Effective: January 1, 2020
Last Updated: December 20, 2022
If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your personal information in that capacity.
NOTICE AT COLLECTION OF PERSONAL INFORMATION
Personal Information Collected
- Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, other similar identifiers)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Other type of state identification card number
- Physical characteristics or description (only if we request your driver’s license for identity verification purposes)
- Debit card number
- Telephone number
- Bank account number
- Other financial information
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Geolocation data
- Commercial information (records of products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies)
- Professional or employment-related information (including employment history)
- Characteristics of protected classifications under California or federal law (gender, age (40 and older), disability, citizenship status, military status)
- Audio, electronic, visual, or similar information
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, behavior, and abilities
Sources of Personal Information
We collect Personal Information directly from California residents and credit reporting agencies, third-party data providers, marketing partners, advertising partners, web browsers, internet service providers, government entities, operating systems and platforms, and data brokers. We do not collect all categories of Personal Information from each source. In addition, because we no longer offer loans to California residents, we do not actively collect Personal Information from all of these sources but have done so in the past. California customers can still log into their accounts with us in which case we will collect information such as their Internet Protocol address.
Business and Commercial Purposes for Collection
We collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use
- Performing services or offering products on our behalf or for our partners, such as processing credit applications and servicing credit products
- Undertaking internal research for technological development
- Undertaking activities to verify or maintain the quality or safety of our products and services
- Advancing our commercial or economic interests
Disclosure of Personal Information
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know or delete through our interactive webform available here or by calling us toll free at 1-888-994-1389. Specifically for the right to correct, you may log into your online account with us to update certain information or contact us by email at firstname.lastname@example.org or by telephone at 1-888-801-9075.
Please note that the CCPA’s privacy rights described above do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
The CCPA’s privacy-related rights also do not apply to certain types of Personal Information subject to the federal Fair Credit Reporting Act (“FCRA”). Some of our services are subject to the FCRA and, therefore, exempt from the CCPA on that basis.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
To verify your request, we will match the personal information you submit with the information we have about you. If we cannot conclude your information matches what we have, you may be directed to contact us with further instructions to assist us in responding to your request. To verify your request, you must submit:
- Your first and last name;
- Your Social Security number;
- Your date of birth; and
- Your email or mailing address (depending on delivery preference).
Individuals with disabilities who require an accommodation to access this policy or to make a request under the CCPA should contact us via email at email@example.com, by telephone at 1-888-994-1389, or by mail at 175 W. Jackson Blvd., Suite 1000, Chicago, IL 60604. Please note that we may need advance notice to provide certain accommodations.
HOW TO CONTACT US
To contact us for questions or concerns about our privacy policies or practices please email us at firstname.lastname@example.org or by telephone at 1-888-801-9075.