarding categories of personal information collected;
Information regarding the purposes for which information is used;
Information concerning categories of third parties to whom information has been disclosed;
A portable copy of certain personal information;
Opt-out of certain uses where applicable;
Limitation of certain uses of sensitive personal information where applicable; and
Appeal of certain privacy-request decisions where required by law.

The availability and scope of these rights depend upon applicable law and may be subject to exceptions.

26. RIGHT TO OPT OUT OF MARKETING

Individuals may opt out of promotional communications at any time using the method appropriate to the communication.

This may include:

Clicking the unsubscribe link within a marketing email;
Replying STOP to promotional text messages where supported;
Following the opt-out instructions contained within a communication; or
Contacting DIG and requesting that promotional communications stop.

Opting out of promotional marketing communications does not necessarily stop communications that are:

Transactional;
Service-related;
Requested by the individual;
Necessary to administer an active account;
Necessary to administer a contest entry;
Legally required; or
Otherwise non-promotional and permitted by law.

27. NO EFFECT ON THE DUNIGAN 5 CONTEST ENTRY

An entrant's decision to:

Decline optional marketing consent;
Unsubscribe from promotional emails;
Opt out of promotional text messages;
Withdraw marketing permission; or
Request that future promotional communications stop

will not invalidate an otherwise valid Dunigan 5 Contest entry.

Opting out of optional marketing communications will not by itself:

Disqualify an entrant;
Reduce an entrant's judging score;
Reduce an entrant's chances of selection;
Cause an otherwise eligible entrant to lose winner status; or
Cause a winner to lose complimentary services if the winner is otherwise complying with the program requirements.

Contest administration communications may still be sent when reasonably necessary to administer an existing entry or winner relationship.

28. PRIVACY REQUEST VERIFICATION

DIG may need to verify the identity of an individual before fulfilling certain privacy requests.

Verification helps prevent unauthorized individuals from gaining access to or deleting another person's information.

Depending upon the nature of the request, DIG may ask for reasonable information necessary to confirm identity.

DIG will not intentionally request more information than reasonably necessary for verification.

29. AUTHORIZED AGENTS

Where applicable law permits an individual to use an authorized agent to submit a privacy request, DIG may require reasonable proof that the agent has authority to act for the individual.

DIG may also take reasonable steps to verify the identity of the individual whose information is the subject of the request.

30. NON-DISCRIMINATION

Where required by applicable law, DIG will not unlawfully discriminate against an individual for exercising a legally protected privacy right.

Exercising a privacy right will not, by itself, result in unlawful denial of services, unlawful penalties, or other prohibited discriminatory treatment.

31. CHILDREN'S PRIVACY

Dunigan Investment Group's credit-related services and promotional programs are intended for adults.

The Dunigan 5 Credit Comeback Giveaway is restricted to individuals age 25 or older.

DIG does not knowingly seek to collect personal information from children under the age of 13 through the Contest.

If DIG becomes aware that personal information from a child was collected inappropriately, we will take reasonable steps to delete or otherwise appropriately address that information.

32. THIRD-PARTY WEBSITES AND LINKS

DIG websites may contain links to websites, platforms, applications, or services operated by third parties.

Examples may include:

SmartCredit;
Social-media platforms;
Payment providers;
Scheduling providers; and
Other external services.

When an individual leaves a DIG website and visits an independent third-party website, that third party's privacy policy and terms apply.

DIG is not responsible for the independent privacy practices of websites or companies that DIG does not own or control.

33. SOCIAL MEDIA

Individuals who interact with DIG through Facebook, Instagram, TikTok, YouTube, or another social-media service should understand that those platforms separately collect and process information under their own privacy policies.

Information voluntarily posted publicly on social media may be visible to other users.

Entrants should never publicly post sensitive identity or financial documentation on social-media pages.

34. CHANGES TO THIS PRIVACY POLICY

DIG may update this Privacy Policy from time to time to reflect:

Changes in our services;
Changes in technology;
Changes in business practices;
Changes in applicable law;
New programs;
Security considerations; or
Other legitimate business reasons.

When material changes are made, the "Last Updated" date at the top of this Privacy Policy will be revised.

Where legally required, additional notice or consent will be provided.

35. PRIVACY POLICY AVAILABILITY

This Privacy Policy should be made reasonably accessible through Dunigan Investment Group websites and landing pages where personal information is collected.

A link labeled substantially:

should be available near forms or other areas in which personal information is submitted.

Where appropriate, the Privacy Policy may also be linked in website footers, Contest forms, customer forms, and other DIG digital properties.

36. CONTACTING DUNIGAN INVESTMENT GROUP ABOUT PRIVACY

Questions, concerns, requests, or complaints concerning this Privacy Policy or DIG's handling of personal information may be submitted to:

Dunigan Investment Group

Through the official contact information or contact form published on the Dunigan Investment Group website.

Individuals submitting privacy requests should clearly state:

"Privacy Request"

in the subject line or beginning of the request when possible.

Please provide sufficient information for DIG to understand and appropriately respond to the request.

DIG may verify identity before providing access to, correcting, or deleting personal information.

37. OUR DATA-PROTECTION PRINCIPLES

Dunigan Investment Group's privacy practices are based upon the following principles:

We collect information for a reason.

We seek to collect information that supports legitimate DIG business, service, security, legal, educational, promotional, or operational purposes.

We do not sell customer information.

DIG does not sell personal information to unrelated third parties as a consumer-data product.

We do not give customer information away for another company's independent marketing.

Customer, entrant, applicant, and program-participant data is not provided to unrelated third parties so those parties can independently solicit DIG customers.

We limit access.

Sensitive personal information should only be accessible to people and service providers who reasonably need it to perform authorized responsibilities.

We protect sensitive information.

DIG uses reasonable safeguards designed to protect sensitive personal and credit-related information.

We respect communication choices.

Individuals may opt out of optional promotional communications through the applicable available methods.

We retain information only as reasonably necessary.

Sensitive information should not be retained indefinitely without a legitimate business, operational, security, legal, or regulatory reason.

We expect our service providers to protect information.

Companies performing services for DIG are expected to appropriately protect personal information they process on our behalf.

38. ACKNOWLEDGMENT

By voluntarily providing information to Dunigan Investment Group, individuals acknowledge that they have had an opportunity to review this Privacy Policy.

Providing information does not waive any privacy right that cannot legally be waived.

Where separate consent is required for a particular use of information, DIG may request that consent separately.

PRIVACY COMMITMENT SUMMARY

DUNIGAN INVESTMENT GROUP DOES NOT SELL, RENT, OR TRADE YOUR PERSONAL INFORMATION.

DIG DOES NOT GIVE YOUR PERSONAL INFORMATION TO UNRELATED COMPANIES FOR THEIR OWN INDEPENDENT MARKETING PURPOSES.

YOUR INFORMATION IS USED FOR LEGITIMATE DUNIGAN INVESTMENT GROUP BUSINESS PURPOSES, INCLUDING PROVIDING SERVICES, ADMINISTERING PROGRAMS, COMMUNICATING WITH YOU, PROVIDING EDUCATIONAL INFORMATION, AND OPERATING OUR BUSINESS.

LIMITED SERVICE PROVIDERS MAY PROCESS INFORMATION ONLY AS NECESSARY TO PROVIDE SERVICES TO DUNIGAN INVESTMENT GROUP.

CREDIT-RELATED INFORMATION MAY BE COMMUNICATED TO CREDIT BUREAUS, CREDITORS, FURNISHERS, OR OTHER AUTHORIZED PARTIES WHEN NECESSARY TO PERFORM SERVICES YOU HAVE REQUESTED.

SENSITIVE DOCUMENTS SUCH AS IDENTIFICATION, SOCIAL SECURITY INFORMATION, UTILITY BILLS, AND CREDIT INFORMATION SHOULD BE SUBMITTED ONLY THROUGH DIG'S DESIGNATED SECURE PROCESS.

THE DUNIGAN 5 ENTRY VIDEOS MAY BE USED IN ACCORDANCE WITH THE SEPARATE MEDIA CONSENT AND OFFICIAL CONTEST RULES.

ENTRANTS WHO ARE NOT SELECTED AS WINNERS MAY STILL RECEIVE FUTURE DIG EDUCATIONAL AND PROMOTIONAL COMMUNICATIONS WHERE PERMITTED BY LAW.

PROMOTIONAL TEXT-MESSAGE OR AUTOMATED-MARKETING CONSENT MAY BE OBTAINED SEPARATELY WHERE REQUIRED.

YOU MAY OPT OUT OF OPTIONAL PROMOTIONAL COMMUNICATIONS.

OPTING OUT OF OPTIONAL MARKETING WILL NOT, BY ITSELF, INVALIDATE AN OTHERWISE VALID DUNIGAN 5 ENTRY.

DUNIGAN INVESTMENT GROUP TAKES REASONABLE STEPS TO PROTECT THE INFORMATION ENTRUSTED TO US.