PRIVACY POLICY

1. COLLECTING AND USING INFORMATION

Personally Identifiable Information We Collect Online

We collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

• MyCredello. You may register for a MyCredello subscription using your Google or Facebook ID, and we will collect your name and email address. We will also collect certain financial information (e.g., account balance and transactions, APR, monthly payment and due date) if you choose to link your credit card and/or loan account(s) to Credello through our third-party provider, MX Technologies, Inc. See more information regarding MX in the section below titled, “THIRD PARTY PROCESSORS.”
• Prequalify for a Loan. If you are interested in receiving a loan offer from one of our lending partners, we will collect your name, email address, mobile telephone number, date of birth, Social Security number, home address, employment information, and certain financial information (e.g., gross annual income and home ownership status).
• Contests and Promotions. From time-to-time we may offer certain sweepstakes, contests, or promotions. To enter, we will collect your name, email address, mailing address, and other Personally Identifiable Information as provided in the terms and conditions of the promotion.
• Interact with our Site or Services. When you log-in to your account, send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you may need to provide us with your log-in information, name and/or email address.

Information as You Navigate Our Site

We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:

• Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
• Device Information. For example, hardware model, operating system, application version number, and browser.
• Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
• Location Information. Location information from Site visitors on a city-regional basis.

Information Collected from Other Sources

We may combine your Personally Identifiable Information with information we receive about you from other sources, such as publicly available information sources, and third parties, such as information about your credit profile from credit bureaus.

Third Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

• Process your MyCredello registration;
• Process transactions, such as your prequalification application;
• Verify your identity and prevent fraud;
• Email you our blog posts or surveys;
• Determine whether you are eligible for a prize in any promotion or contest in which you may enter, and to communicate with you regarding same;
• Contact you regarding our products and services that we feel may be of interest to you;
• Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
• Provide support;
• Maintain and improve our Site and Services;
• Defend our legal rights and the rights of others;
• Efficiently maintain our business; and
• Comply with applicable law.

How We Share Your Personally Identifiable Information

We may share the information that we collect about you in the following ways:

• With service providers who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
• To service providers to prepare, deploy and analyze advertising content;
• To service providers to manage surveys and promotions on our behalf;
• To credit bureaus;
• To third-party lending partners to present you with offers based on your eligibility and requirements;
• If you use the Site on behalf of your employer or another organization, information related to your use of the Site may be used and disclosed by iQuanti to provide products and services to your employer or such organization in accordance with any agreement between iQuanti and your employer or such organization;
• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
• To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
• To any other person or entity where you consent to the disclosure.

2. COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons). To learn more about how we use cookies and to change your cookie settings, please see our Cookie Notice.

3. THIRD PARTY PROCESSORS

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use MX Technologies, Inc. to link to your credit card and/or loan account(s), if you so choose, to your MyCredello account. For more information, please view the MX Privacy Policy available here. You may unlink your credit card and/or loan account(s) at any time through your MyCredello account.

4.“DO NOT TRACK” SIGNALS

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

5. CHOICES ABOUT YOUR PERSONALLY IDENTIFIABLE INFORMATION

Review and Request Changes to Your Personally Identifiable Information

You may use your MyCredello account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. As mentioned above, you may also unlink your credit card and/or loan account(s) at any time through your MyCredello account. To review or request changes to any of your Personally Identifiable Information, please contact us as provided in the section below entitled “How to Contact Us.”

Marketing Communications

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails or select “Communication Preferences” in your MyCredello account. You also may submit a request to us at [email protected].

6. SECURITY

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

7. THIRD PARTY LINKS

The Site and Services may contain links that will let you leave the Site and Services and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on this Site and Services. We accept no responsibility or liability for these other websites.

8. CHILDREN’S PRIVACY

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

9. NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

The CCPA’s privacy rights described below do not apply to Personal Information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice provided at the end of this document.

Right to Know About Personal Information Collected, Disclosed, or Sold

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

1. Specific pieces of Personal Information that we have collected about you;
2. Categories of Personal Information that we have collected about you;
3. Categories of sources from which the Personal Information was collected;
4. Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
5. Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or, if applicable, selling Personal Information.

Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, postal address, online identifier, internet protocol address, email address, account name, Social Security number)
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Telephone number
• Other financial information(e.g., income, debt/loan balances, transaction history)
• Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
• Geolocation data
• Education information
• Professional or employment-related information (i.e., employment status)
• Characteristics of protected classifications under California or federal law (age 40 and older)
• Audio and visual information(e.g., contest video submissions)
• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

The Personal Information is collected from California residents directly and from credit reporting agencies, banks that you choose to link to your MyCredello account, advertising networks, internet service providers, data analytics providers, social networks. Not all categories of Personal Information are collected from each source.

In addition to the purposes stated above in the section “Collecting and Using Information” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Debugging to identify and repair errors that impair existing intended functionality
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of our services and to improve, upgrade, or enhance same
• Commercial purposes, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Disclosure of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the category of third parties to whom the Personal Information was disclosed. We did not sell Personal Information to third parties in the 12 months preceding the Last Update date of this Privacy Policy.

We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

Right to Request Deletion of Personal Information

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

How to Submit a Request to Know or Delete

You may submit a request to know or delete by emailing [email protected].
As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice provided at the end of this document.

Our Process for Verifying a Request to Know or Delete

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “NOTICE TO CALIFORNIA RESIDENTS.”

Authorized Agents

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please contact us as provided in the section below, “How to Contact Us,” with the subject line “Shine the Light Request.”

10. ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

11. HOW TO CONTACT US

For questions or concerns about our privacy policies or practices please contact us at: