Effective date: 04/10/2019
I. Personally and Non-Personally Identifiable Information
NB: SS number and banking information are used only to provide You with the searching and matching service and never shared with any third party marketers and other third parties unless the opposite is determined by the law or required according to special orders from the authorized parties (including but not limited national security issues or alike).
Apart from PII, we collect Your non-personally identifiable information (NPII) available upon Your using the Website regardless of submitting any personal information on the Website. NPII includes but is not limited to the user’s behavioral data, such as Internet Protocol (IP) data, browser details, geo position, user’s operating system, the pages of referral and exiting, date and time details, Internet service provider details etc. The NPII we collect from You can be transmitted to the third parties we contract with unless You exploit the means to hide Your NPII or express Your request to stop using Your NPII directly.
i. The Use of Your PII
Your PII can be shared with governmental entities, disclosed completely or partially upon request from any authority or authorized organization if such disclosure is lawful and considered necessary for these reasons:
- it is ordered or required to comply with the legal processes;
- it is obligatory to protect the property of the owner of the Website or its affiliates and in no way contradicts applicable laws;
- it is necessary to prevent crime and/or protect national security;
- it is necessary to protect personal or public safety.
In case of merging, acquisition, consolidation or purchase of the owning company and its assets, it is possible that Your PII may be transferred and, thus, disclosed to the receiving party on the course of the stated actions. According to the court’s decision on insolvency proceeding, if it takes place, in case of liquidation of the owning company, the liquidating party or the authorized representatives of the company can transfer, sell, dispose or license Your PII within the provisions stated by this court’s decision. In this case, it is possible that the owners of the PII shared on the Website will be notified of the forthcoming procedures and modifications upfront or the notification will be published openly on the Website. It is possible that acquisition, merging and other stated modifications are associated with a non-US company.
ii. Third Party Marketing
It is possible that Your PII can partially (excluding such sensitive information as SS number and banking and financial data) be shared for the marketing purposes with some of third party marketers, lenders and advertisers, we contract with. In this case, the receiving parties, as third part marketers, may use this information and share it with other third party marketers who may initiate marketing activity towards You in the way of presenting You the products You have expressed Your interest previously while submitting Your information. In case You decide to opt out from receiving such marketing messages and/or offers, You can easily unsubscribe and eliminate Your information from the lists compiled by these third party marketers to send You messages simply by using an unsubscribe option (option button or link) in the respective message. The means for marketing activity include but are not limited to direct mail, short messages, online banner ads, telemarketing calls, emails etc.). Apart from that, Your information can be used to track Your online activity and collect Your online behavioral and searching information. This activity is usually performed to improve the quality of the services presented to You online and adjust marketing activity to Your requirements and needs.
By continuous use of the Website and attempt to use the services presented on the Website, You expressly agree that You have read and understand the provisions of the legal documents, which control the use of Your information on the Website, and the terms of collecting, storing, sharing and using of You PII and the way Your shared PII can be used by third party lenders and third party marketers.
In order to discontinue contacting with us and receiving more information from Us, You need to close this and all other Website pages. If You have already shared Your personal information with us and want to opt out from further communication and remove Your information from our lists and database, You can contact us directly with respective request using this https://www.cashsmartohio.com/contact/ or other contact information indicated on this Website. Your request will be processed and the information removed from our database. As soon as Your information is removed from out database, You can be sure it will not be shared with any third party, used for any secondary purposes, or used for marketing activities. Still, since the information has already been shared with third party marketers, we cannot take any responsibility for the communication sent to You by these third parties. You should contact third party marketers directly to remove Your information from their databases.
iii. Credit Implication of the Use of PII
The information shared with our third party lenders can be used to verify Your identity (via SS number and/or driving license number, for example) and Your information against national databases. Additionally, the lenders we contract with may need to perform credit verification and use Your PII to request a credit report from one or more credit organizations, including but not limited to the major credit bureaus, to determine Your credibility and assess the risks associated with providing credit products to You. Credit report request may lower Your credit score. If You continue using the Website and submit Your information via the online form on the Website, You give Your express consent to have Your information verified and Your credibility checked according to the provisions of these third party lenders’ legal documents used to govern and regulate their practices and communication with You.
iv. Email and Telemarketing
Your PII can be used for direct and indirect communication, including but not limited to telemarketing calls, assistance calls and credit product and service offers via the telephone number You have provided in the online form. Either we or third party lenders and marketers can use this number even though it is listed in any corporate, state, or federal Do-Not-Contact registry, suppression lists or the like. Since Your submitting of the information via online form is determined as an attempt to make a purchase or receive a service, the processing and application of Your request is performed according to the provisions of Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the “ATSR”). According to ATSR, even if Your telephone number is listed in FTC Do-Not-Call List, we are authorized to contact You upon Your given consent using telemarketing. Since Your inquiry to third party marketers and request for the service on the Website are also considered as a an attempt to make a purchase, according to ATSR these third party marketers are also authorized to contact You using telemarketing.
v. The Means to Collect Non-Personally Identifiable Information
These are small unique files assigned by a Website server to the users of this Website when these users make visit and perform activity on the Website (such as linking and clicking). Once installed on the user’s computer, these cookies collect the information about the user’s online behavior, browsing and user experience details, and send it to us or third parties authorized to collect this information from You. Cookies are used to enable user’s recognition, to analyze user’s preferences and adjust the services provided online according to the collected information. Additionally, these small files are able to detect fraudulent activity and prevent security breach.
Cookies are of different size and length (temporary or permanent ones). Session or temporary cookies are used for a single operation on the Website and erased shortly after the user exits browser or website. Permanent or persistent cookies are stored longer and survive the exit from webpage or browser. You can manually manage Your cookies preference in Your browser’s options and delete these small files if You consider it is necessary. More about cookies and cookies management on http://www.cookiecentral.com/ and http://www.aboutads.info.
Pixel tags and web beacons
These small images are placed on webpages and emails to monitor the activity of users. These features record the activity of the user during the session, thus, enabling further adjustment and improvement of marketing campaigns and promotions. More about beacons here: www.webopedia.com/TERM/W/Web_beacon.html.
Log files are collected files, which store the information on IP address, browser type, Internet service provider, platform type, date/time stamp, click records, referring and exiting pages etc. These files are also used to provide adjustment and improve user experience online and on websites in particular.
II. Privacy Management
In order to perform effective privacy management, we establish different practices on how we use Your information. Apart from the techniques to upgrade the level of Your online experience and the use of our service and the Website, we provide the options to limit the volume of information You share or eliminate Your information from our records upon Your request.
If You do not want Your NPII information to be collected, stored, shared or used, You should exit the Website immediately. Still, it is possible that cookies, beacons and other tracing files are automatically installed. In this case, You can use Your browser preferences to delete the existing cookies manually, to adjust the default settings and request notification for cookies, accept or reject cookies, remove cookies from Your computer.
Another way to opt out from tracking Your online behavior by third party marketers is to unsubscribe from their email lists via corresponding links.
III. PII Security
Your PII is collected, stored, shared and used under strict compliance with security and privacy protection regulations and practices. We shield Your PII and all the activity performed on the Website from any attempt of malicious activity, fraud, unauthorized use and other jeopardizing online practices. We exploit electronic, physical and managerial security measures to provide overall protection for the users of the Website and Website assets to avoid loss, misuse, unauthorized modification or deformation of any information.
Nevertheless, no entity can unconditionally guarantee that Your online experience will be 100% secured and no violation and/or illegal intervention can take place. The owner of the Website cannot take responsibility for any illegal activity, security breach, stolen or modified information, which happen beyond the owner’s control. In order to guarantee protection from any malicious activity from the outside, You can request to erase Your data from any listing or database You consider insecure. At the same time, third party marketers who receive Your PII are contractually responsible for protecting Your information to the extent reasonably possible. We provide verification on the diligence of our partners via multiple means and regulatory contracts and check their information security policies. In case any violation takes place, applicable laws and regulations are applied to manage the situation and eliminate possible negative consequences.
IV. Information Collection from Children
We and third party marketers we contract with reserve the right to discontinue the provisions of electronic documentation, notifications and other forms of e-communication. In this case, the concerning users may be provided with prior notification of the case of termination in accordance with the provisions state in the policies and terms, regulating business relationship between the parts, as well as other applicable laws and regulations. The hard copies of the documents and records originated in the electronic form are not necessary to be produced and/or stored for the purpose of facilitation and expense reduction. All electronic records, disclosures and documents are to be destroyed according to the routine schedule and procedural practices as it is determined by regulatory requirements. Any of such electronic records can be considered and recognized as a legitimate evidence to validate rights, agreements and obligations, related to the parties bounded by the provisions of these e-documents or pursuant to these records. The time for validation, legal force and providing of such e-communication may differ.
VI. Links to Third Party Websites
The Website contains the links to third part websites, may contain the links to the websites of third party marketers. Since it works as a matching service, it may connect the users of the Website to third party lenders via links. The privacy of the information provided by the users on external websites are subject to the regulations stated on these sites and has nothing to do with this Website. Additionally, these third parties have their own privacy policies and regulative documents on their websites, and it is highly recommended to review these legal documents and disclosures individually prior to sharing any PII on their websites.
VII. Notifications for the Residents of Different States
We strictly follow the regulations and codes, both federal and state. The way PII can be used is regulated in states differently. Some state regulations require the party, which collects personal information, to disclose the complete information on how and in what periods the collected information will be shared and what other parties it will be transmitted to (individually and exclusively). Additionally, it may be required to disclose what types of personal information will be shared and in what manner it is supposed to be used by these third parties. In case the user of the Website is the resident of the state, where specific regulations are in force, we recommend to contact us directly using the contacts we provide on the Website to get all the necessary information in details. In this case, each request will be processed individually. We reserve the right to deny the processing of such request if the enquiry was sent from the user who legally reside in the state where such specific regulations are not in force.
VIII. Modifications and Changes
IX. Inquiries and Complaints
The users of the Website are within their rights to modify, amend and withdraw their PII collected on the Website. In case it is necessary, the user who decides to make changes to their own information should contact us via https://www.cashsmartohio.com/contact/ or other contact details stated on the Website and provide inquiry regarding the modifications to be made. Similarly, if any user of the Website has any complaint regarding the operation on the Website and/or any of its service, this user should use the stated contact details and provide the details of complaint. We will review all requests and complaints in the shortest time possible and reply as soon as we can.
Responsible Lending Policy
We are not a loan providing service, nor do we represent or endorse any lender. But we are working hard to provide you with access to reliable lenders and match you with the lenders who can offer you loan products according to the information you submit in our online form.
We put maximum efforts to ensure that all the lenders in our network are legitimate loan providers adhering to federal, state and local laws, fair and responsible lending practices and the best practices in the industry.
We understand that personal loan industry can be puzzling, as it is regulated in many states heavily and differently. For this reason, we provide you with the necessary information and educational material on the industry to answer your questions regarding personal loans in the USA. In this section we’ll provide the basic information regarding the major laws and acts that secure and protect consumers from unfair practices. We encourage you go through this information and read the basics on [How It Works], [FAQ] and [Rates and Fees] pages to understand your credit options better and make only smart and reasonable credit decisions.
Fair Debt Collection Practices Act
We strictly insist that our lenders follow the guidelines put in place by the Fair Debt Collection Practices Act. We are not a lender, so we will never make any attempt to collect a debt from you. However, our lenders have the right to use all lawful means available to them to collect your debt if your loan is unpaid. They must follow the guidelines of the Fair Debt Collection Practices Act when doing so. These are some of major actions deemed as violations:
- Using any harmful, oppressive, foul or harassing language or tactics in order to collect debt;
- Attempting to contact debtors before 9 a.m. or after 8 p.m. in their local time zones;
- Using deception, falsifying information or misrepresenting a company in order to collect a debt;
- Threaten criminal charges or any legal action when such legal action is not warranted.
Any lender within our network found to be in violation of these guidelines will be immediately removed from our network and reported to law enforcement.
Fair Lending Act
The purpose of the Fair Lending Act is to ensure that all consumers have equal access to credit despite their age, race, creed, gender, religion or other non-financial factor. The Act ensures that consumers are not discriminated against and that they have access to the loan and other forms of consumer credit as long as these consumers can meet the legal and financial guidelines associated with obtaining such credit. If you feel that you are a victim of discrimination, please contact the Equal Opportunity and Fair Lending Office of your local Consumer Financial Protection Bureau.
Truth in Lending Act
The Truth in Lending Act was established to ensure that consumers have all of the information about an offer of credit available to them in writing before they take any responsibility and e-sign any contract or decide to extend any credit. Lenders are required to disclose information about the rates, fees, interest and terms associated with loans before they provide any credit to any consumer. Each state has its individual regulations regarding online personal lending, and lenders are required to ensure that all offers are in accordance with these regulations.
Many states have implemented their own regulations for online personal lending industry in an effort to protect consumers. Some of the things individual states regulate include the maximum loan amounts, fees and interest, the number of rollovers that are available and more. The general information about the regulations in specific states can be found in our [Rates and Fees] section of this website. You can find the links to the governmental websites with detailed explanation on personal loan regulations and up-to-date rate limits in different states.