Last updated and effective as of Aug 7th, 2023.
Our commitment to your privacy
- How we safeguard your information.
- How, what, and why we collect certain information about you.
- How we use your information and with whom we share it.
- How you can access and update this information.
- The choices you can make about how we collect, use, and share your information.
FI Connect maintains industry safeguards, in accordance with applicable federal and state laws and regulations, to keep your Personal Information safe and secure. When we provide Personal Information to financial entities, our affiliates, or third-party service providers, we require that those parties agree to process and keep the information in compliance with applicable privacy laws. The use of your information by our business partners may be subject to that party’s own privacy notice. Unless we are permitted by law, we will not disclose the information we collect about you from consumer or credit reporting agencies, without your consent. For certain online features or services, such as those that may include Personal Information, we require the use of username/password and/or encryption technologies for the protection of your Personal Information. You are responsible for protecting your username, password, and other user account information from disclosure to third parties, and you are restricted from circumventing the use of required encryption technologies. You agree to: (a) immediately notify us at [email protected] OR call us at 866-918-2898 of any unauthorized use of your username, password, and/or user account information, and/or any other breach of security; and (b) make sure that you log out from your user account at the end of each session. While we may provide certain safeguards to protect your confidential information, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.
Your consent to this privacy notice
Types of Information We Collect and Sources
We may collect certain information from you, and third parties we engage may also collect such information for the purpose of, administering and processing your transaction. We do not use your personal or sensitive information for additional purposes that are incompatible with the disclosed purpose for which the information was collected without providing you notice. We do not retain your personal information longer than is reasonably necessary to complete these services.
Information we may collect about you may be collected by from the following sources:
- Applications or other forms we receive from you or your authorized representative (such as name, address, employment information)
- Correspondence you or others send to us
- Information such as account or loan numbers we receive through our Information Channels, i.e. financial institutions, third-party providers.
- Information from consumer or other credit reporting agencies and public records maintained by government entities that we obtain directly from those entities, including your credit worthiness and credit history
- Information we receive from other sources, as permitted by applicable, laws, and regulations
We may collect certain sensitive information from you solely for the purpose of administering and processing your transaction, or to verify a request from you under the California Consumer Privacy Act We do not sell or share your sensitive personal information. The sensitive information we may collect from you may include:
- Social Security Number
- Driver’s License
- State identification
FI Connect does not collect or process sensitive personal information with the purpose of inferring characteristics about a consumer, nor use or disclose sensitive personal information to service providers, contractors or third parties other than to perform the services for which it was obtained.
Use of Collected Information
The information we collect from you is used for one or more of the following business purposes:
- To provide products and services to you or any financial entity or other third party who is obtaining services on your behalf, or in connection with a transaction involving you
- To communicate with you regarding your transaction or our products and services
- To improve our products and services
- To personalize your user experience regarding our information channels
- To verify your identity or determine your creditworthiness.
- To respond to law enforcement requests, court orders, or governmental regulations
FI Connect has collected consumer Personal Information in these categories within the last 12 months.
When Information is Disclosed or Shared
We are permitted by law to disclose your Personal Information to various companies and individuals, without obtaining your permission. Certain laws do not allow you to restrict these disclosures. In the section below entitled, “Your Information Choices,” we share with you how to limit certain disclosures of your Personal Information.
We may disclose personal information to service providers, unaffiliated third parties for a business purpose, and to government agencies and regulatory authorities. FI Connect does not share or sell your Personal Information to any entity.
When we disclose personal information to a service provider or third party for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services required. We disclose personal information for business purposes to the following categories:
- Our affiliates
- Service providers, such as business process outsourcers
- Governmental agencies and regulatory authorities
- Third parties such as credit unions or other finance companies
FI Connect has disclosed Consumer Personal Information with these entities within the last 12 months for the business purposes noted herein.
Your Information Choices
FI Connect may use your Personal Information for the following purposes, which such use cannot be limited by you:
- For our everyday business purposes – to process your transactions, respond to law enforcement or other government authorities regarding an investigation, and subpoenas or court orders
- For our own marketing purposes
- For our affiliates’ everyday business purposes, we may share information about your transaction and experiences
We do not disclose or use your Personal Information in the following circumstances:
- For our affiliates’ everyday business purposes – information about your credit worthiness
- For joint marketing with financial companies
- For our affiliates and non-affiliates to market to you
Updates and Corrections
State Specific Privacy Laws:
California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents certain rights to know what personal information we collect about them and how we collect, disclose and protect their personal information. This information is set forth above in “Types of Information we Collect” and “When Information is Disclosed or Shared.” The CCPA also provides individual California residents with a right to correct their information, opt-out of the sale of personal information, and a right to request that a business delete their personal information subject to certain exemptions under the CCPA. The consumer has the right to limit the use and disclosure of sensitive personal information collected about them and the right of data portability.
Right to Access
CA residents have the right to request that we disclose certain information to you about our collection, use, and disclosure your personal information. If FI Connect has verified the request is coming from you or an authorized party, and you have not made this request more than twice in a 12-month period, and we have confirmed the information collected is subject to the CCPA, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, sharing, or selling your personal information.
- The categories of third parties with whom we share your personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold your personal information, the categories of personal information sold and the categories of third parties to whom personal information was sold.
- If we disclosed your personal information for a business purpose, the categories of personal information disclosed.
We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us, or the security of our systems or networks.
FI Connect does not sell or share your personal information as defined under the CCPA.
Right to Request Deletion
CA residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify a consumer request, we will erase your personal information from our records, unless an exception applies, or de-identify or aggregate the personal information. There may be instances where applicable law and regulatory requirements allow or require us to retain personal information. We may deny a deletion request if it is necessary for us or our service providers to maintain your personal information for any of the reasons set forth in the CCPA.
Most of the personal information FI Connect obtains is subject to the CCPA exemptions for personal information subject to the Gramm-Leach-Bliley Act (“GLBA”) and the Fair Credit Reporting Act (“FCRA”),
Exercising Access, Data Portability, Deletion and Correction Rights
To exercise these rights as described above, please submit a verifiable consumer request to us using our contact information at the top of this policy labeled “Contact Us”.
Right of Non-Discrimination
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price for goods or services or a different level or quality of goods or services.