Privacy Policy - SurePath Lending, LLC

Privacy Policy – Effective Date 3/1/2024

Introduction

Welcome to SurePath Lending, LLC. We value the privacy of our customers and are committed to protecting your personal and financial information. This Privacy Policy outlines how we collect, use, share, and protect information in connection with our services.

By continuing to use the website, you agree to this Privacy Policy and the collection, use, disclosure, and storage of your personal information as described by this Privacy Policy.

Information We Collect

When you use the website, we may collect personal information about you that you submit on an application or other forms made available through the Website to communicate with us. Personal information may include your name, address, Social Security number, telephone number, email address, income and financial information, or any other information that you may submit through our services.

We also automatically collect certain information about you and your interactions when you visit the Website. This includes information such as your IP address, location, internet browser, operating system type, device, the date and time of your interactions, and the website URL that referred you to us.

We collect information about you that we believe will be necessary or useful in processing or administering products or services that you have requested from us. We will also collect information to notify you about products, services, and other opportunities we think will be of interest to you.

Information We Collect From Other Sources

We obtain information from third-party sources that is necessary or useful in processing or administering products or services that you have requested from us. For instance, we may collect information about you from identity or other verification services, and credit bureaus for your credit report. The information we receive from such third parties varies depending on the information made available by those entities. Other types of personal information we receive may include financial account information, information about account balances, information about account owner, information about account transactions and employment information.

If you create of log into your SurePath Lending account through a third-party platform such as Google or Facebook, we will have access to certain information from that platform, such as your name, birthday, and profile picture in accordance with the authorization procedures determined by the respective platform.

We limit the information that we send service providers and require that our service providers only share personal information to perform the specific services requested in accordance with SurePath Lending’s Privacy Policy. We also require that the service provider has the necessary security measures in place to protect any shared information.

For example, when you authorize us to verify your credit history we send the minimal set of information needed in an encrypted format to the relevant credit bureaus for the sole purpose of retrieving your credit report and credit history data.

We only send the essential information to each service provider in an encrypted format that enables them to perform their specific service that is a necessary part of the loan process that you authorized.

Cookies and Other Tracking Technology

SurePathLending.com uses cookies and other tracking technologies, such as web beacons (pixel tags). We use both first-party and third-party cookies and tracking technologies on the Website. These cookies and tracking technologies may collect your personal information for the following purposes:

Monitor how our website is used.
Customize content for your user experience.
Serve advertisements and assess the effectiveness of the campaigns.
Identify issues with the website.
Analyze website visits and other analytic purposes.
Monitor security of the website.
Measure effectiveness of communications and content.

Most web browsers allow you to adjust your preferences to reject or accept cookies or receive notifications before they are placed on your computer. If your browser rejects cookies, you may continue to use the Website , but some aspects of the Website may not function as intended.

Tracking

Our first-party cookies and tracking technologies do not track users over time or across third-party websites. We also use third-party cookies to serve targeted ads on third-party websites. These cookies may track users over time and across third-party websites and services. For this reason, you may still see some of our ads on third-party websites even if you opt out of advertising cookies.

Third Parties

We may share personal information with third parties to provide, maintain, and improve our services. We ensure that these third parties adhere to strict data protection and privacy standards. We only share the minimum amount of information necessary for them to perform their functions, and they are prohibited from using your information for any other purpose. By using our services, you consent to this sharing of your information. We will never sell your personal information.

Links to Other Websites

The Website may contain links to third-party websites, such as Facebook, Twitter, YouTube, or other social media websites. This Privacy Policy is only applicable to this Website. We do not have any control of third-party websites’ information practices. Please note that you should review these third-party websites’ privacy policies before visiting them.

Access and Control of Information

We are committed to providing you with complete access and control over your personal information. You may see what data we have about you and can change or correct any data. You may delete any of your personal information that is not required by law for us to retain. You may express any concern you have about the use of your data.

You may also opt-out of any future communications that is not required by law by calling us at (888) 525-9176 or by sending an email to info@surepathlending.com.

Protection of Personal Information

SurePath Lending uses physical, digital, and administrative security measures to protect personal information we collect from loss, misuse, unauthorized access, or improper disclosure. We use encryption technologies when transmitting information to and from the Website and with our third-party service providers. All security measures comply with federal standards to keep your information safe.

Children’s Privacy

SurePath Lending’s products and services are not intended for persons under the age of 18. We do not knowingly collect, maintain, or use personal information from children under the age of 16. If we become aware that a child under the age of 16 has submitted personal information to us, we will immediately delete such information.

Privacy Policy Updates

SurePath Lending reserves the right to update this Privacy Policy at any time. Any update to the Privacy Policy will be immediately effective upon the posting date of the policy change. If we make changes, we will notify you by revising the date at the top of the Privacy Policy. Your continued use of the Website after the updates are posted represents your consent to the terms of the new Privacy Policy. Please regularly check this Privacy Policy to stay informed about our information practices and the choices available to you.

Additional State Privacy Rights for California Residents

California law permits residents of California to request certain details about how their personal information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request please call us at (888) 525-9176 or email us at info@SurePathLending.com.

This specific section of the Privacy Policy applies to customers, visitors, and users of our website who reside in the state of California. This section provides a description of our online and offline privacy practices regarding the collection, use, and disclosure of personal information of California residents and their rights protected under the California Consumer Privacy Act of 2018 (CCPA).

Information We Collect

When you use our Website, we may collect personal information about you, such as your name, address, Social Security number, telephone number, email address, asset information, income information, or any other information that you submit on applications or other forms made available through the Website. We collect this information when you request a rate quote, begin an application, or make an inquiry.

As part of our business, and in our efforts to serve you, we collect this information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

Notice of Information Collected

In the preceding 1-12 months, we have collected the following categories of personal information:

Identifiers – A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or other similar identifiers.
Personal Information Categories Listed In The California Customer Records Statute – A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
Protected Classification Characteristics Under California or Federal Law – 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.
Commercial Information – Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming information.
Internet or Other Similar Network Activity – Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation Data – Physical location or movements.
Sensory Data – Audio recordings of your contact with our customer service team.
Professional or Employment Information – Current or past job history.

What is Not Collected:

Biometric Information – Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Non-Public Education Information – Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences Made From Other Personal Information – Audio, electronic, visual, thermal, olfactory, or similar information.

Personal Information Does Not Include:

Publicly available information from federal, state, or local government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We Obtain the Categories of Personal Information Listed Above From The Following Category sources:

Directly from our customers or their agents related to the products or services that we are asked to perform.
Indirectly from our customers or their agents through information we collect from our customers while providing services to them.
Directly and indirectly from activity on our Website.
From Third Parties that interact with us in connection with the services we perform or products that we provide.
From our affiliates.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide personal information to apply for a loan, we will use that information to process your application, payment, and facilitate loan closing. We may also save your information for legal or regulatory purposes, loan fulfillment, and/or loan servicing.
To provide, support, personalize, and develop our website’s products and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our response.
To personalize your website experience and to deliver relevant content, product, and services offerings, including targeted communications (with your consent, where required by law).
To help maintain the safety, security, and integrity of our website, products, services, databases, and other technology assets.
For testing, research, analysis, and product development, including developing and improving our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or for other business purposes or that are otherwise set forth in the CCPA.
To respond to audits or state or federal examinations by our regulators.

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 notice.

Sharing Personal Information

We may disclose your personal information to third parties for business purposes. We limit the information that we send to service providers and require that our service providers only use shared personal information to perform the services requested in accordance with our Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

We may share personal information with third parties:

Such as vendors who provide employment verification, degree verification, title, document import, or other necessary services.
Such as our subsidiary and affiliated businesses that provide quality services or products you may be interested in.
For any purpose to which you expressly consent.
To protect our rights or the rights or safety of others, as may be required by law or regulation.

Sale of Personal Information

In the preceding 12 months, we have not sold to another business or any third party any personal information subject to the CCPA.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

Access to Information

Unless your personal information is excluded from the scope of the CCPA, 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 12 months.

Deletion Requests Rights

Unless your personal information is excluded from the scope of the CCPA, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to exceptions.

Please note that the Gramm-Leach-Bliley Act and the CCPA allow us to keep certain forms of data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information.
Provide a product or service that you requested and take actions anticipated within the context of our ongoing business relationship with you.
Perform a contract between us and you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Enable solely internal uses that are aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically (provided we can do so securely). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded.