June 1st, 2019
The USA Patriot Act
IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING AN ACCOUNT
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
What this means for you: When you open an account with a financial institution, you will be asked for your name, mailing address and other information that will allow your identity to be verified. Conejo Credit, related brokers and funders may also ask to see a driver’s license or other identifying documents.
In connection with your use of the Site, we collect, directly or indirectly, three types of information:
Information regarding a business (“Business Information”); Information about the business’s owners and principals (“User Information”); and General information (i.e. non personally identifiable information such as website-use information) that is automatically collected as you interact with the Site (“General Information”).
Business and User Information
In connection with providing services to our funders, we may receive Business Information from users, including, but not limited to: business name, mailing address, email address, telephone number, business size, business type, business incorporation date, bank account information, marketplace account information, payment processing procedures, social network data, shipping information, accounting information and vendor service information. We may also receive User Information that consists of personally identifiable information, including, but not limited to: the owner’s or principal’s name, mailing address, email address, telephone number, date of birth, social security number, and estimated FICO score.
We collect User Information and Business Information from you when you (i) register on the Site, (ii) fill out forms or fields on the Site, (iii) complete an application for a product or service available through the Site or (iv) communicate with us by email, mail, text, telephone, facsimile or other electronic means. In the course of providing services to our funders, we may collect additional Business Information or User Information from third parties, including, but not limited to, referral partners, identity verification services, mailing list providers, credit bureaus, and publicly available sources and may combine this information with information we already have about you.
We collect General Information from your computer, mobile device or other access device when you use the Site (including downloading and using a mobile application or accessing a mobile optimized site), view content about the Site on a third-party website or open emails or links in emails from us. This General Information includes, but is not limited to, information about (i) your Internet connection; (ii) the equipment you use to access the Site and usage details; (ii) your operating system, browser version and IP address; (iii) your mobile device type, your device’s unique identifier and your mobile network information and (iv) web pages or advertisements that you view and information that you search for on the Site. As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We may link this automatically collected data to other information we collect about you.
We also use analytics software to allow us to better understand the functionality of our mobile application. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
Use of Information
One of our primary purposes in collecting Business Information, User Information and General Information from the Site and from third parties is to establish a safe, smooth, efficient and customized experience that allows website and mobile users to take full advantage of the products and services available through the Site. We use the information collected through the Site to:
Enable users to obtain products and services through the Site;
Facilitate activities and transactions that occur in connection with marketing, underwriting, lending, servicing and collections;
Send notifications and information regarding the Site and products or services available through the Site;
Provide customer support;
Protect against potentially prohibited or illegal activities, including fraud;
Fulfill legal requirements;
Customize and enhance user experience;
Provide targeted marketing and advertising;
Measure the performance of and improve the Site or mobile application functionality;
Manage and protect our information technology infrastructure;
Administer and manage the security of the Site;
Compile, use, research, analyze, and generate data analytics reports to better understand our customers
To support our business operations including, but not limited to, Site customer services, fraud prevention, secure data storage, and other similar services. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other transfer of all or a portion of our business or an operating unit;
To fulfill the purpose for which you provide such information to us or any other purpose disclosed by us when you provide the information to us;
To any third party with your consent;
To protect the confidentiality or security of your records, to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability, or for resolving disputes or inquiries;
To comply with federal, state or local laws, rules and other applicable legal requirements, to comply with properly authorized civil, criminal or regulatory investigations, subpoenas, summons, bankruptcy notices by federal, state or local authorities, or to respond to judicial process or government regulatory authorities that have jurisdiction over us for examination, compliance or other purposes as authorized by law; and
To the extent permitted or required under other provisions of laws to law enforcement, the Federal Trade Commission or self-regulatory organizations for an investigation related to public safety.
Subject to any opt-out under the “Your Choices” section, we may share, whether aggregated or not, Business Information and User Information with our business partners, including for jointly offered products and services, under agreements which restrict our business partners’ use of the information and require business partners to follow policies regarding privacy and safeguarding of User Information and Business Information. Business partners may use such information obtained from us to market their or our products or services to you, including jointly offered products or services.
We may also use, sell, license or distribute General Information (i.e., non-personally identifiable information) or personally identifiable User Information that has been anonymized so that the information does not identify a specific user without restriction, including, but not limited to for producing data analytics and reports for business partners or others.
You may review or modify your Business Information and User Information by logging into your Conejo Credit account and updating your customer profile. This section of the Site is password protected to better safeguard your information. As a customer, you can update your password, physical address, and phone number at any time on the Site and if you need to change any other information in your profile, you can contact us at firstname.lastname@example.org or 305-929-0233.
We will retain your information for as long as your account is active or as long as reasonably useful for commercial purposes. We may be able to close your application but will need to retain certain information as necessary to comply with applicable laws regarding recordkeeping, reporting and audits. Upon request, we can inform you of whether we maintain any of your personally identifiable information.
Providing information regarding your browsing and application activity is voluntary. Most computer systems and browsers offer their own privacy settings. You can adjust your privacy settings to disable the cookies used on the Site. If you disable cookies, you can still use the Site, but your ability to use some features of the Site may be limited. Most mobile phones allow you to control privacy settings, including location-based services by accessing the device’s setting’s menu. If you have questions about the privacy settings on your mobile device, you should contact your mobile service carrier.
Conejo Credit, its affiliates or its business partners may contact you to offer you products and services that may be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails, telephone solicitations or other forms of contact from Conejo Credit, our affiliates, and our trusted business partners by following the unsubscribe instructions included in these emails or by contacting us at email@example.com or 305-929-0233. We will respond to your request within a reasonable timeframe. If you no longer wish to receive marketing notifications through the Conejo Credit mobile application, you can adjust your device’s privacy preferences by visiting the settings page of the application. Opting out of newsletter or marketing emails or notifications will not stop any non-marketing emails or notifications related to the Site’s functionality or the products or services available through the Site.
Third Party Information Collection
Links to Third Party Websites
Security of Information
We protect User Information and Business Information by using reasonable physical, electronic and procedural safeguards in compliance with applicable federal and state regulations. We use computer safeguards such as firewalls and data encryption using Transport Layer Security (TLS) technology. We also limit access to User Information and Business Information to employees who need the information to fulfill their job responsibilities. Such employees are provided access to User Information and Business Information only to the extent necessary to complete their job duties.
We store and process information using third-party servers located in secure data centers in the United States. If you have any questions about the security of User Information and Business Information, you can contact us at the address at the bottom of this policy.
We may display testimonials of satisfied customers of Conejo Credit on the Site in addition to other endorsements. With your consent we may, on behalf of our funders, post your testimonial along with the business’s and business owner’s or principal’s name and picture. If you wish to update or delete your testimonial, you can contact us at the address at the bottom of this policy.
If you choose to participate in the Conejo Credit referral service program to tell a business about the Site, we will ask you for the business’s name and email address. We will automatically send the business an email, on behalf of our funding network, inviting the business to visit the Site. We store information about the business for the purpose of sending an email and tracking the success of the referral program.
Social Media Widgets
We will retain your information for as long as the information is needed to provide you Site services. If you wish to request that we no longer use your information to provide you Site services, you may contact us at the address at the bottom of this policy. We will nonetheless retain your information to the extent that we deem necessary to comply with our legal or contractual obligations, resolve disputes or for other business purposes.
Data Collected through the Site
Conejo Credit, Inc. handles customer information provided to our funders through the Site in accordance with policies and procedures established by our funders. Inquiries regarding customer information should be directed to firstname.lastname@example.org or 305-929-0233. A request to remove customer information will be responded to within 30 days of receipt of the request.
For inquiries please call: 305-929-0233