Oregon Privacy Policy
Effective and last updated July 1, 2024
Introduction
We (NetCredit Loan Services, LLC and NetCredit Finance, LLC) respect the privacy of your information. This Oregon Consumer Privacy Act ("OCPA") Policy is designed to assist Oregon residents in understanding how we collect, use, disclose, share, and retain their personal information, both online and offline, including the information you provide to us in using our website ("Site"), when you use our services through the Site, or when you use our services provided through a third-party platform ("Platforms") (collectively, the "Services").
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.
In addition, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal data.
This Privacy Policy covers the following topics:
- Personal Data We Collect
- How We Use Your Personal Data
- How We Share Your Personal Data
- Cookies and Other Tracking Technologies
- “Do Not Track” Signals
- Choices About Your Personal Data
- Security
- Third Party Links
- Children’s Privacy
- Notice to Oregon Residents
- Accessibility
- How to Contact Us
1. Personal Data We Collect
We collect personal data from you through your use of the Site and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:
Personal Data You Provide
Depending on how you interact with our Site and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:
- Applying for a Credit Product. To apply for a credit product, you will need to create an account where you will provide us with your personal information, including name, physical address, phone number, email address, bank account information, Social Security number, and you will create a password for future logins.
- Identity Verification. To verify your identity when you use our Services, you will provide us with your personal information, including your name, email address, Social Security number, passport and/or driver’s license or government-issued identification card.
- External Bank Account Information. We will collect information regarding your bank account in order to issue funds to you from your credit product and/or to make payments towards your credit product, including the account name, account type, account number, and routing number.
- Servicing Your Account. In order to service your account, you will be required to update your information with us from time to time, including physical address, phone number, email address, and bank account information.
- Contact Us. To contact us, you will provide us with your personal information, including your name, email address, phone number, and any other information you choose to provide or that we may need to verify your identity.
Personal Data as You Navigate Our Site
We automatically collect certain personal data through your use of the Site and our use of cookies and other tracking technologies, such as the following:
- Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
- Device Information. For example, hardware model, operating system, IP address and browser.
- Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from Site visitors on a city-regional basis.
For more information on our cookie usage see our "Cookies and Other Tracking Technologies" section below.
Personal Data We Collect About You from Other Sources
In some cases, we may receive personal data about you from other sources. That includes credit reporting agencies, third-party data providers, marketing partners, advertising partners, web browsers, internet service providers, government entities, operating systems and platforms, and data brokers.
2. How We Use Your Personal Data
In addition to the purposes stated above, we may use the personal data we collect in accordance with applicable law such as to:
- Provide the Services, perform obligations under our agreements, and carry out related business functions;
- Verify your identity;
- Process your credit application;
- Process your transactions, including disbursing funds to you and processing your payments;
- Allow our partners to fulfill their promotional obligations to you;
- Contact you regarding our products and services that we feel may be of interest to you;
- Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
- Provide customer support to you or the Platforms, including to help respond to your inquiries related to our Services;
- Maintain and improve our Site and Services;
- Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use;
- Responding to inquiries from regulators, including responding to exams and complaints;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business; and
- Comply with legal obligations, audit requirements, and applicable laws, including those relating to customer identification, "know-your-customer" procedures, and anti-money laundering and counter terrorism financing.
3. How We Share Your Personal Data
We may share the personal data that we collect about you in the following ways:
- With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, and financial service providers who enable you to use certain features;
- With the banks we partner with to provide you with credit services;
- With vendors to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- To protect you against actual or potential fraud, identity theft, unauthorized transactions, claims, or other liability;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
- With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding or in preparation for any of these events;
- With any other person or entity where you consent to the disclosure; and
- For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for marketing purposes.
4. Cookies and Other Tracking Technologies
How We Use Cookies
Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).
We use Cookies to:
- Estimate audience size and usage patterns;
- Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
- Advertise new content and services that relate to your interests;
- Keep track of advertisements and search engine results;
- Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
- Recognize when you return to the Site.
We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies other entities set to provide us with useful information, to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Facebook, and other similar companies. Please see our Terms of Use for additional information about our use of Cookie.
How You Can Opt Out of Cookies
To manage your Cookie setting, please click here.
Browser Settings
You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.
You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.
Platform Controls
You can opt out of Cookies set by specific entities by following the instructions found at these links:
- Google: https://adssettings.google.com
- Facebook: https://www.facebook.com/about/ads
- Microsoft: https://account.microsoft.com/privacy/ad-settings/
- Adobe: https://www.adobe.com/privacy/opt-out.html
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
Google Analytics
We use Google Analytics, a web analytics service provided by Google, LLC. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.
Hotjar
We use Hotjar to better understand our users’ needs and to optimize the service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our Site. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information, please view Hotjar’s privacy page by clicking here.
LiveRamp Authenticated Traffic Solutions
When you use our Site, we share information that we collect from you, such as your email (in hashed form), IP address, or information about your browser or operating system, with our identity partners/service providers. These partners return an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with service providers to enable interest-based and targeted advertising. To opt out of this use, please click here.
Other Types of Collecting Activities
The Site and Services may use cookies and similar technologies third-party vendors provide to collect information, such as IP address, device information (e.g., operating system), and information on user behavior (e.g., screens and pages visited, buttons and links clicked, limited information entered, and user taps and mouse movements). This information enables us to monitor and improve the user experience.
5. “Do Not Track” Signals
The Site recognizes the Global Privacy Control ("GPC") signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out and this will be indicated in the banner notice that appears when you visit our Site. You can manually indicate your preferences via the Do Not Sell or Share My Personal Information link at the bottom of the Site. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the "Do Not Track" signal, the Site does not currently interpret, respond to or alter its practices when it receives "Do Not Track" signals.
6. Choices About Your Personal Data
Review and Request Changes to Your Personal Data
You may use your online account to access, correct, or view certain personal data we have collected and which is associated with your account. To review or request changes to any of your personal data, visit our privacy request webform here or contact us via email at support@netcredit.com or by telephone at 1-877-392-2014.
Marketing Communications
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may log in to your account at www.netcredit.com to change your marketing preferences in the “Communications Preferences” section under your Personal Info or contact us via email at support@netcredit.com or by telephone at 1-877-392-2014 to change your marketing preferences.
7. Security
We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.
8. Third Party Links
The Site and Services may contain links that will let you leave the Site and Services and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to personal data that is acquired by us on this Site and Services. We accept no responsibility or liability for these other websites.
9. Children’s Privacy
The Site and Services are not intended for children under 18 years of age. We do not knowingly collect, use, or disclose personal data from children under 18.
10. Notice to Oregon Residents
If you are an Oregon resident, you have the following privacy rights:
- The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
- The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
- The right, at our option, to obtain a list of specific third parties, other than natural persons, to which we have disclosed your personal data or any personal data;
- The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
- The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
- The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
- The right not to receive discriminatory treatment by us for the exercise of your privacy rights.
How to Submit a Privacy Request Under Oregon Law
You may submit a request to know (including to (i) obtain your personal data, (ii) obtain a list of third parties to which we disclose personal data, or (iii) confirm whether we are processing or have processed your personal data and the categories of personal data we have processed), delete, opt out of processing, or correct through our interactive webform available here or by calling us at 1-877-392-2014. If legally required, we will comply with your request upon verification of your identity. To do so, we will ask you to verify data points based on information we have in our records. See “Our Process for Verifying a Privacy Requests Under Oregon Law” below for further information. If we deny your request, you may appeal our decision by completing our privacy request webform here or by calling us at 1-877-392-2014.
Please note that your privacy rights described above do not apply to personal data that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and the Fair Credit Reporting Act. Because we are subject to those laws, much of the personal data that we collect is exempt from compliance under Oregon law. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
If you are submitting a request on behalf of an Oregon resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the Oregon resident.
Our Process for Verifying a Privacy Request Under Oregon Law
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the Oregon resident on whose behalf you are making such request.
To verify your request, we will match the personal information you submit with the information we have about you. If we cannot conclude your information matches what we have, you may be directed to contact us with further instructions to assist us in responding to your request. To verify your request, you must submit:
- Your first and last name;
- Your Social Security number;
- Your date of birth; and
- Your email or mailing address (depending on delivery preference).
11. Accessibility
Individuals with disabilities who require an accommodation to access this policy or to make a request under this policy should contact us via email at support@netcredit.com, by telephone at 1-877-392-2014, or by mail at 175 W. Jackson Blvd., Suite 600, Chicago, IL 60604. Please note that we may need advance notice to provide certain accommodations.
12. How to Contact Us
To contact us for questions or concerns about our privacy policies or practices please email us at support@netcredit.com or by telephone at 1-877-392-2014.