Table of Contents
- Notice at Collection
- Personal Information We Collect, Use, and Share
- How We Use Your Information
- Disclosure of Personal Data
- Do Not Track Signals
- Cookies, Other Tracking Devices, and Targeted Advertising
- Your Privacy Rights and Choices
- Data Retention
- Other Websites
- Notice to California Consumers
- Your California Privacy Rights
- SHINE THE LIGHT
- Notice to Residents of Colorado, Connecticut, Utah, or Virginia
- Contact Us
The Sites are intended for adult use only, and we do not knowingly collect any Personal Information from a minor. If you learn that a child has, in violation of this Policy, provided their Personal Information, please report it to us for deletion. In the event that we learn that a child has provided us with Personal Information, we will delete it. Please see section 11, “Children,” for more info.
We may collect or process various categories of Personal Information. The section directly below titled, “Personal Information We Collect, Use, and Share,” contains information on the categories of Personal Information collected and/or whether we sell or share Personal Information. As an overview, we may collect identifiers, personal information categories contained in customer records, characteristics of protected classifications, commercial information, professional or employment-related information, education information, internet, technical, or other similar electronic network activity information, sensitive Personal Information, and inferences drawn from other Personal Information. We retain the information for as long as needed to meet the purpose of processing and in accordance with this Policy.
If you have a request regarding your information and would like to exercise your rights under applicable law, please contact us through the methods provided in the, “CONTACT US,” section below. To exercise your right to ask that we do not sell, share, or use your Personal Information for targeted advertising, please click the, “Do Not Sell or Share My Information,” link or call (888) 775-0859.
For purposes of this Policy, “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household. Below, we describe how we will handle your Personal Information in accordance with this Policy and describe the information we may have collected, how it may be used or shared, and the sources below.
3.1 INFORMATION YOU PROVIDE
We may collect Personal Information when you voluntarily provide it to us through our forms on our Sites, including the information you provide to our service providers or other parties who collect it on our behalf in relation to our Services. For example, this could include Personal Information such as name, address, email address, telephone number, social security number, and date of birth.
Your decision to provide any Personal Information is voluntary. However, please note that if you do not provide certain Personal Information, we may not be able to accomplish some purposes outlined in this Policy and you may not be able to use or access certain Services on our Sites.
3.2 AUTOMATICALLY COLLECTED INFORMATION
3.3 INFORMATION FROM THIRD PARTIES
We may obtain additional information about you from third parties such as marketers, affiliates, partners, researchers, social networks, service providers, data services companies, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide. We may also obtain Personal Data indirectly, such as from publicly available sources (e.g., websites or publicly accessible databases), third-party data vendors, and third-party partners and collaborators. We may combine Personal Data from multiple online and offline sources.
We use your information for business purposes, including to provide the products and Services you request, to perform customer service functions, for security and fraud prevention, for marketing and promotional purposes, and to perform website and application analytics. Listed below are additional ways we may utilize the information we collect about you to:
- Provide Support and Products. Including to provide our products, including our Website, applications, and online Services; to communicate with you about your access to and use of our products and Services; to respond to your inquiries; to provide troubleshooting; to fulfill your orders and requests; to process your payments and provide technical support; and for other customer service and support purposes.
- Provide the Features, Products, and Services You Request. We may use the Personal Information we collect to fulfill your requests for, and to enable your use of, our features, products, and Services. This includes payment processing for purchases, subscriptions, or sales; to protect against or identify possible fraudulent transactions; contacting you; improving our Sites, our products, and Services; tailoring your experience on our Sites; for internal business purposes; and to otherwise maintain and administer our Sites and our business.
- Analyzing and Improving Products and Operations. We may use this information to better understand how users access and use our products and Services; to evaluate and improve our products, Services, and business operations; to develop new products and Services; to conduct surveys and other evaluations (such as customer satisfaction surveys); and for other research and analytical purposes.
- Personalizing Content and Experiences. We use Personal Information to tailor the content we send or display on our Websites and other products and to otherwise personalize your experiences.
- Securing and Protecting Our Business. Including to protect and secure our business operations, assets, products, network information, and technology resources; to investigate, prevent, detect, and take action regarding fraud, unauthorized access, and situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
- Corporate Governance and Internal Operations. Including our general business, accounting, record keeping, and legal functions; legal compliance; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business.
- Advertising, Marketing and Promotional Purposes. Including reaching you with more relevant ads and evaluating, measuring, and improving the effectiveness of our ad campaigns; sending you newsletters, offers or other information we think may interest you; contacting you about our products or information we think may interest you.
- Complying with Legal Obligations. Including complying with the law, our legal obligations, and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests.
- Defending our Legal Rights. Including managing and responding to actual or potential legal disputes and claims, and otherwise establishing, defending, or protecting our rights or interests, including in the context of anticipated or actual litigation with third parties.
- When We Perform Our Duty in a Contract With You. We may use your Personal Information when you work as a service provider or apply for a job with us, as needed. If you are a consumer or a user of our Services, we will use your Personal Information to fulfill our duty in our agreement with you.
- To Assess and Accept Franchisees, Customers, or Vendors. This includes verifying the identity and credit status of some franchisees, customers, or vendors, conducting due diligence, and screening against publicly available government and/or sanctions lists and other third-party data sources, the use of and participation in the Company’s incident registers, and sector warning systems and/or third-party verification services. Collecting this Personal Information may involve a reference agency or other third parties.
- To Improve the Features, Products, and Services That We Offer Through the Sites. We may use Personal Information to improve our product offerings, Services, as well as our Sites and features.
5. DISCLOSURE OF PERSONAL INFORMATION
We may share or disclose Personal Information with third parties to carry out the above business purposes, including our affiliates and service providers. We may also share your Personal Information with third parties to whom you consent to us disclosing your Personal Information. Prior to sharing Personal Information with these third parties, we review the services performed by each third party and require that the third party keep such Personal Information confidential and secure and not use it for any purpose except performing the services.
We generally share Personal Information with third parties for the business and commercial purposes described below:
- With Our Affiliates, Vendors, and Subsidiaries. We disclose your Personal Information to our corporate affiliates, including our holding company, sister companies, and subsidiaries for the purposes described in the, “HOW WE USE YOUR INFORMATION,” section above. We also have relationships with various vendors that help us operate our business and for whom it may be required to have access to your Personal Information in the course of providing services. We require them to handle your Personal Information collected through the relationships in accordance with appropriate contractual privacy and security provisions.
- With Our Service Providers. We disclose Personal Information to unaffiliated companies or individuals we hire or work with that perform services on our behalf, including customer support, web hosting, information technology, payment processing, financing, product fulfillment, fraud control, marketing and database management, direct mail and email distribution, events, and advertising and analytics services. These service providers have access to Personal Information needed to perform their services but may not use it for other purposes.
- With Contractors and Third-Party Partners. We disclose Personal Information to unaffiliated companies or individuals we partner with to provide certain products, services, or experiences to you. For example, we disclose Personal Information to third parties that provide financing for your service or request. We also permit certain third parties, like our fraud prevention partners, to collect Personal Information in order to detect and prevent fraudulent transactions.
- In Connection with a Corporate Transaction. Personal Information may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization, or financing.
- With Our Professional Advisors. We disclose Personal Information to our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of lendchoice.com’s business or operations.
- With Your Consent or at Your Direction. We disclose Personal Information such as profile data and communications data to third parties when we have your consent or direction to do so.
- Aggregated, Anonymized or De-identified Data. We may also disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you. lendchoice.com processes, maintains, and uses this data only in a de-identified fashion and will not attempt to re-identify such data, except as permitted by law.
6. DO NOT TRACK SIGNALS
The “Do Not Track” (“DNT”) privacy preference is an option that may be utilized in some web browsers allowing you to opt out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We, therefore, do not recognize and/or respond to all DNT signals.
A cookie is a small piece of data sent from the Sites and stored in a user’s web browser while the user is browsing Sites (“Cookie”). Every time the user loads Sites, the browser sends the Cookie back to the server to notify the Sites of the user’s previous activity. Web beacons (also known as image tags, gifs, or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views, or advertising responses (“Web Beacons”). We also utilize pixels in connection with our email communications and in connection with the Sites. Our Sites’ web servers automatically collect and may use your Cookies, Web Beacons, pixels, and other similar tracking technologies (collectively “Tracking Technologies”) to collect information as you browse our Sites. We use Tracking Technologies, web server log files and tracking code, and information we receive through the use of these Tracking Technologies to analyze trends, administer the Sites, track users’ movement, and gather broad demographic information for aggregate use. Information of this type may be combined with other sources of information for these purposes.
Some of these Tracking Technologies may be placed by third-party service providers to help determine the effectiveness of our advertising campaigns or email communications. These Tracking Technologies may be used by these service providers to place a persistent Cookie on your computer. Doing this allows the service provider to recognize your computer each time you visit certain pages or emails and compile anonymous information in relation to those page views. The use of Tracking Technologies by third-party service providers is within their control and not ours. We do not control their sites or their policies and practices regarding your information and you should be aware that different rules might apply to the collection, use, or disclosure of your information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet. This Policy does not cover any use of information that a third-party service provider may directly collect from you and we do not undertake to confirm, investigate, or police their practices.
You have the right to choose whether or not to accept Cookies. However, they are an important part of how our Services work, so you should be aware that if you choose to refuse or remove Cookies, this could affect the availability and functionality of the Services. You may reject Cookies, Web Beacons, and entity tags by adjusting the appropriate settings in your browser. Each browser is different, but many browsers have preferences or options that may be adjusted to allow you to either accept or reject Cookies and certain other technologies before they are set or installed, or to allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser.
When it comes to your data, we’re committed to providing you with choices and controls. We offer all individuals, regardless of residency, certain privacy choices that you can manage about how we contact you and how we use or share your information. Additionally, you have choices about how certain third parties and advertisers use your information, including how we use and share your information for advertising and marketing purposes. Residents of certain states (such as California, Colorado, Connecticut, Utah, and Virginia) are afforded additional privacy rights by applicable law. We comply with all state and federal laws and you can learn more about those rights and choices in the “NOTICE TO RESIDENTS OF COLORADO, CONNECTICUT, UTAH, OR VIRGINIA,” section below.
8.1 Right to Non-Discrimination.
Applicable law prohibits unreasonable adverse treatment or retaliation of individuals for exercising their rights.
We will retain your information for as long as needed to provide you with products and Services, and to comply with our accounting and legal obligations, resolve disputes, and enforce our agreements. Your Personal Information will be destroyed or permanently deleted as required by applicable law.
lendchoice.com uses reasonable technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. Unfortunately, no transmission of data over the Internet is guaranteed to be completely secure. While we strive to protect your Personal Information, we cannot ensure or warrant the security or confidentiality of any Personal Information you transmit to us.
We do not knowingly collect, use, share, or sell the Personal Information of individuals under the age of 16 and this Site is not directed to individuals under 16. If you become aware that an individual under 16 has provided us with Personal Information, please contact us through the methods provided in the, “CONTACT US,” section below or by visiting our “Contact Us” form. If we are made aware that we have collected Personal Information from an individual under the age of 16, we will delete this information as soon as practicable.
We reserve the right to modify or amend this Policy at any time and for any reason. Changes to this Policy shall be effective when posted to the Sites. In case of any material change to the Policy, we will notify you by providing a prominent notice on the Sites or by using the contact information you have on file with us. We will also revise the “Updated” date at the top of this Policy. You are responsible for reviewing this Policy each time you use or access the Sites. Your continued use of the Sites is an acknowledgment and consent to any terms contained in this Policy, as it may be amended from time to time. By visiting our Sites, you acknowledge and agree that you have read this Policy and agree to the collection, use, and other processing of your information in accordance with the practices described in this Policy. If you do not agree to any or all of the terms, conditions, and practices set forth herein, do not access the Sites or any of its pages.
If you are a California resident, California law requires us to disclose the following additional information with respect to our collection, use, and disclosure of Personal Data. If you are a California resident, this section applies to you.
14.1 Categories of Personal Information We Collect
14.2 Categories of info lendchoice.com May Have Collected in the Preceding 12 Months. lendchoice.com may have collected the following categories of Personal Info: (i) identifiers, such as a name, email address, telephone number, postal address, unique personal identifier, online identifier, IP address, account name, Social Security number, driver’s license number; (ii) personal identifiers under Cal. Civ. Code § 1798.80(e), such as education, employment status, bank account information, financial information, medical information; (iii) protected classification characteristics under California or federal law, such as age, marital status, medical condition, gender, veteran or military status; (iv) commercial information, such as products or services obtained or considered, or other purchasing or consuming histories or tendencies; (v) Internet or other electronic network activity, such as browsing history and search history information; (vi) geolocation data; (vii) professional or employment-related history, such as consumer-reported current or past job history; (viii) inferences drawn from some of the information above (e.g., email open rates and time); and (ix) sensitive Personal Information, such as Social Security number, driver’s license number, and medical information.
14.3 Sources of Data lendchoice.com Collects.
lendchoice.com collects Personal Information from various sources, including directly from You, the consumer, who visits or engages with our Sites, in addition to the following categories outlined below.
Partners and Third Parties: Consumers who visit websites our Partners own may be redirected to our Sites. In some cases, we may gather data directly from our Affiliate or Partner websites, or other third parties may post data to our Sites or otherwise transfer data to us. This may occur via display ads, click listings, inquiry forms, or telephonic transfers from our Partners’ or Affiliates’ call centers. Our Advertising Partners may also provide us with data.
Service Providers: lendchoice.com engages service providers to perform a variety of functions (e.g., verifying consumer consent, validating email addresses or phone numbers).
Authorization: We require all parties from whom we receive Personal Information, whether they are Partners, service providers or other third parties, to represent and warrant to us that they have appropriately obtained the Personal Information provided to us and have the authority to share the Personal Information with us.
14.4 Purposes for Which Personal Information is Collected and Used
14.5 Categories of Third Parties with Whom lendchoice.com Has Disclosed Personal Information for a Business Purpose.
lendchoice.com may also disclose or sell such data and Third-Party data to other lendchoice.com businesses or with a third party in the event of a sale or transfer of all or part of our business.
Additionally, lendchoice.com may disclose Personal Information and Third-Party data (e.g., identifiers, personal identifiers, protected classification information, geolocation data, and inferences) with service providers who assist us in compliance and verification activities, or provide services, such as payment processing, IT, and data analysis information.
14.6 Categories of Personal Information Sold or Shared.
Under California law, some uses of Cookies and similar Tracking Technologies may be characterized as “selling” or “sharing” Personal Information. Because we use such Tracking Technologies, in the preceding 12 months we may have “sold” or “shared” the following categories of Personal Information for commercial purposes, such as to serve advertisements, to analyze the success of marketing campaigns, or to understand the use of our Websites, and such receiving entities may use the Personal Information for their own purposes, such as to improve their ability to target advertisements. As described above in Section 5, ”Disclosure of Personal Data,” lendchoice.com may disclose or sell Personal Information and Third Party data, including identifiers, internet activity, personal identifiers, and protected classification characteristics (e.g., name, email address, telephone number, browsing history, education, bank information, veteran or military status, browsing history, geolocation data) to Advertising Partners who can provide the consumer with information about the products and services they are seeking or to otherwise serve advertisements, analyze the success of marketing campaigns, or to understand the use of our Websites, and such receiving entities may use the Personal Information for their own purposes, such as to improve their ability to target advertisements.
14.7 Retention of Personal Information.
We retain Personal Information only for so long as reasonably needed to fulfill the purposes for which we collected or obtained it. We use reasonable business criteria to establish retention periods for Personal Information. For example, if you register on our Sites, we will store your Personal Information for as long as needed to maintain your account, fulfill your requests, enforce any applicable terms that govern your use of the Sites, maintain appropriate records of the above, or as otherwise required by law.
Under the CPRA, a California resident has Privacy Rights that enable each resident a:
15.1 Right to Know and Access Your Personal Information
Under the CPRA, you have the right to request that we provide you with information regarding what Personal Information about you we have collected, used, disclosed, shared, or sold in the preceding twelve (12) months. Once we receive your request and verify your identity, we will disclose to you one or more of the following as requested: The categories of Personal Information we have collected about you in the preceding twelve (12) months; The categories of sources from which we collected your Personal Information in the preceding twelve (12) months; The business or commercial purposes for collecting your Personal Information in the preceding twelve (12) months; The categories of third parties to whom we disclosed your Personal Information in the preceding twelve (12) months; and The specific pieces of Personal Information we collected about you in the preceding twelve (12) months.
15.2 Right to Delete Your Personal Information
You have a right to request the deletion of your Personal Information that we have collected or have maintained in the past 12 months. However, this right to deletion does not apply to any of your Personal Information that is subject to an exception under the CPRA. Once we receive your request and verify your identity, we will delete (and direct our contractors and service providers to delete) your Personal Information in our records that is not subject to any of the CPRA exceptions.
15.3 Right to Correct
You have the right to request us to correct inaccurate Personal Information we maintain about you.
15.4 Right to Opt-Out of the Sale or Sharing of Personal Information
You have the right to opt out of the “sale” or “sharing” of your Personal Information to a third party for cross-context behavioral advertising, as those terms are defined by applicable California law.
15.5 Right to Non-Discrimination
You have a right to not receive discriminatory treatment by us for the exercise of these privacy rights under the CPRA.
15.6 Authorized Agent
15.7 California Privacy Rights Act Reporting
Please visit our California Privacy Rights Act Reporting page to view our metrics regarding consumer requests and responses.
15.8 Contact Us
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of Personal Information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
To request a copy of the information disclosure provided by lendchoice.com pursuant to Section 1798.83 of the California Civil Code, please submit a request to [email protected].
For more information on data subject rights requests and how to submit a request, please visit our Notice to Residents of Colorado, Connecticut, Utah, or Virginia page. Please note that you may need to verify your identity and request before further action is taken. As a part of this process, you may be required to provide Personal Information, such as your name, state of residence, phone number, and email address associated with your account, and/or government identification. Consistent with applicable laws, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, we may require that (i) you or your authorized agent provide a valid power of attorney; (ii) the agent provide proof that you gave the agent signed, written permission to submit the request; (iii) you verify your identity with us; and/or (iv) directly confirm with us that you provided the authorized agent permission to submit the request.