HOW WE COLLECT INFORMATION
WE COLLECT INFORMATION DIRECTLY FROM YOU
We may collect, both personally identification information and non-personally identifiable information directly from you when you use our Services — for example, when you register to become a Member, when you link your third-party financial accounts, when you transfer money, when you fill out calculators, forms or other fields on our Website, send us feedback, sign up for one of our mailing lists, participate in a survey, etc. The types of information we collect may include, but not be limited to first and last name, mailing address, social security number, email address, employer, job title and department, mobile telephone and facsimile numbers, assets, liabilities financial account information such as ID and password and financial information such as investments, income, expenses, investible assets, investing risk tolerance or other similar types of information and age, gender, or other similar demographic information when such information is relevant to a particular financial product or service you may have requested.
WE COLLECT INFORMATION WHEN YOU VISIT OUR SITE
When you visit our Site, use our Services or open an email from creditanddebt.org, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation:
- IP address or other device address or ID.
- Web browser and/or device type.
- Geolocation data, including if you use the Site on a mobile device.
- Hardware and software settings and configurations.
- Web pages or sites that you visit just before or just after visiting our Site.
- Pages you view on our Site.
- Your actions on our Site.
- Dates and times that you visit, access or use our Services.
WE COLLECT INFORMATION FROM OUR THIRD-PARTY PROVIDERS
Information is collected from third-party service Providers such as our advertisers.
These third-party sources vary over time and include:
- Data brokers from which we may purchase demographic data to supplement the data we collect.
- Services that make user-generated content from their service available to others, such as local business reviews or public social media posts.
- Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
- Service providers that may help us determine your device’s location.
- Providers with which we offer co-branded services or engage in joint marketing activities.
- Developers who create experiences through or for creditanddebt.org.
- Third parties that deliver experiences through creditanddebt.org.
- Publicly-available sources such as open databases.
WE COLLECT INFORMATION FROM COOKIES AND OTHER TRACKING TECHNOLOGIES
Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technologies such as cookies and web beacons to collect information directly from your device about your browsing activities, your interactions with websites and the device you are using to connect to the internet.
We may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device when your browser loads our Website. We may use both session cookies and persistent cookies. Session cookies are used to store information about your website page activities so you can easily pick up where you left off and don’t have to start navigating a site all over again. Cookies act as a sort of “bookmark” within the site. For instance, session cookies can store ordering information needed to make shopping carts work instead of making you remember all the items you put in a shopping cart. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site, but you can always remove it (see below). For instance , if you enter your city or postal code to get local news or weather information, depending on your settings, the data in the cookie is stored so that you will see the same relevant local information when you return to the site. Saving your preferences with cookies, such as your preferred language, prevents you from having to set your preferences repeatedly. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. If you delete, or choose not to accept cookies from our Site, you may not be able to utilize all our Services to their fullest potential.
Some of our webpages contain web beacons which we use to help deliver cookies on our websites, count users who have visited those websites and deliver co-branded services. In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us to, for example, develop statistics on how often clicking on an advertisement on creditanddebt.org results in a purchase or other action on the advertiser’s website. It also allows us to understand your activity on the website of a creditanddebt.org Provider in connection with your use of creditanddebt.org Services.
Creditanddebt.org Sites often contain web beacons or similar technologies from third-party analytics providers such as Google Analytics which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. Google Analytics helps us perform marketing analytics and to collect behavioral information about how you use our site or other websites.
In addition to cookies and web beacons, our Services can also use other similar technologies to store and read data files on your computer:
Location: We may collect and store information about your location if you enable your computer or mobile device to send us location information and provide us with your consent to do so. This will enable us to collect, share and process information about your specific location to enhance our Services and provide better offers to you, using things like GPS or Wi-Fi access point information. We may also use information like your IP address or other device identifiers for approximate location information, like your city or state.
Contacts: When you invite your friends to join our Site by providing their contact information or allowing us to use your address book from your computer, mobile device, or other sites, we may use and store your friends’ contact information.
HOW DO WE USE THE INFORMATION WE COLLECT
We may use your collected information, for example, to:
- Identify you when you visit our websites.
- Deliver the products and services you requested.
- Improve customer service and create new features and functionality.
- Improve our Site.
- Personalize your user experience such as remembering your information so you don’t have to re-enter it the next time you visit our Site.
- Communicate with you about products or services that may be of interest to you.
- Provide customized advertisements, content, and information.
- Manage our business.
- Conduct analytics.
- Assist in fraud detection and information security.
- Understand and analyze usage trends and preferences of our users across different devices.
- Send you promotional materials, offers, and/or messages from third parties we work with.
WHO DO WE SHARE YOUR INFORMATION WITH?
We may share your information with our Providers in connection with providing the products and services you requested. For example, we may share your personal information, such as your name, email, address and social security number with credit reporting agencies to verify your identity in obtaining your credit score or other financial information (when requesting your credit report and score on your behalf, we do not do a hard inquiry; rather, we do a soft inquiry of your credit report, however, if you apply for a line of credit or a loan directly with one or more of our third-party Providers, they may make a hard credit inquiry of your credit file before approving your application.).
We may share information collected directly from you, for example:
- When you request to prequalify for a loan or credit card on our Site.
- When you request additional or personalized information regarding financial products from third-party financial service aggregators we partner with.
- When you request access to your credit report or score.
- When you request access to banking, credit card, retirement or investment products on our Site.
- When you report a complaint about a product or Provider featured on our Site.
- When you request answers or advice through our Site in which case we may provide your information to third-party experts, advocates and advisors.
We may share automatically collected information from you such as your IP address with our Providers when you leave our Site and go to a third-party site to request information or apply for financial products.
We may share your credit report and other personal information with our Providers in order to provide you with recommendations on financial products and services that might be of interest to you.
We may share your information with third-party Providers to support our own internal and business operations. In such cases, service Providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure.
When you choose to share your information on a publicly accessible area of our Site such as a public profile page or any section where you can publicly submit questions to us or our third-party Providers, that information will be available to anyone who is able to access that content, including other users. When you post things like photos or videos on our Site, if applicable, we may also receive additional related data (or metadata), such as the time, date, and place you took the photo or video. Please also keep in mind that whenever you voluntarily make other personal information (e.g. your home address) available online for viewing by third parties by posting it on our Site, that information is public and can be seen, collected and used by others. We cannot be responsible for any unauthorized use of such information.
We may offer contests, sweepstakes or other promotions with third-party Providers. If you decide to enter a contest, sweepstakes or promotion that is sponsored by a third-party Provider, the information that you provide will be shared with us and with them.
We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
We may share aggregate analytics with third-party Providers about how users interact with our Site, including usage patterns for certain programs, content, services, advertisements, promotions and/or functionality.
We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant or to otherwise cooperate with law enforcement activity. We may also disclose your information when we believe it’s appropriate in order to investigate, prevent, or take action regarding actual or suspected illegal activity or other wrongdoing; to protect and defend the rights, property, or safety of our business, our users, our employees or others. We may disclose your information in connection with a substantial corporate transaction involving our business, such as a sale of creditanddebt.org or any entity, brand or division thereof, a divestiture, merger, consolidation, asset sale or bankruptcy
We may share information with third parties that is not personally identifying, such as aggregated or anonymized data, in our discretion, where not prohibited by law
Some of our Websites may include features that are designed to permit interactions that you initiate between our Site and third-party websites or services, including third-party social networks. For example, you may be able to “like” or “share” content from our Site on other websites or services, such as Facebook, Twitter, Instagram, YouTube, and LinkedIn.
HOW DO WE PROTECT YOUR INFORMATION
However, no data transmission over the internet or any wireless network can be guaranteed to be one hundred percent (100%) secure. As a result, while we strive to protect your information, you acknowledge that there are security and privacy limitations of the internet that are beyond our control; the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third-party. We make no warranty, express, implied or otherwise, that we will prevent unauthorized access to your private information.
Advertising allows us to provide, support, and improve some of our Services. Creditanddebt.org does not use what you say in email, chat, video calls or voice mail, or your documents, photos, or other personal files to target ads to you. We use other data for advertising in our Services and on third-party properties.
The ads that you see may be selected based on data we process about you, such as your interests and favorites, your location, your transactions, how you use our Services, your search queries, the content you view, demographic data, location data and the information we may collect about you from the sites and apps of our advertisers and Providers.
CHAT BOT DISCLOSURE
UPDATING YOUR MEMBER ACCOUNT INFORMATION
Corrections or updates to your Member account information, including your email address, mailing address and credit card information, can be made through your Member account.
You can choose whether you wish to receive promotional communications from creditanddebt.org by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt-out, you can do so by following the directions in that message. There are a number of other ways to opt-out of having your online activity and device data collected by us:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Use of plug-ins or browsers with privacy features. You can block our websites from setting cookies by using a browser with privacy features or installing browser plugins and configuring them to block third-party cookies/trackers.
Opt-out directly with our Providers. The following advertising partners offer opt-out features that let you opt-out of use of all or some your information for interest-based advertising:
Opt-out directly with the advertising industry. You can also opt-out directly with the following interest-based advertising companies:
Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org/?c=1
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
HOW TO CONTACT US
This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) addresses how creditanddebt.org (collectively “we”, “us”, “our,” or “creditanddebt.org”) collect, use, and share your “Personal Information” as defined in the California Consumer Privacy Act (“CCPA”) Cal. Civ. Code §1798.100 et seq. This CCPA Disclosure applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) and describes certain rights under the CCPA regarding your personal information, including:
- the right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months;
- the right to request, on legitimate grounds, deletion of your personal information that we collected;
- the right to have someone you authorize make a request on your behalf; and
- the right not to be discriminated against for exercising any of these rights.
We also must provide in this online disclosure certain details about our collection and handling of categories of personal information. The information that follows shows the types of personal information we may collect about California residents who are subject to the CCPA, the sources from which we collect it, and the ways in which we use and disclose it.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have/will collect the following categories of personal information from consumers within the last/next twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|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|
|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|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|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.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|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.||NO|
|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:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
HOW DO WE COLLECT YOUR INFORMATION?
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
USE OF PERSONAL INFORMATION
Business and Commercial Purposes for Use of Personal Information:
- Providing and maintaining our products and services
- Verifying your identity
- Detecting and preventing fraud
- Protecting against security risks
- Advertising and marketing
- Conducting research and data analysis
- Maintaining our facilities, systems, and infrastructure
- Improving our products and services
- Carrying out our legal and business purposes, such as complying with federal, state, or local laws, responding to civil, criminal, or regulatory lawsuits or investigations, exercising our rights or defending against legal claims, resolving complaints and disputes, performing compliance activities, performing institutional risk control, and otherwise operating, managing, and maintaining our business
- As otherwise disclosed to you at or before the point of collecting your personal information
We may also use personal information relating to California residents for one or more of the specific “business purposes” listed in the CCPA:
- Certain auditing and measurement purposes, such as counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with applicable 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
- Short-term, transient use
- Performing services on behalf of creditanddebt.org or its service Providers, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of creditanddebt.org or its service Providers
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by creditanddebt.org, and to improve, upgrade, or enhance the service that is owned or controlled by creditanddebt.org
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
DISCLOSURE OF PERSONAL INFORMATION
In the past 12 months, we have/will disclose each of the above-listed categories of personal information for our business purposes to one or more of the following categories:
- You and, where appropriate, your family, your associates and your representatives
- Anti-fraud services
- Accountants, auditors, financial advisors, lawyers and other outside professional advisors to Chase, subject to confidentiality
- Data aggregation services
- Accreditation bodies
- Third party service Providers (such as payment services Providers; shipping companies; etc.)
- Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
- Any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)
DO WE SELL ANY PERSONAL INFORMATION?
Creditanddebt.org does not sell any consumer personal information.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of personal information we disclosed to third parties and the categories of third parties to whom we disclosed personal information.
- The specific pieces of personal information we collected about you.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service Providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service Providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 949-614-1036
- Visiting creditandebt.org
Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the revised CCPA Disclosure on our website.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Credit Swag Ventures, Inc.
27762 Antonio Parkway, Suite L1 626
Ladera Ranch, CA 92694
PRIVACY STATEMENT – NEVADA
YOUR RIGHTS AS A NEVADA CONSUMER UNDER SB-220
SB-220 grants Nevada-based consumers the right to opt-out of the “sale” of their “covered information” by web “operators” to another person in exchange for monetary consideration. SB-220 defines a consumer as a person who seeks or acquires, by purchase or lease, any good, service, money or credit for personal, family or household purposes from the internet, website or online service of an operator. Under SB-220, “sale” means the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons. The definition of “sale” under SB-220 does not include disclosures of covered information:
- To a person who processes the covered information on behalf of the operator;
- To a person with whom the consumer has a direct relationship for the purposes of providing a product or service requested by the consumer;
- To a person for purposes which are consistent with the reasonable expectations of a consumer considering the context in which the consumer provided the covered information to the operator;
- To a person who is an affiliate of the operator; or
- To a person as an asset that is part of a merger, acquisition, bankruptcy or other transaction in which the person assumes control of all or part of the assets of the operator.
EXERCISING YOUR RIGHTS UNDER SB-220
If you are a Nevada consumer and wish to exercise your rights related to SB-220, please contact creditanddebt.org at firstname.lastname@example.org. Please note that if we receive a request from you to exercise your rights, credtianddebt.org has the right to have you take reasonable steps to confirm your identity. Creditanddebt.org is not obligated to, and will not, give effect to data subject rights unless creditanddebt.org can reasonably verify that the request is a “verified request” (as defined under SB-220).