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
2. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018
1. Right to Know
2. Right to Delete
3. Right to Opt-Out
4. Right to Non-Discrimination
3. SUBMITTING A VERIFIED CONSUMER REQUEST
1. Exercising Right to Know and Right to Delete
2. Authorized Agents
3. Response Timing and Delivery Method
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.||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|
|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||YES, for uses 1,2 and 5 set forth in Section 1.3 above||Our lenders, banks, service providers, and third parties|
|G. Geolocation data||Physical location or movements.||YES||Vendors 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|
|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||YES, for uses 1 and 2 set forth in Section 1.3 above||Our lenders, banks, service providers, and third parties|
|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.
2. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018
The CCPA provides consumers (California residents) with specific rights regarding their personal information—the Right to Know, the Right to Delete, the Right to Opt-Out and the Right to Non-Discrimination. This section describes your CCPA rights and explains how to exercise those rights, if applicable.
1. Right to Know:
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (“Right to Know”). Once we receive and confirm your verifiable consumer request for access, based on your request, we will disclose to you:
• the categories of personal information we collected about you;
• the categories of sources for the personal information we collected about you;
• our business or commercial purpose for collecting that personal information;
• the categories of third parties with whom we share that personal information;
• the specific pieces of personal information we collected about you (also called a data portability request); and
• with respect to disclosures of your personal information for a business purpose, the categories of personal information that each recipient obtained.
We may deny your request for access if we are unable to verify your identity or have reason to believe that the request is fraudulent. We may also deny your request if the personal information is subject to an exemption under the FCRA, the GLBA, the FIPA, or the DPPA.
2. Right to Delete:
You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable consumer request, we will delete, de-identify, or aggregate your personal information (and direct our service providers to do the same), unless an exception applies. We may deny your deletion request if retaining the personal information is necessary for us or our service providers to:
• complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• debug to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
• enable solely internal uses that are reasonably aligned with your expectations based on our relationship with you;
• comply with legal or regulatory obligations; or
• otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
We may also deny your deletion request if the personal information is subject to an exemption under the FCRA, the GLBA, the FIPA, or the DPPA.
Additionally, we may deny your request to delete if we are unable to verify your identity or have reason to believe that the request is fraudulent.
3. Right to Opt-Out:
Under the CCPA, you have the right to opt-out of the sale of your personal information (“Right to Opt-Out”). However, we do not and, without notice to you, will not sell your personal information. Further, we do not and will not sell the personal information of minors under 16 years of age without affirmative authorization.
4. Right to Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA rights (“Right to Non-Discrimination”); therefore, unless permitted by the CCPA, we will not:
• deny you goods or services;
• charge you higher prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• provide you a lower level or quality of goods or services; or
• suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
3. SUBMITTING A VERIFIED CONSUMER REQUEST
1. Exercising Right to Know and Right to Delete:
To exercise the Right to Know and Right to Delete described above, please submit a verifiable consumer request to us by either: Calling us at 877-287-2448 Only (1) you, (2) a person authorized by you to act on your behalf, or (3) an entity registered with the California Secretary of State and authorized by you to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. We are only required by the CCPA to respond to a Request to Know twice within a 12-month period. To constitute a verifiable consumer request, a request must:
• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Given the sensitivity of your personal information that we collect and retain, we will need to verify your identity with at least 3 separate pieces of information such as name, address, account number, date of birth, last 4 of your Social Security Number, phone number, etc.; and
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
For Requests to Know specific pieces of information (as opposed to categories), you will need to sign and return a declaration signed under the penalty of perjury stating that you are making the request on behalf of yourself.
2. Authorized Agents:
Before we can respond to a verifiable consumer request submitted by an authorized agent, we need to confirm not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.If you are authorized to submit a request on behalf of a California resident, please email us at [email protected] and provide the following information:
1. To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
• California Secretary of State authorization,
• written permission from the California resident, or
• power of attorney
2. To verify your identity, please attach copies of the following to your request email:
• valid Government Issued ID (not expired) AND
• a Utility Bill, Bank Statement, or similar documentation to verify your name and address.
3. To verify the identity of the consumer for whom you are submitting the request, please submit the required information by calling us at 877-287-2448
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
3. Response Timing and Delivery Method:
Privacy Support E-Mail: [email protected]