The State of California requires that we provide privacy information for individuals that are residents of California. If you are not a resident California, you can disregard this document.
1. PERSONAL INFORMATION WE COLLECT
1. Personal Information Does Not Include
2. How We Obtain Your Personal Information
3. How We Use Your Personal Information
4. Who We Share Your Personal Information with for a Business or Commercial Purpose
5. Categories of Personal Information Collected
6. Sale of Personal Information
1. PERSONAL INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”).
1. Personal Information Does Not Include:
• Publicly available information from government records
• De-identified or aggregated consumer information
• Information excluded from the CCPA, including:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).
2. How We Obtain Your Personal Information:
|Directly from you||You enter or provide us with information in person, online, in our mobile application, by email, by phone, or by document upload
For example, when you apply for a loan, make a wire transfer, cash a check, show us your government issued ID, or pay your bills
|Directly and indirectly from you based on activity on our website||For example, from submissions through our website or mobile application or website or mobile application usage details collected automatically|
|From vendors or third parties that interact with us in connection with the products and services we provide||For example, credit reporting agencies, banking institutions or other vendors that provide data we use in underwriting or that assist us in verifying your identity and information you provide to us or in protecting you and our products from fraud and identity theft|
3. How We Use Your Personal Information:
We may use or disclose the personal information we collect for one or more of the following business and commercial purposes:
1. Performing services on behalf of us or our service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of us or our service providers. This includes:
• to fulfill or meet the reason for which the information is provided;
• to provide you with information, products, or services that you request from us;
• to provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you; and
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
2. Undertaking internal research for technological development and demonstration
3. Debugging to identify and repair errors that impair existing intended functionality
4. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
5. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
6. Undertaking activities to verify or maintain the quality or safety or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
In addition to the business purposes above, we also use your personal data to comply with our legal or regulatory obligations and for short-term, transient use, including disclosing such personal information to third parties to build a profile about you or to otherwise alter your online experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. Who We Share Your Personal Information with for a Business or Commercial Purpose:
We may disclose your personal information to a service provider, vendor or third party for a business or commercial purpose. When we disclose personal information for a business or commercial purpose, we enter into a contract that describes the purpose and requires the service provider, vendor or third party to both keep that personal information confidential and not use it for any purpose except performing the services described in the contract. Examples of who we share with include:
• Our affiliates, lenders and banks.
• Vendors and service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products and services we provide to you.
5. Categories of Personal Information Collected:
Within the last 12 months, we collected the categories of personal information listed below and shared it as follows:
|CATEGORY||EXAMPLES||COLLECTED (Yes/No)||SOURCES OF COLLECTED PERSONAL INFORMATION||BUSINESS OR COMMERCIAL PURPOSE FOR SHARING (Section 1.3 #1-6 above)||CATEGORY OF THIRD PARTIES|
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, social security number, driver’s license number, passport number, or other similar identifiers.||YES||You, your activity on our site, or from vendors, service providers, and third parties||YES, for uses 1-6 set forth in Section 1.3 above||Our lenders, banks, service providers, and third parties|
|B. Personal Information||A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, vehicle identification number, license plate number, title number, other vehicle related information, education, employment, employment history, bankruptcy status, bank account number, credit card number, debit card number, any other financial information, medical information, or legal documentation, including wills provided in connection with certain of our services. Some personal information included in this category may overlap with other categories.||YES||You, vendors, service providers, and third parties||YES, for uses 1-6 set forth in Section 1.3 above||Our lenders, banks, service providers, and third parties|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.||YES||You, vendors, service providers, and third parties||YES, for uses 1,2 and 5 set forth in Section 1.3 above||Our lenders, banks, service providers, and third parties|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO||N/A||N/A||N/A|
|E. Biometric information||Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES||You||N/A||N/A|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES||Your activity on our site, vendors, service providers, and third parties||N/A||N/A|
|G. Geolocation data||Physical location or movements.||NO||N/A||N/A||N/A|
|H. Sensory data||Audio, electronic, visual, or similar information.||YES||You||N/A||N/A|
|I. Professional or employment-related information||Current or past job history.||YES||You, vendors, service providers, and third parties||N/A||N/A|
|J. Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C.
Section 1232g, 34 C.F.R. Part 99)).
|Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO||N/A||N/A||N/A|
|K. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO||N/A||N/A||N/A|
6. Sale of Personal Information:
We do not and, without notice to you, will not sell your personal information. We do not and will not sell the personal information of minors under 16 years of age without affirmative authorization.
Privacy Support E-Mail: [email protected]