Effective Date: August 1st, 2022
Types of Information We Collect
The following are examples of the types of information that we may collect directly from you, about you, and/or from other sources, including third parties, business partners, our affiliates, or publicly available sources.
Information collected directly from you:
- Account Registration. Your name, email, phone number and other relevant information when you create an account. We also may collect information relating to the actions that you perform while logged into your account. The purpose for collection and use ofthis data is that we have a business need to provide account related functionalities to our users. Accounts can be used for easy checkout, save your preferences, select areas of interest, and transaction history.
- Lead Forms and Order Placement. We collect information when you use our lead and order forms on our Services. This may include your name, email, phone number, billing address, shipping address, and payment information (e.g., credit card number). In addition, these forms may ask for information specific to your request, such as car make and model for auto insurance, military service for secondary education, or other information requested by one of our business clients. The purpose of collection and use of this data is that we use your information to perform activities associated with a contract to provide you with products or services.
- Financial information. On certain Financing Services you may provide us with information such as national identifier, credit history, income, loan amounts, and account balances related to requesting financial products and services. Examples include credit card inquiries, and loan inquiries for products such as mortgages, personal loans, and student loans. In some situations for certain Services, our GLBA notice may also apply to the collection of this information. The purpose of the collection is we have a business need to use this information to facilitate your request and connect you to lenders that deliver the products and services you request.
- Information You Post on the Services. When available on the Services, we may collect Personal Information from you when you provide or post information to our Services, including your username, comments, likes, interests, status, pictures, and references to your online presence. We may use this information for our purposes and/or make this information available to others as you request.
- Information You Provide About Others. Sometimes, you may provide information about others- for example, to refer a friend for a newsletter. We may use this information to make our Services available to the people you refer.
- Sweepstakes or contests. When you choose to participate in a sweepstakes or contest, we collect information about you, which includes contact information to notify you if you are selected. The purpose of collection and use of this data is that we have a business need to operate the contest or sweepstakes. In some contexts, we are also required by law to collect information about those that enter our sweepstakes, and we have a business interest in complying with those laws.
- Mailing List. If you sign up for one of our mailing lists we collect your email address and/or postal address. The purpose of collection and use of this data is that we have a business need to share information about our products or services.
- Partner Promotion. We collect information that you may choose to provide as part of a promotion with another company. The purpose of collection and use of this data is that we have a business need to fulfill our promotions.
- Feedback/Support. If you provide us feedback or contact us for support, we may collect your name and e-mail address, as well as any other content that you send to us, to reply.
- Employment-related data (directly from you): When you choose to apply for employment with a Financing Company, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your resume or CV, Social Security Number, and other information you provide during the application and recruitment process. The purpose of collection is to help us match you to open positions, facilitate the recruiting process, and perform our contract of employment or the anticipation of employment with you.
Information collected Automatically:
- E-mail Interconnectivity. If you receive email from us, we may use tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. The purpose for collection and use of this data is that we have a business need to understand how you interact with our communications to you.
- Mobile Devices (such as Phones, Tablets, Connected TVs, Gaming Consoles, and Other Digital Media Streaming Devices). We may collect information from your Mobile Device, such as unique identifying information broadcast from your device when visiting one of our Services. The purposes of collection and use of this data are that we have a business need to identify unique visitors and understand how users interact with us on their devices.
- Website interactions. We use technology to discover how you interact with our website (e.g., session replay). This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. The purposes of collection and use of this data are that we have a business need to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a business need to secure our Services and detect and prevent fraud.
- Location Data. When you use certain of our Services, we may solicit your permission to collect your location data.. Some features within our Services (such as location-based offers) may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data. The specificity of the location data may depend on several factors, including the device you are using and how your connected to the Internet. If you enable location services for our Services, we may collect location data periodically as you use or leave open our Services. Depending on the platform you use to access our Applications (e.g., Apple’s iOS, Google’s Android) you may be able to control whether location data is collected from with the controls on your device.
- Cookies, for advertising. Some of our Services participate in behavior-based advertising, which means that technology (e.g., a cookie) is used to collect information about your use of our Services to provide advertising about products and services tailored to your interests on our Services , or on other websites. The purposes for collection and use of this data are that we have a business need to engage in behavior-based advertising and capture analytics on our Services. The information we collect may include geolocation data, such as (a) information that identifies the precise location of your mobile device (when you agree to allow an app or Service to collect this) and (b) your IP address, which may be used to estimate your approximate location. We use this information to ensure that the Services work properly, and to deliver customized content and advertising, including personalized ads, to you.
- Cross-Device Tracking. We and our service providers may collect and store information about users’ interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. The purposes for collection and use of this data are that we have a business need to understand our users’ use of our sites across devices in order to allow users to use our services on one device and pick up seamlessly where they left off on another device. We also have a business need to provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.
Information we may collect from other sources:
- Client Information. We may collect contact information such as name, e-mail, address and/or phone number of our business clients and their employees with whom we may interact. The purposes for collection and use of this data is that we have a business need to make our website operate efficiently and to provide our business clients with ability to save preferences such as login and preferred language.
- Financial information. We may collect information from credit reporting services and, with your permission, financial data aggregator(s) and your financial service provider(s) when you use certain of our Services. We use the information as needed in the course of providing services you request, ongoing customer relationships, to service an account, and as permitted by state and federal law.
- Demographic Information. Personal Information such as your age, gender, family size, and/or educational level. The purpose for collection and use of this data is that we have a business need to customize content, advertising and learn about our audiences.
- Activity and usage information. including information about your interests, purchase behavior, and other navigation data, such as websites visited and advertisements viewed or clicked on, used to customize content and advertising.
- Publicly-observed data. Such as activities on blogs, videos, and other online postings used to customize content and advertising.
- Social Media Platforms and Other Third-Party Services. Some of our Services may include features that are designed to interact with social media platforms and other third-party services (e.g., Facebook, Instagram, and loyalty programs). If you access the Services using one of these social media platforms or provide us access to third-party services, we may receive information about you from those third-parties such as account and profile data and we may combine this data with information we already have about you.
- Employment-related data. When you choose to apply for employment with Financing, including information from a recruitment agency. The purpose of collection is to help us match you to open positions and facilitate the recruiting process.
Use and Processing of Information
In addition to the purposes and uses described elsewhere in this policy, we may use information in the following ways:
- To identify you when you engage with us and our Services.
- To provide content recommendations based on your interactions and interests.
- To make our Services available to you and to complete orders placed in our Services and with our Clients.
- To process transactions associated with your use of Services for which there is a charge, including to process payments and verify your identity or payment information for your security and protection.
- To communicate with you (e.g., about your account or updates to our terms) and to respond to inquiries related to support, employment opportunities, or other requests.
- To deliver marketing and promotional materials related to our Services in accordance with applicable laws, including information relating to our products, services, sales, marketing research or promotions.
- To provide you with personalized advertising on our Services based on your online activity. We use the information we have to improve our advertising systems so we can show you relevant interest-based advertising, measure the effectiveness and reach of advertisements and services, verify delivery and track performance of an advertising campaign, and ensure that an ad is only delivered when a real person is visiting the site and that the same users don’t see the same ads too frequently. You may update your preferences regarding personalized advertising by visiting the Cookie Settings link in the footer of each site to manage your settings.
- To verify your entry into and eligibility to participate in contests, giveaways, or sweepstakes and inform you if you’ve won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that contest, giveaway, or sweepstakes.
- To monitor, improve, and conduct analytics on our Services and advertiser product offerings.
- For internal administrative purposes, such as safety and security of our Services, and to manage our relationships.
- To permit you to participate in social sharing, including live social media feeds and to implement Social Features you choose to use.
- The Apps in our Services may request to send you push notifications from time to time in order to update you about any events or promotions that we may be running. The Apps may also ask for your permission to access your camera and your photos. If you no longer wish to receive these types of communications, or if you’ve initially agreed for the application to access your camera and photos and you would like to stop the Apps from accessing them, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
- To detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, and terms and conditions.
- To comply with legal obligations, to establish or exercise our rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible misconduct.
Although the sections above describe our primary purpose(s) in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information as we have a business need in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our need to conduct our business.
Sharing of Information
In addition to the specific situations discussed elsewhere in this policy, we may disclose your Personal Information in the following situations:
- Affiliates and Acquisitions. We may share your Personal Information with our business partners. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share your Personal Information with that company using appropriate safeguards, including at the negotiation stage.
- Our Business Clients. When we collect information on behalf of our business clients, we share that information with those clients.
- Service Providers. We share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, assist or support our business operations and other administrative functions, process payments, and assist in the fulfillment of orders.
- Audience Measurement Services. We may share your Personal Information with audience measurement companies like Comscore and Nielsen that help us and other websites measure and understand the audiences that view our content.
- Video Viewing Behavior. Consistent with applicable law, we may share your video viewing behavior with third parties including advertising companies, analytics partners, and social media sites.
- Aggregated and Anonymous Information. We may share aggregated, anonymous information with any third party. This information is not linked to personal information that can identify you or another individual person.
- Advertising. We may share certain data with Advertising platforms, including Google and Social Networks such as Twitter, Facebook, LinkedIn and Snapchat to allow us to target existing users and customers with highly relevant advertising campaigns. For the purposes of such campaigns. We may share a unique code (such as a hashed email address) with the applicable Advertising platform in order for that identifier to be matched against existing users of the relevant Advertising Platform and to identify potentially relevant audiences for targeted advertising. We use services such as Google Ads’ Customer Match, LiveRamp, LinkedIn Matched Audiences, and Facebook Custom Audiences for these purposes.
- Public. Some of our Services may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on our Services, that information may be publicly available
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
If you use Social Features on our Services or access our Services from Social Features, both Financing and the social media services that operate those Social Features may have access to certain information about you and your use of both our site and theirs. If you are a member of a social media site and logged in, the interfaces configured on our Services may allow the social media site to connect your site visit and browsing behavior to the personal data held on your social media site. We may use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.
In addition, we may request your permission to a) access and collect information available from your social networking account; and b) post information to your friends on your behalf. When you connect your social networking service with your Financing account, you authorize us to access certain information about you from your social networking service to provide content and services, including to help us tailor our communications to you and to develop rich online content and services across the Services. The information we may access from your social networking services is governed by the privacy policies and settings of those third-party services.The information collected and stored by the social media sites remains subject to those sites’ privacy practices, including whether they continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.
Manage Your Information
You can make the following choices by emailing us at email@example.com using our online form regarding your Personal Information:
- Access to Your Personal Information. You may request access to your Personal Information that we collect on our own behalf. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
- Changes to Your Personal Information. We rely on you to update and correct your Personal Information. Note that we may keep historical information in our backup files as permitted by law. If our Services do not permit you to update or correct certain information, contact us at the address described below. If we are processing your Personal Information on behalf of one of our clients, we will respond that we are operating as a Service Provider and are unable to act on your request.
- Deletion of Your Personal Information. When we collect information on our own behalf, we typically retain your Personal Information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request to delete your Personal Information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in some situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. If we are processing your Personal Information on behalf of one of our clients we will respond that we are operating as a Service Provider and are unable to act on your request.
- Objection to Certain Processing. When we process information on our own behalf, you may object to our use of your Personal Information by contacting us at the address described below. For example, California residents may be entitled to object, or opt-out, of having their Personal Information sold to third parties. If you are a California resident and would like to opt-out of having your information sold, please email us at firstname.lastname@example.org. We do not discriminate against California consumers who exercise any of their rights described in this policy.
- Revocation of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to deliver newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
- Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
- Text Messages and Push Notifications. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP” or “UNSUBSCRIBE.” You control on your device whether you receive push notifications.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
How We Protect Personal Information
- Transmission of Information to Other Countries. As a multi-national company, we may transmit information between and among our affiliates. As a result, your information may be stored and processed in any country where we have facilities or in which we engage service providers. We take steps to treat personal information using the laws of the country in which we first received your information.
- Collection of Information from Children. We recognize the importance of protecting the privacy and safety of children, and our website and services are directed towards a general audience and are not directed towards children. We do not knowingly collect information about children under the age of 18 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 18 has provided personal information through one of our websites, we will use reasonable efforts to remove that information from our databases.
- Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we collect on our own behalf and how we share that information here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Information” section.