If you are a California resident, please read our California Resident’s Privacy Notice.
If you are a Vermont resident, please read our Vermont Resident’s Privacy Notice.
CATEGORY
EXAMPLES
COLLECTED?
A. Identifiers
A real name, alias, postal address,
unique personal identifier, online
identifier, Internet Protocol address, email address, account name, SocialSecurity number, driver’s license number, passport number, or other similar identifiers
Yes
▪ Communicating with you
▪ Performing services
▪ Marketing our services
▪ Research and development
▪ Quality assurance
▪ Security/Fraud
▪ To comply with our legal obligations
B. Personal information categories
listed in the California Customer
Records statute (Cal. Civ. Code §
1798.80(e))
A name, signature, Social Security
number, physical characteristics or description, address, telephone
number, passport number, driver’s
license or state identification card
number, insurance policy number,
education, employment,
employment history, bank account
number, credit card number, debit
card number, or any other financial information, medical information, or health insurance information. Some personal information included in this
category may overlap with other
categories.
Yes
▪ Communicating with you
▪ Performing services
▪ Marketing our services
▪ Research and development
▪ Quality assurance
▪ Security/Fraud
▪ To comply with our legal obligations
C. Protected classification
characteristics under California or
federal law
Age (40 years or older), race, color,
ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Yes
▪ Performing services
▪ Research and development
▪ Quality assurance
▪ To comply with our legal obligations
D. Commercial Information
Records of personal property,
products or services purchased,
obtained, or considered, or other
purchasing or consuming histories or tendencies.
Yes
▪ Communicating with you
▪ Performing services
▪ Marketing our services
▪ Research and development
▪ Quality assurance
▪ Security/Fraud
▪ Debugging
▪ To comply with our legal obligations
E. Biometric Information
Genetic, physiological, behavioral,
and biological characteristics, or
activity patterns used to extract a
template or other identifier or
identifying information, such as,
fingerprints, faceprints, and
voiceprints, iris or retina scans,
keystroke, gait, or other physical
patterns, and sleep, health, or
exercise data.
No
F. Internet or other similar network
activity
Information regarding interactions
with our website, mobile
applications, emails computer
systems, devices, or advertisements, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers, including browsing or search history,
Yes
▪ Communicating with you
▪ Performing services
▪ Marketing our services
▪ Research and development
▪ Quality assurance
▪ Security/Fraud
▪ Debugging
▪ To comply with our legal obligations
G. Geolocation Data
Device location, IP address, physical location.
Yes
▪ Performing services
▪ Marketing our services
▪ Research and development
▪ Quality assurance
▪ Security/Fraud
▪ Debugging
▪ To comply with our legal obligations
H. Audio and Visual Information
Audio, electronic, visual or similar
information (e.g. when customer
interacts with employee regarding
product and services).
Yes
▪ Performing services
▪ Quality assurance
▪ Security/Fraud
▪ To comply with our legal obligations
I. Inferences drawn from personal
information
Derivation of information, data,
assumptions, or conclusions from
facts, evidence, or another source of information or data; a characteristic deduced about a consumer.
Yes
▪ Performing services
▪ Marketing our services
▪ Research and development
▪ Quality assurance
▪ Security/Fraud
▪ Debugging
▪ To comply with our legal obligations
J. Non-public education
information (per the Family
Educational Rights and Privacy Act
(20 U.S.C. Section 1232g, 34 C.F.R.
Part 99))
Education records directly related
to a student maintained by an
educational institution or party
acting on its behalf, such as
grades, transcripts, class lists,
student schedules, student
identification codes, student
financial information, or student
disciplinary records.
Yes
▪ Performing services
▪ To comply with our legal obligations
K. Inferences drawn from other
personal information
Profile reflecting a person’s
preferences, characteristics,
psychological trends,
predispositions, behavior,
attitudes, intelligence, abilities,
and aptitudes.
No
Personal information does not include:
Use of Artificial Intelligence
AI Virtual Assistants and Agents, Voice and Chat
Another use of artificial intelligence is with AI virtual assistants and AI agents. We may use virtual assistants and AI agents to help in addressing customer inquiries, requests and lending process. These virtual assistants and agents are AI-powered tools. They include voice and text conversational chat interfaces to assist you with loan applications, products or questions. They can perform routine tasks for account management such as transaction searches, billing, and interacting with, or transitioning to, human agents in products inquiries or requests for information.
-Opt-out: Request that your conversation not be used or subject to AI, and request a human being.
-Access and Delete: Request access to or deletion of your personal data, including chat history.
How Do We Use Information We Collect from Online Services?
We may use the information we collect from you while using our Online Services as described below.
• To perform or fulfill the online service you requested. We use information to do business with you by providing our services to you and fulfilling your requests.
COLORADO, CONNECTICUT, UTAH, VIRGINIA RESIDENTS
Colorado, Connecticut, Utah, and Virginia law require certain disclosures for companies that "sell" personal information pursuant to the respective state's privacy law. Each state defines the "sale" of data differently. Colorado, Connecticut, Utah, and Virginia define the "sale" of data as a company exchanging personal information for monetary consideration with a non-affiliated third party.
Under Colorado, Connecticut, Utah, and Virginia law, we do not "sell" your personal information.
If you are a resident of Vermont, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.
If you are a resident of North Dakota, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.
This section applies only to Nevada residents. Nevada residents may elect to opt-out of the sale of their Personal Information. To make a request, please contact us as described in the How to Contact Us section, below. Indicate in your email or letter that you are a Nevada resident.
Colorado Privacy Act (CPA)
This section applies only to Colorado residents. Colorado residents have the following rights to:
If you are a resident of California, we will not share personal information we collect about you unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits to which you are entitled. We also limit sharing among our Affiliates to the extent required by California law. For example, we may share minimal California resident personal information with Affiliates who may be able to provide a complementary or related service to you and market those products or services to you. We may share information with our partners if we believe the disclosure is reasonably necessary to protect us, users of our Services, or the public from harm, fraud, or potentially prohibited or illegal activities. You may visit our California Applicant Privacy Notice which provides more information about California residents and their rights under the applicable laws.
California residents also have specific privacy rights provided by the California Consumer Privacy Act (CCPA), as it may be amended from time to time. These include: (1) the right to request information from us regarding what categories of personal data we have collected about you; (2) the right to request a copy of the specific personal information collected about you during the last 12 months; (3) a limited right to have such information deleted (with exceptions); (4) the right to request that your personal information not be sold to third parties, if applicable; and (5) the right not to be discriminated against because you exercise your rights.
California residents have the right to request deletion of personal data that has been collected within the last 12 months. There are circumstances where the law may not permit or require removal in certain circumstances. You may visit our California Applicant Privacy Notice for more information about California residents and their rights under the applicable laws.
To exercise these rights or to inquire about privacy protection at the Company, you may visit Do Not Sell or Share Data
Under California Civil Code Section 1798 (California’s Shine the Light Law), California residents with an established business relationship with us can request information once a year about sharing their personal data with third parties for the third parties’ direct marketing. If you are a California resident and want to request information from us based on the Shine the Light Law, you can do so via the Contact Information below.
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