Effective Date: January 1, 2020
This policy describes: (i) The types of information we collect when you use our service; (ii) How we use, share, and protect that information; (iii) How long we retain that information; and (iv) Your rights and options regarding the information we collect.
1. Information We Collect. We collect two different classes of information from you.
a. The first is Personally Identifiable Information (PII) which pertains to you as an individual. We will collect PII from you only if you choose to complete an application on our website or over the phone with one of our agents.We may also obtain PII about you via the Internet, or from third parties, such as contractors or credit reporting agencies. As of this date, we collect the following information when you complete an application on our site or over the telephone:
- Your name, postal address, email address, and telephone number;
- Your Social Security number;
- Your financial information, including your income;
- Your employment status; and
- Such other elements of PII submitted by you or provided by third parties.
Following the submission of your online application, we may also collect additional information required by participating Lenders over the phone.
In addition, when you visit our website, we will record your computer IP address or mobile device number, and may tie it to your specific account. Under ordinary circumstances, an IP address or mobile device number recorded in isolation is not PII under the standard definition of the term. However, it may become PII when it is combined with other information, as in this case.
b. General Information: General Information consists of information that is anonymous in nature and does not identify you as an individual. General Information of this nature is collected through a small piece of computer code called a “cookie,” and includes your computer IP address, unique mobile device identifier, browser type, ISP or carrier name, the URL of the last webpage you visited before visiting our website, and actions you undertake on our site whenever you visit. This information gives us insights on how our users use our site and our services.
We also obtain clickstream data using these automated collection methods, which is a log of content on which you click while browsing. As you click through our Site, a record of your actions may be collected and stored. Clickstream data also can tell us the type of computer and browsing software you use, the address of the website from which you linked to our Site, and the pages you access on our Site. Your clickstream data may allow us to narrow or limit the advertising materials provided to you based on your prior online activities or preferences.
3. How We Use Information. We use your PII and other information to provide you with our service, or as otherwise directed by you. We may also use your PII in the following ways:
- To facilitate your application;
- To verify documents;
- To send you email messages about your application and other matters that we believe may be of interest to you, including offers for third party products and services;
- For internal business purposes, such as market research, site analysis, etc.; and
- To comply with applicable legal requirements, protect our legal rights, and to enforce our Terms of Service
We use the information we collect through cookies and your clickstream data to improve our site’s features, to customize your visits, to determine which of our site’s pages you access, to narrow or limit the advertising materials provided to you based on your prior online activities.
Note that we may also choose to anonymize certain elements of the PII you provide to us so that it can no longer be attributed to you. We will use PII that we render anonymous in the same manner as we use General Information.
3. How We Share Information. We share PII and General Information as follows:
a. Employees and Contractors: We share your PII with those employees and contractors that must have access to it in order to perform their functions.
b. Participating Lenders: We share your PII with participating Lenders. It is important to note that Lenders are not affiliated with us, and handle their own customer service and billing functions, and may use your information in accordance with their own privacy policies, which we encourage you to review.
c. Service Providers: We also share PII and General Information with nonaffiliated third parties that perform services or functions on our behalf, including cloud storage and web hosting providers, email service providers, and software maintenance service providers. We must necessarily share your information with such third parties as may be required to perform their functions, but only to the extent necessary for them to do so. As of the effective date of this policy, we share PII with the following service providers:
d. Legal Requests: If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have collected from you. We also may disclose your information to exercise or protect our legal rights or to defend against legal claims.
e. Other: In some cases, we may choose to buy or sell assets. In these business transfers, customer information is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used as set forth in this policy.
4. How We Protect Information. We take the security of your information seriously and use appropriate technical and organizational measures to protect PII against unauthorized or unlawful processing and against accidental loss, destruction or damage. Our website and the server(s) upon which our data is stored is hosted using 256-bit Secure Socket Layering (SSL) to encrypt all elements of PII, PGP email encryption, password protection and CAPTCHA. This website also uses a generally accepted standard of technological security for the purpose of protecting all information provided by visitors from misuse, loss, or corruption. We also limit access to PII to those employees and contractors who reasonably need access to it to deliver our service.
However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you. In addition, we have no control over the security of other web sites on the Internet that you might visit even when a link may appear to those web sites site from our Site. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. If there is a breach of security, then we may either post a notice through the service or attempt to notify you via email so that you can take reasonable protective steps.
5. How Long We Keep Information. We reserve the right to retain your information for as long as we deem necessary to fulfill a business purpose or comply with a legal request, and may anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.
6. Your Rights and Control. You may limit how we use your PII as follows: (i) You may elect not to have a unique cookie identification number assigned to your computer to avoid aggregation and analysis of data collected on our Site by configuring your browser; and (ii) You may stop receiving commercial emails from us by clicking the “unsubscribe” link at the bottom of the email (this will not prevent or interfere with us sending you non-marketing transactional communications).
8. Tracking Technology and Do-Not-Track Requests. We do not currently employ any technology that enables us to track your online activities over time and across third-party Web sites, nor do we plan on doing so in the future. Keep in mind, however, that we have no control over the activities of third parties, and they may employ such technology that tracks your activity on this site. Because we do not employ tracking technology, we offer no response to Do-Not-Track requests transmitted by Web browsers.
9. Children under 13. Our service is not intended for users under the age of 13, and we do not knowingly collect any information from children under 13, except any Third Party Information you provide to us. If we are informed that you have provided us with the information of anyone under the age of 13 in a manner that violates any statute or regulation concerning the same, we will attempt to delete it as soon as possible.
10. For Residents of Certain States.
a. California: The California Consumer Privacy Act (CCPA) grants residents of California (“California Users”) certain rights regarding PII collected or obtained by companies covered by the CCPA. As of the effective date of this Policy, our company does not fall within the statutory definition of businesses covered by the CCPA, and we are not required to comply with the disclosure and deletion requirements under the law.
However, under the California Online Privacy Protection Act, California Users may request information regarding the types of personal information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. California Users may request further information about our compliance with this law by sending us a message via the Contact Us link on the Site.
Please note that we are only required to respond to one request per customer each year concerning this law, and we are not required to respond to requests made by means other than through the Contact page on our website
b. Other States: Certain states have specific requirements regarding the disclosure and protection of certain customer and personal information. For more information please follow these links: