By using the Site, you agree to the terms of this Policy. If you do not agree to the terms of this Policy, please do not use the Site. We reserve the right to change this Policy without prior notice. You agree to obtain annual notices of, and changes to, this Policy electronically by visiting this Site. You can determine when this Policy was last revised by referring to the “Last Revised” legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect. Therefore, we encourage you to review this Site from time to time for changes to our Policy.
WHAT TYPES OF INFORMATION DO WE COLLECT ABOUT YOU?
We collect personal information and non-personal information through the Site. Personal information is information that identifies you as an individual. Non-personal information is aggregated information, demographic information, IP addresses and any other information that does not reveal your specific identity.
Personal information. We may collect the following types of personal information:
- Information provided by you when ordering credit-related products through the Site. For example, you will be required to submit personal information such as your name, address, social security number, date of birth, telephone number and e-mail address.
- Information from third-party data providers, including consumer credit information, when fulfilling information requests made by you when ordering credit-related products through the site.
- When you make a purchase through the Site, we may collect your credit card number or other payment account number, billing address and other information related to such purchase (collectively, “Payment Information”) from you.
- Other information we collect, such as city of birth and mother’s maiden name, is used to verify your identity in the event you forget your login information required for our online products.
- Information you provide us through customer service correspondence and general feedback.
Without your permission, we do not allow third parties to collect personally identifiable information (PII) about a user’s online activities, over time and across different sites, services, and applications, when that user uses our site, service, or application. PII that you have given permission to be collected may be retrieved, reviewed, and deleted at your request, by contacting Cloakwire.
Non-Personal information. When you visit the Site, we may collect non-personal information, such as a catalog of the Site pages you visit. Non-personal information is generally collected through the Site from the following sources: server log files, environmental variables, cookies, pixel tags and other similar technologies and information that you voluntarily provide.
- Server Log Files. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site’s servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
- Environmental Variables. We and our service providers may also collect certain environmental variables, such as computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.
- Pixel Tags. We, our service providers, and/or non-affiliated Third-parties, may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Site visitors and may be associated with Cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, to provide online advertising, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened.
- Information That You Voluntarily Provide. We also collect non-personal information (e.g., your geographic location, etc.) when you voluntarily provide such information to us. When such information is not combined with any personal information, such information is considered to be non-personal information, as it does not personally identify you or any other user. Additionally, we may aggregate personal information in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using personal information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered non-personal information for purposes of this Policy.
HOW DO WE USE THE INFORMATION COLLECTED?
Personal Information. We may use personal information we collect in the following ways:
- Fulfillment of Requests. We may use personal information collected about you to provide you with products, services or information that you request. Specifically, we may share your information with our affiliates and business partners to provide you with specific commercial finance products such as credit cards and loans.
- Administrative Communications. From time to time we may use personal information to send to you important information regarding the Site, or changes to our terms, conditions, and policies. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.
- Other Communications. From time to time, we may use personal information to inform you of products, programs, services and promotions that we believe may be of interest to you. If you would prefer that we do not send such email marketing messages to you, please see the “Your Choices” section below.
- Purchases. We may use personal information, including Payment Information in order to fulfill your purchase.
- Internal Business Purposes. We may also use personal information for our internal business purposes, such as data analysis and audits. In addition, we may also use personal information to enhance our information and to aid us in providing our customers with targeted promotions.
- Cloakwire Marketing and Joint Marketing. We may share or make available anonymous or aggregate information that cannot be used to identify you with third parties for research, marketing and promotional purposes, and users of our services for purposes of comparison of their business financial situation relative to the broader community.
Non-Personal Information. Because non-personal information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to disclose such non personal information to other third parties, for any purpose.
In some instances, we may combine non-personal information with personal information. If we combine any non-personal information with personal information so that it personally identifies you, the combined information will be treated by us as personal information as long as it is combined.
We may, along with our affiliates and marketing partners enhance and/or merge personal information about you with data collected from other sources and use it in direct and/or online marketing and, to the extent permitted by law, individual reference and look-up service programs. In the event we enhance and/or merge such personal information with data collected from other sources, we will take reasonable steps to maintain the integrity and quality of that information.
DO WE DISCLOSE INFORMATION TO THIRD PARTIES?
We may disclose information about you to affiliated and non-affiliated third parties.
- Affiliates. We may disclose the information that we collect to our affiliated companies to provide the products you request, to enhance our products to better suit your needs, and from time to time for marketing purposes.
- Business Partners. We may partner with other companies to offer you products or services or to fulfill the products or services that you order. We may disclose personal information and/or non-personal or de-identified information collected about you to such third-party partners for the purposes described in this Policy.
- Service Providers. We work with third parties who provide services including but not limited to data analysis, order fulfillment, list enhancement and other administrative services. We may disclose personal information to such third parties for the purpose of enabling these third parties to provide services to us. Such services may include: marketing distribution, email list management services, advertising, certain product functionalities, customer support, web hosting, customer data management and enhancement, fulfillment services (e.g., companies that fill product orders or coordinate mailings), research and surveys, data analysis and email service.
- Assignment. We reserve the right to transfer any and all information that we collect from Site users to an affiliate or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
You have choices when it comes to updating your information, learning about new offers or products offered by us, our partners or affiliates. If you do not wish to receive offers of products from us, our partners or affiliates, here are the methods in which you can opt out:
- Cloakwire. Commercial Email. If you prefer not to receive emails from us about offers and Promotions please unsubscribe via the unsubscribe link in an email, or contact us at [email protected].
- Changing information. Corrections or updates to your information including your email address, phone number, mailing address, credit card information or password reminder phrase can be made through the edit profile section of your account on the Site. If necessary, other corrections or updates to your information can be made by contacting a customer care representative at [email protected]. For your protection, our customer care representatives may request supporting documents before making any changes or updates to your membership information.
We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove personal information about you from the databases of third parties with which we have already disclosed personal information as of the date that we implement your opt-out request. If you wish to cease receiving marketing-related e-mails from third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.
HOW DO WE PROTECT YOUR INFORMATION?
We have security measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem as soon as possible by contacting us in accordance with the Section “Contacting Us” below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
We control and operate the Site from the United States, and the Site is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
CALIFORNIA PRIVACY RIGHTS
California residents may be entitled to additional rights over their personal information. For more information about those rights and how to exercise them, please see our California privacy notice here, which is incorporated by reference into this policy.
A SPECIAL NOTE REGARDING INDIVIDUALS UNDER 18 YEARS OLD
The Site is not directed to individuals under the age of eighteen (18), and we request that such individuals not provide personal information through the Site. If you are under 18 years of age, you may browse our Site; however, you may not provide personal information to us such as name, address, or email address, and you may not register for, enroll in, and/or make product purchases.
If you have any questions regarding this Policy, please contact us at [email protected]. Please note that email communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us.