Version Date: 02/14/2014
GENERAL

StartAutoLoan.com (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) whether they use our website, including other media forms and media channels, including mobile websites and mobile applications, related or connected thereto (collectively, the “Website”) to participate in the Website’s services that are designed to market certain products and services and attempt to match you with appropriate providers of such products and services (the “Website Services”) or to simply view the Website. The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

Our Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of our Website would be unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
CHILDREN

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Website represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred personal information to the Website, please contact Company using our contact information below to have that child’s account terminated and information deleted.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

“Personally-Identifying Information” is information that can be directly associated with a specific person. Company collects a range of Personally-Identifying Information from and about Website users.
Website Services

It is important that you are aware that we are not a seller of any products or services to users of this Website and Company is not a lender or provider of any financial, insurance or other services. Our Website serves merely as a marketing and matching platform between users and our network of partners (the “Partners”) that offer or market products and services, which may include, depending upon which of our websites you visit, payday loans, auto loans, educational loans, mortgage products, insurance products, home contractor services, or other products and services (the “Offerings”). In order to receive information about the Offerings or to apply for the Offerings, you will be requested to submit Personally-Identifying Information via our online application forms (“Your Application Information”). Depending upon the type of Offering you are applying for, Your Application Information may include any of the following, in addition to other information: your name, address, telephone number (work, home, mobile or other), email address, date of birth, driver’s license number, citizenship status, income, social security number, bank account information, employment information, home ownership information and active military information.

By submitting Your Application Information via the Website, (i) you acknowledge and expressly authorize us to transfer Your Application Information directly to our Partners and (ii) you expressly request us and each of the Partners with which Your Application Information is shared to contact you (directly or through third party marketing agents) by any means (including, without limitation, email, telephone (via home and mobile numbers, whether utilizing an autodialer or pre-recorded messaging or other automated features), facsimile, SMS, direct mail, and website redirect). Your agreement to be contacted by the means stated is not a condition for your purchase of any product or service. If your browser is redirected to a Partner’s website, or you are otherwise contacted in any manner by a Partner, then all subsequent interactions with the Partners, are subject to each such Partner’s privacy policy, terms of use, and other policies and/or terms provided by that Partner. You acknowledge and agree that we and the Partners may verify Your Application Information against national databases that track similar consumer transactions, perform credit checks with credit reporting bureaus/consumer credit bureaus, and verify your social security number and other information contained in Your Application Information. Any and all information that is collected from third-parties may be used to determine if you are eligible for an Offering. By submitting Your Application Information, you agree to allow us and Partners to review, verify, and research Your Application Information in such manner. You understand that Partners may retain Your Application Information, whether or not you are qualified for an Offering with them, in accordance with such Partners’ privacy policies. Your use of this Website is an agreement that you may be contacted in any manner outlined in this Agreement, even if your number is found on a do-not-call registry or similar registry.

Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.

You authorize us to use your information to obtain other information about you (for example, your social security number) from third parties when Your Application Information is incompletely or improperly filled out on our registration form. Third parties include, but are not limited to, consumer reporting agencies, consumer credit bureaus and other outside parties, as permitted or required by applicable laws. If you choose to provide information, such as your social security number, we may use that information to determine your financial status. If you do not provide such information, we may also use other information that you provided for the purpose of verifying your eligibility for a loan or for any other programs, offer, or services.

In certain circumstances, Company acts as a limited agent for the actual third party lender or seller of the products and/or services available at or through the Website. In these circumstances: (a) you will be redirected to the applicable third party lender’s or seller’s website after you have completed entering your information; (b) we will collect and send your Personally-Identifying Information to the respective third party lender or seller in connection with completing your application or purchase from the third party lenders or seller, as applicable; and (c) your application or purchase will subject you to the third party lender’s or seller’s privacy policy, as applicable.

BY SUBMITTING YOUR APPLICATION INFORMATION, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
Company Communications

We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails, if applicable, at the time of application, though we reserve the right to send you notices about your account even if you opt out of all voluntary email notifications.
Company Disclosures

Company will disclose Personally-Identifying Information under the following circumstances:

Website Services. When users participate in our Website Services offered through the Website, they expressly authorize Company to use and disclose their Personally-Identifying Information in accordance with this Privacy Policy and the terms of our Terms of Use for the purpose of providing the Website Services, including disclosures to Partners described above in this Privacy Policy.
By Law or to Protect Rights. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our Company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
Direct Mail Partners. From time to time we may share our postal mailing list with selected providers of goods and services that may be of interest to you. If you prefer not to receive mailings from these providers, you may opt-out at the time you register for our Website (if applicable), or at any time thereafter by going to your account settings (if available) or contacting us using the contact information below.
Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company will email users about products and services that Company believes may be of interest to them and Company also will provide users’ email information to third parties, so that those third parties may directly contact users about additional products and services. If a user wishes to opt-out of receiving marketing materials from Company, user may do so by following the unsubscribe link in email communications, by going to your account settings (if available) or contacting us using the contact information below. Similarly, to cease having your email information provided to third parties, you may do so by contacting us using the contact information below. Even after opting-out, a user may continue to receive marketing emails from third parties to whom Company already has provided the user’s email information. Users will be responsible for directly contacting such third parties to request cessation of further marketing emails.
Mobile Marketing. By submitting your information to this Website you agree to receive mobile marketing including, but not limited to, text messaging based marketing, from both of us and our third party advertisers and marketers. By doing so, you agree that you may incur charges on your individual carrier plan in association with such text messages and you agree to be solely responsible for these charges. By submitting your information you also indicate that you are least 18 years of age and the owner or authorized the user of the wireless device on which messages will be received and that you were authorized to approve the applicable charges. Hereafter, should you choose to opt out of receiving text messages from an individual sender, you may do so by texting “STOP” or “OPT-OUT” as specifically set forth in the communication. Regardless of whether your mobile telephone number is listed on state and/or federal do-not-call registries, we retain the right to contact you by text message.
Affiliates. We may share some or all of your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include a parent company or any subsidiaries, joint venture partners, or other companies that we control or that is under common control with us.
Third Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website, providing direct mail and email, removing duplicate information from customer lists and analyzing data. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination

You may at any time review or change your Personally-Identifying Information by contacting us using the contact information below. Upon your request, we will delete your contact information from our active databases. Such information will be deleted as soon as practicable based on our policy and applicable law. To make this request, contact us as provided below. We will retain in our files some personal information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your personal information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.
General Use

We use the Personally-Identifiable Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website to: deliver the products and services that you have requested, manage your account and provide you with customer support, communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties, develop and display content and advertising tailored to your interests on our Website and other sites, resolve disputes, troubleshoot problems, measure consumer interest in our services, reward you for the ads you watch, inform you of updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our Terms of Use, and as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifiable Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifiable Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on our Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website Generally

“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Website. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

We may also periodically obtain both Personally-Identifying Information and Non-Personally-Identifying Information about you from other Company-affiliated businesses, business partners, contractors and other third parties and add it to our account information or other information we have collected. Examples of information that we may receive include: updated address information, purchase history, and additional demographic information.
Web Cookies

A “Web Cookie” is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site. Company uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. Company does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
Third Party Providers

We use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: https://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.

Web technology information:

This may be personal or non-personal information and collected by us or third parties under contract with us. We use two third party services:  ActiveProspect’s TrustedForm Script is used to independently document users’ consent to be contacted. The TrustedForm Script is embedded on this website and collects the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the TrustedForm Script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser. For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at ActiveProspect.  Similarly, we utilize Jornaya’s LeadiD script which is embedded on this website and also collects information such as browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, IP address and number of clicks and  tracks users’ movements around the site (including the capture of visual snapshots of the user’s activity on the site).  To review Jornaya’s data use and collection policies and practices, please visit: Jornaya.  The information collected from this technology is combined with other aggregate data to issue a unique identifier for that site visit. 

Web Beacons

A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
Aggregated and Non-Personally-Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on our Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
CONTESTS, GIVEAWAYS AND SURVEYS

From time to time, Company may offer Website users the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, Company may also ask Website users to participate in surveys designed to help Company improve the Website. Any Personally-Identifying Information provided to Company in connection with any survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Privacy Policy only in non-personally-identifying, aggregated form.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Company, other than in accordance with this Privacy Policy. Third parties are under no obligation to comply with this Privacy Policy, however, with respect to Personally-Identifying Information that users provide directly to those third parties or that those third parties collect for themselves. Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third-party, or using a third party application, whether by means of a link on the Website, directly through the Website, or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.
SECURITY

We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks.
PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Users should regularly check this page for any changes to its Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.
CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
CONSENT TO ELECTRONIC DISCLOSURE

By submitting your information via the Internet, you agree to receive certain notifications, disclosures and/or documents electronically. This Consent to Electronic Disclosures applies to the information you are providing on this Website and any other communications we or any third party may provide to you. By submitting your information you agree to receive all such notifications, disclosures and/or documents from us or any third party in electronic form or online in accordance with this document. You may withdraw your consent prior to submitting your information by exiting the Website or by closing your browser. However, you will not be able to submit your information if you withdraw your consent by exiting the Website or closing your browser. Following the submission of your information, you may be able to withdraw your consent to future electronic disclosures from a third party by contacting the third party directly, but due to rules regarding the timing of delivery of disclosures that need to be made to you, you acknowledge that an opt-out notice may not be received and acted upon by such third party prior to such disclosures being delivered to you electronically. We do not process opt-out communications for third parties, and each third party establishes its own rules regarding opting out of future electronic communications and disclosures.

All notifications, disclosures and/or documents that we or any third party provide to you in electronic format will be provided either (i) via e-mail; (ii) by access to a secure customer service website which will be provided to you in an e-mail notice sent to you when the documents are available; (iii) by posting on this Website or the third party’s site; (iv) by SMS text messaging to your mobile device; or (v) by posting on a website designated for that purpose. All notifications, disclosures and/or documents provided in electronic or paper format from us or any third party to you will be considered “in writing,” and you should print a copy for your records. You may obtain any notifications, disclosures and/or documents in paper form without charge from us by printing them yourself from our Website or the appropriate third party’s Website, when available. To access, view and retain the notifications, disclosures, and/or documents available to you in electronic form, you must have Internet access, sufficient electronic storage capacity, an e-mail account with an Internet service provider e-mail software.

You agree and intend the federal Electronic Signatures in Global and National Commerce Act to apply to (i) your consent to receive notifications, disclosures and/or documents in electronic form; (ii) the information you provide, and (iii) our and/or any third party’s ability to conduct business with you by electronic means.

By completing and submitting your information, you (i) agree to provide us with an accurate and complete e-mail address and other required information requested on this Website; (ii) confirm your consent to receive notifications, disclosures and/or documents from us and any third party in electronic format; (iii) affirmatively demonstrate your ability to access the notifications, disclosures and/or documents in electronic form; (iv) confirm that you have provided a current e-mail address at which electronic notifications, documents and/or disclosures can be sent to you; (v) acknowledge that you have read and reviewed the terms contained in this Consent to Electronic Disclosure; and (vi) agree to the terms contained in this Consent to Electronic Disclosure.

We and any third party, reserve the right, in our sole discretion, to discontinue electronic provision of notifications and/or documents. You will be provided with notice of any such termination or change as required by law.

To facilitate electronic commerce, to reduce the expense of records storage, and to obtain the benefits of faster access to records, you acknowledge and agree that all records may be stored electronically; and that neither we nor any third party will retain and have no obligation to retain any original or electronic documents for any period of time beyond the regulatory requirements. This applies to all notifications, disclosures and/or documentation. You further acknowledge and understand that all original and electronic notification, disclosures and/or documentation will be routinely destroyed, but not before the period of time designated by regulatory requirements. Records may be stored electronically via imaging, scanning, filming or other technology used for the storage of documentation via internal processes or third-party processors that we or any third party approve for these services. You agree that such storage shall be secure, and further agree that such records shall for all purposes be recognized and admissible in evidence or otherwise to prove the agreements, rights and obligations of the parties pursuant to any such records. We will retain your information for as long as needed to provide you services. If you wish to request that we no longer use your information to provide you services please contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
DO NOT TRACK POLICY

Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, this Website does not currently respond to Do Not Track signals. Our business partners and advertising networks that serve interest-based advertisements on our Website have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests, and it is possible that they may reuse this small amount of information on other websites or services.
CONTACT

If you have any questions regarding our Privacy Policy, please contact our privacy officer at:

Privacy Officer
StartAutoLoan.com
Email: [email protected]