Collection of Information
We may ask you to provide us with certain information any time that you are in contact with us, our subsidiaries or affiliates, which could reasonably be used to identify you and/or your company, including without limitation, your name, company name, address, email address and phone number (“Identity Information”). All Identity Information we collect is in response to your direct or indirect inquiries, requests, submissions, or correspondence. Specifically, such information we may collect includes information we receive through: (i) information you provide us in submitting a “Quick Application,” “Standard Credit Line Application,” or other online application; (ii) records and copies of your correspondence (including email addresses), if you contact us; (iii) details of transactions you carry out through our website or applications; and (iv) financial information collected in connection with processing a voluntary transaction, including, without limitation, credit card numbers, debit card numbers, bank account numbers, and other methods of payment, together with any information you submit to effect such transactions.
In addition to any Identity Information that you choose to provide us with, we, our affiliates, subisidiaries, and any third-party service providers may use publicly available information, as well as certain technology (including cookies), that actively or passively collects additional information (“Non-Identity Information”) that you provide when you visit or use our websites, mobile apps, receive or reply to electronic communications with us, view or click on our ads or content, or interact with us through social media websites and other websites and apps. Such additional information that we may collect includes, but is not limited to: (1) the devices you use; (2) your Internet Protocol (“IP”) addresses or similar identifiers; (3) information related to your IP addresses and similar identifiers (e.g. domain information, your internet provider, and general geographic information); (4) your browsing history; (5) the search queries you used to find us; (6) the referrer URL; (7) what you view, access or click on; (8) whether you open electronic communications; and (8) the time zone and geographic location of the device you are using.
We do not knowingly collect or solicit any information from anyone under the age of eighteen (18). In the event that we learn that we have collected Identity Information from anyone under the age of eighteen (18) without parental consent, we will delete such information as quickly as possible.
How We Use Your Information
We may use the information we collect on our own or combine it with information that we have collected from others to:
- Respond to your requests and inquiries;
- Update you concerning your accounts, our products, our services, as well as changes to the terms, conditions, policies and/or other administrative information related to our websites and online applications;
- Develop and improve our products, services, websites and online applications, including personalizing your experience on our site;
- Deliver products and services to you and/or complete transactions;
- Evaluate your interest in our products and services, as well as your eligibility to receive such products and services;
- Create content and send marketing communications, ads or offers that are tailored to your preferences or interests;
- Analyze whether our ads, promotions and offers are effective;
- Administer and permit you to participate in market research, including surveys, sweepstakes, contests and other promotions.
- Create and produce data analytics, statistical research, and reports;
- Assess credit risks related to our business;
- Manage fraud and security risk;
- Comply with laws, regulations, and other legal process and law enforcement requirements; and
- Use your information in any other way as required or permitted by law or your consent.
Sharing of Information
We may collect, use, transfer, and disclose Non-Identity Information, including any Non-Identity Information relating to multiple parties that is aggregated, for any purpose.
If your Identity Information is combined with Non-Identity Information in any ratio, then the combined information will be treated as Identity Information for as long as it remains combined.
Notwithstanding the foregoing, we may share your information with our subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the websites and online applications; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
Protection of Your Information
We maintain physical, electronic, and procedural safeguards that comply with federal regulations to protect information that we collect about you. When your Identity Information is no longer of use to us, we will take reasonable steps to destroy or de-identify your Identity Information, unless we are required to keep such information in accordance with our internal policies and procedures, or in order to comply with any applicable law or regulation.
Your California Privacy Rights
California’s “Shine the Light” law, California Civil Code § 1798.83, requires certain businesses to respond to requests from California customers (those who have an established business relationship with us) asking about the business’ practices related to disclosing Identity Information to third parties for the third parties’ direct marketing purposes. We do not share customer information with third parties for their direct marketing purposes, and California’s Shine the Light law therefore does not apply to Counsel Financial.
Managing Your Information
You are responsible for maintaining the accuracy of any information you submit to us. If you want to make sure that your information is accurate and up to date, then you may do so by contacting us here.
Other Important Information