State
Specific Privacy Rights
Residents
of the States of California, Colorado, Connecticut, Virginia and Utah, as well
as businesses organized under the laws of the State of California
(collectively, “Covered Users”) are afforded additional rights pursuant
to applicable state law. Please see our “Privacy Provisions for Covered
Users” below for a more complete description of
your rights as a Covered User.
1. Your
California Privacy Rights
Shine
the Light. If you are a resident of the State of California and
would like to learn how your “personal information” (as defined in the Shine
the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what
categories of personal information that we have shared with third parties in
the preceding year, as well as the names and addresses of those third parties,
please: (a) email us at: [email protected] with the subject
line “Privacy”; or (b) send us correspondence via U.S. Mail to: PennyGreenLoan,
10001 Marshall Drive, Lenexa, KS, 66215.
Further,
if you are a resident of the State of California and would like to opt-out from
the disclosure of your personal information to any third party for marketing
purposes, please: (a) email us at: [email protected] with the subject
line “Privacy”; or (b) send us correspondence via US mail to: PennyGreenLoan, 10001
Marshall Drive, Lenexa, KS, 66215.
California
Consumer Privacy Act of 2018 (“CCPA”). In addition to
the foregoing, if you are a resident of the State of California certain other
privacy-related rights may apply to you in accordance with the CCPA, including
the right to opt-out of our sale/sharing of your personal information, as well
as the right to know what personal information about you we have collected,
whether your personal information was shared/sold with/to third-parties in the
preceding year and, if so, what categories of personal information were
shared/sold, as well as the categories of third parties with whom we shared or
sold that personal information. Please see our “Privacy Provisions for
Covered Users” below for a more complete description of
your rights under the CCPA as a California resident.
The
California Privacy Rights Act (“CPRA”). In addition to
the foregoing, if you are a resident of the State of California, certain other
privacy-related rights may apply to you in accordance with the CPRA, including
the right to correct personal information we have collected about you, the
right to opt-out of our use/sharing of your sensitive personal information, the
right to know how long we retain your sensitive and non-sensitive personal
information, the right to know what sensitive personal information about you we
have collected, whether your sensitive personal information was shared with
third-parties in the preceding year and, if so, what categories of sensitive
personal information were shared, as well as the categories of third parties
with whom we shared that sensitive personal information. Please see our
“Privacy Provisions for Covered Users” below for a more complete description of
your rights under the CPRA as a California State resident.
Browser
“Do Not Track” Signals. Most browsers contain a
“do-not-track” setting. In general, when a “do-not-track”
setting is active, the User’s browser notifies other websites that the User
does not want her/his personal information and online behavior to be tracked
and used, for example, for interest-based advertising. As required by
California Online Privacy Protection Act (“CalOPPA“), we are
required to inform you that, as is the case with most websites, we do not honor
or alter our behavior when a Site User has activated the
“do-not-track” setting on her/his browser; provided, however, that
you may have certain rights with respect to the use of automated technologies
to deliver targeted advertising to you, as well as to create profiles of you
using your personal information.
2. Your
Colorado Privacy Rights
If you
are a resident of the State of Colorado, certain privacy-related rights may
apply to you in accordance with the Colorado Privacy Act (“CPA”),
including the right to opt-out of our sale/sharing of your personal
information, as well as the right to know what personal information about you
we have collected, whether your personal information was shared with
third-parties in the preceding year and, if so, what categories of personal
information were shared, as well as the categories of third parties with whom
we shared that personal information. Please see our “Privacy Provisions
for Covered Users” below for a more complete description of
your rights under the CPA as a Colorado State resident.
3. Your
Connecticut Privacy Rights
If you
are a resident of the State of Connecticut, certain privacy-related rights may
apply to you in accordance with the Connecticut Data Privacy Act (“CDPA”),
including the right to opt-out of our sale/sharing of your personal
information, as well as the right to know what personal information about you
we have collected, whether your personal information was shared with
third-parties in the preceding year and, if so, what categories of personal
information were shared, as well as the categories of third parties with whom
we shared that personal information. Please see our “Privacy Provisions
for Covered Users” below for a more complete description of
your rights under the CDPA as a Connecticut State resident.
4. Your
Nevada Privacy Rights
Nevada
State residents have the right to submit opt-out requests to website operators
instructing those website operators not to sell any “covered
information” that the website operators have collected about Nevada State
residents to any third party data broker(s). Covered information includes a
consumer’s name, postal and email address, telephone number and Social Security
Number, and includes the Information described below in the “Personal
Information that We Collect” section.
If you
are a Nevada State resident and you wish to exercise your right to request that
we to stop the sale of your Information to third party data brokers, please
e-mail us at: [email protected]; or send us U.S. Mail to: PennyGreenLoan,
96 Linwood Plaza, #458, Fort Lee, NJ 07024. In your request, please specify
that you want to exercise your rights to opt-out from the sale of covered
information under the Nevada Privacy Law and specify the website that you
visited and the email address you registered with. Please allow thirty (30)
days for a response.
5. Your
Virginia Privacy Rights
If you
are a resident of the State of Virginia, certain privacy-related rights may
apply to you in accordance with the Virginia Consumer Data Protection Act (“VCDPA”),
including the right to opt-out of our sale/sharing of your personal
information, as well as the right to know what personal information about you
we have collected, whether your personal information was shared with
third-parties in the preceding year and, if so, what categories of personal
information were shared, as well as the categories of third parties with whom
we shared that personal information. Please see our “Privacy Provisions
for Covered Users” below for a more complete description of
your rights under the VCDPA as a Virginia State resident.
6. Your
Utah Privacy Rights
If you
are a resident of the State of Utah, certain privacy-related rights may apply
to you in accordance with the Utah Consumer Privacy Act (“UCPA”),
including the right to opt-out of our sale/sharing of your personal
information, as well as the right to know what personal information about you
we have collected, whether your personal information was shared with
third-parties in the preceding year and, if so, what categories of personal
information were shared, as well as the categories of third parties with whom
we shared that personal information. Please see our “Privacy Provisions
for Covered Users” below for a more complete description of
your rights under the UCPA as a Utah State resident.
General
Privacy Provisions
Personal
Information Collection
Please
see our Privacy Provisions for Covered Users below for additional details regarding
the categories of personal information collected.
We
collect your personally identifiable information when you register to use the
Contact Services and/or register for the Newsletter. In connection with
registering to use the Contact Services and/or registering to receive the
Newsletter, you may be required to submit, and PennyGreenLoan™ may collect,
some or all of the following information: (a) your e-mail address; (b) your
full name; (c) your telephone number; (d) your mailing address; (e) your date
of birth; (f) the amount of the loan requested, as applicable; (g) your yearly
income; (h) your credit score; (i) whether you rent or own a home; (j) your
drivers’ license number; (k) the state that issued your driver’s license; (l)
your primary source of income; (m) your time at your current job; (n) your
employer’s name; (o) your employer’s telephone number; (p) your monthly income;
(q) your pay frequency; (r) your pay dates; (s) whether you are an active
member of the military; (t) your bank account number; (u) your bank routing
number; (v) your bank name; (w) your time at your current bank; (x) your
account type; (y) whether you have direct deposit; (z) your Social Security
Number; and (aa) any other information collected via the applicable Contact
Services form (collectively, “Contact Data“).
Upon
entering Contact Data and clicking on the applicable submission button on the
Site: (i) PennyGreenLoan™ may pass your Contact Data along to one (1) or more
of Yonkers Financial’s™ Third-Party Service Providers and/or Third-Party
Advertisers; (ii) you may be contacted by PennyGreenLoan™ and/or one (1) or
more Third-Party Service Providers regarding your request; and/or (iii) you may
be contacted by one (1) or more Third-Party Advertisers with third-party offers
that may be of interest to you. Any information that you supply to any
Third-Party Service Provider and/or Third-Party Advertiser shall be governed by
that third-party entity’s privacy policy. Where PennyGreenLoan™ contacts
you in connection with your submission of Contact Data, a PennyGreenLoan™
representative may request additional information over the telephone
(collectively, “Follow-Up Data,” and together with the Contact
Data, the “User Data“). For purposes of this Privacy Policy,
items (g), (h), (i), (j), (k), (l), (m), (n), (o), (p), (q), (r), (s), (t),
(u), (v), (w), (x), (y) and (z) shall be deemed “Sensitive Information.
Please
be advised that PennyGreenLoan™ does not itself provide the Third-Party
Products, or any other comparable products and/or services, and the ultimate
terms and conditions of any product or service featured by and through the Site
Offerings will be determined by the applicable Third-Party Service Provider(s)
and/or Third-Party Advertiser(s).
Use and
Sharing of Personal Information
Please
see our Privacy Provisions for Covered Users below for details regarding our uses and
sharing of personal information.
The
personal information that you submit to PennyGreenLoan™ remains your property,
but by submitting that personal information to PennyGreenLoan™, you agree that
we may share, sell, rent, lease or otherwise provide that personal information
(other than Sensitive Information) to any third-party (including Third-Party
Advertisers) for any purpose permitted by law, and we may work with other
businesses to bring selected third-party offers to you. These businesses and
third-parties may include, but are not limited to: (a) providers of direct
marketing services and applications, including lookup and reference, data
enhancement, suppression and validation; (b) e-mail marketers; (c)
telemarketers (where permitted by applicable law); and (d) direct marketers. We
may also use your personal information to send you promotional messages
regarding various PennyGreenLoan™ products and/or services, as well as
third-party products and/or services that we think may be of interest to you.
Without
limiting the foregoing, with your permission, we may share your User Data
(including Sensitive Information) with those Third-Party Service Providers that
you request to be contacted by. These Third-Party Service Providers may
use your User Data to offer you credit card, personal loan and auto
loan-related products and/or services, and for any other lawful purposes,
subject to any restrictions contained herein. Where you submit personal
information, we use the personal information that you make available to
personalize your experience with the Site and to facilitate the delivery of the
applicable Site Offerings to you, including to respond to any inquiries made by
you.
You
also agree that we may contact you at any time with updates and/or any other
information that we may deem appropriate for you to receive in connection with
your continued use of the Site Offerings, and to keep you informed of our other
products and services.
We may
also provide your information to third-party companies and individuals to
perform certain functions on our behalf. Examples include sending direct and
electronic mail, removing duplicate information from end-user lists, analyzing
data and providing marketing analysis. The agents performing these limited
functions on our behalf shall have access to our end-users’ personal
information as needed to perform these functions for us, but we do not permit
them to use end-user personal information for other purposes.
We will
also use your personal information with your permission, for customer service,
to provide you with information that you may request, to customize your
experience with the Site Offerings and/or to contact you when necessary in
connection with your use of the Site Offerings. We may also use your personal
information for internal business purposes, such as analyzing and managing our
service offerings including, without limitation, the Site Offerings. We may
also combine the information that we have gathered about you with information
from other sources.
By
submitting your personal information by and through the Site Offerings, and
thereby providing your permission, you agree that such act constitutes an
inquiry and/or application for purposes of the Amended Telemarketing Sales Rule
(16 CFR §310 et seq.), as amended from time to time (the “Rule“)
and applicable state do-not-call regulations. As such, notwithstanding that
your telephone number may be listed on the Federal Trade Commission’s
Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the
right to contact you via telemarketing in accordance with the Rule and
applicable state do-not-call regulations.
Where
you provide “prior express consent” within the meaning of the
Telephone Consumer Protection Act (47 USC § 227), and its implementing
regulations adopted by the Federal Communications Commission (47 CFR §
64.1200), as amended from time-to-time (“TCPA“), you consent
to receive telephone calls from PennyGreenLoan™ and/or its designated
Third-Party Service Provider(s) and/or Third-Party Advertiser(s), as
applicable, including artificial voice calls, pre-recorded messages and/or
calls (including SMS text messages) delivered via automated technology, to the
telephone number(s) that you provided. Please note that you are not required to
provide this consent in order to obtain access to the Site Offerings, and your
consent simply allows PennyGreenLoan™ and its designated Third-Party Service
Providers and/or Third-Party Advertiser(s), as applicable, to contact you via
these means.
Without
limiting the foregoing, where you provide “prior express consent” within
the meaning of the TCPA to receive SMS messages from PennyGreenLoan™ and/or its
designated Third-Party Service Providers and/or Third-Party Advertisers, you
may receive a maximum of fifteen (15) such SMS messages per calendar month per
Third-Party. Text “STOP” to opt-out from future messages. No
other words or combination of words will achieve a successful opt out result.
You may text “HELP,” or email us at [email protected],
for help. Active keywords include HELP, STOP, END, QUIT, CANCEL, UNSUBSCRIBE.
Please
be advised that by agreeing to this Privacy Policy, you are obligated to
immediately inform us if and when the telephone number that you have previously
provided to us changes. Without limiting the foregoing, if you: (i) have your
telephone number reassigned to another person or entity; (ii) give up your
telephone number so that it is no longer used by you; (iii) port your telephone
number to a landline or vice versa; or (iv) otherwise stop using that telephone
number for any reason (collectively “Phone Number Change“),
you agree that you shall promptly notify PennyGreenLoan™ of the Phone Number
Change via e-mail at: [email protected], or by using one of the methods
set forth in the “Contact Us” section below.
We
reserve the right to release current or past personal information (including
Sensitive Information): (A) in the event that we believe that the Site
Offerings are being or have been used in violation of the Terms and Conditions
or to commit unlawful acts; (B) if the information is subpoenaed; provided,
however, that, where permitted by applicable law, we shall provide you
with e-mail notice, and opportunity to challenge the subpoena, prior to
disclosure of any personal information pursuant to a subpoena; or (C) if we are
sold, merge with a third-party or are acquired by a third-party
(collectively, ”M&A Transactions”) (including where we share
your personal information in connection with the due diligence process
associated with a potential M&A Transaction); or (D) if we are the subject
of bankruptcy proceedings; provided, however, that if PennyGreenLoan™
is involved in a bankruptcy proceeding or M&A Transaction, you will be
notified via email and/or a prominent notice on the Site of any change in
ownership or uses of your personal information, as well as any choices that you
may have regarding your personal information.
You
hereby consent to the disclosure of any record or communication to any
third-party when we, in our sole discretion, determine the disclosure to be
appropriate including, without limitation, sharing your e-mail address with
third-parties for suppression purposes in compliance with applicable law,
including the CAN-SPAM Act of 2003, as amended from time to time. End-users
should also be aware that courts of equity, such as U.S. Bankruptcy Courts,
might have the authority under certain circumstances to permit personal
information to be shared or transferred to third-parties without permission.
Non-Personally
Identifiable Information Collection and Use
Please
see our Privacy Provisions for Covered Users below for more details regarding the
categories and types of non-personal information collected
Computer
IP Addresses/Browser Type
We may
collect certain non-personally identifiable information about you and your
desktop computer when you visit many of the pages of the Site. This
non-personally identifiable information includes, without limitation, the type
of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP
address, the type of operating system that you use (e.g., Windows or iOS) and
the domain name of your Internet service provider (e.g., Verizon, AT&T).
We use the non-personally identifiable information that we collect to
improve the design and content of the Site Offerings and to enable us to
personalize your Internet experience. We also may use this information in
the aggregate to analyze usage of the Site Offerings.
Cookies
When an
end-user visits the Site, we send one (1) or more cookies and/or gif files
(collectively, “Cookies”) to assign an anonymous, unique identifier to
the applicable end-user’s computer and/or mobile device, as applicable. A
Cookie is a piece of data stored on your hard drive containing non-personally
identifiable information about you. Cookies have many benefits to enhance
your experience on the Site, as applicable. To find out more about
Cookies, please visit www.cookiecentral.com. We use Cookies to improve
the quality of the Site Offerings, including for storing end-user preferences
and tracking Site usage (such as pages opened and length of stay at the Site,
as applicable).
Most
Internet browsers are initially set up to accept Cookies, but you can reset
your browser to refuse all Cookies or to indicate when a Cookie is being sent.
To disable and reject certain Cookies, follow the instructions associated
with your Internet browser. Even in the case where an end-user rejects a
Cookie, he or she may still use the Site Offerings; provided, however, that
certain functions of the Site Offerings may be impaired or rendered inoperable
if the use of Cookies is disabled. We reserve the right to retain Cookie
data indefinitely.
Behavioral
Tracking
PennyGreenLoan™,
its Third-Party Service Providers and its Third-Party Advertisers may use
Cookies, pixels and other tracking technology (collectively, “Tracking
Technology”) in connection with the Site for purposes of tracking
end-users’ activities (such as websites visited, advertisements selected and
pages viewed) after they leave the Site. PennyGreenLoan™, its Third-Party
Service Providers and its Third-Party Advertisers use this Tracking Technology
to target applicable end-users with advertisements featuring PennyGreenLoan™
products and services and third-party products and/or services that PennyGreenLoan™,
its Third-Party Service Providers and/or its Third-Party Advertisers, as
applicable, think may be of interest to applicable end-users. To opt out of
this behavioral tracking, please: submit an unsubscribe request here.
In
general, end-users may be able to disable some, but not all, of this tracking
activity by utilizing the “Do Not Track” setting or similar options within most
major Internet browsers. We do not honor or alter our behavior when an
end-user has activated the “do-not-track” setting on her/his browser. In
addition, end-users may be able to opt-out of this form of tracking utilizing
the options made available by the Network
Advertising Initiative or Digital
Advertising Alliance. To the greatest extent permissible under
applicable law, we are not responsible for the tracking practices of
third-parties in connection with the Site.
Cross
Device Tracking
PennyGreenLoan™
tracks your use of the Site Offerings across various devices, including your
personal computer and mobile device, in order to optimize and personalize your
Site Offerings experience. PennyGreenLoan™ may collect certain of your
personal information across various devices. If you would like to opt-out
of having your use of the Site Offerings tracked across multiple devices,
please e-mail us at: [email protected]. Please be
advised that where you opt-out of having your use of the Site Offerings tracked
across devices, you may need to upload certain information multiple times
and/or input your log-in information multiple times.
Site-Visit
Recordation Technology
We use
certain scripts and Site-visit recordation technology provided by third-party
service providers, such as those provided by Lead Intelligence, Inc. d/b/a
Jornaya (“Jornaya”) and ActiveProspect, Inc. (including its TrustedForm
service). We use these scripts/technologies to record Site visits and
independently document users’ consent to be contacted, including that those
users have provided their respective “prior express consent” as required by the
TCPA. For more information about the data usage, retention and collection
policies and practices of these third-party service providers, please click on
the links located below:
•
ActiveProspect Trusted Form Script Privacy
Policy: https://activeprospect.com/privacy-policy
•
Jornaya’s Script Privacy Policy:
https://www.jornaya.com/consumer-privacy-policy/
Aggregate
Data
PennyGreenLoan™
reserves the right to transfer and/or sell aggregate or group data about
end-users of the Site Offerings for lawful purposes. Aggregate or group
data is data that describes the demographics, usage and other characteristics
of end-users as a group, without disclosing personally identifiable
information.
Third-Party
Links
The
Site Offerings may contain links to other third-party owned and/or operated
websites including, without limitation, websites owned and/or operated by our
Third-Party Service Providers and/or Third-Party Advertisers. PennyGreenLoan™
is not responsible for the privacy practices or the content of such websites.
In some cases, you may be able to make a purchase through one of their
third-party websites. In these instances, you may be required to provide
certain information, such as a credit card number or banking information, to
register or complete a transaction at such website. These third-party websites
have separate privacy and data collection practices and PennyGreenLoan™ has no
responsibility or liability relating to them.
Opt-Out/Unsubscribe
Please
see our Privacy Provisions for Covered Users below for instructions on how Covered
Users can opt-out of the sale of their personal information to third parties.
To stop
receiving future communications from PennyGreenLoan™, please unsubscribe.
To unsubscribe from all PennyGreenLoan™ e-mail lists, please unsubscribe.
Notwithstanding
the foregoing, we may continue to contact you for the purpose of communicating
information relating to your request for Site Offerings, as well as to respond
to any inquiry or request made by you. To opt-out of receiving Site
Offerings-related and/or inquiry response-related messages from PennyGreenLoan™,
you must cease requesting and/or utilizing the Site Offerings and/or cease
submitting inquiries to PennyGreenLoan™, as applicable.
Deleting
and Updating Your Information
Please
see our Privacy Provisions for Covered Users below for instructions on how Covered
Users can access and/or delete personal information that we have collected.
At your
request, we will: (a) inform you of what personal information we have on file
for you; (b) amend the personal information that we have on file for you;
and/or (c) remove personal information that you have provided to us, or that we
have collected. You may do so by e-mailing us at: [email protected].
We ask
individual end-users to identify themselves and the information requested to be
accessed, corrected or removed before processing such requests, and, to the
extent permitted by applicable law, we may decline to process requests that are
unreasonably repetitive or systematic, require disproportionate technical
effort, jeopardize the privacy of others or would be extremely impractical (for
instance, requests concerning information residing on backup tapes).
Please
be advised that deleting your personal information may terminate your access to
certain of the Site Offerings. If you wish to continue using the full
complement of Site Offerings, you may not be able to delete all of the personal
information that we have on file for you.
Please
be further advised that, after you delete your personal information, residual
copies may take a period of time before they are deleted from our active
servers and may remain in our backup systems.
Children’s
Privacy
Please
see our Privacy Provisions for Covered Users below for more details regarding the
personal information of minors.
We do
not knowingly collect information from individuals under eighteen (18) years of
age. No information should be submitted to, or posted at, the Site by
individuals under eighteen (18) years of age. We encourage parents and
guardians to spend time online with their children and to participate and
monitor the interactive activities of their children.
Security
of Your Personal Information
We
endeavor to safeguard and protect our end-users’ personal information.
When end-users make personal information available to us, their personal
information is protected both online and offline (to the extent that we
maintain any personal information offline). Where our
registration/application process prompts end-users to enter Sensitive
Information, and when we store and transmit such sensitive information, that
information is encrypted with advanced TLS (Transport Layer Security).
Access
to your personal information is strictly limited, and we take reasonable
security measures to ensure that your personal information is not accessible to
the public. All of our end-users’ personal information is restricted in
our offices, as well as the offices of our third-party service providers.
Only employees or third-party agents who need end-user personal
information to perform a specific job are granted access to end-user personal
information. Our employees are dedicated to ensuring the security and
privacy of all end-user personal information. Employees not adhering to
our firm policies are subject to disciplinary action. The servers that we
store end-user personal information on are kept in a secure physical
environment. We also have security measures in place to protect the loss,
misuse and alteration of personal information under our control.
Please
be advised, however, that while we take every reasonable precaution available
to protect your data, no storage facility, technology, software, security
protocols or data transmission over the Internet or via wireless networks can
be guaranteed to be 100% secure. Computer hackers that circumvent our
security measures may gain access to certain portions of your personal
information, and technological bugs, errors and glitches may cause inadvertent
disclosures of your personal information; provided, however, that
any attempt to breach the security of the network, our servers, databases or
other hardware or software may constitute a crime punishable by law. For
the reasons mentioned above, we cannot warrant that your personal information
will be absolutely secure. Any transmission of data at or through the
Site, other Site Offerings or otherwise via the Internet or wireless networks,
is done at your own risk.
In
compliance with applicable federal and state laws, we shall notify you and any
applicable regulatory agencies in the event that we learn of an information
security breach with respect to your personal information. You will be
notified via e-mail in the event of such a breach. Please be advised that
notice may be delayed in order to address the needs of law enforcement,
determine the scope of network damage, and to engage in remedial measures.
Modifications
to this Privacy Policy
PennyGreenLoan™
reserves the right to change or update this Privacy Policy at any time by
posting a notice on the Site that we are changing our Privacy Policy. If the
manner in which we use personally identifiable information changes, PennyGreenLoan™
will notify users by: (a) sending the modified policy to our users via email;
and/or (b) by any other reasonable means acceptable under applicable state and
federal law. You will have a choice as to whether or not we use your
information in this different manner, and we will only use your information in
this different manner where you opt-in to such use.
Transfer
of Personal Information Internationally
If you
are visiting the Site from a country other than the country in which our
servers are located, your communications with us may result in the transfer of
information across international boundaries. By visiting the Site and/or
otherwise communicating electronically with us, you consent to such transfers.
Even if your jurisdiction does not have the same privacy laws as the
jurisdiction where our servers are located, we will treat your information as
subject to the protections described in this Privacy Policy.
Contact
Us
If you
have any questions about this Privacy Policy or the practices of PennyGreenLoan™,
please feel free to: (a) send email to: [email protected]; or (b) send us U.S.
Mail at: Account Services, PennyGreenLoan, 96 Linwood Plaza, #458, Fort
Lee, NJ 07024.
Filing
a Complaint with the Federal Trade Commission
To file
a complaint regarding our privacy practices, please click here.
Privacy
Provisions for Covered Users
These
Privacy Provisions for Covered Users (“Provisions”) supplement, and do not
limit in any way, the Privacy Policy set forth above. These Provisions
apply solely to the Covered Users, who are residents of the States of
California, Colorado, Connecticut, Virginia and Utah, as well as businesses
organized under the laws of the State of California. We adopt these Provisions
in compliance with the CCPA, CPRA, CPA, CDPA, VCDPA and UCPA (collectively, “Applicable
State Laws”). Any terms defined in Applicable State Laws have the same
meaning when used in these Provisions. Users with disabilities who wish to
access this Privacy Notice in an alternative format can contact us by emailing
us at: [email protected]; or sending us U.S. Mail to: PennyGreenLoan, 96
Linwood Plaza, #458, Fort Lee, NJ 07024.
Categories
of 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 Covered User or device (“personal information”).
In particular, we have collected the following categories of personal
information from Covered Users within the last twelve (12) months:
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address,
account name, telephone number, or other similar identifiers. |
YES |
|
B. Personal information categories established by
Applicable State Laws. |
A name, signature, Social Security number, physical
characteristics or description, postal 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. |
YES |
|
C. Protected classification characteristics under
Applicable State Laws. |
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). |
YES |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a
User’s interaction with a website, application or advertisement. |
YES |
|
I. Professional or employment-related information. |
Current or past job history or performance
evaluations. |
YES |
|
L. Sensitive Personal Information. |
A Social Security number, driver’s license number,
state identification card number, or passport number. Account log-in
information, financial account, or debit or credit card number used in
combination with any required security code, access code, password, or log-in
credentials necessary to access an account. Precise geolocation, racial or
ethnic origin, religious or philosophical beliefs, or union membership. The
contents of a consumer’s U.S. mail, electronic mail, or text messages unless
the business is the intended recipient, and a consumer’s genetic data. |
YES |
Personal
information does not include:
We
obtain the categories of personal information listed above (including (a) your
e-mail address; (b) your full name; (c) your telephone number; (d) your mailing
address; (e) your date of birth; (f) the amount of the loan requested and loan
purpose, as applicable; (g) your yearly income; (h) your credit score; (i)
whether you rent or own a home; (j) your drivers’ license number; (k) the state
that issued your driver’s license; (l) your primary source of income; (m) your
time at your current job; (n) your employer’s name; (o) your employer’s
telephone number; (p) your monthly income; (q) your pay frequency; (r) your pay
dates; (s) whether you are an active member of the military; (t) your bank
account number; (u) your bank routing number; (v) your bank name; (w) your time
at your current bank; (x) your account type; (y) whether you have direct
deposit; and (z) your Social Security Number) from the following categories of
sources (with the specific categories of personal information indicated in
parenthesis). Directly from our Users. For example, from online registration
forms that our Users submit to us related to the products and/or services that
we (and our third party service providers) offer by and through the Site.
(Category A, B, C, I and L)
Retention
of Personal Information and Sensitive Personal Information
We
retain all categories of your personal information and sensitive personal
information (including the information set forth in the “Personal
Information Collection” section above) that we collect for the maximum period
permitted by applicable law. We may also use certain criteria to determine
whether and when to delete certain categories of collected personal and
sensitive personal information including:
Use of
Personal Information
We may
use or disclose the personal information that we collect (including (a) your
e-mail address; (b) your full name; (c) your telephone number; (d) your mailing
address; (e) your date of birth; (f) the amount of the loan requested and loan
purpose, as applicable; (g) your yearly income; (h) your credit score; (i)
whether you rent or own a home; (j) your drivers’ license number; (k) the state
that issued your driver’s license; (l) your primary source of income; (m) your
time at your current job; (n) your employer’s name; (o) your employer’s
telephone number; (p) your monthly income; (q) your pay frequency; (r) your pay
dates; (s) whether you are an active member of the military; (t) your bank
account number; (u) your bank routing number; (v) your bank name; (w) your time
at your current bank; (x) your account type; (y) whether you have direct
deposit; and (z) your Social Security Number) for one or more of the following
business purposes (with the specific categories of personal information
indicated in parenthesis
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 with notice.
Sharing
Personal Information
Subject
to your right to opt-out of such sharing/sale, we may share, rent and/or sell
your personal information (with the specific categories of personal information
indicated in parenthesis): (a) with/to third party providers of the
loan-related products and services featured on the Sites (Category A, B, C, F,
I and L); (b) with/to third parties for marketing purposes, only where you
expressly opt-in to such use (Category A, B, C, F and I) and (c) for the other
business purposes set forth above (Category A, B, C, F, I and L, as
applicable).
When we
disclose personal information to a third party service provider or other
entity, we enter into a contractual relationship that describes the purpose for
which such third party may use the personal information and requires that third
party to both keep the personal information confidential and not use it for any
purpose other than the performance of its services under the applicable
contract. Please note, we do not collect information from Covered Users
that we actually know are less than eighteen (18) years of age and we do not
share or sell the personal information of Covered Users that we actually know
are less than eighteen (18) years of age. Without limiting the foregoing,
we have not shared or sold the personal information of Covered Users that we
actually know are less than sixteen (16) years of age in the preceding twelve
(12) months.
In the
preceding twelve (12) months, we have disclosed the following categories of
personal information for a business purpose:
Category
A: Identifiers.
Category B: Personal information categories
established by Applicable State Laws.
Category C: Protected classification
characteristics under Applicable State Laws.
Category F: Internet or other similar
network activities.
Category I: Professional or
employment-related information.
Category L: Sensitive Personal Information
(disclosed solely as necessary in connection with facilitating your request for
loan related products and/or services)
We
disclose your personal information (including (a) your e-mail address; (b) your
full name; (c) your telephone number; (d) your mailing address; (e) your date
of birth; (f) the amount of the loan requested and loan purpose, as applicable;
(g) your yearly income; (h) your credit score; (i) whether you rent or own a
home; (j) your drivers’ license number; (k) the state that issued your driver’s
license; (l) your primary source of income; (m) your time at your current job;
(n) your employer’s name; (o) your employer’s telephone number; (p) your
monthly income; (q) your pay frequency; (r) your pay dates; (s) whether you are
an active member of the military; (t) your bank account number; (u) your bank
routing number; (v) your bank name; (w) your time at your current bank; (x)
your account type; (y) whether you have direct deposit; and (z) your Social
Security Number) for a business purpose to the following categories of third
parties (with the specific categories of personal information indicated in
parenthesis
In the
preceding twelve (12) months, we have sold the following categories of personal
information to third parties:
Category
A: Identifiers.
Category B: Personal information categories
established by Applicable State Laws.
Category C: Protected classification
characteristics under Applicable State Laws.
Category F: Internet or other similar
network activities.
Category I: Professional or
employment-related information.
Category L: Sensitive Personal Information
(disclosed solely as necessary in connection with facilitating your request for
loan related products and/or services)
In the
preceding twelve (12) months, we have sold the above referenced categories of
personal information to the third parties who purchase and/or license your
personal information for marketing purposes as well as the third parties who
provide the products and/or services featured on the Site.
Your
Rights and Choices
Applicable
State Laws provide Covered Users with specific rights regarding their personal
information. This section describes certain data privacy rights provided under
Applicable State Laws and explains how to exercise those rights.
Opt-Out
from the Sale of Your Personal Information
You
have the right to opt-out of our sale of your personal information to third
parties. To exercise your right to opt-out of our sale of your personal
information to third parties, please submit a verifiable Covered User request
to us by either:
We
endeavor to act on all opt-out requests as soon as practicable, but in all
cases within fifteen (15) days of the receipt of your request.
Opt-Out
from the Sharing of Your Personal Information
You
have the right to opt-out of our sharing your personal information with third
parties. To exercise your right to opt-out of our sharing your personal
information with third parties, please submit a verifiable Covered User request
to us by either:
We
endeavor to act on all opt-out requests as soon as practicable, but in all
cases within fifteen (15) business days of the receipt of your
request. Subject to the aforementioned fifteen (15) business day period,
where we receive and confirm your verifiable opt-out request, we will cease
sharing your Personal Information with third parties.
Opt-Out
from the Use and/or Sharing of Your Sensitive Personal Information
You
have the right to limit our use of your sensitive personal information,
including any sensitive information from Category B (Personal information
categories established by Applicable State Laws), Category C (Protected
classification characteristics under Applicable State Laws), Category I
(Professional or employment-related information) and/or Category L
(Sensitive Personal Information), to those uses which: (i) are necessary to
perform the services or provide the goods requested by you; (ii) help us to
ensure security and integrity of your personal information to the extent the
use of your sensitive personal information is reasonably necessary and
proportionate for these purposes; (iii) are short-term, transient uses
including, but not limited to, non-personalized advertising shown as part of
your then-current interaction with the Site, provided that your personal
information is not disclosed to another third party and is not used to build a
profile about you or otherwise alter your experience outside the then-current
interaction with the Site; (iv) involve performing services on behalf of PennyGreenLoan™,
including maintaining or servicing accounts, providing customer service,
processing or fulfilling orders and transactions, verifying customer
information, processing payments, providing financing, providing analytic
services, providing storage, or providing similar services on behalf of PennyGreenLoan™;
and (v) include activities to verify or maintain the quality or safety of a
service or device that is owned, manufactured, manufactured for, or controlled
by, PennyGreenLoan™, and to improve, upgrade, or enhance the service or device
that is owned, manufactured, manufactured for, or controlled by, PennyGreenLoan™.
You
also have the right opt-out of our sharing your sensitive personal information
with third parties, including any sensitive information from Category B
(Personal information categories established by Applicable State Laws),
Category C (Protected classification characteristics under Applicable State
Laws), Category I (Professional or employment-related information) and/or
Category L (Sensitive Personal Information).
To
exercise your right to limit our use of your sensitive personal information
and/or opt-out of our sharing your sensitive personal information with third
parties, please submit a verifiable Covered User request to us by either:
We
endeavor to act on all such requests as soon as practicable, but in all cases
within fifteen (15) business days of the receipt of your request. Subject
to the aforementioned fifteen (15) business day period, where we receive and
confirm your verifiable opt-out request, we will cease using your Sensitive
Personal Information/sharing your Sensitive Personal Information with third
parties (and direct our service providers and contractors to do the same).
Access
to Specific Information and Data Portability Rights
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 twelve (12)
months. Once we receive and confirm your verifiable Covered User request, we
will disclose to you:
Deletion
Request Rights
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. Subject to
the time period allotted to comply with such requests, where we receive and
confirm your verifiable User request, we will delete (and direct our service
providers, contractors and third parties to whom we sold/shared your personal
information, to delete) your personal information from our (their) records,
unless an exception applies.
We may
deny your deletion request if retaining the information is necessary for us or
our service providers, contractors or third parties to whom we sold/shared your
personal information, to:
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, and where
previously provided informed consent.
7.
Enable solely internal uses that are reasonably aligned with
Covered User 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.
Right
to Request Correction of Inaccurate Personal or Sensitive Personal Information
You
have the right to request correction of inaccurate personal and/or sensitive
personal information that we collect. Upon receiving a verifiable consumer
request for correction, we will make commercially reasonable efforts to correct
information identified as inaccurate. Where we correct inaccurate personal
and/or sensitive personal information, we shall instruct all service providers
and/or contractors that maintain such personal and/or sensitive personal
information in the course of providing services to us to make the necessary
corrections in their respective systems.
Exercising
Access, Data Portability, Right to Correct and Deletion Rights
To
exercise your access, data portability, right to correct and/or deletion rights
described above, please submit a verifiable Covered User request to us by
either:
You may
only make a verifiable User request for access or data portability twice within
a 12-month period. The verifiable Covered User request must:
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 that
the personal information relates to you. Making a verifiable Covered User
request does not require you to create an account with us. We will only
use personal information provided in a verifiable Covered User request to
verify the requestor’s identity or authority to make the request.
Response
Timing and Format
We
endeavor to respond to all verifiable Covered User requests to exercise Access,
Data Portability, Right to Correct and Deletion Rights within forty-five (45)
days of the receipt thereof. If we require more time (up to ninety (90)
days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your
option. Any disclosures we provide will only cover the twelve (12) month
period preceding the receipt of your verifiable request. 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 Covered User 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.
Opt-Out
Preference Signal Processing
Global
Privacy Control (“GPC”) is a setting you can enable in your web browser to
communicate your privacy preference for not having certain information about
your webpage visits collected across websites. For all the details, including
how to turn on GPC, visit https://globalprivacycontrol.org/.
Our websites that link to this privacy policy recognize and respond to GPC
signals.
Right
to Opt-Out of Profiling
You
have the right to opt-out from any Profiling that may be conducted by PennyGreenLoan™.
For purposes of these Provisions, “Profiling” means any form of
automated processing performed on your personal data to evaluate, analyze or
predict personal aspects related to you or your economic situation, health,
personal preferences, interests, reliability, behavior, location or movements.
You have the right to opt-out of our Profiling you. To exercise your right to
opt-out of our Profiling you, please submit a verifiable Covered User request
to us by either:
We
endeavor to act on all Profiling opt-out requests as soon as practicable, but
in all cases within forty-five (45) days of the receipt of your request.
Right
to Opt-Out of Targeted Advertising
You
have the right to opt-out from Targeted Advertising conducted by PennyGreenLoan™.
For purposes of these Provisions, “Targeted Advertising” means
displaying advertisements to you where the advertisements are selected based on
personal data obtained from your activities over time and across nonaffiliated
websites or online applications to predict your preferences or interests.
You have the right to opt-out from Targeted Advertising. To exercise your
right to opt-out of our Targeted Advertising, please submit a verifiable
Covered User request to us by either:
We
endeavor to act on all Targeted Advertising opt-out requests as soon as
practicable, but in all cases within forty-five (45) days of the receipt of
your request.
Authorized
Agents
Covered
Users may permit an authorized agent to exercise any rights granted under
Applicable State Laws as set forth above. In order to utilize an
authorized agent, you must provide the authorized agent with written permission
from you to act on your behalf for these purposes. When you use an
authorized agent to submit a request to delete, request to correct or a request
to know, we may require the authorized agent to provide proof that you gave the
agent signed permission to submit the subject request. We may also
require you to do either of the following: (a) verify your own identity
directly with us; or (b) directly confirm with us that you provided the
authorized agent permission to submit the request.
For
California residents, only you or a person registered with the California
Secretary of State that you authorize to act on your behalf, may make a
verifiable Covered User request related to your personal information.
Non-Discrimination
We will
not discriminate against you for exercising any of your rights granted under
Applicable State Laws. Unless permitted by the Applicable State Laws, we will
not:
Changes
to these Provisions
We
reserve the right to amend these Provisions in our discretion and at any time.
When we make changes to these Provisions, we will notify you by email or
through a notice on the Site’s homepage.
Contact
Information
If you
have any questions or comments about these Provisions, our Privacy Policy, the
ways in which we collect and use your personal information, your choices and
rights regarding such use, or wish to exercise your rights under Applicable
State Laws, please do not hesitate to contact us by either:
·
Sending us U.S. Mail to: PennyGreenLoan, 10001 Marshall Drive,
Lenexa, KS, 66215
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