Privacy Policy

We take your privacy seriously and we understand that your privacy is important. This Privacy Policy describes how we collect and use the personal information that we collect about you on www.equifylending.com (the "Website").

By continuing to use the Website,you agree to this Privacy Policy and the collection, use,disclosure, and storage of your personal information as described by this Privacy Policy.

Information We Collect

When you use the Website, we and/or our subsidiaries (collectively referred to herein as“we”, “us” or “our”) may collect personal information about you, such as your name, address, Social Security number, telephone number, email address, asset information, income information, or any other information that you submit on applications or other forms made available through the Website.

We may also collect personal information about you from third party sources, which we may combine within formation that you provided to us or we previously collected.For example, we may receive information from a social media service about you if you use asocial media account to log into the Website.

We also automatically collect certain information related to you and your activities on the Website when you visit the Website. This information includes information such as your IP address,your internet browser and operating system type, the date and time of your visit, and the website that referred you to us.

Cookies and Other Tracking Technologies

Our Website uses cookies and other tracking technologies, such as web beacons (otherwise known as pixel tags). A"cookie" is a small file placed on your computer that helps us to recognize your browser. We use both first and third-party cookies and tracking technologies on the Website. These cookies and tracking technologies may collect your personal information. We may use cookies and tracking technologies to monitor how the Website is used, customize content, serve advertisements and evaluate the effectiveness of our advertising campaigns, identify problems with the Website, improve the Website, analyze Website traffic and other analytics purposes, monitor the security of the Website, and gauge the effectiveness of our communications. Most web browsers allow you to adjust your preferences to reject cookies or to receive notifications before they are placed. If your browser is set to reject cookies,you may continue to use the Website, but some aspects of the Website may not function as intended.

Tracking

Our first-party cookies and tracking technologies do not track users over time and across third-party websites, and therefore the Website does not respond to web browser do-not-track signals.

We also use third-party cookies to serve targeted advertisements on both the Website and on third-party websites.These cookies may track users over time and across third-party websites and services. Please note that if you opt-out of advertising cookies, you may still see our advertisements on third-party websites and services.

How We Use Collected Information

We use personal information and anonymous information for the following purposes:

To complete and fulfill your loan application; to respond to and fulfill your requests;

For our marketing efforts, such as to send you marketing communications that we believe may be of interest to you;

For our business purposes; such as for analysis and to develop new products and services;

To improve the Website and for analytics purposes;

or For any other purpose to which you consent.

The Fair Credit Reporting Act gives you the opportunity to limit the sharing of“non-experience information” among our affiliates. “Non-experience information”includes information that is used,expected to be used, or collected for the purpose of establishing your eligibility for consumer credit, insurance or deposit accounts, and is not related solely to your transactions or other experiences with us, including information:

From your applications, such as your income or marital status;From a credit report, such as your credit history;

From sources used to verify representations made by you, such as your open lines of credit or employment history.

How We Share Personal Information

We will only share personal information with third parties as described in this Privacy Policy. We may share personal information with third parties:

Such as vendors who provide employment verification, degree verification, title, document import, or other necessary services;

Such as our Equify Capital, Inc affiliated businesses that provide quality services or products you may be interested in;

For any purpose to which you expressly consent;

To protect our rights or the rights or safety of others; and As may be required by law or regulation.

We limit the information that we send service providers, and require that our service providers only use shared personal information to perform the services requested in accordance with this Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

For example,after you authorize us to verify your credit history, we send the minimal set of information needed (potentially including your social security number) to ensure we are requesting the correct record in an encrypted form to the relevant credit bureaus with the sole purpose of retrieving your credit report and associated credit history data. We would not send the same level of information to a service provider where it is not essential to perform their services.

In the event that we enter into a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), personal information that we have collected may be transferred in the course of that corporate transaction to the relevant third party purchaser, joint venture partner, merged entity, assignee or similar party.

How We Protect Personal Information

We use reasonable physical, technical, and administrative security measures to protect personal information we collect from loss, misuse, unauthorized access, or improper disclosure. For example, we use encryption technologies when transmitting information to and from the Website and with our third-party service providers. Please understand that no security technology is completely secure, and remember that when communicating with us, email is not a secure form of communication when transmitting sensitive or personal information.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain,or use personal information from children under the age of 13. If we become aware that a child under the age of 13 has submitted personal information to us through the Website, we will immediately delete such information.

Access to and Control Over Information

You may opt-out of any future marketing contacts from us at any time. You can do the following by contacting us via the email address or phone number given on our website:

See what data we have about you, if any;

Change/correct any data we have about you;

Delete any information about you that we are not required by law to keep;

and Express any concern you have about our use of your data.

Updates to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be immediately effective upon the posting of the updated policy. Your continued use of the Website after these updates are posted represents your consent to the terms of the new Privacy Policy. Please regularly check this Privacy Policy for any such updates.

California Privacy Policy (CCPA)
This CCPA PRIVACY NOTICE is for California residents only and supplements the information contained in the Privacy Statement of Equify Capital, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, clients, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

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 collected the following categories of personal information from consumers within the last twelve (12) months:
 
Category
Examples
Collected
A. Identifiers
A real name, alias, postal address, unique personal identifier, onlineidentifier, Internet Protocol address, email address, account name, SocialSecurity number, driver’s license number, passport number, or other similaridentifiers.
This information is collected.
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.
This information is collected.
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).
This information is collected.
D. Commercial information.
Records of personal property, products or services purchased, obtained,or considered, or other purchasing or consuming histories or tendencies.
This information is collected.
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, face prints, and voice prints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
This information is never collected.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
This information is collected.
G. Geolocation
Physical location or movements.
This information is never collected.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
This information is never collected.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
This information is collected.
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.
This information is collected.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
This information is never collected.
Personal information does not include:

Publicly available information from federal, state or local government records.

De-identified or aggregated consumer information.

Information excluded from the CCPA’s scope, such as 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.

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 that we are asked to perform.

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 (www.equifylending.com). 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, credit reporting agencies, appraisers and other service providers.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a rate quote or ask a     question about our products or services, we will use that personal information to respond to your inquiry.

To provide, support, personalize and develop our Website, products and services.

To provide you with information, products or services that you request from us.

To provide you with email alerts, event registrations and other notices concerning our products or  services, or events or news, that may be of interest to you.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

For testing, research, analysis and product development. As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as     part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

To respond to audits or state or federal examinations by our regulators.

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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.

Service providers.

Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information and we have no intention of doing so in the future.

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

Unless your personal information is excluded from the scope of the CCPA, 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 third parties with whom we share that personal information. The specific pieces of personal information we collected about you (also called a data portability request).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business  purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

Unless your personal information is excluded from the scope of the CCPA, 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:

1.  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.

2.  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.  Debug products to identify and repair errors that impair existing intended functionality.

4.  Exercise free speech,ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.  Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).

6.  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.

7.  Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.  Comply with a legal obligation.

9.  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 or Emailing us.

Only you or a person registered with the California Secretary of State 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.  Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If were quire more time (up to 90 days), 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.

Non-Discrimination

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.