California Privacy Policy

THIS PRIVACY POLICY IS EFFECTIVE AS OF JANUARY 1, 2020

California Privacy Policy

This California Privacy Policy supplements the information contained in our Online Consumer Information Privacy Policy, and applies solely to all visitors, 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 any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD

You have the right to request that we disclose certain information to you about the personal information we have collected, used, disclosed or sold.

You may submit your request by clicking here or calling (866) 439-0996. We will use the information you submit to ensure we have a verifiable consumer request and will fulfill your request in accordance with CCPA requirements.

 

INFORMATION COLLECTED, DISCLOSED OR SOLD —

Over the past 12 months we have collected information from the Identifier category as defined in the CCPA, such as name, address, email address, social security number, driver’s license number, payment card information, and information from the Professional or Employment Related category as defined in the CCPA, such as employment information. Information is collected from you when you complete an application for credit products or services on our site and information you provide on forms as your account is serviced. We have also collected internet activity such as browsing history, search history, information on interaction with a website, application, or advertisement. Information is also collected from third parties in order to allow us to provide our services to you and/or our clients. This includes information such as credit scores.

In addition, we collected information from the Identifier category as defined in the CCPA, specifically name and mailing address, from a consumer data reseller in order to send one or more marketing offers about our student loan products. We shared these names and mailing addresses with our vendor so that they could print and mail the offer. Our contract with the vendor prohibits them from using the information for any other purpose.

Under the CCPA, “sell” includes disclosing or communicating personal information, and not necessarily a monetary exchange for personal information. (See the Right to Opt-Out of the Sale of Personal Information section below for further details). We do not sell your personal information under the traditional definition under any circumstances. We do not sell (as defined by the CCPA) personal information of minors under 16 years of age.

 

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

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.

We may deny your deletion request if retaining the information is necessary for us or our service providers to perform certain actions permitted under the CCPA. Most information we collect is subject to one or more of the permitted exceptions. For example:

  • Completing the transaction for which we collected the personal information (such as servicing your account or maintaining your account record), providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities.
    Debugging products to identify and repair errors that impair existing intended functionality.
  • Enabling solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Complying with a legal obligation.
  • Making other internal and lawful uses of that information that are compatible with the context in which you provided it.

You may submit your request by clicking here or calling (866) 439-0996. We will use the information you submit to ensure we have a verifiable consumer request, and will fulfill your request in accordance with CCPA requirements

 

RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION

You have the right to opt out of the sale of your personal information. A “sale” is defined in the CCPA as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. It does not include sharing your personal information with a service provider if the service provider does not further collect, sell, or use the personal information beyond the business purpose for which it was shared.

You may submit your request to opt out of the sale of information by clicking here.

 

RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF YOUR PRIVACY RIGHTS

You have the right to be protected from discrimination for exercising your CCPA rights. We will not discriminate against you for exercising your rights under the CCPA by doing any of the following: denying goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to the consumer; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

DESIGNATING AN AUTHORIZED AGENT

You may use an Authorized Agent to submit a request to know or a request to delete. The person (or business registered with the California Secretary of State) you may have previously designated to act on your behalf for another purpose with us may be used to submit this request for you. If you haven’t previously designated an Authorized Agent, you may do so by contacting us.

 

CONTACT FOR MORE INFORMATION

Phone: (866) 439-0996

This Privacy Policy is effective as of January 1, 2020