Individuals under the Age of 18
We are committed to not knowingly collecting, requesting, or retaining Personal Information from individuals under the age of 18, and we do not knowingly permit such individuals to register for our Services. If you are below 18 years of age, please refrain from providing any Personal Information, such as your name, address, phone number, or email address, to us. Should we become aware that we have inadvertently gathered Personal Information from a minor under the age of 18 without verified parental consent, we will make reasonable efforts to remove that information from our records. If you have any concerns regarding this matter, please reach out to us.
For residents of California, "Personal Information" will have the meaning as defined by the California Consumer Privacy Act of 2018 ("CCPA"). Refer to the section titled "Notice to California Residents" for further details.
Personal Information excludes information that has been deidentified, pseudonymized, anonymized, aggregated, or otherwise processed in a manner that renders it unable to be associated with a specific individual without using additional information. This additional information is kept separate and securely to prevent unauthorized re-identification of an individual (collectively referred to as "De-Identified Personal Information").
What Personal Information do we Collect?
We might gather and retain various categories of Personal Information pertaining to the individuals we engage with. The kinds of Personal Information we acquire encompass the following:
|Identifiers||Real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP”) address, email address, or other similar identifiers|
|Personal information described in the California Customer Records statute (Cal. Civil Code §1798.80(e))||A name, or description, address, telephone number, or employment, employment history, or any other financial information. Note: Personal information included in this category (1) does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records, and (2) may overlap with other categories|
|Protected classification characteristics under California or federal law||Age (40 years or older), veteran or military status|
|Internet or other electronic network activity information||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement|
|Geolocation data||Physical location or movements|
|Audio, electronic, visual, thermal, olfactory, or similar information||Electronic recording of customer or prospective customer calls.|
|Inferences drawn from any other category of personal information||Deriving information, data, assumptions, or conclusions from facts, evidence, or another source of information or data to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes|
Information You Provide Us
The Personal Information we gather via our Website, business partners, affiliates, or service providers may be acquired through the following means:
- Information you provide through webforms on our Website. This encompasses data you furnish when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, seeking information from us, submitting material on our forums (where permissible), engaging with customer support, reporting issues with our Website or Services, or engaging in other forms of communication with us.
- Records and copies of your correspondence, including email addresses, if you reach out to us.
- Your survey responses, which we or our service providers might request for research purposes.
- Your search queries conducted on our Website
- Interactions with customer service/support
- Participation in loyalty/rewards programs
- Information from third-party websites and mobile applications (e.g., websites sharing information with us or advertising partners about online activities).
- Data from suppliers (e.g., companies providing consumer demographics and other data).
- Data acquired from mobile applications (parent, subsidiary, and affiliate brands).
- Joint marketing partners.
- Online advertising companies.
- Social media companies.
- Other service providers.
Data obtained in response to employment opportunities. Furthermore, we might collect your Personal Information in relation to financial-related Services you seek from us. This includes suggesting financial or other products based on our experience and the information you provide, to improve the likelihood of acceptance.
We might also gather market-related data, including Personal Information, about market trends and activities influencing our operations. Such data could involve contract details, financial particulars, and other relevant information for market analysis and strategic planning. Additionally, we may amass information related to our media, investor, and public relations endeavors, as well as data connected to our interactions with financial experts and advisors.
On occasion, we might engage third-party services within our operations, and these parties may furnish us with Personal Information they've gathered as part of their service provision or otherwise. In such cases, we will take reasonable measures to confirm that these third parties have assured us of their authority to disclose your Personal Information to us.
Privacy and our Website
You are welcome to explore our Website without divulging your identity or sharing any personal details, including your email address. During your visit, our web server might collect data concerning your interaction with our Website. This could encompass the IP address and domain used for access, browser type and version, the referring website, the entry and exit pages, the pages viewed during that IP session, and the country indicated by your IP address. We use this information for performance monitoring purposes (e.g., visits, average duration, page views) and for business enhancements to continually enhance our Website.
Furthermore, we gather the Personal Information that you provide through our Website, such as your name, address, and any other contact details you opt to provide. You may provide this information in the following ways:
- By utilizing the "contact us" section on our website; or
- By communicating with a representative of our site via email using the designated hyperlinks.
Should you request information from us, the email address you provide might be used to send you information about offers on products and services that we believe align with your interests. If you've subscribed to our email list, requested regular information, or receive offers by email, you have the option to unsubscribe at any time using the instructions provided in each email or on the sign-up page.
Our Website and Cookies
Information We Collect Through Automatic Data Collection Technologies
As you navigate and interact with our Website, we utilize automatic data collection technologies to gather specific information about your device, browsing behaviors, and usage patterns, including:
- Details regarding your visits to our Website, encompassing traffic data, geolocation data, logs, communication data, and the resources you access and utilize on the Website.
- Information concerning your computer, mobile device, and internet connection, such as your IP address, operating system, browser type, clickstream patterns, the URL of the preceding website you visited before reaching ours, the duration of your visit, and the pages viewed during your time on our Website.
- Behavioral Tracking: We might also employ these technologies to compile insights about your online activities across time and various third-party websites or online services. This information might be associated with De-Identified Personal Information we collect. While we don't permit personalized third-party behavioral tracking, we may use De-Identified Personal Information to track users' click or browsing patterns.
- Keystrokes: We or our service providers might observe and collect keystrokes and cursor movements of Website visitors before purchasing a Product or Service from our Website (prior to having specific identifying information about you beyond your IP address). This information remains anonymous, and we don't initially link it to your identifiable identity. However, if you subscribe to receive our emails (e.g., through a popup box), we can subsequently link keystroke and cursor information to the provided email address. This data is used solely to enhance the Website for an improved user experience (e.g., better navigation, readability).
The automatically collected information is primarily statistical data, which may include Personal Information, and we may either maintain it or associate it with Personal Information obtained through other methods or from third parties. This data assists us in enhancing the Website and delivering more tailored Products and Services. It enables us to estimate audience size, analyze usage patterns, store preferences, enhance and customize the Website, accelerate search functions, and recognize returning visitors.
The technologies we utilize for this automatic data collection encompass cookies, local storage cookies, web beacons, pixel tracking, GIFs, and IP addresses. Each of these is detailed below.
Cookies (or browser cookies)
A cookie is a small file stored on your computer or mobile device's hard drive. It may contain various data, such as the server's name that placed it, a unique identification number, and an expiration date (in some cases). These cookies are managed by your web browser (e.g., Internet Explorer, Firefox, Safari, or Google Chrome) on your device.
Our Website employs different types of cookies, each serving distinct purposes.
These cookies are indispensable for enabling you to navigate our Website and utilize its functionalities. They are necessary for services like shopping carts and electronic invoicing to function properly.
Performance cookies gather data about your interaction with our Website, such as the most frequently visited pages. This information empowers us to optimize the Website's performance and simplify navigation. Additionally, performance cookies allow our affiliates and partners to ascertain if you accessed our pages through their site and whether this visit resulted in using or purchasing a Product or Service from our Website, including the relevant product references. These cookies do not gather information that could identify you personally. All collected data is aggregated and thus remains anonymous.
These cookies empower our Website to recall the choices you've made while browsing. For instance, we can store your geographical location in a cookie to display the corresponding regional content. Preferences like text size, font, and other customizable elements of the Website can also be remembered. Functionality cookies might also track viewed products or videos to prevent redundancy. The data collected by these cookies is incapable of identifying you and does not track your browsing activity on external sites beyond our control.
On certain pages of websites not managed by us, you might encounter third-party cookies.
We also utilize cookies to implement tracking technology on our Website. This enables us to showcase tailored advertising on our Website, comprehend which content sections interest you the most, and determine the preferred Product or Service categories. This tracking relies on De-Identified Personal Information data. We will not merge this data with your other Personal Information without your explicit consent. Some of our service providers are permitted to place cookies on our Website. These companies may offer you the choice to opt out of cookie usage in the future. For more information, please contact the relevant third-party provider.
You retain the ability to prevent future cookie usage at any time. By adjusting the appropriate setting in your browser, you can decline the acceptance of browser cookies. However, this action might impact your experience on our Website, potentially restricting access to certain sections. If your browser settings are not configured to reject cookies, our system will issue cookies when you visit our Website.
Local Storage Cookies: Certain functionalities of our Website may utilize local stored objects (or Adobe Flash cookies) to accumulate and store data about your preferences and navigation on our Website. These local storage cookies are not managed through the same browser settings as traditional browser cookies.
Web Beacons: Our Website pages and emails may contain tiny electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs). These elements enable us, for instance, to tally users who have visited specific pages or opened an email, and provide other relevant website statistics (such as tracking the popularity of specific website content and confirming system and server integrity).
GIF: We may employ small images referred to as clear GIFs to monitor user behavior, including collecting statistics about email openings.
IP Address: When you access the Website, our servers (or those of our service providers) automatically capture specific log file details provided by your browser. These server logs might encompass data such as the web pages you accessed on the Website, your internet protocol ("IP") address, browser type, and other insights into your interactions with the Website. Typically, these log files are regularly purged.
Information We Collect from Third Parties
We may gather information that others provide about you when you utilize the Website or acquire data from alternative sources, and then combine it with the information we collect via the Website.
- Third Party Services: If you link, connect, or log in to your account using a third-party social media service (such as Facebook, Google, Instagram, Yelp, etc.), that service may transmit us information such as your registration and profile details from their platform. The nature of this information may vary and is governed by the terms of that service or your privacy settings within that service.
- Other Sources: Subject to the extent allowed by applicable law, we may receive supplementary information about you, such as demographic details or fraud detection insights, from third-party service providers and/or partners. This information could be combined with the data we already possess about you. For instance, we might receive background check outcomes or fraud alerts from service providers like identity verification services, which contribute to our fraud prevention and risk assessment endeavors. Additionally, through partnerships, we might receive information about your interactions both on and off the Website, as well as insights from our partner advertising networks. Such third-party providers encompass various functions, including backend processing, order fulfillment, automation, video hosting platforms, email management, authentication, form handling, website usage tracking, calendar invitation and scheduling management, and database hosting and maintenance.
Certain content or applications, including advertisements, on the Website are furnished by third parties, such as advertisers, ad networks and servers, content providers, and application providers. These third parties may employ first-party or third-party cookies independently or alongside web beacons and similar tracking technologies to collect information about your interactions with our Website.
Third-Party Tracking Technologies: We lack control over the tracking technologies utilized by these third parties and how they are employed. If you have inquiries regarding a specific advertisement or targeted content, it is advisable to contact the responsible provider directly. Further details on opting out of third-party advertiser tracking mechanisms can be found here.
- Google AdSense Advertising: Our website incorporates Google AdSense Advertising or similar search engine and display network advertising. Google's advertising principles are available here to ensure a positive user experience. We've implemented features like (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.
- Cookie Interactions: We and third-party vendors like Google employ first-party cookies (such as Google Analytics cookies) and third-party cookies (like the DoubleClick cookie) or other third-party identifiers together. This helps compile data regarding user interactions with ad impressions and other ad service functions linked to our Website.
- Google DoubleClick Cookie: We collaborate with Google's DoubleClick Cookie, a third-party vendor utilizing cookies to deliver ads on our Website. The DoubleClick cookie enables Google and its partners to provide users with ads tailored to their visits to our Website or other online platforms. Users can opt out of the DoubleClick Cookie for interest-based advertising via the Google Ads Settings web page here.
- Google reCAPTCHA: We incorporate Google reCAPTCHA, which detects bots by collecting hardware and software details and sending this data to Google for analysis. For more details about Google reCAPTCHA, refer to here and here.
You have the option to customize your Google advertising preferences through the Google Ad Settings page. Alternatively, you can choose to opt-out by visiting the Network Advertising Initiative Opt Out page or by employing the Google Analytics Opt Out Browser add-on.
Why Do We Collect Personal Information?
We gather Personal Information to effectively manage, sustain, and advance our business and operations. This includes:
- Establishing, upholding, and managing our relationship with you to provide requested products and services. For instance, assisting you in obtaining loans, credit cards, or other products/services from third parties might involve conducting a credit check based on the information you've provided, confirming your financial situation and eligibility.
- Evaluating the products and services we offer to comprehend your preferences and enhance our offerings.
- Transmitting promotional and relevant materials to you, within the confines of applicable laws.
- Assessing the products and services you supply to collaborate effectively and meet our requirements.
- Addressing your preferences and complying with your requests, such as using a specific contact number.
- Safeguarding against errors, fraud, theft, and safeguarding our assets, including verifying your identity.
- Ensuring compliance with applicable laws and regulations.
- Pursuing other legitimate purposes with your consent.
How Do We Use and Disclose Your Personal Information:
- • To display our Website and its content to you.
- • To offer you information and answer your queries about Products or Services you request from us, along with updates on new products, services, discounts, special promotions, upcoming events, and features/offers we believe will interest you.
- To provide you with the requested Products, Services, or information.
- To send you notices about your account, including expiration and renewal notifications.
- To inform you about changes to our Website, policies, terms, offered Products or Services, or your account.
- To process your account application and any modifications to your account details.
- To handle Personal Information or other data you submit to us.
- To enable your participation in interactive features on our Website.
- To contact you about our own and third-party products and services that might intrigue you.
- To grant access to restricted sections of our Website, such as areas accessible to user accounts.
- To refine and enhance our products and Services through activities like internal research, user trend analysis, and demographics/interest measurement.
- For internal purposes like Website and system administration, internal audits, and reviews.
- For analyzing Service usage, diagnosing technical issues, maintaining security, and personalizing content.
- To operate, maintain, and deliver the features and functionality of our Services.
- To share usage statistics of the Website and related information with our service providers.
- To inform you about data privacy incidents or fulfill legally mandated information dissemination.
- To reach out regarding promotions, contests, or sweepstakes you've taken part in.
- To request your involvement in ratings, reviews, surveys, focus groups, or other initiatives aiding our product and Service enhancement.
- To fulfill any other purpose for which you provide Personal Information.
- For any other manner described and consented to when you provide the information.
We utilize cookies, clear gifs, and log file data for the following purposes: (a) To remember information, ensuring you don't have to re-enter it during your visit or on subsequent visits to the Website; (b) To provide tailored, personalized content and information; (c) To assess the effectiveness of our Service; (d) To track aggregate metrics like total visitors, traffic, and demographic trends; (e) To diagnose and resolve technology issues associated with specific IP addresses, reported by our users or engineers; and, (f) To facilitate efficient access to your information after signing in.
Your provided Personal Information, as well as information obtained from other sources, may be used to enhance our understanding of your preferences. This helps us anticipate your potential interests in other products, services, and information. This process involves automated decisions based on your information, aimed at tailoring our interactions to make them more relevant and engaging. If you wish to object to this practice, you can do so by reaching out to us.
Furthermore, the information we gather from you may be employed to allow us to present advertisements to the intended audiences of our advertisers. While we don't disclose your Personal Information for such purposes without your consent, if you engage with an advertisement by clicking or otherwise interacting with it, the advertiser might assume that you meet their targeted criteria.
Why Do We Collect Personal Information?
You hereby provide consent to receive informational and marketing communications and messages from us and our service providers regarding mortgage services. These communications may be conveyed by live agents, artificial, automated, or pre-recorded voices, via email, and through Short Message Service ("SMS") text messages to the phone number you have provided, whether it is your residence, mobile, or another contact number (hereinafter collectively referred to as "Contact Info"). Such communications may be initiated manually or by automated telephone dialing systems. In relation to SMS messages, you acknowledge that standard message and data rates may be applicable.
This consent extends even if your Contact Info is listed on our or our service providers' Do Not Call / Do Not Email List, a State or National Do Not Call Registry, or any other Do Not Contact List. You agree to promptly notify us if you cease using a specific number or address that you have previously provided to us. It is important to note that granting consent for the contact described in this section is not a requirement for purchasing our services, and you acknowledge your ability to withdraw this consent at any time. To do so, you can send an email to firstname.lastname@example.org.
You also acknowledge that automated messages or artificial/prerecorded voices may be utilized when the call is answered, whether by you or another individual. Additionally, you agree and acknowledge that we and/or our service providers may listen, record, and retain call recordings between us, our service providers, and you for quality assurance or other lawful purposes, without prior notice, as permitted by relevant laws.
Our services might include SMS messages, with the potential of delivering up to five messages daily to your wireless device. These messages may pertain to your information, purchases, Website updates, surveys, or other informational and service-related matters, including critical security updates. You maintain the option to discontinue these messages by replying "STOP" to the SMS message received. Upon sending "STOP," an SMS message confirming your unsubscribed status will be sent. Subsequently, you will no longer receive SMS messages from us. Should you choose to rejoin, simply follow the initial signup process, and SMS messages will resume. For assistance, respond to a text with "HELP." Message and data rates may be incurred, contingent upon your cell phone plan. Carriers bear no responsibility for delayed or undelivered messages. Alternatively, you may submit a request to halt SMS messages by sending an email to us, specifying the email address and phone number associated with your registration.
Social Media Plugins
We incorporate social media application program interfaces or plug-ins ("Plug-ins") from various social networks, including but not limited to Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest, and possibly others, into our Website. If you choose to register as a user on our platform, you might have the option to sign in using your Facebook or other social media site credentials.
For instance, when you visit our Website, these Plug-ins establish a direct link between your browser and the respective social network's server. This enables the social network to receive information about your visit to our Website, including your IP address. If, while logged into your Facebook account, you click the "Like" button on our Website, you can associate our Website's content with your Facebook profile. Consequently, Facebook may link your visit to our Website with your user account. Please be aware that as the Website provider, we do not receive any information about the content of the data transmitted or its utilization by Facebook. If you prefer Facebook not to link your visit to our Website with your user account, we recommend logging out of your Facebook account.
By taking this action, you grant us permission to access certain information from your social media site account, which can include your public social media profile (subject to your privacy settings on the social media site), email address, interests, likes, gender, birthday, education history, relationships, current city, personal description, photos, friend list, and details about your social media site friends who may share common connections with other users. Plug-ins may automatically transmit information about you to the respective platform without requiring any action on your part. This information could encompass your user identification number on the platform, the website you are currently visiting, and more. Engaging with a Plug-in leads to the direct transfer of information to that Plug-in's corresponding social network, potentially rendering such information visible to others on that platform.
How And To Whom Do We Disclose Your Personal Information?
We may share your Personal Information with our employees, contractors, consultants, and other relevant parties who require such information to support us in managing our relationship with you. This includes third parties that aid us in delivering services to you and those whose services contribute to our business operations.
Such third parties could encompass lenders and dealerships that intend to provide you with goods or services. Related parties involved in processing and storing your Personal Information for our benefit may also be included.
For instance, our third-party service providers may periodically offer information technology, data processing, advertising/marketing, and call center services to facilitate our business operations. As a consequence, your Personal Information might be collected, utilized, processed, stored, or disclosed in locations such as the United States of America, Canada, Europe (including the United Kingdom and Russia), India, or Asia (including China). Consequently, your Personal Information may be accessed, stored, or used in other countries, potentially subject to their respective legal frameworks. For example, information may be revealed in response to legitimate requests or demands from government authorities, courts, or law enforcement agencies in these countries.
In scenarios where you have explicitly requested it or demonstrated it through your actions, we may share your Personal Information with individuals who are considering your application for a loan, credit card, or another product or service. In relation to this, we and/or our third-party business affiliates might perform a credit check on your behalf to verify your financial situation and your eligibility for the requested products and services.
Additionally, your Personal Information might be revealed in the following situations:
- as authorized or mandated by relevant laws or regulatory obligations;
- to adhere to valid legal proceedings like search warrants, subpoenas, or court directives;
- as previously mentioned, to facilitate the management or fulfillment of your objective to secure credit from one or more third parties;
- to safeguard the rights and assets of our platform;
- in cases of emergencies or when essential to ensure the safety of individuals or a collective;
- with your explicit consent.
How We Share Your Personal Information
We may or do reveal your Personal Information, either in entirety or partially, to the following categories of third parties, and for one or more of the subsequent purposes:
- Data storage or hosting providers to ensure the secure storage and transmission of your data
- Database and software service providers to manage and monitor your data
- Technology providers aiding in the development and maintenance of our Website
- Identity management providers for authentication purposes
- Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
- Manufacturers, retailers, and wholesalers for processing and overseeing rebates, discounts, offers, loyalty rewards, and similar aspects
- Outbound call center providers conducting outreach on our behalf regarding our products and services
- Survey and research providers conducting studies on our behalf
- Publishers and learning providers developing products on our behalf
- Learning technology and online event providers for delivering and enhancing web events and learning programs, and tracking your progress
- Advertising partners, including social media providers, for targeted advertisement distribution
- Independent third-party list renters for approved one-time mail or email
- Marketing providers who may engage in selling mailing lists
Sharing with Service Providers: We might share your Personal Information with third parties to deliver or enhance the Services provided to you. This includes sharing your Personal Information with third-party service providers who perform tasks on our behalf ("Service Providers"). This encompasses, but is not limited to, Service Providers offering services related to outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing support, customer information management, customer or support services provision on our behalf, postal mail and email dispatch, eliminating redundant information from customer lists, furnishing search results and links (including paid listings and links), processing credit card payments, or overseeing our conferences and events. These Service Providers might access your Personal Information to furnish services to us or on our behalf. If we engage Service Providers for these purposes, their use of your Personal Information will be governed by confidentiality obligations, and their usage will be limited to providing the specified services to us. We may store Personal Information in locations beyond our direct control (e.g., on servers or databases situated or co-located with hosting Service Providers).
We will aim to inform you about such requests unless: (i) legal process, court order, or applicable law prohibits notice; or (ii) we believe that providing notice would be ineffective, counterproductive, pose a risk of injury or bodily harm to an individual or group, or lead to or exacerbate a risk of fraud against us, our users, our Website, or our Services. In instances where we comply with legal requests without prior notice due to these reasons, we will endeavor to notify the affected user after the fact if we determine in good faith that we are no longer legally restricted from doing so, and if the risk scenarios mentioned in this paragraph are deemed not applicable.
Disclosure of De-Identified Personal Information: Sharing of De-Identified Personal Information: We may share De-Identified Personal Information with third parties for various purposes. Such information, as well as non-Personal Information, may be aggregated for system management and to monitor Website usage. This aggregation helps assess the number of website visits, average visit duration, pages viewed, and other relevant statistics, enabling us to enhance content and user experience. De-Identified Personal Information or anonymous data (including, but not limited to, anonymous usage metrics, referring/exit pages and URLs, IP address, platform types, click count, etc.) may be shared with interested third parties for any intended purpose. We retain the right to disclose, sell, rent, or otherwise use your De-Identified Personal Information, potentially receiving compensation in return.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information: By providing us with your Personal Information, De-Identified Personal Information, and other supplied information ("Transferred Information"), you consent to our potential disclosure of this data to a prospective or actual buyer or acquirer of our company or other successors. This disclosure aims to facilitate considerations of mergers, divestitures, restructuring, reorganizations, dissolutions, changes in control, or sales/transfers of some or all of our assets (referred to as a "Transfer"), whether as a going concern or within bankruptcy, liquidation, or other legal proceedings where our Personal Information constitutes part of the transferred assets. You agree to, and hereby consent to, our assignment, transfer, conveyance, and/or licensing (via contract, merger, or operation of law) of any or all rights, either wholly or partially, in or to Transferred Information, including your consents. This can occur with or without your notice and without requiring your additional consent.
We cannot guarantee the use or transfer of Transferred Information during scenarios like bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By sharing any Personal Information, you explicitly consent to the use and/or transfer of Transferred Information in conjunction with a Transfer. Furthermore, except as legally mandated, we bear no responsibility for any security breaches by third parties or actions taken by third parties who receive Transferred Information disclosed to us.
Data Transfer/Access Outside of the United States
Our headquarters are located in both Canada and the United States. The Personal Information gathered by us or our service providers might be stored and processed on servers located within or outside the United States, as well as in facilities across the globe where we and our service providers operate. Consequently, certain information may be accessible to individuals or entities outside the United States who are engaged in providing services for us. This means that we and our service providers may transfer your Personal Information to, or access it from, jurisdictions that may not offer data protection standards equivalent to those in your home jurisdiction. We will take reasonable measures to ensure that your Personal Information benefits from an adequate level of protection in the jurisdictions where it is processed.
We have established safeguards designed to protect your Personal Information against accidental loss and unauthorized access, use, alteration, and disclosure. Your Personal Information is stored behind secure networks and firewalls, and it is accessible only to our authorized personnel and a limited number of Service Providers who possess special access privileges and are bound to maintain its confidentiality. Regular security scans are conducted on our Website to identify and address any potential vulnerabilities, ensuring a secure browsing experience.
Any payment transactions you make will be conducted through third-party payment processors or gateways that employ appropriate security protocols to safeguard your information. We do not collect or retain complete credit card numbers.
The security of your information also depends on your actions. Maintaining good internet security practices is crucial. When you have password-protected access to your account or specific parts of the Website or Services, it's your responsibility to keep your password confidential and not share it with anyone. Preventing unauthorized access to your account and Personal Information is important. Choose and safeguard your password properly and restrict access to your computer, mobile device, and browser by logging out after using your account.
If your email or social media accounts are compromised, they could be used to gain unauthorized access to your account with us if you've shared those details or granted access through those accounts. In case of such a compromise, promptly update your account credentials with us, especially ensuring that the compromised account can't grant access to your account with us.
Information shared in public areas might be visible to other users. Be cautious when sharing sensitive information. We will never request your password or other account login details via email. If you receive such an email, please forward it to us for investigation.
The duration for which we keep your Personal Information is contingent upon the purposes for which we utilize it. We will hold onto your Personal Information for the duration of your active account or as long as you remain a registered user of our Services. Additionally, we may retain it for other legitimate business motives, such as tax, legal, or operational necessities. After these periods, we will not retain your information for longer than what is stipulated by applicable law, our records retention policy, or what's reasonably needed for internal reporting, reconciliation, or to fulfill any information requests you may have. This retention timeline is subject to potential adjustments based on our periodic review.
We may choose to retain De-Identified Personal Information for a duration that we consider suitable.
Your Consent is Important to Us
Maintaining your privacy is of utmost importance to us, which is why we gather, utilize, and reveal your Personal Information only with your consent. Depending on the sensitivity of the information, your consent may be expressed, implied, or deemed (through an opt-out method). Express consent can be granted orally, electronically, or in writing. Implied consent arises when your actions or inaction reasonably indicate agreement. For instance, when you engage in an agreement with us, we assume your consent for collecting, using, and disclosing your Personal Information for tasks connected to that agreement, as well as any other purposes communicated to you at that juncture.
However, as previously detailed, we may gather, use, or disclose your Personal Information without your awareness or consent as allowed or required by applicable laws or regulatory stipulations.
You have the right to modify or retract your consent at any point, taking into account legal or contractual obligations and providing reasonable notice. To do so, you can get in touch with our Privacy Officer using the contact details provided below. Any communications related to changing or withdrawing your consent should be in written form and directed to our Privacy Officer.
However, please note that in specific situations, withdrawing your consent might impact our ability to continue offering products or services that require the collection, use, or disclosure of your Personal Information.
How is Your Personal Information Protected?
We strive to uphold suitable physical, technical, and procedural measures tailored to the sensitivity of the specific Personal Information. These precautions are intended to mitigate the risks of loss, unauthorized access, copying, use, alteration, or disclosure of your Personal Information.
Ensuring the security of your Personal Information is a top priority for us. If you encounter any incident involving the loss, unauthorized access, or disclosure of Personal Information under our custody or control, please promptly inform our Privacy Officer.
Updating Your Personal Information
Maintaining accurate and up-to-date information in our records is crucial. Should your Personal Information change while our relationship is ongoing, kindly notify our Customer Care department about the update. If you encounter any challenges with the Customer Care department, please feel free to reach out to our Privacy Officer using the provided contact details.
There might be cases where we cannot accommodate your request to modify your Personal Information. Instead, we may choose to add an alternative note to the relevant record in such situations.
Access to Your Personal Information
You have the option to request access to your Personal Information. If you wish to review, verify, or correct your Personal Information, please get in touch with our Customer Care department. In the event that our Customer Care department is unable to assist, please reach out to our Privacy Officer using the provided contact details. It's important to note that any such requests should be submitted in writing.
When making a request to access your Personal Information, please be aware that we might ask for specific details to confirm your identity and your right to access. This will also help us locate and provide you with the relevant Personal Information we hold about you. There could be a fee associated with accessing your Personal Information, which we will inform you about in advance. If you require guidance in formulating your request, you can contact our Customer Care department. If the Customer Care department is unable to assist, please connect with our Privacy Officer using the provided contact information.
While you have the right to access your Personal Information, it's important to understand that this right is not absolute. In some cases, applicable laws or regulatory requirements might allow or compel us to decline providing certain or all of the Personal Information we hold about you. Additionally, there could be instances where the Personal Information has been disposed of, erased, or anonymized in accordance with our obligations and practices for retaining records.
In situations where we cannot grant you access to your Personal Information, we will make an effort to provide you with an explanation, considering any legal or regulatory limitations.
NOTICE TO CALIFORNIA RESIDENTS
We are obligated to comply with the California Consumer Privacy Act of 2018 ("CCPA") by providing California residents with an explanation of how we collect, use, and share their Personal Information, as well as informing them of the rights and choices available to them concerning the handling of their Personal Information (referred to as the "Notice").
Under California law, residents are afforded certain privacy rights, including the following:
- Access to Personal Information: Those exercising this right can receive further details about the sources from which we collect information, the purposes for which we collect and share Personal Information, the information we hold about them, and the categories of parties with whom we share their information.
- Disclosure: Individuals exercising this right can request the deletion of their collected Personal Information, although certain purposes may permit us to retain it. • Non-Discrimination: Users can freely exercise these rights without fear of being denied goods or services based on their choices.
- Deletion: Individuals exercising this right can ask us to delete their Personal Information we have collected, though we may be permitted to retain Personal Information for certain purposes.
- Non-Discrimination: Users can freely exercise these rights without fear of being denied goods or services based on their choices.
- "Opt Out" of Sales: According to applicable law, we might share Personal Information for monetary or valuable consideration (referred to as a "sale" under California law). You have the option to opt out of such "sales" of your Personal Information to third parties. You can exercise this right by sending an email to us using the contact information provided below.
CCPA Scope and Exclusions
The information provided in this Notice regarding our Privacy Practices and Privacy Rights under the CCPA pertains exclusively to California residents whose interactions with us fall within the following categories:
- Visiting our consumer websites,
- Subscribing to email alerts,
- Participating in discussions or contributing to our blogs
- Establishing an account, which may or may not include financial products or services
- Applying for job openings on our websites or third-party sites (please note that Privacy Rights under the CCPA do not extend to job applicants)
- The information outlined in this Notice about our Privacy Policies and CCPA Privacy Rights does not cover the Personal Information we collect, use, or disclose pertaining to:
- Consumers who initiate or complete the application process for financial products or services. This is due to such information being subject to the federal Gramm-Leach-Bliley Act ("GLBA") and its implementing regulations, or the California Financial Information Privacy Act ("FIPA").
- Representatives of businesses that seek to obtain our products or services, or those intending to provide products or services to us.
It's important to note that the CCPA imposes limitations on these rights. For instance, it prohibits us from providing certain sensitive information in response to an access request and defines specific circumstances in which we are obligated to comply with a deletion request. We will address requests for information and access to the extent that we can reasonably associate the information we maintain with the identifying details provided in your request. If your request is denied, we will communicate our decision to you.
You are entitled to exercise the aforementioned rights without experiencing any form of discrimination.
The CCPA mandates that we authenticate the identity of the person making a request to access or delete Personal Information before furnishing a substantial response to the said request. Upon submitting a request, we will require you to confirm your identity.
California residents have the option to authorize an "authorized agent" to make requests on their behalf. To ensure this, we will need the authorized agent to present a written authorization verifying their authority.
"Sales" of Personal Information in the Previous 12 Months: Within the last twelve months, we have engaged in the "sale" (as per the CCPA's definition) of the subsequent categories of Personal Information:
- Personal information categories in the California Customer Records statute
- Characteristics of protected classifications under California or federal law
- Commercial information
- Internet or similar network activity
- Geolocation data
- Professional or employment-related information
- Inferences derived from other personal information
We have conveyed Personal Information to the third parties or categories of third parties as outlined on our website at https://americanbenefitprogramme.com/service-providers/.
Privacy Rights Notice For Nevada Residents Only
Residents of Nevada hold the right to opt-out of the sale of their Personal Information. To exercise this right, kindly send an email to email@example.com with "NV Sale Opt Out Request" in the subject line. Please be aware that we will undertake reasonable measures to verify your identity and the validity of the request. We are committed to responding to your request within sixty (60) days. Once verified, your opt-out preference will be maintained in the event of any changes to our practices. Please be advised that this right does not extend to business-to-business customers, employment applicants, independent contractors with us, or instances where the disclosure of Personal Information aligns with the reasonable expectations of the Nevada resident, considering the context of the submission.
Notices; Opting Out
When you provide us with your email address, whether by "following," "liking," linking your account to our Website or Service on a third-party website or network, or similar actions, you are granting consent for us to use your email address for sending you Service-related notices via email. This includes any notices that may be required by law (such as notifications of data privacy or security incidents), instead of using postal mail for communication. Additionally, you acknowledge that we may send you notifications related to activities concerning the Service, the Website, your Personal Information, or any aspect of our interaction, using the email address you have provided, in accordance with relevant privacy settings.
We may utilize your email address to dispatch other messages or content, such as newsletters, updates to Service features, or special offers, among other things. Should you prefer not to receive such email communications, you can opt out by sending us an email with your opt-out request or by utilizing the "unsubscribe" link located at the bottom of our e-newsletters, if available. It's important to note that opting out might result in you not receiving email messages concerning updates, improvements, special features, announcements, or offers. However, you cannot opt out of emails related to the Service itself.
You maintain the ability to add, modify, or remove your information as previously described. In cases where you update your information, a copy of the unaltered information might still be retained in our records. If you wish to have your account deleted, you can request this by emailing us. Please remember that it is your responsibility to ensure that your current email address is kept up to date with us.
Inquiries or Concerns?
In the event that you find our response unsatisfactory, you have the option to make a written submission to the Privacy Commissioner in your jurisdiction. Your satisfaction and the security of your Personal Information are our top priorities.
- By Email to: firstname.lastname@example.org