1. Collection of Your InformationWe may collect and store various information about you including, for example, information that you provide to us, information that we automatically collect through your use of the Service, and information from publicly available sources or third parties, as further detailed below. If you utilize our Services to obtain a financial product or service through us, we will use and share any information that we collect from or about you in accordance with our U.S. law, which offers you certain choices with respect to the use and sharing of your personal information. Information subject to our Privacy Notice is referred to as Non-Public Personal Information (“NPI”).
B. Information That Is Collected AutomaticallyIn addition to the information you provide to us directly, we may automatically collect information about your use of the Service, as described below.
- Log file information.Log file information is automatically reported by your browser each time you access the Service. When you use our Service, our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
- Location information.When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. You may disable such features, but please note that if you do so, you may not be able to access or receive some or all of the services, content, features and/or products made available via the Service.
- When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser or stores information or settings on your device. Cookies let us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. Our Service may use HTTP cookies, HTML5 cookies and other types of local storage (such as browser-based or plugin-based local storage).
- Clear gifs/web beacons.When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened, which links are clicked by recipients, and whether our emails are forwarded. The information allows for more accurate reporting and improvement of the Service.
- Web analytics. We may use third-party Web analytics services on our Service, such as those of Google Analytics. These service providers use the technology described above to help us analyze how users use the Service. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.
- Third-Party Ad Targeting. We sometimes use the above technologies for interest-based advertising, which may be based on your device or browser’s signals received across websites or applications, and over time. Please see the section titled “Tailored Advertising” to learn how you can opt out of these marketing methods and technologies.
C. Information from Third-Party SourcesWe may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, when you request prequalified rates, we will ask your permission to conduct a soft credit inquiry. Likewise, if you apply for a loan product, either us or a Provider may conduct a hard credit inquiry.
3. Do Not Track Signals and Similar MechanismsSome Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
4. Use of Your InformationWe may use your information and/or combine any or all elements of your information for a number of purposes, including:
- To provide you with and manage the Service.We use your information to provide, develop, maintain and improve our Service and the features and functionality of the Service. This may include customization and tailoring the Service features according to the information that you provide.
- To process and fulfill a request or other transaction submitted to usWe use your information to process or fulfill requests or transactions that you have requested.
- To communicate with you.We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails.
- Provide personalized services, including content, ads, products or services.We may use the information we collect to provide personalized services and advertising to you either through Crediverso or a third party marketing partner, subject to the requirements of the U.S. Consumer Privacy Notice. To learn more about your choices in connection with the use of your information for this purpose, please see the section above titled, “Tailored Advertising.”
- Surveys, Offers, Sweepstakes.We may use your information to conduct surveys and offer sweepstakes, drawings, and similar promotions.
- Marketing and Advertising.We may use your information to market and advertise our services and the services of certain third parties we work with.
- Unique Identifiers.Sometimes, we (or our service providers) may use the information we collect – for instance, log-in credentials, IP addresses and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computer), or work with providers that do this, in order to better tailor advertising, content, and features, and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
- Research and Analytics.We may use your information for research and analytical purposes, for example, to identify trends and effectiveness of certain marketing campaigns we run.
- Business Operations.We may use your information for certain operational purposes including, for example, perform audits and quality control.
- To protect the rights of Crediverso and others.We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of Crediverso, its employees or agents, or other users and to comply with applicable law.
- With your consent.We may otherwise use your information with your consent or at your direction.
- To aggregate/de-identify data.We may aggregate and/or de-identify information collected through the Service. We may use de-identified and/or aggregated data for any purpose and without any restrictions, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
5. Sharing of your informationWe may share the information we collect or receive from you in a variety of circumstances, including as listed below. Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our U.S. Consumer Privacy Notice.
- Providers and co-signers.We may share your information with Providers for the purpose of providing the Service to you such that they may provide you with information about your request for prequalified rates, offers, and information related to other products and services they offer.
- You understand that, subject to any applicable laws or regulations, Providers may keep your information that relates to any submission of information that you may make through your use of the Service and any other information provided by Crediverso in the processing of any submission of information, whether or not you are eligible for the Provider’s products or services. You agree to notify any particular Provider directly if you no longer want to them to keep your information.
- As a prospective borrower or applicant of a Provider’s products or services, you agree that when you nominate a co-signer/co-applicant, Crediverso may share Provider responses relating to your submission with your nominated co-signer/co-applicant, and, as a co-signer/co-applicant, we may share Provider responses relating to your submission with the prospective borrower or applicant.
- We may share information with our subsidiaries.
- Service providers.We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, agents and other representatives. Service providers assist us with a variety of functions. This includes, for example, assisting with customer service-related functions, providing advertising (including interest-based advertising) and analytics services (e.g., Google Analytics and Facebook Custom Audiences), helping us verify your identity, obtain your credit report, providing website hosting services (e.g., Amazon Web Services), assisting with auditing functions, and helping us with marketing and related research activities.
- Marketing partners.We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with. Marketing partners also include those entities who maintain a link to our Services on their site, when you click from their site to our Services.
- Other parties when required by law or as necessary to protect our users and services.Crediverso may share your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) exercise or protect the rights, property, or personal safety of Crediverso, our Users or others.
- Business transfers.We may buy or sell/divest/transfer Crediverso (including any shares in Crediverso), or any combination of its products, services, assets and/or businesses. Your information, which may include NPI, user names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of Crediverso.
- Public Forums.Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If we remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. We are not responsible for the information that you choose to submit in your User Content.
- Aggregated or de-identified information.We may also aggregate or de-identify data and may share that data without restriction.
6. How We Store and Protect Your InformationKeeping Your Information Safe Crediverso takes technical and organizational measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures vary depending on the sensitivity of the information we have collected from you. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. Crediverso is not responsible for the functionality or security measures of any third-party or Provider. For information about how to protect yourself against identity theft, please refer to the Federal Trade Commission’s website at www.ftc.gov/news-events/media-resources/identity-theft-and-data-security.
7. Your Choices About Your Information
A. Email PromotionsYou can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, transaction-related updates, changes/updates to features of the Service, and technical and security notices).
B. Opt-Out and Annual NoticeIf you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information, including the right to opt-out to the sharing of certain information.
C. Choices Relating to Tailored AdvertisingPlease see the section above titled, “Tailored Advertising,” for your choices relating to certain interest-based advertising.
8. Updating Your InformationAfter you log in to the Crediverso system, you can update or edit your personal information and preference through my profile dashboard at any time. Please keep your personal information up to date to get the best services from us.
9. How Long We Keep Your User ContentFollowing termination of your use of our Services, Crediverso may retain your information and User Content for an additional period of time for backup, archival, or audit purposes. In certain circumstances, we are required by Federal and State regulations to store various information. In order to comply with those requirements, we may be unable to delete your information from our database until the legally required retention period expires.
10. Children’s PrivacyCrediverso does not knowingly collect or solicit any information from anyone under the age of 18 or allow such persons to register as Users. In the event that we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information. If you believe that we might have collected any information from a child under 18, please contact us at info@Crediverso.com.
1. What Information is Covered by this CCPA Notice?This CCPA Notice relates to the Company’s collection, use and disclosure of California consumers’ personal information. “Personal information” generally means information that is reasonably capable of being associated with you or your household. For a specific list of the categories of personal information we collect, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.
2. Where Do We Collect Personal Information From?For a list of the categories of sources from which we may collect personal information, please see the Summary of Collection, Use and Disclosure of Personal Information below.
3. How Do We Use Personal Information?We may use your personal information for a variety of “business purposes” and “commercial purposes,” as defined by the CCPA. “Business purpose” means the use of personal information for an operational or other notified purpose including, for example, performing services on behalf of another organization. “Commercial purpose” refers to when we use personal information for commercial or economic interests including, for example, by marketing our Services. For a detailed list explaining how we may use personal information, please see the Summary of Collection, Use and Disclosure of Personal Information below.
4. Who Do We Share Personal Information With?We may share your personal information with the third parties described below. For a more detailed summary of who we may share your personal information with, see the Summary of Collection, Use and Disclosure of Personal Information below.
a. Providers. We may share your personal information with third parties we give you opportunities to interact with through the use of our Services such as when we provide you with the opportunity to obtain prequalified rates from lenders for a personal loan or to submit your loan application to a lender. The term “Provider” referenced here is defined in our Terms of Service. In some cases, if you click to go to a Provider’s site, you will automatically be sending your personal information to that Provider (e.g., when clicking on an option to learn more about debt service providers, high yield savings providers or insurance providers or when applying for a credit card with one of our partner credit card issuers). Remember that any information you provide to the Provider, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
b. Service Providers. We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, agents and other representatives (collectively, “Service Providers”). Service Providers assist us with a variety of functions. This includes, for example, assisting with customer service-related functions, providing advertising (including interest-based advertising) and analytics services (e.g., Google Analytics and Facebook Custom Audiences), helping us verify your identity, obtaining your credit report, providing website hosting services (e.g., Amazon Web Services), assisting with auditing functions, and helping us with marketing and related research activities.
c. Marketing Partners. We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with (collectively, “Marketing Partners”). Marketing Partners also include those entities who maintain a link to our Services on their site, and you click from their site to our Services.
d. Co-Signers. As a prospective borrower or applicant of a product or service, your personal information may be shared with a co-signer or co-applicant that you designate (“Co-Signers”).
e. Public Forums. In certain circumstances, we may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include Personal Information (like your name and email address). This information, of course, may be visible to the public and posted on our Sites. For the purpose of this CCPA Notice, third parties who are able to view and access personal information in accordance with this section shall be referred to as the “General Public.”
f. Affiliate Companies. We may share personal information with our parent company and wholly owned subsidiaries (collectively, “Affiliate Companies”).
g. Special Circumstances. We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) to protect or prevent harm or financial loss; (iii) to protect our legitimate interests and legal rights; and (iv) to detect, investigate and help prevent security, fraud or technical issues (collectively, “Special Circumstances”). For the purpose of this CCPA Notice, third parties who receive personal information in accordance with this section shall be referred to as “Special Circumstances Recipients.”
h. Corporate Transactions. We may transfer your personal information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets (collectively, “Corporate Transactions”). For the purpose of this CCPA Notice, third parties who receive personal information in accordance with this section shall be referred to as “Corporate Transaction Recipients.”
5. Summary of Collection, Use, and Disclosure of Personal InformationAs a recently launched company, we have not yet had 12 months of operations during which we have collected our shared any personal information. When we have implemented our practices for at least 12 months, this section will be updated with a summary of our collection and sharing practices relating to personal information, including with respect to personal information we have collected, used and disclosed in the preceding 12 months.
6. ChildrenOur Site and Services are not intended for minors under 18 years of age. As such, we do not knowingly collect or maintain any data from minors under 18 years of age and, as such, do not sell personal information of minors under 18 years of age.
7. Your CCPA RightsSubject to certain exceptions, the CCPA affords you the following rights with respect to your personal information. It’s worth noting that these rights do not apply to personal information we collect about California consumers who apply for or obtain a financial product and service for personal, family, or household purposes (in other words, information regulated by the Gramm-Leach-Bliley Act).
a. Request to Know. You have a right to request that the Company disclose what personal information it collects, uses, discloses, and sells. It includes a request for any or all of the following:
- Specific pieces of personal information that the Company has about you;
- Categories of personal information the Company has collected about you;
- Categories of sources from which your personal information is collected;
- Categories of personal information that the Company has sold or disclosed for a business purpose about you;
- Categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information.
b. Request to Delete. You have a right to request that the Company delete your personal information that we have collected from you. However, certain information regulated by other privacy and data protection laws (including, for example, the Gramm-Leach-Bliley Act) may be exempt from, or outside the scope of, any deletion request (i.e., the GLBA’s requirement to retain the information may preempt your request that we delete it. In other words, we may be legally required to retain your data for a certain period of time and therefore we cannot delete your data at your request. if this happens, we will let you know in response to your request). As a result, in some instances, we may decline all or part of a deletion request if related to this type of exempt information.
c. Request to Opt-Out. We do not provide personal information about you to other companies for money. The advertising services we use may collect certain information, including cookies and similar information stored on your browsers, advertising identifiers on your mobile devices, and/or the IP address of your devices when you visit our sites or use our apps. Those advertising services we use may tailor and deliver ads to you on your devices. Even though we do not provide personal information to these companies for money, California law may characterize this activity by the advertising providers as “sales” of personal information. You have a right to request that these companies discontinue these targeted advertising activities.
d. No Discrimination. You have a right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA.
8. How to Exercise Your CCPA Rights
a. Submitting a Request to Know or Request to Delete. You may submit a Request to Know or a Request to Delete by contacting us at firstname.lastname@example.org.
b. Submitting a Request to Opt-Out. You may submit a Request to Opt-Out by emailing us at email@example.com. We currently do not have a method that would allow us to contact the advertising service providers on your behalf as we do not associate these cookies and other signals to any personally identifiable information we may maintain about you
c. Verification Methods. Once you submit a request, we will verify that you are the consumer to which the request pertains by matching your name, email address and physical address with information we maintain. Depending on the type of request you submit, we will attempt to match either two or three of these data points to the information maintained in our systems. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request. We may also reach out to you for additional verifying information for requests requiring a higher degree of verification because of the type or sensitivity of the requestYou may designate an authorized agent to submit a request on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that you verify your identity directly with us.