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Privacy Policy

This Privacy Policy takes effect immediately and describes how CreditLink….. and its affiliates (“CreditLink” “our” “we” or “us”) upon accessing and/or using our products or services (“services”) through our website at ………………………….<insert the address>, mobile application or any other means (“Platform”) collects, uses, and discloses your information. By accessing and using any of the CreditLink Services (or clicking agree to this Privacy Policy when this option is made available to you and the CreditLink Terms of Service at ……………….. <insert the terms link>,) you acknowledge to how we collects, uses, and share your information as provided herein.

CreditLink at its sole discretion may from time to time amend this Privacy Policy for any reason. When we make amends to this Privacy Policy, we will make available the new Privacy Policy and also indicate at the top of this Privacy Policy page the updated date (“Last Updated”). Please you are required to visit this page from time to time as such amendment(s) is effective immediately, and if you do not accept the changes you should cease forthwith from accessing and/or using any part of the Services as your continued access or use will be construed as acceptance of the amendments.

What This Privacy Policy Is All About

This Privacy Policy relates and addresses the handling of personally, transactional, and financial information ("Personal Information") collected when you access and utilize the Services, including Personal Information shared between us and any third parties for purposes related to the Services. By using the Services, you expressly acknowledge and grant us permission to access and share your information (including Personal Information) with third parties that facilitate our Services. If we share your Personal Information to affiliates, vendors and other service providers ("Service Providers") who facilitate our Services to you, we demand that they safeguard the confidentiality and security of your information, restrict the use of the information to what is reasonably material for the performance of their services, and adherence to relevant laws. Note that the application of this Privacy Policy does not cover service providers that you opt to access via the Services or to third parties with whom you directly share information. Although we strive to ensure that access is granted only to those third parties and Service Providers that uphold our commitment to your privacy, we cannot be held accountable for their privacy policies. We strongly recommend that you thoroughly examine the privacy policies of any third parties or Service Providers you engage with through the Platform’s Services.

If you have any questions about this Privacy Policy, please contact us at ……………………..<insert support email>

INFORMATION WE COLLECT

We may collect the following categories of information about you:

Identity, Contact, and Account Information

It includes first and last name, phone number, date of birth, email address, mailing addresses, username, account credentials or one-time passcodes, and the services you have used or purchased.

Demographic Information

It includes age, gender, marital status, and veteran status.

Bank Account Information

When you register to use our Services, you may supply us with access credentials that enable us to obtain online access to your account(s) which you maintain with a third-party financial institution in which you choose to designate for use in relation with the Services ( "Bank Account"). The Platform collaborate with one or more Service Providers that will securely store, in accordance with industry standards, any Bank Account access credentials you provide to us via the Services and will access your Bank Account(s) which is held in your name to facilitate the provision and enhancement of the Services. You are permitted to provide account access credentials for and authorize us to access only valid accounts that are held in your own name.

Payment Information

We collect information related to your payment including payment method, account number, type, or expiration date. The Platform uses third party payment processor to process the payment you made to us. During subscription time of any part of the Services, our third party payment processors may require you to accept their terms and conditions including privacy policy.

Credit Information

It includes credit score, credit history, Social Security number, bill and rental history information, employment history information, financial and health insurance information as Well as any other credit-related information that you might make available to us.

Support, Feedback, and Chatbot Information

It includes customer support form, newsletters, question(s) or prompt(s) to our chatbot and chatbot response(s) which you agree to the collection, recording, processing, retention, utilization, and disclosure of your question(s)/prompt(s) along with the chatbot’s response(s) (“Conversation”). We and our Service Providers may use them for communication with you, providing further assistance, fraud prevention, development, analytical and research, maintaining, enhancing, and delivering the chatbot.

Web Browser and Device Information

We and our Service Providers use your web browser, IP address, and Cookie to automatically receive and record information from you when you visit our Platform, geographic location including information about your behavior on the site and your interaction with the Platform such as the links you click on, and usage data like the number and frequency of visits to the Platform. This type of aggregate information enables us and third party providers authorized by us to ascertain and measure how often individuals use parts of the Services so that we can analyze and enhance those services.

Session Replay and Similar Technology

Our Platform uses session replay and similar technology to record your visit to our Platform (the “Session”). We and our third party providers may associate your Session to other information about you, including but not limited to your IP address, location, name, or social media profile and to your account.

SMS, Email, and Push Notification Communications

We and our Service Providers may communicate with you regarding our Services through SMS, email, or other forms of text messages ("Text Messages") or through push notifications. When we engage with you through Text Messages, or push notifications, we may gather information related to these communications, including confirmation of when you open an email, read a text message, or receive a push notification.

Information We Receive from Third Party

CreditLink may collect information about you from third party providers that facilitate our Services. The third party information may include credit bureaus, data providers, data analytics providers, and fraud detection services.

Interest-Based Advertisements Information

We may display advertisements and permit third-party digital marketing partners to serve advertisements via the Platform. The advertisements which may promote both our Services and those of third parties, may be directed towards users who meet specific general profile/account categories or exhibit certain preferences or behaviors. Information related to Interest-Based Ads (including Personal Information) may be supplied to us by you or derived from the usage patterns of specific users on the Platform and/or the services of Service Providers. Such information may be collected by tracking users' activities over time and across unrelated properties of the Platform.

Social Media and Data in the Public domain

It includes information available from engaging or using our social media where your social media accounts settings permits it. Also data from public or government websites or records.

Corporate Affiliates

Data relating to you from our business affiliates which is companies that are controlled by CreditLink, that control, or are under common control with CreditLink.

HOW WE USE INFORMATION

Here is how we collect and use your information:

  • We use your information to provide you our Services, respond to your request and inquiries, including processing and executing transactions.
  • Your data aids in risk management control and enable us to detect, prevent, as well as respond to fraudulent activities, security issues and other detrimental behaviors.
  • We may use your data as described to you at the time of collecting the information including as allowed by applicable law.
  • We may use your information based on your interactions with the Services to improve user experience and the functionality of the Services. It further aids us to avail you products, services, recommendations and advertisements tailored to your interest. In addition, we may use the data to conduct analysis, research and to test our new related products or Services.
  • We may use your information to introduce to you our new update, features, products or services, including offers. We may further use your data to serve you ads of our products and/or services including that of our advertising partners that we consider might be of interest to you on the Services or that of the third party such as use of tracking technologies or cookies. We may also use your aggregated data about you to measure our or third-party partners ads campaigns.
  • We may collect and use your information if you interact with the Platform’s chatbots (or generative AI). The data we may collect includes your question(s) or prompt(s), messages and the access device, and use the information to improve the features of our generative AI and Services.

HOW WE SHARE YOUR INFORMATION

For Everyday Business

We may disclose your data for every day business purposes such as to handle your application, underwriting, manage your transactions, oversee your account, comply with court orders and legal inquiries, or report to credit agencies.

Credit Bureaus:

As a user of CreditLink Reporting Services, we share your information with national consumer reporting agencies which currently are Experian, Equifax, and TransUnion (“Consumer Bureaus “) that obtain ownership of such information upon transmission and determines the manner in which any data provided to them is utilized. Please refer to each Consumer Bureau’s website for their policy statement including terms and conditions relating to the collection, storage, usage, modification, dissemination, management of such information.

Information Disclosed for Our Marketing Purposes

We share information about you for our marketing purposes to offer products and services to you.

Business Transfers

In the event that we choose to purchase or sell assets, user information is generally considered one of the business assets that are transferred. If we are acquired, or if we cease operations or file for bankruptcy, user information would be among the assets that could be transferred or acquired by a third party. Any entity that acquires us or our assets may persist in utilizing your Personal Information as described herein.

Information Disclosed for Our Protection and the Protection of Others

We reserve the right to access, read, preserve, and disclose any information that we reasonably deem necessary to:

  • Comply with any relevant laws or governmental requests;
  • Identify, prevent, or address issues related to security, fraud, or technical matters;
  • Enforce this Privacy Policy along with our Terms of Service and may include investigating potential violations;
  • Address user support inquiries; or
  • Safeguard our rights, property, or safety, as well as that of our users and the general public. This may involve sharing information with other companies and organizations in order to prevent fraud, malware and spam.

Deidentified and Aggregated Information

We may diclose deidentified, anonymized, or aggregated data with third parties for research, analysis, or other business purposes.

Information We Share With Your Consent

In addition to the disclosures described in this Privacy Policy, we may also share your information, which may include your Personal Information, in additional ways when notice has been provided and you consent.

Your Choices On How You May Control Your Information:

Phone Communications:

You have the option to opt-out of receiving the majority of these messages at any time by sending a request to support……………..<insert the support email> or by replying with "STOP" to any text message. If you respond with "STOP", we will send you an SMS to confirm your unsubscription, after which you will cease to receive marketing SMS messages from us. You understand that opting out of text message communications may affect your use of the CreditLink Services. Note, we may utilize your contact information to send you notifications regarding the Services. Also you can unsubscribe from certain messages via your CreditLink account settings; however, we retain the right to reach out to you when we deem it necessary, such as for account recovery purposes.

Email Communication:

You have the option to opt out of receiving specific emails communications by modifying your notification settings within the CreditLink Service, by contacting support……………..<insert the support email> or choosing to unsubscribe as indicated in the relevant correspondence. Nevertheless, you may continue to receive service-related crucial communications that are necessary for your ongoing use of the Services, including but not limited to, account verification or important service updates.

Targeted advertisements

We and our marketing partners offer you interest-based advertisement. The Digital Advertising Alliance ("DAA") and the Network Advertising Initiative ("NAI"), various media and marketing organizations have established a self-regulatory program aimed at enhancing consumer awareness and control over advertisements tailored to their online activities across multiple websites. To make informed decisions regarding Interest-Based Ads from participating third parties, including opting out of behaviorally targeted advertisements from these organizations, please visit the consumer opt-out pages of the DAA or NAI, which can be found at http://www.networkadvertising.org/choices/ and www.aboutads.info/choices, respectively. Please note that by opting out of targeted advertisements do not imply that you would stop seeing ads on the Services, but it means that you will stop seeing ads that are tailored to your interest.

Google Analytics

We use Google Analytics as analytics provider to understand customers behaviour the Services. You have the choice to opt out of Google's use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

Cookies:

Individuals can manage cookies by adjusting their browser settings to receive notifications when a cookie is sent and decide whether to accept it, automatically reject certain types of cookies, or disable current cookies. However, such controls may or may not be available for other tracking technologies (such as SDKs, pixels, and localStorage). Although there may exists options within your email client to prevent the automatic downloading of images that could contain technologies enabling us to determine whether or not you have accessed our email and taken specific actions regarding such emails. Please note that limiting the use of these technologies may adversely affect an individual’s experience on the Platforms and may not allow the individual take advantage of the Services.

Mobile Settings

You can use your mobile device settings to control your mobile advertising identifier.

Account Deletion:

You may opt to delete your account through your CreditLink account settings or by contacting our support through email at support………….. <enter the support’s email address>. Note that when we receive account deletion request, we will take steps and delete your account and information. Also note that some of your data will be retained as permitted by applicable law for the purpose of legal compliance, legitimate business purposes, and internal-record keeping.

Do Not Track:

Currently we do not support do not track features.

OTHER PROVISIONS

Information Retention:

CreditLink which furnishes Consumer Bureaus information of payment history, the Reporting Services, may retain your information for a period reasonably necessary to achieve the purpose of the Reporting Services, unless a longer retention duration is needed or allowed by law. In addition, where we are required to keep all or part of your information to meet necessary legal compliance, uphold our agreements, legitimate business purpose, settle disputes, or safeguard against fraudulent or unlawful activities.

Children Privacy

If you are below 18 years do not use the Services or provide and submit information to the Platform. We do not intentionally collect Personal Information from individuals under the age of 18 years. If we learn that an individual under the 18 years has created an account or has otherwise shared Personal Information with us, we will take steps to close the account and remove the information.

Third-Party Link

There may be links to other external website and resource made available on the Platform by third parties. This links may be contained in an advertisement and we do not have control of such websites or its contents. In the event you access the website, you take full responsibility of the risk of so doing and bound by the site’s terms and conditions.

Information Security

We safeguard your Personal Information against unauthorized access and usage by implementing physical, electronic, and administrative safeguards in accordance with relevant laws. These protective measures includes computer safeguards as well as secured files and facilities. We permit our contractors and employees to access your information solely when necessary for their job functions, and we demand that the third-party providers we engage with also protect your information. Nevertheless, we cannot assure the absolute security of any information. Unauthorized access or usage, hardware or software malfunctions, and various other factors may jeopardize the security of user information at any given time.

For more information about this Privacy Policy, or any questions, please contact us at …………..<enter support email address>

U.S. State Privacy Notice

For individuals who are protected by the State Privacy Laws, this U.S. State Privacy Notice serves in addition to the details contained in our Privacy Policy. Broadly State Privacy Laws relates to various U.S. State regulations that oversee the processing of consumers personal information which differs with sector law specific s. Herein are the rights you may exercise over your personal information depending on your State of residency and subject to certain exclusions and exemptions:

Request to Know

Subject to your identity verification and certain exemptions under the applicable law, you may request to access and we will provide:

  • The categories of Personal Information we collected about you.
  • The categories of sources from which the Personal Information is collected.
  • The categories of Personal Information sold or shared for purposes of targeted advertising to a third party, as well as the categories of third parties to whom such personal information was disclosed, by category of categories of personal information for each category of third party.
  • The categories of Personal Information that the business disclosed about the consumer for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
  • Our business or commercial purpose for collecting, selling, or sharing for purposes of targeted advertising your Personal Information.
  • The specific pieces of Personal Information we collected about you.

Request to Delete

You may request that we delete Personal Information we have collected from you, subject to verification of your identity and the exceptions provided by law. If you do not delete your account, however, we may retain Personal Information to provide services requested.

Request to Correct

You may request that we correct inaccurate Personal Information we have collected from you, subject to verification of your identity and exceptions provided by law.

Request Not to Sell or Share Personal Information

You have the right to opt-out from having your Personal Information and Sensitive Personal Information sold to or shared with third parties for targeted advertisements or other purposes. CreditLink has no actual knowledge of any sales of Personal Information or Sensitive Personal Information of minors under 16 years of age.

Request to Limit Use and Disclosure

You may request that we limit the use and disclosure of your Sensitive Personal Information.

Your aforementioned rights are subject to various exceptions and exclusions under applicable laws. Prior to processing your request, it may be necessary for us to verify your identity and confirm your residency. To verify your identity, we may require either (i) the alignment of sufficient information you provide with the data we have on record about you in our systems or (ii) the successful authentication of your account. This verification process may necessitate that we ask for additional personal information from you, which may include, but is not limited to, your email address, phone number, or the date of your recent transaction history on the Platform. In the event that we are unable to verify your identity or find your information in our systems, we may decline your request and provide you the reason for so doing.

Exercising Your Privacy Rights

You or an agent you designate to act on your behalf, may submit a verifiable request concerning your Personal Information. With respect to right to know, you may request for access or data portability. The request must contain adequate information that enables us to reasonably confirm that you are the individual from whom we collected personal information or an authorized representative; therefore, it must include your name, phone number, and address.

To authorize another person to make a request on your behalf, you must provide that person with written permission (“Power of Attorney”) clearly describing their authority to make a request on your behalf. That agent must also be able to verify their identity with us and provide us with their authority to act on your behalf. If your request is denied, we will give you reason(s) for such denial and provide you with method of appeal. You may also appoint and authorize someone to appeal on your behalf. If you wish to so do, your authorized agent must submit signed Power of Attorney from you to make such a request, and we may still verify your identity directly where necessary.

If we have collected information regarding your minor child, you are entitled to exercise the aforementioned rights on the behalf of the minor child as CreditLink Services is designed exclusively for individuals of 18-year or older, and we do not intentionally collect information about minors. In the event we discover that we have collected or received personal information from a child under 18 without confirming parental consent, we will remove that information. If there is a reasonable suspicion of such, you may contact us at………………….. <enter support email>

If you would like a copy of this notice, please submit a written request to ……………<CreditLink company full name>, …………………….<insert CreditLink physical office address >

California Consumer Privacy Act

This section relates and applies to all California residents under the California Consumer Privacy Act (“CCPA”) from whom we have collected personal information from. The source of the information may include your usage of our Platform, products, services, any electronic communication, in-person interactions with us, or written correspondence. We implements privacy and security measures to safeguard your personal information in accordance with United States federal law, the Fair Credit Reporting Act, amongst others. In view of above, most of personal information we may collect and utilize about you is exempt from the CCPA, with only a limited amount of personal information being governed by the CCPA.

Exercising Your Privacy Rights Under CCPA

If you are a California resident, to submit a request to exercise your right under the CCPA, please email………………….. <enter support email address> for assistance.

California resident are entitled to rights and exercising of the rights under the U.S States Privacy Notice above. In addition, with respect to right to know, you may request for access or data portability only twice within a 12-month period. The request must contain adequate information that enables us to reasonably confirm that you are the individual from whom we collected personal information or an authorized representative; therefore, it must include your name, and phone number, and address.

“Personal information” herein means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household (e.g. Identifiers, customer records, commercial information, network information, geolocation data, protect classification characteristics, sensory information, sensitive personal data, professional/employment information, and other personal data. Personal information does not include publicly available information, information that has been de-identified, or information that does not fall within the definition of personal information above.

Please see “How we Use your Information” section on how we use information collected from you.

You have the right to opt out of your personal information being “shared” or “sold” by contacting us via …………………….<insert emails address>. We may have in the past 12 months shared or sold with our third-party service providers and partners these categories of personal information: identifiers, geolocation information, network data, and commercial information.

For questions or comments concerning this Privacy Policy, please contact us at …………………..<insert emails>