Effective Date: May 1, 2020
1. HOW AND WHY WE COLLECT INFORMATION ABOUT YOU
11.1. Information You Provide Us
11.1.1. Personal Information
We collect personal information from you to help you use our services. When we say, “personal information,” we mean information that specifically identifies you.
We collect this information in a number of ways. You are asked to provide personal information to us when you use our Site, authorize us to obtain information about you from a third party, communicate with us about our services, and provide feedback to us. Examples of personal information include:
- Telephone Number
- Email Address
- Household Composition
- Income Information
- Expense Information
- Credit Information
Please note that any information, photos, contact information, email addresses, videos, and other content you post to your profile on Creditly's Community site is available to everyone using that service. The information you share is available to everyone accessing that service, and may be read, collected or used by others for any purpose, including sending you unsolicited messages.
We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on a Site or on or through any of its features. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at email@example.com.
1.2. Information We Collect About You
1.2.1. Information Collected
Creditly collects information about your computer or mobile device to improve and evaluate your use of our Site and our services. We may gather data such as your browser type, operating system, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device.
1.2.2. Cookie Information
Creditly uses “cookies” and similar tools to track your use of the Site when you use our services. We collect information such as the types of service used, and number of users we receive daily. Our web servers automatically log information about your computer or mobile device, but we do not use this information to identify you personally.
A web beacon embeds a small transparent gif image in a web page or email used to track when the page or email has been viewed. A similar device may be used where a product, service or functionality sends data to a server when a set of user-initiated events occur such as clicking a button on the Site or in an email. This is similar to a cookie – it tracks your visit and the data is only read by the server that receives the data. However, it differs because it is not browser-based, may not function as an ID card and does not store any data on your computer.
Most Internet browsers are set up to accept cookies automatically. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. For some web pages requiring an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages.
1.2.3 Contacting Us By Telephone
If you communicate with us by telephone, we may monitor or record the call. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of Creditly's services.
1.3. Information Third Parties Provide About You
As a company engaged in helping consumers manage their unsecured personal debt, Creditly receives data from consumer reporting agencies. We partner with these agencies to assess your current debt load and to prevent fraud and identity theft.
Information we collect in these reports includes, but is not limited to:
- Information about open and closed credit accounts, including the date opened, the date closed (if applicable), the latest reported monthly balance and monthly payment
- Information about credit inquiries
- Information about late payments and collection actions occurring on open and closed credit accounts
- Information regarding public records of bankruptcy, judgements, tax liens, and other payment statuses
- The credit score produced by the credit bureau providing the report
- Information about your bank account transaction history, assets, and account balances
Additionally, we may supplement the personal information you submit to us with information from third-party sources. For example, we ask you to connect your bank account with Creditly using a third-party service to verify your income.
Finally, we contract with third parties to place advertisements for our services on web sites that are not our own. We place these advertisements where we think they are likely to be most relevant. These advertisements on third-party web sites allow us to track responses to our advertisements. We use this information to track the performance of our advertising and marketing campaigns by using tools like cookies, web beacons and similar technologies. We use these tools to collect and store information about the user's visit, page visits and duration, and the specific advertisement or link that the user clicked on to visit the site.
2. USE OF YOUR PERSONAL INFORMATION
2.1 How We Use Your Personal Information
We use your personal information to provide you with information or services you request, to inform you about other information and services we think will be of interest to you, to facilitate your use and our operation of our Site, and to improve our services. We do not forget about you once you have received our services — Creditly will continue to provide services to propel your financial future.
Here are some examples of ways in which we use your personal information:
- Creating and maintaining your login information on our Site
- Contacting you regarding issues with your online profile
- Sending you information about new services
- Generating a personal debt score
2.2. Aggregate Data
Aggregate data means records which have been stripped of information potentially identifying customers, landing pages or end-users, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information will be kept anonymous in aggregated data. Aggregate data is used to help us understand consumer trends, needs, interests, and preferences so we can improve our products and services.
Creditly also collects demographic information, and may include:
- Date of Birth
- Geographic Area
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share information, including personal information, with third parties in a variety of ways, such as:
- Non-affiliated third-party creditors: We may share information with creditors with whom you already have a relationship in connection with providing our services.
- Affiliated third party partners: We may share information about you with affiliated third party partners, such as non-profit credit counseling organizations. Non-profit credit counselors do not work for Creditly, but instead work directly with you the consumer to provide financial education and impartial advice on debt management. In order to facilitate your interaction with a credit counselor, Creditly may share information about you with the counselor. Creditly works exclusively with high-quality, trusted credit counseling agencies that are members of the National Foundation for Credit Counseling. Creditly receives no incentive or bonus payment from a credit counselor should you choose to enroll in a debt management plan.
- Legal reasons: We reserve the right to transfer or disclose information about you to third parties for certain legal purposes. With your consent: There may also be other limited contexts in which we share specific types of personal information with your express consent.
4. PROTECTING YOUR PERSONAL INFORMATION
4.1. What We Do to Protect Your Personal Information
Creditly takes seriously the privacy and security of consumers' personal information. We maintain administrative, technical and physical safeguards designed to protect your information's security, confidentiality and integrity.
We protect personal information you provide online in connection with registering yourself as a user of our Site. Access to your own personal information is available through a unique user ID and password selected by you. This password is encrypted while transmitted from your browser to our servers and while stored on our systems. To protect the security of your personal information, never share your password to anyone. Please notify us immediately if you believe your password has been compromised.
Whenever we save your personal information, it's stored on servers and in facilities that only selected Creditly personnel and our contractors have access to. We encrypt all data that you submit through the Site during transmission using Transport Layer Security (TLS) in order to prevent unauthorized parties from viewing such information. Remember – all information you submit to us by email is not secure, so please do not send sensitive information in any email to Creditly.
4.2. Steps You Can Take to Help Us Keep Your Information Safe
There are many steps you can take to help us keep your information safe. First and foremost, choose complex, independent passwords for each website and service with which you maintain an account or profile. This helps keep any breach of any of your accounts or profiles isolated to one service.
Creditly urges your caution when using public computers or networks, like at a coffee shop or library. To best protect your personal information and login information, do not use such computers to access your sensitive accounts, and if you must, ensure that you logout of your account entirely.
When either you or we update information in your account, such as the status of a loan application, we typically send you notice of these changes via email or text message. In recent years, individuals, businesses and even governments have seen a rise in “phishing” attacks. Phishing occurs when someone attempts to obtain your password or other sensitive information. Scammers often do this by impersonating a trusted user or offering a compelling reason to open a malicious email attachment, click on a link or give over information. We never ask for your sensitive personal information, such as password, over email or other unsecure methods or through any site not under the Creditly.com domain. Please notify us at firstname.lastname@example.org if you ever receive suspicious correspondence from us.
5. YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION
We want you to be aware of the choices you have in limiting the sharing of your personal information. Please refer to the below table to review your options in sharing with us:
|Reason we share this information||Can this sharing be limited?|
|For our everyday business purposes—such as to process your application or maintain your online profile||No|
|Improve our products and services||No|
|For joint marketing with other financial companies||No|
|For our marketing purposes—to offer our products and services to you||No|
5.1. Your Rights as a California Resident
This section contains disclosures required by the California Consumer Privacy Act (“CCPA“) and applies only to “personal information“ that is subject to that law. Effective January 1, 2020, the CCPA allows California residents, upon a verifiable consumer request, to request the following:
- For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may view a comprehensive list of the categories of information we have shared with corresponding categories of third parties within the last 12 months at https://www.creditgenie.com/vendor-sharing/
- The right to know the categories and specific pieces of personal information we collect, use and disclose about you, the categories of sources from which we collected your personal information, our purposes for collecting your personal information, the categories of your personal information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information. The business purpose for which we have collected your information.
- The right to request that we delete the personal information we have collected from you or maintain about you, subject to certain legal exceptions, for example, when the personal information is necessary to complete a transaction for which we collected it or to comply with a legal obligation.
- The right to opt out of our sale(s) of your personal information. Please be advised that we do not currently sell personal information. This opt-out, however, would apply to the extent we began to engage in sales of personal information governed by the CCPA.
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To limit our sharing once your creditgenie.com account has been created, email us at email@example.com
At this time, we do not respond to “do not track“ signals or similar mechanisms – where a visitor to our Site requests that we disable the collection of information about the visitor's online activities, including navigation around our Site and the service. We may also permit third parties to collect aggregate usage information on our Site, and they may also not respond to “do not track“ signals.
5.2. Changing and Updating Your Personal Information
We want to provide you with the resources you need to keep your information with us correct and up-to-date. If you need to change any other information in your profile, please contact our customer service at firstname.lastname@example.org
6. COMPLAINTS & CONCERNS