FCRA Disclosures

This page provides disclosures required under the federal Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.) and related state consumer credit reporting laws. Torque.ai Incorporated, a Delaware corporation operating as RunTorque (“we,” “us,” or “our”), is a “user of consumer reports” as defined by the FCRA.

1. Why We Access Your Credit Information

When you submit a credit application through the RunTorque platform, we may obtain a consumer report (a “credit report”) about you from one or more consumer reporting agencies. We access this information for the permissible purpose of evaluating your application for credit and routing it to participating Lenders, as authorized by 15 U.S.C. § 1681b(a)(3)(A) — credit transactions initiated by the consumer.

2. Soft Inquiries vs. Hard Inquiries

RunTorque distinguishes between two types of inquiries:

• Soft inquiries are used for pre-qualification and lender matching. Soft inquiries do not affect your credit score. Multiple Lenders in our network may evaluate your application using the soft inquiry data without each generating a separate inquiry.
• Hard inquiries are used only after you have selected a specific offer and consented separately to a hard inquiry. Hard inquiries may have a temporary impact on your credit score.

3. Your Consent

Before each inquiry, we present you with a clear disclosure and obtain your affirmative consent. We retain a cryptographic hash of the disclosure language you agreed to, along with the version, IP address, and timestamp, so that we can demonstrate later exactly what you authorized.

4. Adverse Action Notices

If a Lender declines your application, or extends credit on terms materially less favorable than you requested, federal law (FCRA § 615 and ECOA / Regulation B § 1002.9) requires that you receive a written notice. RunTorque generates and delivers these notices on behalf of the Lender within thirty (30) days of the adverse decision. The notice will include:

• The principal reasons for the adverse action
• The credit score used in the decision and the score range, if applicable
• The name, address, telephone number, and website of the consumer reporting agency whose information was used
• A statement that the consumer reporting agency did not make the decision and cannot give you the specific reasons
• Notice of your right to obtain a free copy of your consumer report from the consumer reporting agency within 60 days
• Notice of your right to dispute the accuracy or completeness of any information furnished by the consumer reporting agency
• The notice required by the Equal Credit Opportunity Act

5. Risk-Based Pricing Notices

Where applicable, we provide risk-based pricing notices in accordance with Regulation V § 1022.72. These notices inform you when the terms of credit offered are materially less favorable than those offered to other consumers with the same Lender.

6. Consumer Reporting Agency Contact Information

Experian

P.O. Box 4500, Allen, TX 75013
1-888-397-3742
experian.com

Equifax

P.O. Box 740241, Atlanta, GA 30374
1-800-685-1111
equifax.com

TransUnion

P.O. Box 2000, Chester, PA 19016
1-800-916-8800
transunion.com

7. Your Rights Under the FCRA

Federal law gives you significant rights related to consumer reports. A summary of those rights is available from the Consumer Financial Protection Bureau at consumerfinance.gov. In summary, you have the right to:

• Know what is in your file and who has accessed it
• Obtain a free copy of your credit report annually from each major consumer reporting agency at annualcreditreport.com
• Dispute incomplete or inaccurate information
• Have outdated information removed from your file
• Limit “prescreened” offers of credit and insurance based on information in your credit report
• Place a security freeze on your file
• Seek damages from violators of the FCRA

8. Your Rights Under the Equal Credit Opportunity Act

The federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding contract), because all or part of the applicant’s income derives from any public assistance program, or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The federal agency that administers compliance with this law concerning this creditor is:

Federal Trade Commission
Equal Credit Opportunity
Washington, D.C. 20580

9. Contact Us

For questions about how we use consumer reports, or to exercise your rights, contact:

Compliance Officer
Torque.ai Incorporated
800 N. King Street, Suite 304
Wilmington, DE 19801
compliance@runtorque.ai