This notice of our privacy practices is provided to you on behalf of CNU Online Holdings, LLC and its parent company, Enova International, Inc., their respective family of companies, and their respective subsidiaries and affiliates including but not limited to those that operate under the trade names CashNetUSA (hereafter collectively referred to as the “CashNetUSA Related companies,” “we”, “our”, or “us”). “You” or “Your” means you as a participant in or as a user of the products and/or services offered by a CashNetUSA Related Company.
All information transmitted, printed or otherwise submitted to us shall be deemed to be our property and we shall be free to use such information for any lawful purpose described herein, and for other purposes as required or permitted by law.
Please read this Policy carefully. This Policy provides important information about the way we collect, share, and protect your information and governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Policy (including, without limitation, both mobile and online versions of our site), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a site and that posts a link to this Policy regardless of how you access or use them, whether via personal computers, mobile devices or otherwise regardless of how you access or use the site, whether via personal computers, mobile devices or otherwise. This Policy applies to anyone who applies for or uses our products or services, or visits our websites, including, but not limited to, current and former customers. We must notify you about our sharing practices when you establish a customer relationship and each year while you are a customer. A customer relationship begins when you obtain a financial product or service from us. A customer relationship terminates when you pay off a transaction in full. This Policy does not govern the data practices of third parties that may interact with our site.
To the extent we provide you notice on our site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
We collect personally identifiable information, including, but not limited to, non-public personal information, as well as other types of personally identifiable information from you and from other sources as described herein (collectively, “Your Information”). Our primary goal in collecting Your Information is to provide you with efficient, accurate, and customized financial products and services. Your Information also helps us personalize and improve your customer experience with us. We collect and/or track the following types of information:
We use Your Information to:
(Customers that reside in California, Connecticut, North Dakota or Vermont should refer to the state-specific notices provided at the end of this Policy)
The CashNetUSA Related Company delivering this Policy to you (the “CashNetUSA Provider”) may share or sell Your Information with any other CashNetUSA Related Company (collectively, its “Affiliated Companies”) and with other companies with whom any CashNetUSA Related Company does business (“Non-Affiliated Third Parties”) as permitted by law and as described in this Policy. These Affiliated Companies and Non-Affiliated Third Parties may be: (1) financial service providers, such as mortgage bankers, mortgage brokers, consumer lenders, small loan lenders, tax refund anticipation loan lenders, loan brokers, deferred deposit providers, check cashers, supervised lenders, delayed deposit providers, deferred presentment providers, collection agencies, consumer reporting agencies, banks, credit card providers, debit card providers, store valued card providers, insurance agencies, bill payment agencies, ATM providers, pawn and title pawn providers, automobile dealers, automobile financing providers, automobile leasing providers, money transfer and remittance providers, sellers and remitters of money orders, insurance services providers, and financial service provider holding companies, or agents, contractors, or representatives of any of the foregoing; (2) non-financial companies, such as retailers, tax preparers, payroll service providers, advertisers, marketing companies, lead generators, advertisers on our websites, companies or individuals that do industry-related research, surveys or polls, automobile dealers, and any person who offers a non-financial product or service, and holding companies, or agents, contractors, or representatives of any of the foregoing; and (3) other businesses, such as non-profit organizations, trade associations, and industry analysts or agents, contractors, or representatives of any of the foregoing.
Affiliated Companies and Non-Affiliated Third Parties may use Your Information for any legal purpose, including, but not limited to, developing and promoting new or joint products, improving existing products and services, and contacting you to offer products and services that may be of interest to you. We may also disclose Your Information, as described above, to companies who perform services on our behalf or to other financial institutions with which we have joint marketing agreements.
The CashNetUSA Provider may also disclose Your Information to Affiliated Companies and Non-Affiliated Third Parties that provide services to us or you (collectively, “Service Providers”). We contract with Service Providers to perform certain functions on our behalf. Examples include database providers who assist in identity verification, credit scoring companies, magazine publishers, retailers, and direct marketers. Service Providers’ access is limited only to the personal data needed to perform their functions, and only for the purpose of performing those functions, and they are prohibited from using or disclosing Your Information for other purposes.
Third-party analytics and other Service Providers such as Google Analytics may set and access their own Tracking Technologies on your personal computer, laptop, tablet, mobile phone or other device and they may otherwise collect or have access to information about you. These Service Providers use the technology described above to help us analyze how users use the website. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices. For example, to learn about opting out of Google Analytics, please click here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
We also may share Your Information if it becomes necessary for compliance with the law or to protect the rights, property, or safety of our websites, our users, or third parties. We reserve the right to release such personal data to law enforcement or other governmental officials as we, in our sole and absolute discretion, deem necessary to comply with the law. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. In addition, we reserve the right to use and disclose Your Information that is not in individually identifiable form as we deem appropriate, in our sole discretion.
In addition to any personally identifiable information or other information that you choose to submit to us via our site, we and our Service Providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our site. To the extent we associate Usage Information with your personally identifiable information we collect directly from you on the site, we will treat it as personally identifiable information.
This Usage Information may include:
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the site. A web browser is usually set to accept cookies automatically but can be changed to decline them. The Help section of the toolbar on most web browsers will tell you how to prevent your browser from accepting new cookies, how to have the web browser notify you when you receive a new cookie or how to disable cookies altogether. In most cases, a visitor may refuse a cookie and still fully navigate our websites. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s web site www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our site may not function properly, and that when you revisit our site your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the site, to monitor how users navigate the site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party Service Provider, is active only while you are connected to the site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
We may use Tracking Technologies for a variety of purposes, including:
TargetingRelated. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our site and third-party sites based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements or content that has been delivered to you.
There may be other Tracking Technologies now and later devised and used by us in connection with the site. Further, third parties may use Tracking Technologies with our site and this may involve the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our site and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms. If you would like more information on self-regulatory programs that permit you to exercise choice, see the Section entitled “Interest-Based Advertising” below.
In some circumstances, you have the right to direct the CashNetUSA Provider to not share Your Information with its Affiliated Companies and/or Non-Affiliated Third Parties (i.e., “Opt-Out”). Please note that even if you Opt-Out, the CashNetUSA Provider may still share Your Information with its Affiliated Companies and Non-Affiliated Third Parties as permitted or required by law. Also, the CashNetUSA Provider may share information it collects regarding its transactions and experiences with you with its Affiliated Companies. The CashNetUSA Provider may also share all information it collects about you with Affiliated Companies and Non-Affiliated Third Parties: to facilitate providing our services to you, to administer our business, in order to receive services from those companies, as permitted under joint marketing agreements, and as otherwise permitted or required by law.
The CashNetUSA Provider is delivering this notice to you on behalf of itself and all other CashNetUSA Related Companies. You may limit how the CashNetUSA Provider’s Affiliated Companies use Your Information the CashNetUSA Provider shares with them. Federal law gives you the right to limit some but not all marketing from the CashNetUSA Provider’s Affiliated Companies. You may limit a CashNetUSA Provider’s Affiliated Companies from marketing their products or services to you based on Your Information that they receive from the CashNetUSA Provider. This information includes your income, your account and payment history, and your credit history, report or score.
To limit the CashNetUSA Provider’s sharing of Your Information with Affiliated Companies and Non- Affiliated Third Parties, as described above, contact us:
Unless we hear from you, we can begin sharing Your Information thirty (30) days from the date we first deliver this Notice to you. However, you may Opt-Out at any time by contacting us. Once we receive your Opt-Out request, we will stop sharing the information you request that we don’t share as soon as reasonably practicable. Your Opt- Out request will remain in effect until you notify us otherwise in writing.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The site may allow you to review, correct or update personally identifiable information you have provided through the site’s registration forms or otherwise, and you may provide registration updates and changes by contacting us here. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your personally identifiable information or change your preferences on the site, information that you remove may persist internally for our administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
Data about your activities online is being collected on our website for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics Service Providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Policy provides details and explains how to exercise that choice.
You may see certain ads on other websites because we participate in advertising networks administered by third parties. These networks track your online activities over time by collecting information through automated means, including through the use of the technologies described in the “Automatic Information and Cookies” Section above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our websites, such as the pages you have viewed. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.
We restrict access to Your Information to those employees who need to know that information to provide products or services to you. We maintain commercially reasonable physical, electronic, and procedural safeguards that comply with federal regulations to guard Your Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our site and provide us with your information at your own risk
We reserve the right to contact you regarding your account status and changes to subscriber agreements, our Policy, or any other policies or agreements relevant to you. By visiting our websites, you understand and agree that we may contact you at the phone number or email address you provide to us through our websites or on your transaction agreements, applications, loan documents or any other document to assist you with your product or to discuss other products and services that a CashNetUSA Related Company may provide for you.
Our site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including personally identifiable information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personally identifiable information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including personally identifiable information, in the United States as set forth in this Policy.
Pursuant to state law, the CashNetUSA Provider may not share information it collects about you with its Affiliated Companies or with Non-Affiliated Third Parties, except in the limited circumstances, as set forth in this Policy, as permitted under state law, or if you give us your permission.
California Civil Code Section 1798.83, also known as S.B. 27, permits California residents, who have supplied personal information, as defined in the statute, to request certain information regarding our disclosures in the prior calendar year, if any, of personally identifiable information to third parties for their own direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2013 will receive information about 2012 sharing activities). To make such a request, please contact us at www.cashnetusa.com or write to us at: Attn: Customer Service, 175 W. Jackson Blvd., Suite 1000, Chicago, Illinois 60604. To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response.
Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
Pursuant to state law, we will only share information with our Service Providers and with third parties as required or permitted by law, or if you give us your permission.
The CashNetUSA Provider will not disclose information about you with its Affiliated Companies or with Non-Affiliated Third Parties, other than as required or permitted by law, without your express permission.