This Privacy Notice applies to your interaction with DisasterLoanAid.com (“DLA”) or any of related individuals or entities (collectively “DLA,” “we,” “us,” “our”). This Privacy Notice is effective as of 4/23/2020.
- CATEGORIES OF PI WE COLLECT AND HOW WE USE IT
We collect information you provide DLA when you interact with us directly or through a third-party, such as when you register for our Service, sign up for our mailing list, or otherwise communicate with us. We use all of the information we collect to operate, maintain, improve and provide to you the features and functionality of the Service and to create new features. The types of PI we collect depends on the products and Service you request and use. Below is a list of categories of PI we collect and have collected and disclosed for a business purpose, the sources from which the information was collected, the business purposes for which the information was collected, and categories of third parties with whom the information was shared in the last 12 months.
- This information may include a real name, alias, postal address, telephone number, email address or other communication information
- We use this information to verify your identity, facilitate transactions, to advertise to you, and to create your account. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices).
- We share information in this category with third-party service providers, originating banks, parties to a company transaction, and legally interested parties as described below.
- This information may include payment and bank information, credit card number, debit card number.
- Only information received from you.
- We use this financial information to process your transaction, and improve our Service. If you register as a borrower, we will use financial information about you to facilitate your loan request. We use this financial information for creditworthiness if you are a borrower, assess risks related to your transaction, and to help investors determine whether to commit to or purchase your loan.
- We share information in this category with third-party service providers, other third parties, originating banks, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described below.
- This information may include information about your business, such as legal business name and company practice name, and other information about your company or practice such as fax, telephone number, website, relevant email addresses, physical address, business-related licensing information such as a license number, federal tax identification or social security number, and business or practice bank account information. This information may be collected, for example, when you become part of a DLA business program, apply for a business-related loan, or apply for our Service as self-employed.
- We use this information for processing your application, facilitating transactions, for verification purposes, and to improve or expand our Service. We may also use this information to contact the practice if there is a problem completing a transaction or to discuss a refund, or a problem with a patient’s application. We may also use this information to enable our financial services partners to implement automatic payments.
- We share information in this category with DLA companies, third-party service providers, other third parties, originating banks, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.
SHARING OF INFORMATION
We may share person information (PI) about you in the instances described below.
We may share PI about you with:
- Third-Party Service Providers. Third-party vendors and other service providers that perform services on our behalf, such as operational support services, data processors and companies that help us market our own products and third-party products that we believe may be of interest to you. We work with a number of service providers who support our operations, including but not limited to electronic payment service providers and customer support call centers. We share information with these third parties to process the transactions you initiate or to perform other specific services on our behalf, such as collections or identity verification, creating and providing targeted advertisements, or providing marketing analytics services. Our service providers are legally required to keep PI private and secure and adhere to applicable state and federal laws and regulations and to only use the PI we provide in order to provide such services to us;
- Other Third Parties. Third parties at your request, such as financial services companies, lenders, insurance companies, retailers, membership clubs, or other consumer service providers. For example, if we are unable to offer you a loan, you may be given the option to allow us to share PI about you to third parties who may be interested in offering you a loan. We will share this information at your direction, which may be provided through interaction with or selection of a third-party offer presented on one of our websites;
- Credit Bureaus. We may share PI about you with credit bureaus to meet our credit reporting obligations;
- Parties to a Company Transaction. Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
We may also share information with others in an aggregated or otherwise de-identified or anonymized form that does not reasonably identify you directly as an individual.
- THIRD-PARTY TRACKING AND ONLINE ADVERTISING
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our websites or Service on your browser or mobile device, login to your account on our Service, or otherwise engage with us. We may share a unique identifier, like a user ID or hashed email address, with Google to facilitate the Service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at https://www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
HOW WE PROTECT AND STORE INFORMATION ABOUT YOU
Keeping information safe: As a financial services company, DLA understands that the information collected and shared with us by our borrowers, investors and business partners contains sensitive data. We take our role in safeguarding information about you seriously. We maintain a security program that draws on industry standards and best practices. We take a defensive, in-depth approach to implementing physical, administrative, and technical safeguards to protect information against unauthorized access or misuse. The safeguards include preventive, detective, and corrective controls, for example: physical safeguards like access badges and a video monitoring system; administrative safeguards like an employee security training program, employment background checks, and access controls; and technical safeguards like perimeter security, encryption, two-factor authentication, and regular security monitoring with layered and complementary controls. In addition, we use:
- Encryption & website certificates. Encryption protects the information you share with us from the moment it leaves your computer until it reaches our systems. Look for the secure locked padlock on your browser, which signifies a secure web connection. Consult your web browser documentation for more information.
- Passwords. You should never share your password with anyone. Your password is not known to any DLA employee or third party, and we will never ask for your password by phone or email. If you ever receive a communication claiming to be from DLA that asks for your password, you should immediately report it by contacting us at firstname.lastname@example.org
We do not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected PI from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at privacy@DLA.com.
LINKS TO OTHER WEBSITES AND SERVICES
The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on third-party websites.
YOUR CALIFORNIA PRIVACY RIGHTS
In California, you may opt-in to have PI about you shared with third parties for their direct marketing purposes. Consistent with California Civil Code Section 1798.83, if you no longer wish to have PI about you shared with third parties for their direct marketing purposes, please email us at privacy@DLA.com to request to not have your information shared in this manner.
The California Consumer Privacy Act or CCPA provides for additional rights for California consumers. Your rights under the CCPA include: a) the right to request that a business that collects a consumer’s PI disclose to that consumer the categories and specific pieces of PI the business has collected; b) the right to request that a business delete certain PI about the consumer which the business has collected from the consumer; c) the right to request that a business that collects PI about the consumer disclose to the consumer the categories of PI it has collected about that consumer, the categories of sources from which the PI is collected, the business or commercial purpose for collecting or selling PI, the categories of third parties with whom the business shares PI, and the specific pieces of PI it has collected about that consumer; d) the right to request that a business that sells the consumer’s PI, or that discloses it for a business purpose, disclose to that consumer the categories of PI that the business sold or disclosed; and e) the right to opt-out of the sale of PI.
These rights do not apply to PI collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (GLBA), including certain information relating to financial services we offer such as information about financial accounts, credit information, or information collected as part of the application process. Most of the information we collect is subject to GLBA and therefore not subject to the CCPA and the rights described above, However, to the extent your information is subject to the CCPA, you may exercise your rights under the CCPA by submitting the form at https://www.DLA.com/californiaprivacy. You will be asked to provide certain identifying information to verify your consumer request, such as your name, social security number, date of birth, email address, and your mailing address. You will be required to verify your email address. You may also send an email to californiaprivacy@DLA.com for more information. If you have a loan with us, access to your loan information is conveniently available by logging into your account.
DLA does not sell your PI as described in the CCPA.
DLA does not sell PI of minors as described in the CCPA.
You have a right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the CCPA. Also, you may designate an authorized agent to make a request under the CCPA on your behalf.
HOW TO CONTACT US
If you have a privacy or data use concern, please contact us first at privacy@DLA.com.