LAST UPDATED: Jan 1, 2019
- Publicly available information form government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994
Information we collect, sell, or disclose
Over the past 12 months we have collected the following categories of information about consumers. We do not sell any personal information either anonymized or identifiable. We do not sell (as defined by the CCPA) personal information of minors under 16 years of age. This information is collected in connection with the making or servicing of loan products, and for marketing products we offer:
Identifiers, such as name, address, email address, social security number, and driver’s license number.
Personal Information Categories Listed in the California Customer Records Law, such as telephone number, financial information such as income and credit bureau information, bank account number, credit or debit card number, and medical information.
Protected Classification Characteristics Under California or Federal Law, such as age, citizenship, marital status, and veteran or military status.
Commercial Information, such as records of personal property, products, or services purchased.
Biometric Information, such as voiceprints through recording of calls with consumers.
Internet/Electronic Network Activity, such as browsing history and interactions with our websites.
Professional/Employment-related Information, such as employment history.
Non-Public Education Information, such as school completion status, grade point average, college plans and student financial information.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from consumers, such as when they apply for one of our products.
Indirectly from consumers, such as when they access our website and through the use of tracking technologies such as cookies.
From our clients, for whom we service one of their customers’ loan or debt on their behalf.
Marketing partners from whom we buy or obtain lists for marketing purposes.
Consumer reporting agencies, for purposes of obtaining credit information when a consumer applies for a loan with us.
Publicly available data sources.
Under the CCPA, “sell” includes disclosing or communicating personal information, and not necessarily a monetary exchange for personal information. We do not sell your personal information under the traditional definition under any circumstances.
Right to request deletion of information
You have the right to request we delete the personal information we collected from you, unless the CCPA recognizes an exception.
How To Exercise Your Rights: We will need to verify your identity before processing most requests, which may require you to provide additional information. In some instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity.
You may submit a request by using our self-service Personal Information Request Form and our Deletion Request Form, or by calling us at 1-415-630-2323.
All requests for Your Right To Know will be honored within forty-five (45) days of receipt, unless we are unable to process your request in such a time, in which case we will provide you an explanation for the delay
Right to Opt-out of the sale of personal information
Under the CCPA, “sell” includes releasing, disclosing, disseminating, making available, transferring, or otherwise communicating personal information, in addition to the traditional definition of a monetary exchange. The definition does not include sharing personal information with a service provider if the service provider does not further collect, sell, or use the personal information beyond the business purpose for which it was shared. Certain activities with a service provider are excluded in the definition. You have a right to opt out of the sale of your personal information.
We do not sell personal information as defined in the CCPA. However, in the event we decide to sell personal information in the future, you may submit your request to opt out of the sale of information here.
Right to Non-Discrimination for the exercise of your privacy rights
You have the right to be protected from discrimination for exercising your CCPA rights. We will not discriminate against you for exercising your rights under the CCPA by doing any of the following: denying goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to the consumer; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Designating an Authorized Agent
You may use an Authorized Agent to submit a request to know or a request to delete. The person (or business registered with the California Secretary of State) you may have previously designated to act on your behalf for another purpose with us may be used to submit this request for you. If you haven’t previously designated an Authorized Agent, you may do so by contacting us.