Privacy Policy

Privacy Policy (Doing business as "850 Boost Club" and "Zilac Development"; collectively, "Zilac", "we", "us", "our") Effective Date: July 6, 2026 1. Scope & Acceptance This Privacy Policy explains how Zilac Development LLC, doing business as "850 Boost Club" and operating my850.ai and the 850 Bureau Blaster platform (collectively, the "Services"), collects, uses, stores, discloses, and otherwise exploits information. BY ACCESSING, REGISTERING FOR, OR USING THE SERVICES, YOU ("you", "your", "User", "Subscriber") ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY AND YOU AFFIRMATIVELY CONSENT TO THE COLLECTION, USE, STORAGE, DISCLOSURE, AND EXPLOITATION OF YOUR INFORMATION AS DESCRIBED BELOW. This Policy is incorporated into, and should be read together with, our Master Terms of Service & Subscription Agreement located at https://my850.ai/terms, including Section 7 (Privacy; Comprehensive Grant of Rights in Your Data, Content & Communications) of that Agreement. If you do not agree to this Policy, do not use the Services. 2. Information We Collect We collect the broadest scope of information reasonably useful to operate, secure, improve, and monetize the Services, including but not limited to: • Identity Data: full legal name, date of birth, Social Security number, driver's license or other government-issued identification (front and back images), signatures, and other identity-verification data. • Contact Data: mailing address, email address(es), and phone number(s). • Financial & Credit Data: credit reports, credit scores, tradelines, balances, payment history, inquiries, collections, charge-offs, and related data from credit bureaus, creditors, or connected credit-monitoring accounts. • Credentials: usernames and passwords for third-party credit-monitoring or bureau accounts you choose to connect, stored encrypted at rest. • Communications & Content: the full content of any email, text/SMS, phone call (including recordings), fax, chat, letter, document, image, upload, or other communication or file you send to, receive from, or exchange with us, our personnel, contractors, mail-houses, or AI/automated systems, including any personal or financial information contained in it. • Payment Data: billing information processed by our third-party payment processors. • Usage & Device Data: IP address, device identifiers, browser type, log files, cookies, pixels, analytics events, and similar technical data collected automatically as you use the Services. • Derived & Aggregated Data: information we generate by analysing, combining, scoring, or de-identifying any of the above. 3. Broad License; How We Use Information By submitting any information or content to us, or by using the Services, you grant Zilac, its affiliates, successors, assigns, representatives, contractors, mail vendors, and AI systems an irrevocable, perpetual, worldwide, royalty-free, fully paid-up, sublicensable, and transferable license to collect, access, record, store, host, copy, reproduce, analyse, process, aggregate, de-identify, create derivative works from, edit, translate, transmit, publish, publicly display, distribute, and otherwise exploit — for any commercial or non-commercial purpose — any data, document, image, communication, or other content you submit to us or that is generated through the Services ("Your Content"), including without limitation to: a. operate, provide, maintain, secure, and improve the Services; b. prepare, generate, sign, and transmit dispute correspondence, letters, filings, and related communications to credit bureaus, creditors, collectors, and regulators on your behalf; c. train, test, fine-tune, and improve artificial-intelligence and machine-learning models and systems, whether operated by us or by third-party vendors, using Your Content, including in de-identified or aggregated form; d. develop new products, features, analytics, benchmarks, and research; e. market, advertise, and promote the Services, including publishing Your Content (or portions of it) as described in Section 4; and f. any other purpose disclosed in our Master Terms of Service. This license survives termination of your account and cannot be revoked except to the extent required by applicable law. 4. Marketing & Public Use of Your Information You expressly authorise us, in our sole discretion, to use your name, likeness, voice, testimonials, success metrics, before/after credit results, and any documents, images, or communications you provide, in marketing, advertising, social media, and promotional materials, without further notice, consent, or compensation to you, except where prohibited by applicable law. If you would prefer we not use your name or likeness in public marketing going forward, you may request removal by contacting us at the address in the "Contact Us" Section; requests are handled at our discretion and do not affect the license granted in Section 3, our internal use of your data, or materials already published or distributed. 5. How We Share Information We share information as follows, and you consent to such sharing: • With credit bureaus, creditors, debt collectors, data furnishers, and regulators, to submit and process disputes, complaints, and related correspondence on your behalf. • With our affiliates, employees, contractors, mail-houses, AI vendors, and other service providers who perform functions on our behalf (hosting, payment processing, identity verification, mailing/fax delivery, analytics, customer support, and similar functions), bound by confidentiality obligations. • With business partners for co-marketing, referral, or affiliate purposes. • In aggregated or de-identified form, which we do not consider personal information, with any third party for any purpose, including analytics, research, and commercial licensing. • As required by law, subpoena, court order, or governmental request, or to protect the rights, property, safety, or interests of Zilac, our users, or the public. • In connection with a merger, acquisition, financing, reorganisation, bankruptcy, or sale of some or all of our assets, subject to this Policy. We do not sell personal information for money to unaffiliated third-party data brokers, but we reserve the right to monetise aggregated, de-identified, and derived data as described above. 6. Data Retention We retain information, including Your Content and the license described in Section 3, for as long as necessary to operate the Services, for our legitimate business, archival, evidentiary, and research purposes, and as required or permitted by law — which in most cases means indefinitely, even after your account is closed. Copies of communications, documents, and correspondence sent on your behalf may be retained permanently as business records. 7. Security; No Liability for Unauthorised Access or Mis-delivery We use commercially reasonable safeguards, including encryption in transit and encryption of designated sensitive data at rest (AES-256-GCM), to protect information. No system is completely secure. If your information is inadvertently sent to, intercepted by, or accessed by an unintended recipient (including through mail, email, fax, or third-party error), or is subject to unauthorised access despite our safeguards, you agree that Zilac bears no liability and you waive all claims arising from such disclosure, to the maximum extent permitted by law. See also Section 20 (Limitation of Liability) of our Master Terms of Service. 8. Your Rights and Choices Depending on your jurisdiction, you may have certain rights regarding your personal information (for example, to request access, correction, or deletion). To the extent required by applicable law, we will honour valid requests submitted to the email address in the "Contact Us" Section. However, exercising these rights does not require us to unwind, recall, or delete Your Content already used, published, or distributed under the license in Sections 3–4, and we may retain and continue processing information as necessary for legal, contractual, security, evidentiary, or legitimate business purposes, or as already reflected in records delivered to bureaus, creditors, or other third parties on your behalf. Closing your account does not revoke licenses already granted. 9. Cookies & Tracking We and our service providers use cookies, pixels, SDKs, and similar technologies to operate the Services, remember preferences, measure usage, and support analytics. By using the Services you consent to this tracking. You may adjust browser settings to limit cookies, but doing so may impair functionality. 10. Third-Party Services & Links The Services may link to, integrate with, or rely on third-party services (credit-monitoring providers, payment processors, bureaus, App Store purchases). Those third parties have their own privacy practices, which are not covered by this Policy, and we are not responsible for them. 11. Children's Privacy The Services are intended for adults 18 years of age and older. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us so we can address it. 12. International Users The Services are operated from the United States. By using the Services, you consent to the transfer, storage, and processing of your information in the United States and any other location we or our service providers operate, which may have different data-protection laws than your jurisdiction. 13. State Privacy Rights (California, Virginia, Colorado, Connecticut, Utah & Similar Laws) This Section supplements the rest of this Policy and applies to residents of U.S. states with comprehensive consumer-privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA") and similar laws in Virginia, Colorado, Connecticut, Utah, and other states as they take effect. Certain financial information we handle is regulated by the Gramm-Leach-Bliley Act ("GLBA") and may be exempt from some state-law rights; where an exemption applies, that information is governed by our financial-privacy practices instead. a. Categories Collected. In the past twelve (12) months we have collected the categories of information described in Section 2, including identifiers, government-identification numbers (such as Social Security and driver's-license numbers), financial and credit information, commercial/transaction information, internet and device activity, audio/electronic communications, and inferences drawn from the foregoing. "Sensitive personal information" we collect includes your Social Security number, driver's-license or state-ID number, account log-in credentials, and financial/credit information. b. Purposes & Sources. We collect this information from you, from your devices, and from third parties such as credit bureaus and credit-monitoring providers, and we use it for the business and commercial purposes described in Sections 3–5. c. Sale/Sharing. We do not "sell" your personal information for money to unaffiliated data brokers, and we do not "share" it for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. We may disclose personal information to service providers and for the business purposes described in this Policy, and we may use and monetize aggregated or de-identified data as described in Sections 3–5. d. Use of Sensitive Information. We use sensitive personal information only to provide the Services you request, to verify identity, to prepare and transmit disputes and filings, to prevent fraud and secure our systems, and for other purposes permitted without a right to limit under applicable law. e. Your Rights. Subject to verification and to the exemptions and limits described in this Policy and in applicable law, you may have the right to: (i) know and access the personal information we hold about you; (ii) request correction of inaccurate information; (iii) request deletion of your information; (iv) obtain a portable copy; (v) opt out of any "sale" or "sharing" (to the extent it occurs) and of certain profiling; and (vi) not be discriminated or retaliated against for exercising these rights. f. How to Exercise Rights; Appeals. Submit requests to the email address in the "Contact Us" Section, or through any request mechanism we designate. We will verify your identity before responding and will respond within the timeframes required by applicable law. You may use an authorized agent where the law permits. If we deny your request, you may appeal by replying to our decision; where required, we will explain how to contact your state Attorney General. g. Limits. As permitted by the CCPA/CPRA and other applicable laws, we may decline or limit a request where an exemption applies (including GLBA-regulated data), where the information is necessary for security, legal, evidentiary, or legitimate business purposes, or where the request would require us to unwind Content already used, published, transmitted to third parties, or licensed under Sections 3–5 of this Policy or our Master Terms of Service. 14. Data Breach Notification We maintain administrative, technical, and physical safeguards designed to protect Personal Information. In the event we determine that a breach of security affecting your Personal Information has occurred, we will notify affected users and applicable regulators as, and within the timeframes, required by applicable federal and state data-breach-notification laws. Where the law permits, notice may be provided by email, through the Services, or by other reasonable means. Nothing in this Section limits the disclaimers, waivers, or limitations of liability set forth in Section 7 of this Policy or in our Master Terms of Service. 15. Service Providers, Subprocessors & AI Vendors We engage third-party service providers and subprocessors to perform functions on our behalf, and we may disclose Personal Information to them for those purposes. Categories of such providers include, without limitation: cloud hosting and database providers; payment processors; identity-verification vendors; mail, fax, and email delivery providers; credit bureaus and credit-monitoring integrations; analytics and error-monitoring providers; communications/SMS providers; and artificial-intelligence and machine-learning model providers used to power chat, analysis, document generation, and Service improvement. These providers are permitted to process Personal Information only to perform services for us and are bound by contractual confidentiality and data-protection obligations. We may add, remove, or replace providers from time to time; upon written request to the email address in the "Contact Us" Section, we will provide a current list of the material categories of subprocessors then in use. Our use of AI vendors and model training is further described in Section 3. 16. Changes to This Policy We may amend this Privacy Policy at any time, in our sole discretion, effective immediately upon posting to the Services. Continued use of the Services after changes are posted constitutes your acceptance of the revised Policy. 17. Relationship to Terms of Service This Policy is incorporated into and forms part of our Master Terms of Service & Subscription Agreement. In the event of any conflict, whichever provision grants Zilac greater rights or lesser liability shall control, to the maximum extent permitted by law. 18. Governing Law; Dispute Resolution This Policy is governed by the laws of the State of Texas. Any dispute relating to this Policy is subject to the binding arbitration, venue, and governing-law provisions of our Master Terms of Service. 19. Contact Us Questions about this Privacy Policy or our data practices may be directed to: Zilac Development LLC (d/b/a "850 Boost Club") Email: support@my850.ai Website: https://my850.ai BY USING THE SERVICES, YOU CERTIFY THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY, INCLUDING THE IRREVOCABLE, BROAD LICENSE GRANTED TO ZILAC TO COLLECT, USE, PUBLISH, AND EXPLOIT YOUR INFORMATION AND CONTENT AS DESCRIBED ABOVE.