Updated November 25, 2019
If you apply for or obtain a financial product or service where we function as a service provider
In connection with your use of the Services, we collect two types of information about you:
User Personal Information. User Personal Information includes information about you, such as: name, user name(s), mailing address, email address, and primary telephone number. In addition, if you acquire any Services via the Site that require payment, we may obtain certain financial information, solely for the purpose of processing such payments.
General Information. General Information includes technical information such as information regarding your use of and interactions with the Site. This General Information includes, but is not limited to, information about (i) your Internet connection, (ii) the equipment you use to access the Site and usage details, (iii) your operating system, browser version and internet protocol (IP) address, (iv) your mobile device type, your device's unique identifier, and your mobile network information, and (v) web pages, content, communications, or advertisements that you view or otherwise interact with, and (vi) referring/exit pages, clickstream data, and information that you search for using the Services.
Information Provided by You. We collect any information you provide when you use the Services. For example, we collect User Persona; Information from you when you (i) register an account on the Site or (ii) fill out forms or fields on the Site. We also collect any information you may submit through communications with us by email, mail, text, telephone, facsimile or other means.
Information We Collect When You Use Our Services. We automatically collect General Information from your computer, mobile device or other device you use when you access the Services (including downloading and using a mobile application or accessing a mobile optimized Site), view content about the Services on a third-party website or open emails or links in emails from us.
Service-Related Usage. We use the information we collect about and from you, both in a personally-identifiable form and in an aggregated or anonymized form, for a number of purposes, including for providing, supporting, promoting, and improving the Services. Such uses include:
Enabling users to obtain products and services through the Services;
Facilitating marketing, processing, servicing, and collections activities;
Providing customer support;
Understanding, customizing, and enhancing user experience;
Providing targeted marketing and advertising;
Determining your eligibility for the Services;
Verifying your identity, conducting appropriate diligence, and keeping your information current;
Creating an account connection between your account and a third-party account or platform;
Sending notifications and information regarding the Services;
Measuring and improving the performance and functionality of the Site;
Managing and protecting our information technology infrastructure;
Administering and managing the security of the Site;
Developing new products and services; and
Compiling, using, researching, analyzing, and generating data analytics reports to better understand our Customers and to improve the Services;
Communications. We may communicate with you using the information collected (i) for customer service, (ii) to provide you with updates or information relating to the Services, or (iii) to conduct surveys and collect feedback about the Services.
Marketing and Advertising. We may use the information we collect for marketing and advertising purposes, such as providing you with promotional materials that may be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications. To learn more about your choices regarding interest-based advertising and cross-device tracking, please see the Third-Party Information Collection section below.
Other Purposes. We may use the information we collect for other purposes for which we provide notice to you at the time of collection or for which we obtain your consent.
Aggregate Data. We may process your information in an anonymized or aggregated form for purposes other than described above.
We may share User Personal Information and General Information as follows:
Service Providers. We may engage service providers to assist us in providing Services. We may share any information we receive with such parties as is necessary for the provision of the Services.
As Required By Law and Similar Disclosures. We may disclose your information if we believe doing so is required or appropriate to (i) comply with applicable laws and regulations, (ii) comply with regulatory investigations, enforcement requests, and legal process, such as subpoenas, court orders, and bankruptcy notices, (iii) respond to your requests or resolve disputes or inquiries, (iv) detect, prevent, or otherwise address fraud, confidentiality, security or technical issues, (v) respond to regulatory authorities jurisdiction over us for examinations, compliance, or other purposes and (vi) protect your, our, or others' rights, property, or safety, or the security or integrity of our Services.
Business Partners. We may disclose information about you with business partners in connection with jointly offered products and services, as well as products and services offered by these partners and made available through the Services or which we believe may be of interest to you or your business. These business partners are subject to contractual obligations entered into with us restricting how they may use this information.
Corporate Changes. We may disclose your information in connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets; equity or debt financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.
Consent. We may disclose your information to any third party with your consent. For example, we may disclose information at your direction, as described at the time you agree to share, or when you authorize a third-party application or website to access your information.
Other Purpose. To fulfill the purpose for which you provide such information to us or any other purpose disclosed by us when you provide the information to us.
We may work with third-party advertising partners (e.g., Facebook) to display advertisements on the Site and other websites and mobile applications and third-party analytics partners (e.g., Google Analytics) to evaluate and provide us with information regarding your use of the Site. We may also utilize framing techniques to serve you content from third-party providers, while preserving the look and feel of the Services. In such cases, you will be providing information to these third-parties.
If you are a user of our applications, we may send push notifications or alerts to your mobile device even when you are not logged in. We may use push notifications to send you notifications related to the Services and various triggers based on your selections. You can manage your push notification preferences or deactivate these notifications by turning off notifications under settings for your mobile device. If you choose not to receive push notifications, you may still receive in-app notifications.
You may choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails. You may also request that we do not call you for marketing-related purposes. In addition to following the unsubscribe instruction in relevant email communications, you may make these requests by contacting us at firstname.lastname@example.org, Subject: Opt-Out Requests. We will respond to your request within a reasonable timeframe. In addition, if you no longer wish to receive marketing notifications through our mobile applications you can adjust your device's privacy preferences by visiting the settings page of the device. Opting out of marketing emails or notifications will not stop your receipt of non-marketing emails and notifications related to the Services.
Various browsers may offer their own tools to manage cookies. If you disable cookies, you can still use the Services, but your ability to use some features of the Services may be limited.
We take reasonable measures, including administrative, technical, and physical safeguards to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. Your information is securely sent to us with at least 128 bit-encryption over the Transport Layer Security (TLS) protocol. This creates an encrypted connection between your browser and us so that any sensitive information you provide can be securely transmitted. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
If you link your bank account information as a part of applying for or receiving the Services, we will have read-only access to such information. We do not have access to change, edit, or modify your bank account information. We also cannot see your banking credentials (i.e., username and passwords). You are responsible for securing and maintaining the privacy of your banking credentials and account information. We are not responsible for protecting any information we share with a third-party based on an account connection that you have authorized.
The Site collects information that identifies, relates to, describes, references, capable of being associated with or could reasonably be linked, directly or indirectly, with a consumers or device ("personal information"). In particular, the Site has collected the following categories of personal information from consumers within the last twelve (12) months:
|Identifiers||A real name, Internet Protocol address, email address or other similar identifiers|
|Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application or advertisement|
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
We may use, or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose (or sell your personal information, subject to your right to opt-out of those). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.
In the preceding twelve (12) months, Company had not sold personal information.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice's effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
118 Zamora Ave #206
Coral Gables, FL 33134