Version Date: 02/14/2014
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Website represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred personal information to the Website, please contact Company using our contact information below to have that child’s account terminated and information deleted.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
“Personally-Identifying Information” is information that can be directly associated with a specific person. Company collects a range of Personally-Identifying Information from and about Website users.
It is important that you are aware that we are not a seller of any products or services to users of this Website and Company is not a lender or provider of any financial, insurance or other services. Our Website serves merely as a marketing and matching platform between users and our network of partners (the “Partners”) that offer or market products and services, which may include, depending upon which of our websites you visit, payday loans, auto loans, educational loans, mortgage products, insurance products, home contractor services, or other products and services (the “Offerings”). In order to receive information about the Offerings or to apply for the Offerings, you will be requested to submit Personally-Identifying Information via our online application forms (“Your Application Information”). Depending upon the type of Offering you are applying for, Your Application Information may include any of the following, in addition to other information: your name, address, telephone number (work, home, mobile or other), email address, date of birth, driver’s license number, citizenship status, income, social security number, bank account information, employment information, home ownership information and active military information.
Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
You authorize us to use your information to obtain other information about you (for example, your social security number) from third parties when Your Application Information is incompletely or improperly filled out on our registration form. Third parties include, but are not limited to, consumer reporting agencies, consumer credit bureaus and other outside parties, as permitted or required by applicable laws. If you choose to provide information, such as your social security number, we may use that information to determine your financial status. If you do not provide such information, we may also use other information that you provided for the purpose of verifying your eligibility for a loan or for any other programs, offer, or services.
BY SUBMITTING YOUR APPLICATION INFORMATION, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails, if applicable, at the time of application, though we reserve the right to send you notices about your account even if you opt out of all voluntary email notifications.
Company will disclose Personally-Identifying Information under the following circumstances:
Direct Mail Partners. From time to time we may share our postal mailing list with selected providers of goods and services that may be of interest to you. If you prefer not to receive mailings from these providers, you may opt-out at the time you register for our Website (if applicable), or at any time thereafter by going to your account settings (if available) or contacting us using the contact information below.
Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company will email users about products and services that Company believes may be of interest to them and Company also will provide users’ email information to third parties, so that those third parties may directly contact users about additional products and services. If a user wishes to opt-out of receiving marketing materials from Company, user may do so by following the unsubscribe link in email communications, by going to your account settings (if available) or contacting us using the contact information below. Similarly, to cease having your email information provided to third parties, you may do so by contacting us using the contact information below. Even after opting-out, a user may continue to receive marketing emails from third parties to whom Company already has provided the user’s email information. Users will be responsible for directly contacting such third parties to request cessation of further marketing emails.
Mobile Marketing. By submitting your information to this Website you agree to receive mobile marketing including, but not limited to, text messaging based marketing, from both of us and our third party advertisers and marketers. By doing so, you agree that you may incur charges on your individual carrier plan in association with such text messages and you agree to be solely responsible for these charges. By submitting your information you also indicate that you are least 18 years of age and the owner or authorized the user of the wireless device on which messages will be received and that you were authorized to approve the applicable charges. Hereafter, should you choose to opt out of receiving text messages from an individual sender, you may do so by texting “STOP” or “OPT-OUT” as specifically set forth in the communication. Regardless of whether your mobile telephone number is listed on state and/or federal do-not-call registries, we retain the right to contact you by text message.
Third Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website, providing direct mail and email, removing duplicate information from customer lists and analyzing data. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Changing Personally-Identifying Information; Account Termination
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Website. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
We may also periodically obtain both Personally-Identifying Information and Non-Personally-Identifying Information about you from other Company-affiliated businesses, business partners, contractors and other third parties and add it to our account information or other information we have collected. Examples of information that we may receive include: updated address information, purchase history, and additional demographic information.
A “Web Cookie” is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site. Company uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. Company does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
Third Party Providers
We use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: https://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.
A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on our Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
CONTESTS, GIVEAWAYS AND SURVEYS
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
CONSENT TO ELECTRONIC DISCLOSURE
By submitting your information via the Internet, you agree to receive certain notifications, disclosures and/or documents electronically. This Consent to Electronic Disclosures applies to the information you are providing on this Website and any other communications we or any third party may provide to you. By submitting your information you agree to receive all such notifications, disclosures and/or documents from us or any third party in electronic form or online in accordance with this document. You may withdraw your consent prior to submitting your information by exiting the Website or by closing your browser. However, you will not be able to submit your information if you withdraw your consent by exiting the Website or closing your browser. Following the submission of your information, you may be able to withdraw your consent to future electronic disclosures from a third party by contacting the third party directly, but due to rules regarding the timing of delivery of disclosures that need to be made to you, you acknowledge that an opt-out notice may not be received and acted upon by such third party prior to such disclosures being delivered to you electronically. We do not process opt-out communications for third parties, and each third party establishes its own rules regarding opting out of future electronic communications and disclosures.
All notifications, disclosures and/or documents that we or any third party provide to you in electronic format will be provided either (i) via e-mail; (ii) by access to a secure customer service website which will be provided to you in an e-mail notice sent to you when the documents are available; (iii) by posting on this Website or the third party’s site; (iv) by SMS text messaging to your mobile device; or (v) by posting on a website designated for that purpose. All notifications, disclosures and/or documents provided in electronic or paper format from us or any third party to you will be considered “in writing,” and you should print a copy for your records. You may obtain any notifications, disclosures and/or documents in paper form without charge from us by printing them yourself from our Website or the appropriate third party’s Website, when available. To access, view and retain the notifications, disclosures, and/or documents available to you in electronic form, you must have Internet access, sufficient electronic storage capacity, an e-mail account with an Internet service provider e-mail software.
You agree and intend the federal Electronic Signatures in Global and National Commerce Act to apply to (i) your consent to receive notifications, disclosures and/or documents in electronic form; (ii) the information you provide, and (iii) our and/or any third party’s ability to conduct business with you by electronic means.
By completing and submitting your information, you (i) agree to provide us with an accurate and complete e-mail address and other required information requested on this Website; (ii) confirm your consent to receive notifications, disclosures and/or documents from us and any third party in electronic format; (iii) affirmatively demonstrate your ability to access the notifications, disclosures and/or documents in electronic form; (iv) confirm that you have provided a current e-mail address at which electronic notifications, documents and/or disclosures can be sent to you; (v) acknowledge that you have read and reviewed the terms contained in this Consent to Electronic Disclosure; and (vi) agree to the terms contained in this Consent to Electronic Disclosure.
We and any third party, reserve the right, in our sole discretion, to discontinue electronic provision of notifications and/or documents. You will be provided with notice of any such termination or change as required by law.
To facilitate electronic commerce, to reduce the expense of records storage, and to obtain the benefits of faster access to records, you acknowledge and agree that all records may be stored electronically; and that neither we nor any third party will retain and have no obligation to retain any original or electronic documents for any period of time beyond the regulatory requirements. This applies to all notifications, disclosures and/or documentation. You further acknowledge and understand that all original and electronic notification, disclosures and/or documentation will be routinely destroyed, but not before the period of time designated by regulatory requirements. Records may be stored electronically via imaging, scanning, filming or other technology used for the storage of documentation via internal processes or third-party processors that we or any third party approve for these services. You agree that such storage shall be secure, and further agree that such records shall for all purposes be recognized and admissible in evidence or otherwise to prove the agreements, rights and obligations of the parties pursuant to any such records. We will retain your information for as long as needed to provide you services. If you wish to request that we no longer use your information to provide you services please contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
DO NOT TRACK POLICY
Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, this Website does not currently respond to Do Not Track signals. Our business partners and advertising networks that serve interest-based advertisements on our Website have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests, and it is possible that they may reuse this small amount of information on other websites or services.