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Effective January 1, 2020
The state of California requires that we provide privacy information for individuals that reside in California. If you do not reside in California, you can skip this document.
Below is the legal information we are required to share:
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual consumer or device (“personal information”).
|Directly from you.||
You enter or provide us with information, whether online or by email, phone or document upload.
For example, your contact information that you provide, your application for a loan, or documents you provide to verify your identity.
|Directly and indirectly from you based on activity on our website.||For example, from submissions through our website or website usage details collected automatically.|
|From vendors or third-parties that interact with us in connection with the services we perform.||For example, companies that work with us to market our products to you, credit reporting agencies from which we check your credit in connection with a submitted application, or other vendors that provide data we use in underwriting or in protecting you and our products from fraud and identity theft.|
We may use or disclose the personal information we collect for one or more of the following business purposes:
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.
We may disclose your personal information to a service provider or third party for a business or commercial purpose. When we disclose personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract. Examples of who we share with include:
|CATEGORY||EXAMPLES||COLLECTED (Yes/No)||SOURCES OF COLLECTED PERSONAL INFORMATION||BUSINESS OR COMMERCIAL PURPOSE FOR SHARING (Section 1.3 #1-9, above)||CATEGORY OF THIRD PARTIES|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES||You, your activity on our site, or from vendors and third-parties||1-9||Our affiliates, lending partners, 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, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES||You, or vendors and third-parties||1-9||Our affiliates, lending partners, 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, genetic information (including familial genetic information).||YES||You or vendors and third-parties||1, 2, 4-9||Our affiliates, lending partners, 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 or vendors and third-parties||1-9||Our affiliates, lending partners, service providers and third-parties|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO||N/A||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 or vendors and third-parties||1-9||Our affiliates, lending partners, service providers and third-parties|
|G. Geolocation data.||Physical location or movements.||YES||Vendors and third-parties||1, 2, 5-9||Our affiliates, lending partners, service providers and third-parties|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES||You||1-9||Our affiliates, lending partners, service providers and third-parties|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES||You or vendors and third-parties||1, 2, 4, 6-9||Our affiliates, lending partners, 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|
We do not and 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.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
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. Once we receive and confirm your verifiable consumer request for access, we will disclose to you:
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.
You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and third parties to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the personal information is necessary for us or our service providers to:
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.
The CCPA provides consumers with the right to opt-out of the sale of your personal information. However, we do not and 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Making a verifiable consumer request does not require you to create an account with us. However, if you already have an existing online account, we will require you to log in to submit a request.
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.
You may only make a verifiable consumer request for access (aka Right to Know) or data portability twice within a 12-month period. The verifiable consumer request must:
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 behalf of a consumer and 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@example.com and provide the following information:
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. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We will acknowledge receipt of the request within 10 days of its receipt. We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
|Privacy Support Phone:||(844) 200-6413|
|Privacy Support E-Mail:||firstname.lastname@example.org|
P.O. Box 101808
Fort Worth, Texas 76185
Version 1.0 – Effective Date 1/1/2020