Purpose

This Data Use & Non‑FCRA Policy (“Policy”) governs the access to, use of, and reliance upon data, information, records, reports, and search results made available through the services of United Software Developers Inc., doing business as USD GoPay (the “Company”).

This Policy is incorporated by reference into the Company’s Terms and Conditions, Acceptable Use Policy, and related agreements.

Historical Services and Policy Updates

The Company has provided data‑enabled software platforms, search tools, and administrative services for many years prior to the Effective Date of this Policy.

This Policy represents a consolidated and updated statement governing data use and applies to all continued and future access to data‑related services as of the Effective Date, regardless of when you first began using any Company services.

Continued use of data‑related services on or after the Effective Date constitutes acceptance of this Policy.

Scope of Data Covered

This Policy applies to all data accessed, retrieved, displayed, transmitted, or made available through the Services, including but not limited to:

• Driving record information
• License‑related or motor vehicle data
• Property‑related data
• Business, administrative, or operational data
• Aggregated, derived, or third‑party sourced informational data

The Company does not generate original government or authoritative records and does not control the source systems supplying such data.

Informational and Administrative Use Only

All data made available through the Services is provided solely for informational and administrative purposes.

You acknowledge and agree that:

• Data may be incomplete, outdated, or inaccurate
• Data is not guaranteed to reflect real‑time status
• Independent verification through authoritative sources is required before taking action

You assume all responsibility for decisions or actions taken based on data obtained through the Services.

Non‑FCRA Positioning and Disclaimer

No Consumer Reporting Agency

United Software Developers Inc. and USD GoPay do not operate as a “consumer reporting agency” as defined by the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. §1681 et seq.

The Services do not provide “consumer reports” under the FCRA.

Prohibited FCRA‑Regulated Uses

You may not use any data obtained through the Services, either in whole or in part, for purposes governed by the FCRA, including but not limited to:

• Employment decisions or background screening
• Tenant or housing screening
• Credit, lending, or financing determinations
• Insurance underwriting, eligibility, or premium decisions
• Licensing or benefit eligibility determinations

Use of the Services for any FCRA‑regulated purpose is strictly prohibited unless expressly authorized by the Company in a separate written agreement.

No Sole‑Source Decision Use

You agree that data obtained through the Services will not be used as the sole or determinative basis for any:

• Legal decision
• Regulatory decision
• Eligibility determination
• Adverse action

The Company disclaims responsibility for downstream decisions made by users.

User Obligations and Compliance

You are solely responsible for:

• Ensuring lawful use of data
• Ensuring compliance with all applicable laws and regulations
• Maintaining appropriate verification, audit, and review processes

You represent and warrant that you will not use the Services or any data obtained through them in violation of this Policy.

Data Sources and Third‑Party Providers

Data provided through the Services may originate from third‑party sources, aggregators, or public records.

The Company does not guarantee:

• Accuracy
• Completeness
• Timeliness
• Availability of any data

Third‑party providers may change, suspend, or restrict data sources at any time.

No Monitoring of Decision‑Making

The Company does not monitor, control, or audit how customers ultimately use data obtained through the Services beyond contractual restrictions.

You are solely responsible for downstream usage and compliance.

Suspension and Termination

The Company reserves the right to:

• Suspend or terminate access to data services
• Restrict availability of certain datasets
• Investigate suspected violations of this Policy

Violations may result in immediate suspension or permanent termination without notice.

Indemnification

You agree to indemnify, defend, and hold harmless the Company from any claims, damages, penalties, fines, or liabilities arising from:

• Improper or unlawful use of data
• Use of data for prohibited FCRA‑regulated purposes
• Reliance on data without independent verification
• Violations of this Policy or applicable law

Relationship to Other Policies

This Policy supplements the Company’s:

• Terms and Conditions
• Privacy Policy
• Acceptable Use Policy
• Merchant Services Agreement (where applicable)

In the event of a conflict, the Terms and Conditions control.

Changes to This Data Use & Non‑FCRA Policy

The Company may update this Policy from time to time. Updates will be posted with a revised “Last Updated” date.

Continued use of data‑related Services constitutes acceptance of any updated version.