Effective Date: 01/2018
emBorrow is serious about protecting your privacy. This policy notice is provided to you on behalf of emBorrow and its controlling companies (“emBorrow”) and all of their respective subsidiaries and affiliates, (hereafter collectively referred to as the “emBorrow Related Companies”, “we,” “our,” or “us”). “You” or “Your” means you as a participant in or as a user of the products and/or services offered by emBorrow Related Companies.
All information transmitted, printed or otherwise submitted to us shall be deemed to be our property and we shall be free to use such information for any lawful purpose described herein, and for other purposes as required or permitted by law.
Please read this Policy carefully. This Policy provides important information about the way we collect, share, and protect your information and governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Policy (including, without limitation, both mobile and online versions of our site), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a site and that posts a link to this Policy regardless of how you access and/or use them, whether via personal computers, mobile devices or otherwise. This Policy applies to anyone who applies for or uses our products or services, or visits our websites, including, but not limited to, current and former customers. We must notify you about our sharing practices when you establish a customer relationship and each year while you are a customer. A customer relationship begins when you obtain a financial product or service from us. A customer relationship terminates when you pay off a transaction in full. This Policy does not govern the data practices of third parties that may interact with our site.
To the extent we provide you notice on our site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
- Information Collection
- Use of Your Information
- Sharing Your Information
- Furnishing Negative Information
- Automatic Information and Cookies
- Right to Limit the Sharing of Your Information and Opt-Out
- Interest-Based Advertising
- Protecting Your Information
- Right to Contact You
- Right to Change This Policy
We collect personally identifiable information, including, but not limited to, non-public personal information, as well as other types of personally identifiable information from you and from other sources as described herein (collectively, “Your Information”). Our primary goal in collecting Your Information is to provide you with efficient, accurate, and customized financial products and services. Your Information also helps us personalize and improve your customer experience with us. We collect and/or track the following types of information:
- Information we receive from you on applications or other forms, such as transaction documents, sales documents, online forms, e-mails, registration forms, surveys, or other documents or submissions related to the products and services we provide, including your name, address, telephone number, social security number, driver’s license number, email address, employment information, demographic information, bank account information, and information about your assets, debts and income;
- Information about your transactions with us, our affiliates, or others, such as your account history, transaction balances, payment history, overdraft history, parties to transactions, and your reasons for doing business with us;
- Information we receive from third parties, such as consumer reporting agencies and other lenders, regarding your credit worthiness and credit history, and to verify your identity;
- Information we obtain to verify representations made by you, such as your employment history or income;
- Information obtained from specialized marketing information firms, such as household demographics;
- Information obtained from Web page http headers (home server domain names, IP address, type of client computer, and type of Web browser);
- Information, user specific or aggregate, we receive from our web pages recording visitor’s access;
- Information you provide when you contact our customer service department; and
- Information you provide to us when you communicate with us via email or regular mail.
Use of Your Information
We can use Your Information to:
- Provide you with information, products and services you request and process transactions that you have requested or agreed to receive;
- Offer you additional products or services, from us or from others that may be of interest to you;
- Process your registration with the site, including verifying your information is active and valid
- Comply with all reporting and other legal requirements;
- Enhance your overall experience at our websites;
- Enable you to participate in a variety of the site’s features such as online entry sweepstakes, or other promotions;
- Process payments and update account records;
- Analyze customer demographics, payment histories, and preferences;
- Contact you with regard to your use of the site and, in our discretion, changes to the site and/or site’s policies;
- Conduct statistical analyses;
- Conduct internal business; and
- Provide our advertisers with editorial or feedback information.
Sharing Your Information
share or sell Your Information with any other emBorrow Related Company (collectively, its “Affiliated Companies”) and with other companies with whom any emBorrow Related Company does business (“Non-Affiliated Third Parties”) as permitted by law and as described in this Policy. These Affiliated Companies and Non-Affiliated Third Parties may be: (1) financial service providers, such as mortgage bankers, mortgage brokers, consumer lenders, small loan lenders, tax refund anticipation loan lenders, loan brokers, deferred deposit providers, check cashers, supervised lenders, delayed deposit providers, deferred presentment providers, collection agencies, consumer reporting agencies, banks, credit card providers, debit card providers, store valued card providers, insurance agencies, bill payment agencies, ATM providers, pawn and title pawn providers, automobile dealers, automobile financing providers, automobile leasing providers, money transfer and remittance providers, sellers and remitters of money orders, insurance services providers, and financial service provider holding companies, or agents, contractors, or representatives of any of the foregoing; (2) non-financial companies, such as retailers, tax preparers, payroll service providers, advertisers, marketing companies, lead generators, advertisers on our websites, companies or individuals that do industry-related research, surveys or polls, automobile dealers, and any person who offers a non-financial product or service, and holding companies, or agents, contractors, or representatives of any of the foregoing; and (3) other businesses, such as non-profit organizations, trade associations, and industry analysts or agents, contractors, or representatives of any of the foregoing.
Affiliated Companies and Non-Affiliated Third Parties may use Your Information for any legal purpose, including, but not limited to, developing and promoting new or joint products, improving existing products and services, and contacting you to offer products and services that may be of interest to you. We may also disclose Your Information, as described above, to companies who perform services on our behalf or to other financial institutions with which we have joint marketing agreements.
The emBorrow Provider may also disclose Your Information to Affiliated Companies and Non-Affiliated Third Parties that provide services to us or you (collectively, “Service Providers”). We contract with Service Providers to perform certain functions on our behalf. Examples include database providers who assist in identity verification, credit scoring companies, magazine publishers, retailers, and direct marketers. Service Providers’ access is limited only to the personal data needed to perform their functions, and only for the purpose of performing those functions, and they are prohibited from using or disclosing Your Information for other purposes.
Third-party analytics and other Service Providers may set and access their own Tracking Technologies on your personal computer, laptop, tablet, mobile phone or other device and they may otherwise collect or have access to information about you. These Service Providers use the technology described above to help us analyze how users use the website. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
We also may share Your Information if it becomes necessary for compliance with the law or to protect the rights, property, or safety of our websites, our users, or third parties. We reserve the right to release such personal data to law enforcement or other governmental officials as we, in our sole and absolute discretion, deem necessary to comply with the law. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. In addition, we reserve the right to use and disclose Your Information that is not in individually identifiable form as we deem appropriate, in our sole discretion.
Notice of Furnishing Negative Information
WE MAY REPORT INFORMATION ABOUT YOUR ACCOUNT TO CREDIT BUREAUS. LATE PAYMENTS, MISSED PAYMENTS, OR OTHER DEFAULTS ON YOUR ACCOUNT MAY BE REFLECTED IN YOUR CREDIT REPORT.
Automatic Information and Cookies
In addition to any personally identifiable information or other information that you choose to submit to us via our site, we and our Service Providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our site. To the extent we associate Usage Information with your personally identifiable information we collect directly from you on the site, we will treat it as personally identifiable information.
This Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the site, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our site;
- the areas within our site that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day, among other information.
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed): Cookies, Web Beacons, Embedded Scripts, Browser Fingerprinting, ETag, or entity tag.
We may use Tracking Technologies for a variety of purposes, including:
- to allow you to use and access our site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of site functionality.
- to assess the performance of the site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the site.
- to offer you enhanced functionality when accessing the site, including identifying you when you sign-in to our site or keeping track of our specified preferences, including in terms of the presentation of content on our site.
- to deliver content, including ads, relevant to your interests on our site and third-party sites based on how you interact with our advertisements or content.
There may be other Tracking Technologies now and later devised and used by us in connection with the site. Further, third parties may use Tracking Technologies with our site and this may involve the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them.
Right to Limit the Sharing of Your Information and Opt-out
In some circumstances, you have the right to direct the emBorrow Provider to not share Your Information with its Affiliated Companies and/or Non-Affiliated Third Parties (i.e. “Opt-Out”). Please note that even if you Opt-Out, the emBorrow Provider may still share Your Information with its Affiliated Companies and Non-Affiliated Third Parties as permitted or required by law. Also, the emBorrow Provider may share information it collects regarding its transactions and experiences with you with its Affiliated Companies. The emBorrow Provider may also share all information it collects about you with Affiliated Companies and Non-Affiliated Third Parties: to facilitate providing our services to you, to administer our business, in order to receive services from those companies, as permitted under joint marketing agreements, and as otherwise permitted or required by law.
The emBorrow Provider is delivering this notice to you on behalf of itself and all other emBorrow Related Companies. You may limit how the emBorrow Provider’s Affiliated Companies use Your Information the emBorrow Provider shares with them. Federal law gives you the right to limit some but not all marketing from the emBorrow Provider’s Affiliated Companies. You may limit a emBorrow Provider’s Affiliated Companies from marketing their products or services to you based on Your Information that they receive from the emBorrow Provider. This information includes your income, your account and payment history, and your credit history, report or score.
To limit the emBorrow Provider’s sharing of Your Information with Affiliated Companies and Non- Affiliated Third Parties, as described above, contact us:
- By email: firstname.lastname@example.org
- By mail: emBorrow, LLC. 2100 Sanders Rd – Suite 200, Northbrook, IL 60062
Unless we hear from you, we can begin sharing Your Information thirty (30) days from the date we first deliver this Notice to you. However, you may Opt-Out at any time by contacting us. Once we receive your Opt-Out request, we will stop sharing this information as soon as reasonably practicable. Your Opt- Out request will remain in effect until you notify us otherwise in writing.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The site may allow you to review, correct or update personally identifiable information you have provided through the site’s registration forms or otherwise, and you may provide registration updates and changes by contacting to the above email or mailing address. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your personally identifiable information or change your preferences on the site, information that you remove may persist internally for our administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your website account and changing your communication preferences if those website features are available. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
Data about your activities online are being collected on our website for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics Service Providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Policy provides details and explains how to exercise that choice.
You may see certain ads on other websites because we participate in advertising networks administered by third parties. These networks track your online activities over time by collecting information through automated means, including through the use of the technologies described in the “Automatic Information and Cookies” Section above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our websites, such as the pages you have viewed. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your device and may set or change settings on your device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.
This collection and ad targeting takes place both on our websites and on third-party websites that participate in the ad network, such as sites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts.
Protecting Your Information
We restrict access to Your Information to those employees who need to know that information to provide products or services to you. We maintain commercially reasonable physical, electronic, and procedural safeguards that comply with federal regulations to guard Your Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we are not able to ensure the security of any information you transmit to us, and you use our site and provide us with your information at your own risk.
Right to Contact You
We reserve the right to contact you regarding your account status and changes to subscriber agreements, our Policy, and/or any other policies or agreements relevant to you. By visiting our websites, you understand and agree that we may contact you at the phone number, email address or mailing address you provide to us through our websites or on your transaction agreements, applications, loan documents or any other document to assist you with your product or to discuss other products and services that a emBorrow Related Company may provide for you.
Our Right to Change This Policy