PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT EXPLAINS WHAT INFORMATION WE COLLECT, HOW WE USE AND SHARE IT, AND THE CHOICES AVAILABLE TO YOU, INCLUDING RIGHTS THAT MAY APPLY UNDER STATE PRIVACY LAW AND THE FAIR CREDIT REPORTING ACT.

Privacy Policy – Summary

This summary is provided for your convenience. The full Privacy Policy below is the legally binding version, and if there is any difference between this summary and the full policy, the full policy controls.

TopFundings.com (the “Site”) is operated by Kolmind Ltd., an Israeli company, doing business as TopFundings (“TopFundings,” “we,” “us,” or “our”). We help you compare and connect with third-party lenders, brokers, platforms, and service providers (“Partners”) for mortgage, debt-relief, and related financial products.

When you submit a Match Request, we collect information you provide (such as your name, contact details, and financial information) and share it with Partners so they can contact you with offers. Some Site experiences also use a credit-informed matching feature: a third-party technology provider, Array US, Inc. (“Array”), performs a soft credit inquiry that does not affect your credit score, after you provide separate written instructions through a dedicated Credit Authorization Agreement. Array does not send us your full consumer report – it returns only a pre-configured set of matching outputs. Section 5 below explains your rights under the Fair Credit Reporting Act and how to dispute information on your consumer report.

We also automatically collect technical and usage information (such as device and log data, and cookies) when you visit the Site, and we share certain information with advertising and analytics partners, including Google, Microsoft, and Meta, to measure and improve our marketing.

We do not sell your information for money. Depending on your state of residence, you may have rights to access, delete, or opt out of certain sharing of your information, including sharing that some state laws classify as a “sale” or “share” or use for targeted advertising. See Section 8 below for details on how to exercise these rights.

We encourage you to read the full Privacy Policy below, which explains our practices in more detail.

Privacy Policy

Last Updated: August 17, 2026

This Privacy Policy (“Privacy Policy”) describes the data collection practices of Kolmind Ltd. and its wholly owned U.S. subsidiary, Kolmind Insurance Services Inc. (together, “TopFundings,” “we,” “us,” or “our”) in connection with TopFundings.com (together with its subdomains, landing pages, forms, comparison tools, and related services, the “Site”), and in connection with your use of or engagement with any feature, content, offer, or service we make available to you via the Site (the “Services”).

We may change this Privacy Policy at any time. We will post the updated version on the Site, and the “Last Updated” date above will reflect the effective date of the update. If you access or use the Site after that date, you accept the updated Privacy Policy. If we make a material change, we will provide more prominent notice, such as a notice posted on the Site at least seven (7) days before the change becomes effective.

1. Terms of Use and Key Terms

This Privacy Policy forms part of TopFundings’ Terms of Use (the “Terms”) and should be read together with them. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Terms.

“Personal Information” means information that identifies, relates to, or could reasonably be linked with you, such as your name, email address, phone number, postal address, date of birth, or financial information. Depending on how we use it and the law that applies to you, this may also include your IP address and other online identifiers.

You are not required to provide us with Personal Information, and you are not required to use the Site. By using the Site and engaging with the Services, you consent to this Privacy Policy. If you do not agree, please do not access or use the Site.

Our processing of Personal Information is generally based on one or more of: your consent (for example, when you submit a Match Request or a Credit Authorization); performance of a request you made (for example, connecting you with Partners); our legitimate business interests (for example, improving the Site or preventing fraud); and compliance with legal obligations.

2. Information We Collect

2.1 Information You Provide to Us

Match Requests. Some Site features let you submit information to receive a recommendation, comparison, or introduction to one or more Partners (a “Match Request”). This may include your name, contact information, and financial information relevant to the product category you selected (for example, income, loan amount, or debt information). Information you submit through a Match Request is shared with the relevant Partners as described in Section 4 below.

Credit Authorization. Certain Site experiences offer a credit-informed matching feature. If you affirmatively click “Agree and Find My Rates” after being shown a separate Credit Authorization Agreement, Array US, Inc. (“Array”), a third-party technology provider, performs a soft credit inquiry – not a hard inquiry – that does not affect your credit score. Array pulls the full consumer report from Equifax on the backend, but does not send TopFundings your full report or credit score. Instead, Array returns to us only a pre-configured set of matching outputs used to evaluate eligibility and display results. See Section 5 below and our Credit Authorization Agreement for the full description of this feature.

Contact Us. If you contact us – for example, by email or through a form – you may provide your name, email address, and the content of your message.

Newsletters and Blog. If the Site offers a newsletter, blog, or similar content, subscribing or interacting with it may require your name and email address.

2.2 Information We Collect Automatically

Device and Usage Information. When you use the Site, we automatically collect information such as your device type, operating system, browser type and version, screen resolution, language settings, approximate location (derived from IP address), the pages you view, the time and date of your visit, time spent on pages, and the site from which you arrived and the one to which you are directed.

Log Data. Our servers automatically record information (“Log Data”) that your browser sends whenever you visit the Site, including your IP address. We use IP address information for a limited time and for limited purposes: to approximate your geographic location, to help detect and prevent fraudulent activity, and to help evidence consents you have given us.

Cookies and Similar Technologies. The Site uses cookies and similar tracking technologies (such as pixels and tags) placed by us or by third-party service providers, to recognize your browser, remember preferences, and measure how the Site is used. You can set your browser to refuse cookies or to alert you when a cookie is sent; some Site features may not work properly without cookies.

Advertising Identifiers. We may collect identifiers such as Google Click ID (GCLID) or comparable identifiers from Microsoft and Meta, to measure the effectiveness of our advertising campaigns. These identifiers are used for performance-tracking and analytics purposes.

2.3 Information We Receive from Partners and Service Providers

We may receive information from Partners and service providers, such as an internal identifier our systems generate for you, confirmation of whether you applied for or received a product from a Partner, and a summary of actions you took (for example, a click, a form submission, or a call).

3. How We Use Information

We use the information we collect to:

• operate, provide, and improve the Site and the Services;
• evaluate your Match Request and connect you with relevant Partners;
• process the credit-informed matching feature through Array, where you have provided the separate Credit Authorization Agreement;
• communicate with you, including responding to inquiries and sending non-marketing communications reasonably necessary to complete a Site interaction;
• send you marketing communications where you have provided the separate consent required under our Terms of Use, Section 7;
• measure, analyze, and improve our advertising and marketing performance;
• detect, prevent, and investigate fraud, misuse, and security incidents; and
• comply with applicable law and enforce our Terms of Use.

4. Sharing Your Information with Third Parties

We do not sell your Personal Information for money. We share Personal Information only in the following circumstances:

4.1 Partners

When you submit a Match Request, we share the information you provided with the Partner(s) selected to match your request, so that they can contact you about their products and services. Partners use information according to their own privacy policies as well as this one. You acknowledge that we do not control how a Partner uses your information once shared, or the content of their communications with you.

4.2 Array (Credit-Informed Matching)

If you use the credit-informed matching feature, Array obtains your consumer report from Equifax under your written instructions, and returns a pre-configured matching output to us – not your full report or score. Per our agreement with Array: Array retains the underlying data for two (2) years; we may retain the matching output we receive for no more than thirty (30) days, after which a fresh inquiry is required for that data to be used again; and only Array, TopFundings, and you have access to this data – it is not shared with Partners or any other party. Section 5 below describes your rights regarding this consumer report information in more detail.

4.3 Advertising and Analytics Partners

We work with advertising platforms, including Google, Microsoft Advertising, and Meta, to run and measure our marketing campaigns. We may share hashed or pseudonymized identifiers and interaction data (such as pixel, tag, or conversion-API events) with these platforms for attribution, analytics, and campaign optimization. These platforms may combine this information with data they collect independently and process it under their own privacy policies.

4.4 Service Providers

We use third-party service providers that help us operate the Site and our business. We use Amazon Web Services (AWS) and Microsoft Azure for cloud hosting and data storage, and we use additional service providers for functions such as customer support tools and email delivery. These providers are permitted to use your information only to perform services on our behalf and are contractually restricted from using it for their own purposes.

4.5 Affiliates

We may share information with companies under common ownership or control with TopFundings.

4.6 Legal and Safety

We may disclose information where we believe in good faith that disclosure is necessary to: comply with applicable law, regulation, legal process, or governmental request; enforce our Terms of Use; detect, prevent, or address fraud or security issues; or protect the rights, property, or safety of TopFundings, our users, or the public.

4.7 Business Transfers

If TopFundings or its parent is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, your information may be transferred as part of that transaction, subject to standard confidentiality arrangements.

5. Consumer Reports and Your FCRA Rights

5.1 Our Use of Consumer Reports

If you use our credit-informed matching feature, Array US, Inc. (“Array”), a third-party technology provider acting in connection with TopFundings, obtains a consumer report about you from Equifax under your written instructions, for the purpose of evaluating your eligibility and matching you with relevant Partner offers. This is a soft inquiry and does not affect your credit score. Array does not send TopFundings your full consumer report or credit score – Array returns to us only a limited, pre-configured set of matching results. See our Credit Authorization Agreement for the full description of this feature.

5.2 Your Rights Under the Fair Credit Reporting Act

The Fair Credit Reporting Act (FCRA) gives you specific rights regarding consumer reports, including the right to: know what information is in your consumer report file; dispute incomplete or inaccurate information with the consumer reporting agency and have it investigated, corrected, or deleted if it cannot be verified; have accurate negative information removed from your file after a set period of time; limit access to your file to those with a permissible purpose recognized by the FCRA; opt out of certain prescreened credit and insurance offers; and seek damages from parties who violate the FCRA. These rights exist under federal law and are not created, limited, or waived by your use of the Site.

5.3 How to Dispute Information on Your Consumer Report

If you believe information used in our credit-informed matching feature is inaccurate, you have two options, which you may pursue separately or together:

• Contact us first at support@spotower.com, and we will escalate your concern to Array, which will advise whether it can be resolved directly or should be directed to the applicable consumer reporting agency; or
• Dispute the information directly with Equifax, the consumer reporting agency that furnished the report, at https://www.equifax.com/personal/credit-report-services/credit-dispute/.

A consumer reporting agency that receives a dispute is generally required to investigate it, typically within 30 days, and to correct or delete information found to be inaccurate, incomplete, or unverifiable. TopFundings is not a consumer reporting agency, does not prepare consumer reports, and cannot directly correct your credit report.

5.4 Security and Retention of Consumer Report Information

Array retains the consumer report information it obtains for two (2) years. We may retain the matching output we receive from Array for no more than thirty (30) days, after which a new inquiry is required before that data can be used again. Only Array, TopFundings, and you have access to this information – it is not shared with Partners or any other party. See Section 7 below for our general data security practices.

6. Links to Other Websites

The Site may link to or display websites, content, and services operated by Partners or other third parties. This Privacy Policy does not apply to those third-party properties, and we are not responsible for their privacy practices. We encourage you to review the privacy policy of any third-party website before providing it with information.

7. Data Security and Retention

We use commercially reasonable administrative, technical, and physical safeguards designed to protect the Personal Information we collect. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Consumer report information follows the specific retention terms described in Section 5.4 above.

8. Your Choices and Privacy Rights

8.1 Cookies

You can set your browser to refuse some or all cookies, or to alert you when a cookie is being set. If you disable cookies, some features of the Site may not function properly.

8.2 Marketing Communications

You may opt out of TopFundings marketing text messages at any time by replying STOP, and request help by replying HELP, consistent with our Terms of Use, Section 7. To stop marketing communications from a Partner, you may need to contact that Partner directly.

8.3 GLBA Opt-Out (Nonpublic Personal Information)

Our data collection and sharing practices comply with the Gramm-Leach-Bliley Act (GLBA) to the extent it applies to our activities. You have the right to direct us not to share nonpublic personal financial information with nonaffiliated third parties, except as permitted by law (for example, sharing needed to complete the Match Request you asked for, or sharing with our own service providers). Vermont residents: we will not share your nonpublic personal information with unaffiliated third parties without your consent, except as permitted by law, and we will not share credit scores with our affiliates. To exercise this right, contact us using the information in Section 11 below.

8.4 State Privacy Rights

Depending on your state of residence, you may have additional rights regarding your Personal Information, which may include the right to: know what Personal Information we have collected, used, or disclosed about you; request deletion of your Personal Information, subject to certain exceptions (such as fraud prevention, debugging, or legal compliance); correct inaccurate Personal Information; and opt out of certain sharing of your Personal Information that applicable law classifies as a “sale,” a “share,” or use for targeted or cross-context behavioral advertising – including sharing through cookies, pixels, and advertising technologies described in Section 4.3 above.

We will not discriminate against you for exercising these rights, including by denying goods or services, charging different prices, or providing a different level or quality of service.

To exercise these rights, contact us using the information in Section 11 below. We aim to respond to a verifiable request within forty-five (45) days; if more time is needed (up to another 45 days), we will notify you of the reason and extension. We may need to verify your identity before completing certain requests.

8.5 Do Not Track

Some browsers offer a “Do Not Track” (DNT) signal. We do not currently respond to DNT signals.

9. Children’s Privacy

The Site and Services are not directed to, and are not intended for use by, anyone under the age of 18, consistent with the eligibility requirement in our Terms of Use. We do not knowingly collect Personal Information from anyone under 18. If we learn that we have collected Personal Information from someone under 18, we will take reasonable steps to delete it. If you believe a minor has provided us with Personal Information, please contact us using the information in Section 11 below.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on the Site with a revised “Last Updated” date. Changes are effective when posted, unless we state a later date or applicable law requires additional notice. For material changes, we will provide at least seven (7) days’ advance notice by posting a notification on the Site. Your continued use of the Site after a change becomes effective constitutes your acceptance of the updated Privacy Policy.

11. Contact Us

TopFundings is a trading name operated by Kolmind Ltd., Israeli company number 516266269. Kolmind Insurance Services Inc. is a wholly owned U.S. subsidiary of Kolmind Ltd. and serves as TopFundings’ U.S. mailing contact.

Email: support@spotower.com

U.S. mailing address: c/o Kolmind Insurance Services Inc., 715 Roslyn Rd, Newport News, VA 23601