Privacy Policy
Last Updated: July 20, 2010
- My Secure Payday ("MySecurePayday"), is the owner and operator of this website. MySecurePayday respects the privacy of our consumer users ("you" or "your") and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. If you are an individual who is a user of this website or any other of the MySecurePayday family of websites relating to cash or payday loans (collectively, "our websites"), who accesses or responds to advertisements or offers e-mailed or displayed to you, or who is otherwise as a user of the services provided by MySecurePayday, this Privacy Policy is intended to describe for you, among other things:
- We encourage you to read this Privacy Policy carefully when using our website or services, responding to our advertisements and offers, or transacting business with us. By using our websites, you are accepting the practices described in this Privacy Policy.
- If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.
INFORMATION WE COLLECT ABOUT YOU
- In General. We may collect personal information that can identify you such as your name and e-mail address, as well as other information that does not identify you. When you provide personal information through our websites, the information may be sent to MySecurePayday servers located in the United States and other countries around the world.
- Information You Provide. We may collect and store your username and password and any personal information you enter on our websites (for example, on loan or credit line applications, registration forms and quizzes) or provide to us in some other manner. This includes identifying information (such as your name, home or mailing address, e-mail address, telephone numbers, fax number, Social Security number and driver's license number), information about your home and employment (such as employer's name, location, address and telephone number and the length of your employment), your financial information (such as your income, pay dates, assets and debts), information about your references (such as name and telephone number), other personal information such as your gender, age, citizenship and military status, information you provide when completing a survey, and, if you apply for a loan, credit line or other product for which a fee is charged, bank or financial account information such as your bank's name and contact information, your bank account number and type, ABA routing number, valid credit card number, type, expiration date or other financial information. We may also track your interaction with email advertisements sent to you by MySecurePayday or others (for example, when you register, purchase, or browse in response to such emails).
- List Information from Vendors. We may obtain information about you after you provide information to a third party and you permit that party (the "Seller") to share the information, which MySecurePayday subsequently purchases, licenses or otherwise lawfully acquires. Such information may include, but is not limited to, your name, street address, zip code, telephone numbers, birth date, gender, salary range, education, marital status, occupation, industry of employment, personal and/or online interests, and/or other information which you provided to the Seller (together, "Vendor List Information"). When acquiring Vendor List Information, MySecurePayday requires assurances from the Seller that the Seller has a right to transfer the Vendor List Information to MySecurePayday and that MySecurePayday may lawfully use the Vendor List Information to transmit offers to you.
- Information from Other Sources. We may also periodically obtain both personal and non-personal information about you from business partners, contractors and other third parties, as well as information from public databases. Examples of information that we may receive include information about your home and additional demographic information. However, MySecurePayday does not pull credit reports on loan or credit line customers or engage in loan processing. We also do not collect "experience" information (such as a customer's account history with a lender) as defined in the Fair Credit Reporting Act.
- Information about Others. We may also collect and store personal information that you provide to us about other people (such as co-borrowers and references), including their name, address, phone number, Social Security number, financial information or other personal information.
- Use of Cookies and Other Technologies to Automatically Collect Information. We and our authorized service providers, advertising companies, and ad networks may use various activity tracking technologies, such as cookies, pixels and web beacons, to collect information from your computer and about your activities on our websites or interaction with our advertisements (see "Information Collected by Third Parties" below). We and these companies may automatically collect information from your browser when you visit our websites. This information may include your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us or them (see "Cookies" below) and the referring website address.
- Cookies. When you visit our websites, we may assign your computer one or more cookies, to facilitate access to our websites, to personalize your online experience, and to record information about your visit to our websites. A cookie is a small amount of data stored on the hard drive of your computer that allows your computer's browser to store your preferences and allows MySecurePayday, our authorized service providers, advertising companies and ad networks to identify you by a unique identifier and associate this with corresponding information in our or their database. Through the use of a cookie, we and these companies may store your registration information and user preferences and may also automatically collect information about your online activity on websites, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while on websites. We may also use cookies to store and associate with you personal information you submit on our websites (including, but not limited to, name, e-mail address, mobile telephone number, driver's license number and bank or financial account information) to facilitate the process of enabling you to find a loan through our websites. In addition, MySecurePayday may set a cookie on your computer when you view our advertisements delivered on or in connection with a third-party website you are visiting. After a cookie is set, MySecurePayday may track how you interact with the advertisement (for example, registering, purchasing, browsing, etc.). Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our websites.
- Other Technologies. We may use other standard Internet activity tracking technologies, such as web beacons and similar technologies, to track your use on our websites or your interaction with our advertisements. A web beacon is a programming code used to display an image on a web page and can also transfer an individual's user identification to a database and associate the individual with previously acquired information about the individual. We may include web beacons in promotional e-mail messages or newsletters or online advertisements to determine whether messages have been opened or acted upon. We may use the information we obtain in this manner to customize the services and offers we provide our websites' visitors, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming or other activities.
- Information Collected by Third Parties. We may allow third-parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements and other materials on our websites, and to deploy technology for our benefit, for example, to load web pages quicker or to gauge website traffic. We and these companies may use tracking technologies, such as cookies and pixels, to collect information about users who view or interact with these advertisements and/or connect to our websites. The information collected allows us and these companies to deliver and gauge, among other things, the effectiveness of targeted advertisements. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative (www.networkadvertising.org), which offers a single location to opt out of ad targeting from member companies.
HOW WE USE THE INFORMATION WE COLLECT
- In general. We may use information that we collect about you to:
- deliver the products and services that you have requested;
- send you offers that you have opted in to receive;
- manage your relationship with us and provide you with customer support;
- perform research and analysis about your use of, or interest in, our products, services or content, or products, services or content offered by others;
- communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or third parties;
- develop and display content and advertising (such as targeted ads) tailored to your interests on our websites and other websites;
- verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;
- enforce our terms and conditions;
- protect MySecurePayday, our websites, our customers and/or our other users from fraud, hacking or other harm;
- cooperate with legal, criminal or regulatory investigations or proceedings;
- manage our business; and
- perform functions as otherwise described to you at the time of information collection.
- Financial and Application Information. We use the financial, financial account and other application information you provide to match you with lenders or to provide their or other third parties' conditional loan, credit line, shopping card and similar offers to you that you have requested, to verify your identity, to protect against or identify possible fraudulent transactions, or otherwise as needed to manage our business, and to charge you or debit your financial account for any fees related to your application or any product you have requested.
- Please review the "Your Choices About Collection and Use of Your Information" section below.
WITH WHOM WE SHARE YOUR INFORMATION
- We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our websites, while using our services or in your other interactions (such as responding to e-mails) with us.
- Personal Information. We do not share your personal information with others except as indicated below. Except for highly sensitive personal information (such as Social Security numbers and financial account information, which we only disclose in limited situations, such as to process a transaction or match you with a lender at your request, and which we do not share for marketing purposes without your prior consent), we may share all personal information with:
- Authorized Service Providers. We may share your personal information with our authorized service providers that perform certain services on our behalf. For example, we may engage other companies to handle the processing of payments, to provide data storage, to assist in marketing MySecurePayday's products or services, to conduct audits, to provide web analytics, and to provide hosting, design, development and other operations which make our websites work. Other third-party service providers may help us communicate with you through e-mail, direct mail, SMS or telephone communication. Our policy is to permit these third-party service providers to obtain only the personal information they need to provide the services, and to require them to protect personal information to the same extent as MySecurePayday, including not using it for any improper purpose.
- Business Partners. When you express interest in products, services or promotions offered through our websites or our services, we may share your expression of interest with the businesses with which we partner to offer you those products, services and promotions, and, as applicable, their affiliates and third-party finder or marketing companies. When you elect to engage in a particular offer or program, you authorize us to provide your e-mail address and other information to those businesses.
- Lenders and Other Partners. If you submit a completed application for a loan, credit line, shopping card or other product featured on our websites (an "Application"), we may share your personal information with lenders and other partners on the MySecurePayday network with your prior consent for the purpose of enabling you to find a loan. We may also share your bank and financial account information with such persons so that they can charge you or debit your account for any fees related to your Application or any product you have requested. If you submit an Application but leave portions of the Application incomplete, we may share your personal information with lenders and other partners on the MySecurePayday network, who may help you complete your request or possibly extend conditional offers to you. However, no credit check will be performed by MySecurePayday. Because the lenders and other partners on the MySecurePayday network with whom you are matched may retain or use your personal information whether or not you qualify for, or obtain, a loan, credit line, shopping card or other product from them, you should contact these persons directly concerning their privacy and information sharing practices.
- Affiliates. We may share information we collect, including personal information, with other companies affiliated with MySecurePayday (some of which are nonfinancial companies). Sharing information with such companies enables us to provide you with information about a variety of products and services that might interest you. These companies will comply with this Privacy Policy and applicable privacy and security laws and, at a minimum, in any commercial e-mail they send to you, will give you the opportunity to choose not to receive such e-mail messages from that company in the future. However, in no circumstance will MySecurePayday share with affiliated companies any personally identifiable information that you provide to us if that information bears on your creditworthiness.
- Special Notice to California Residents. MySecurePayday will not share any personal information about you with other affiliated companies to the extent prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law.
- Special Notice to Vermont Residents. MySecurePayday will not share any personal information about you with other affiliated companies to the extent prohibited by applicable Vermont law or to the extent your prior consent to share is required by applicable Vermont law.
- Other Situations. We also may disclose your information:
- In response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.
- When we believe disclosure is appropriate in connection with efforts to investigate, or to prevent or take other action regarding, illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees or others; or to enforce our websites' terms and conditions or other agreements or policies.
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy.
- Any third parties to whom we may disclose personal information may have their own privacy policies that describe how they use and disclose personal information. Except for companies affiliated with MySecurePayday and authorized service providers, who agree to comply with this Privacy Policy with respect to personal information we share with them, the third parties' privacy policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.
- Aggregated and Non-Personal Information. We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personal information we collect under any of the above circumstances. We may also share it with third parties and affiliated companies to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our websites and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
- Third-Party Websites. There are a number of places on our websites where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on our websites, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.
HOW YOU CAN ACCESS YOUR INFORMATION
- If you have submitted an Application to us, you can update your personal information by contacting
for assistance. More information about how to contact us is provided below. We will process your request, where possible and subject to the terms contained in this Privacy Policy, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION
- You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our websites because such information may be required in order for you to apply for or obtain products or services.
- If you would like to delete the personal information that we have collected from you, please send your request via e-mail to
. We will process your request, where possible and subject to the terms and conditions contained in this Privacy Policy, within a reasonable period of time after receipt. However, federal and state regulations and/or the need to administer our relationships with our ad networks and other third parties may require that we store certain information for various periods of time. In order to comply with these requirements, we may be unable to delete your information from our database until the expiration of the applicable period. However, we will use reasonable commercial efforts to delete your personal information no later than three (3) months after receiving your request, unless a longer retention period is required by law.
- When you initially sign up or submit information on our websites, you will receive e-mail messages or newsletters from us. You will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. You may also opt out of receiving commercial e-mails by using the "unsubscribe" link on our websites. It may take up to 10 business days for us to fully process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as conditional offers, requests for additional information, confirmations, service updates or announcements, administrative notices and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of commercial e-mail communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
- If you are receiving SMS messages from us, you may opt out from further SMS messages and remove your SMS information from our database by responding "STOP" to the SMS text message you have received.
HOW WE PROTECT YOUR PERSONAL INFORMATION
- We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees and authorized third-party service providers are permitted to access personal information, and they may do so only for permitted business functions. In addition, personal information you submit toMySecurePayday through our websites is transmitted through an encrypted SSL connection, and MySecurePayday's computers and networks have security measures, such as firewalls, to protect against the loss, misuse and/or alteration of the information under MySecurePayday's control.
- We want you to feel confident using our websites to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches or other communications will always remain secure. Users should also take care how they handle and disclose their personal information. Please refer to the Federal Trade Commission's website (http://www.ftc.gov/bcp/menus/consumer/data.shtm) for information about how to protect yourself against identity theft.
OTHER INFORMATION ABOUT OUR PRIVACY PRACTICES
- California Residents. If you are a resident of California, in addition to the rights set forth in this Privacy Policy, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive the following information:
- the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- the names and addresses of the third parties that received that information; and
- if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.
- We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is
.
CHILDREN'S PRIVACY
- Our websites are for adults, and we do not knowingly collect personal information from children under the age of 18.
VISITING OUR WEBSITES FROM OUTSIDE THE UNITED STATES
- This Privacy Policy is intended to cover collection of information on our websites from residents of the United States. If you are visiting our websites from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.
NO RIGHTS OF THIRD PARTIES
- This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our websites.
CHANGES TO THIS PRIVACY POLICY
- We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. Accordingly, you should periodically check the "last updated" date at the top of our Privacy Policy so that you can familiarize yourself with any changes. Any changes to this Privacy Policy will only be applied to information collected after such changes are posted on our websites.
HOW TO CONTACT US
- If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us at
.