Privacy & Security
Earnest’s Privacy Notice
This policy describes our principles and practices regarding the sharing of customer information with our affiliates and outside companies.
One American Bank’s Privacy Notice
For loans originated by One American Bank, this policy describes One American Bank’s principles and practices regarding the sharing of customer information with affiliates and outside parties.
YOUR DATA IS PROTECTED
All data entered into the Site is encrypted using industry-standard SSL technology before being sent to our servers in an off-site data center. Our servers are supported by multiple levels of protection including firewalls, private subnets and multi-factor authentication.
YOUR DATA IS NOT FOR SALE
We do not sell your information. We may need to share information provided by you with our partners so that they can perform requested services – but your information is never sold by us.
PRIVACY & SECURITY POLICY
We believe that you deserve the utmost respect when it comes to the privacy of your personal information. As you use our services, we want to be clear on how we are using information and the ways in which you can protect your privacy. The terms “we,” “us,” and “our,” refer to Earnest LLC, Earnest Operations LLC, Earnest Home LLC, Navient Corporation and/or Navient Solutions, LLC and their respective subsidiaries, affiliates agents, successors, and assignees. The “Site” refers to Earnest’s World Wide Web site located at www.earnest.com, as well as to associated Earnest website content linked to this World Wide Web site and to Earnest’s mobile device-enabled website content and mobile application content.
INFORMATION WE COLLECT
Information we collect while you use the Site helps us improve our services. During the loan application and rate estimate processes we may request and collect personal and financial information from you, such as your name and address.
We may also collect information from you when you use the Site. We collect personal and financial information during your registration, the loan approval process, and during the servicing of your loan. Additional information may be gathered during your future use of the Site. Information that we collect may include personally identifying information, such as your name, address, email address, telephone number, or social security number. This includes authorizing your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber details, if available, to Earnest and service providers for the duration of the business relationship, solely for identity verification and fraud avoidance. We may also collect financial information such as your income, account balance, payment history, credit history, or credit scores.
If you use the “Connect Accounts” feature on the Site, Earnest will utilize a third-party service provider to use and store the username and password information you provide to access your account information from the financial institutions you have identified, as well as to process payments you have approved. Your connected accounts username and password information will not be stored by, or available to, Earnest personnel and will be maintained by the third-party service provider.
LOG ON AND OTHER INFORMATION
We and/or our service providers may also collect and use information about you on a personal or aggregated basis in the administration of the Site to improve products and services, evaluate the success of particular marketing/advertising campaigns, assist in technical support, and help optimize the Site.
Our servers may automatically collect and store certain technical information when you visit or use our Site, mobile device-enabled website content, or our downloaded mobile application, including information such as the Internet Protocol (IP) address of the device you use to connect to the Internet, browser type, device type, mobile device ID (UDID), screen size and resolution, Internet Service Provider (ISP), the website you came from and exited to, operating system, date/time stamp, pages visited and anonymous identifiers.
If you give us your current physical location, for example, when you visit or use our Site or other content, or enter your current address or ZIP code, we may use and store that information to provide you with location-based information or messaging. If you do not want to give us your current physical location, do not enter this location on our Site and do not allow your browser or mobile device to send it to us.
HOW WE USE INFORMATION WE COLLECT
We use this information to help us verify your identity, communicate with you during and after the approval process, review and render decisions regarding your loan application, determine an appropriate loan rate, and service your loan over time. We also use some of this information to improve our products and services, the Site and advertisements, and to let you know when we have new services available. We may also use this information to ensure that any content we display is relevant based on information you included in your profile and your use of the Site.
Earnest may also use your personal information to facilitate activities and transactions that need to occur during the lending process, such as:
- To establish that you are over the age of 18;
- To verify your identity and guard against potential fraud;
- To pull a credit report from a credit bureau, such as Experian, to help determine your creditworthiness;
- To determine your eligibility for an Earnest loan;
- To enable our financial services partners to implement automatic payments and fund transfers;
- To contact you if there is a problem completing a transaction you requested or to discuss a problem with your account;
- To implement collection activities as needed; and/or
- To maintain regular communications with you concerning transactions you initiate, including but not limited to requesting information or assistance, submitting a loan request, and making payments.
More generally, we may use information that we collect from you or that you provide to us:
- To provide, maintain, protect and improve our services, to develop new ones, and to protect Earnest and our users;
- To notify you about changes to the Site or any products or services we offer or provide through it;
- To keep a record of your communication to help solve any issues you might be facing;
- For our marketing purposes to offer our products and services to you, such as advertisements, by us through third parties;
- To offer you tailored content giving you more relevant search results and ads;
- To fulfill any other purpose for which you provide it or otherwise give your consent;
- To conduct and report on certain analytical research, performance tracking and benchmarking through use of anonymous, aggregated information comprised of financial account balances and data, or other available data provided by you; and/or
- To comply with any court order, law, or legal process, including retaining personal data or responding to any government or regulatory request.
INFORMATION YOU SHARE
Your account profile information and certain additional data you provide is available to be reviewed through your online account. You can review and make changes to your profile information by logging into the Site and visiting your account profile page. You may also email us at [email protected] to correct your personal information, including information that cannot be updated online.
Certain information about you cannot be changed due to legal restrictions or requirements and we may not accommodate a request to change information if we believe the change would violate any law or cause the information to be incorrect.
We do not intend to collect personal information from children under 13 years of age. If we learn that we have collected such information from a child under the age of 13, we will promptly take all reasonable steps to delete the data from our system.
REVIEWING AND UPDATING YOUR INFORMATION
Unless prohibited by law, you may, upon reasonable notice, view any information collected from you through your visits to or use of our Site, to make corrections to such information if necessary, or to request that such information be removed from our systems.
INFORMATION WE SHARE
Some of products and services offered on the Site are enabled through the provision of services to us by certain third-party service providers, or through the actions of business partners.
From time to time, you may access our Site through the website of one of our marketing partners. We will try to show clearly whether a page is co-branded by placing our marketing partner’s name or logo in a prominent place or otherwise. If you provide your information on a co-branded page, your registration information may be shared with our marketing partner.
Earnest may also use certain remarketing services to advertise on third-party websites to previous visitors to the Site. This means that we may advertise to previous visitors who haven’t completed a task on the Site (like completing a loan application). This could be in the form of an advertisement on a search results page, or a site in the network of our remarketing partners.
B. PARTNERS & SERVICE PROVIDERS
Some of the services that are offered through the Site may be provided by third-party service providers, like Experian. We may also outsource some of Earnest’s functions to third-party service providers, such as data storage providers, platform administrators, credit bureaus, collection agencies, loan servicers, payment processing functions, and/or other services. We may share information from or about you with these third-party providers so that they can perform the requested services or complete your requests. We may also use and share aggregated and other anonymous data with partners, service providers and third-parties.
C. CONNECTED THIRD-PARTY ACCOUNTS
You can connect your loan application to your accounts on third-party services, in which case we may collect and store information identifying your account with the third-party service. We may use the information to inform your application and service your account after you have taken out an Earnest loan.
D. AGGREGATED INFORMATION
We may share aggregated, anonymized information with third parties, such as advertisers and content distributors to conduct certain analytical research, performance tracking and benchmarking. We and/or our third-party service providers may publish summary or aggregate results relating to metrics comprised of research data, from time to time, and distribute or license such anonymous, aggregated research data for any purpose, including but not limited to, helping to improve products and services and assisting in troubleshooting and technical support. Your personally identifiable information will not be shared with or sold to such third parties.
The Site may contain links to unaffiliated third-party websites. Except as described in this policy, we do not share your personal information with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on all such third-party websites.
F. LAW ENFORCEMENT
We may disclose information from or about you if we have a good faith belief that such investigation or disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with the Site; or (c) protect our rights, reputation, property, or that of our users, affiliates, or the public.
Cookies help us protect your account’s security, and allow us to personalize your Earnest experience.
Most importantly, cookies help us protect your account’s security. Cookies may be stored only during an individual session (“Session ID cookies”) or have long-term expiration dates (“persistent cookies”). Session ID cookies follow your activities on our site so that we can ensure that no one is making changes to your profile or applying for loans, and expire when you close your browser. Persistent cookies that remain on your hard drive for an extended period of time so that we can recognize you when you return to our Site.
The following is a list of the types of cookies that Earnest and its third-party service providers use:
These Cookies make the Site work in the way you expect it to.
B. AUTHENTICATION, SECURITY, AND COMPLIANCE
We use authentication and security cookies to prevent fraud, protect your data from unauthorized parties, and comply with a variety of data security, privacy, and financial protection related legal requirements.
These Cookies help the Site remember information about how you prefer the Site to behave and look.
We use these Cookies to give us notice of information or options that we think could improve your use of the Site.
These Cookies make advertising more relevant to you and more valuable to advertisers.
These Cookies help us understand how visitors use the Site.
Generally speaking, web browsers automatically accept cookies by default. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked, but doing so may affect your ability to use the Site. The method for disabling cookies may vary by device and browser, but can usually be found in preferences or security settings.
PROTECTING YOUR INFORMATION
Earnest takes your privacy and security seriously. We have enabled HTTPS access to the Site, in addition to SSL technology, and your login information of your financial accounts is not accessible to anyone at Earnest.
Additionally, there are a number of precautions you can take to protect the security of your personal information, including selecting a strong Earnest password and not sharing it with anyone.
Earnest takes steps to safeguard your personal information through vigorous electronic and operational policies and practices:
- Session Time-Outs: We employ session time-outs to protect your account. This reduces the risk of others being able to access your account if you leave your computer unattended.
- Protection of Account Numbers: After you have entered your account numbers, we will not display your full account number.
- Passwords: At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including email reset. Your password is not known to any employee or third-party with whom we may partner, and we will never ask you for your passwords as a means of identifying yourself. If you ever receive an email purporting to come from Earnest that asks for your password, you should immediately report this to [email protected].
- Secure Hosting: We store your personal and sensitive financial data such as Social Security numbers and bank accounts in a virtual private cloud hosted by Amazon Web Services or a secure data center.
- Defined Service Access points: Data can only be read or written through defined service access points, the use of which is password-protected and limited to only employees or those third parties that have a need to know.
- Secure Socket Layer certificate technology: We equip our servers with SSL certificate technology to provide a safe and secure channel to visit the Site.
- Network firewalls: There is no inbound communication allowed between data and application servers and the Internet.
- Physical Security: Earnest maintains robust requirements for the protection of information in our offices which are all located in a secure building environment. Access to company and client information is restricted to those persons with valid, tracked, identity-based key-card access. Sensitive physical information is maintained in a locked environment
COMMUNICATIONS FROM EARNEST
Earnest may send you notifications regarding your account. You cannot opt out of these notifications as they are in place to comply with legal requirements and help protect your privacy and security, but you can opt out of certain marketing communications as described in our Privacy Notice. You can opt out of marketing emails by clicking the unsubscribe link at the bottom of any marketing emails you receive.
To protect your account, Earnest may send you notifications that confirm actions taken on your account. These notifications are typically sent to notify you of a change in status or contact information, or for legal or security purposes. For example, you may receive notifications confirming your registration and the successful submission of loan requests, as well as requests from us for additional information and reminders to sign your loan agreement.
You cannot opt out of these notifications as they are in place to protect the security of your account and personal information. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered by these notifications can be undermined if other people have access to your email account.
Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Even under the best of circumstances, the transmission of information via the internet is not completely secure. Any transmission of personal information is done at your own risk. In the event of a data breach, we will comply with the notification guidelines required by federal law as well as the laws of each state in which we do business.
WHAT CAN I DO TO PROTECT MY SECURITY?
Use a strong password, do not share it, and only log onto your Earnest account from a secured computer with virus protection.
You can take several precautions to protect the security of your computer and personal information.
- Use a unique password that you do not use for any other service.
- To choose a strong password, avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and use special characters in place of letters.
- Do not share your Earnest password with anyone.
- Restrict access to the email account you registered with on the Earnest site.
- Install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users.
- Do not log onto your Earnest account in public areas where the internet is unsecured.
- Logout and close the browser window when you are finished with a session on the Site.
YOUR CALIFORNIA PRIVACY RIGHTS:
THIS POLICY WAS LAST UPDATED ON 3/10/2020.
For additional information, or if you have any questions regarding this policy or the privacy practices at Earnest, please submit your questions or comments directly at: [email protected].
303 2nd Street, Suite 401N
San Francisco, CA 94107