Effective Date: April 01, 2023
We are committed to protecting your privacy when you provide data to us. This Privacy Policy (this “Policy”) sets out the privacy practices for Apriority Financial, Inc. (“Apriority,” “us” or “we”) with respect to information we obtain from and about you. When you use, access or interact with our Services or Website (which we define in our Terms of Use, accessible here), you are agreeing to our Terms of Use and consenting to how we collect, share and otherwise use information about you as described in this Policy. You also consent to receiving notifications concerning your financial privacy from us electronically.
Please read the information below to learn about how Apriority collects, uses, and shares information in connection with your access and use of our Services. We may make changes to this Policy in the future, so please review the Policy regularly.
1. Personal Data Collected
Personal Data is information that identifies you or others personally, such as your name, address, email address, or phone number. Non-Personal Data is information about you or your household that doesn’t identify you personally, like your gender, income, or what types of financial products you’re interested in.
Sources of Personal Data
(a) Personal Data You Provide to Us
You directly provide Apriority with most of the Personal Data we collect. You may provide Personal Data to us in various ways, such as by completing a user profile, communicating with customer service, submitting feedback or inquiries, providing your email address, and using other forms, features, or means offered through an Apriority website (“Website”). It is your responsibility to provide us with accurate Personal Data, and to provide us with updated Personal Data when it changes.
(b) Personal Data We Automatically Collect
In addition to information you provide to us, we automatically collect certain information about how you access and interact with our Services and Website (“Usage Information”). Such Usage Information includes things like which features you visit or click on, your search history, and the amount of time you spend looking at different parts of our Website. Usage Information is a key part of how we improve your experience on our Website and provide you with more personalized insights and recommendations. Usage Information is automatically collected from you when you visit our Website and engage with content embedded in our Website.
We and our Providers (as defined in Section 2 below) may use various technologies to collect and store Usage Information in connection with our Services. We use cookies, web beacons, browser web storage, and similar technologies to collect information, record your preferences, and track your use of any Apriority Website. Such information could include the operating system, hardware model, internet protocol (“IP”) addresses, application or browser type and version, internet service provider (“ISP”), date/time stamp, clickstream data, and/or unique identifiers associated with your device. We may combine this automatically collected information with other information we collect about you. You may choose to set your web browser to refuse cookies or to alert you when cookies are being used. If you disable cookies, please be aware that some parts of a Website may not function properly.
(c) Information Third Parties Provide About You
Some of our features rely on information about you that we collect from third parties, such our business partners, payment processors, and service providers. We may also work with third parties to supplement the Usage Information and information we collect directly from you so that we can give you more personalized recommendations. This information allows us to improve and personalize your customer experience, and monitor and improve our Website and Services.
Categories of Personal Data
The “Personal Data” collected by Apriority may include:
o Identifiers (name, address, email, phone number, date of birth, last four digits of social security number)
-We use this information to communicate with you, respond to your inquiries and manage our business.
o Your payment information, including, but not limited to, credit and debit card information and bank account number
- We use this information in order to enable you to purchase or subscribe to Apriority’s products and services.
o Credit reports and outstanding financings
-We use this information to compare your loans against loans of our lending partners and Providers and conduct due diligence.
o Internet or other electronic network activity information (IP addresses, browser information, and other information that is not used to identify you)
-We use this information to improve your experience on the Website, personalize your user experience, gather information about the performance of the Website, and improve our Website.
2. With Whom We Share Personal Data
When you select a financing option provided through the Website, you direct Apriority to share information about you or provided by you with lenders and other third parties in our network (collectively, “Providers”) to deliver the Services you request. The Providers that interact with you may retain or use your information whether or not you use their services, and their privacy and information sharing practices are set forth in their respective privacy policies, terms and conditions, and other Provider policies. Pursuant to the contracts between Apriority and its Providers, if you select a Provider through our Services, Apriority may also receive information about you from that Provider. Apriority and its Providers may exchange information about you, your financing terms, and your accounts for the purpose of providing you with information about financial services and products. Apriority may maintain this information to assist with litigation, regulatory request(s), law enforcement requests, internal analytics, marketing purposes, and any other legally permissible purpose.
We do not sell any of your Personal Data. All information you provide us either via a Website, over the phone, or in person is completely confidential. We will not share your Personal Data unless we get your written permission in advance, except in the following situations:
o We may share your data with our law firm(s);
o We may share your data with Providers and partner financial firms (including banks and lenders) in an effort to obtain financing options;
o We may share your information with service providers that perform certain services on our behalf including, but not limited to, unaffiliated third parties for the purpose of obtaining pricing information, credit bureaus, marketing partners, or entities providing business analysis and/or website support;
o We may share your data with a third party during negotiation of or in connection with a corporate business transaction, such as a merger, acquisition, joint venture, financing or sale of company assets, bankruptcy, or receivership;
o We may share your data as we reasonably believe is required by law in response to a subpoena or investigative demand, a court order, a request for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency, and/or to defend against legal claims. In such cases, we may raise or waive any legal objection or right available to us;
o We may disclose your data when we believe disclosure is appropriate in order to investigate or take action regarding actual or suspected illegal activity or other wrongdoing; to protect and defend the rights, property, or safety of the Apriority business, our users, our employees, or others; or to enforce our website terms and conditions or other agreements or policies; and
o We may disclose your data to certain other third parties or publicly with your consent or direction. If you post a comment or review on our Website, the information you provide may be displayed publicly online for others to view.
We may share with third parties information that is not personally identifying, such as aggregated or anonymized data, where not prohibited by law.
3. Retention of Data
We will keep your Personal Data only for as long as reasonably necessary: (1) to fulfill the purposes for which Personal Data is collected as stated herein; (2) for the performance of the contract between you and us, if any; and (3) to comply with legal and statutory obligations. When your Personal Data is no longer reasonably necessary for our purposes, we will destroy, delete or erase that Personal Data or convert it into an anonymous form.
4. Security of Data
We maintain technical physical, electronic, and procedural measures designed to safeguard your information from loss, misuse, unauthorized access, alteration, and disclosure. Your data is stored on our Website which has secure authentication in place. All information provided to our Website is transmitted using SSL (Secure Socket Layer) encryption. SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us.
We work hard to protect you and Apriority from unauthorized access of information we hold by taking the following commercially reasonable measures to ensure your data is maintained on a secure server at all times:
· We use encryption to keep your data private while in transit;
· We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems; and
· We restrict access to personal information to Apriority employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
While no data transmission over the Internet is completely secure, our Website is built with strong security features that strive to continuously protect your information. The insights we gain from maintaining our Services help us detect and block security threats from reaching you. If we detect a security risk that we think you should know about, we’ll notify you and help guide you through steps to stay better protected.
5. Your California Privacy Rights
If you are a resident of the state of California, the following rights are available to you under the California Consumer Privacy Act (“CCPA”).
Right to access
You can request information about how we have collected, used and shared your Personal Data during the past 12 months. You have the right to request that we disclose the categories of Personal Data collected, the categories of sources from which Personal Data is collected, the commercial purpose for collection, the categories of third parties with which we share Personal Data, and the specific pieces of Personal Data that we have about you. You also have the right to request that we provide your Personal Data to you in a readily usable format. If you have submitted a financing request through us, you can access or update your information by contacting our Customer Care Department at support@apriorityfinancial.com.
Right to request deletion
You have the right to request that we delete Personal Data that we collect from you. Note, however, that certain requests to delete Personal Data may be denied if we are required to retain the information as a matter of law, the information is necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumer expectations.
Right to non-discrimination
You have the right not to receive discriminatory treatment by us for exercise of these privacy rights. We do not offer financial incentives related to the provision of data.
Authorized agent
California residents have the right to designate an authorized agent to make these requests on their behalf. We require any authorized agent to have written authorization of any such authority.
Sale of Personal Information
Apriority does not sell your Personal Data.
To exercise any of these rights, please contact us at privacy@apriorityfinancial.com. Note that the CCPA, as amended, requires us to verify the identity of any individual submitting a request to access, modify, or delete personal information before providing a substantive response. Thus, we will ask you to verify your identity when you submit a request, and we may need to request specific information from you to help us confirm your identity. This is another appropriate security measure to ensure that Personal Data is not disclosed to a person who has no right to receive it.
6. Cookies
Our Website may use cookies and other technologies such as web beacons to collect information about your online activities over time to enhance your experience while using our Website. Cookies are pieces of information used for record-keeping purposes by many websites. Use of cookies makes browsing easier by performing functions such as saving your passwords, saving your personal preferences regarding your use of the Website, and preventing you from seeing the same ad repeatedly. Many consider the use of cookies to be an industry standard.
Many browsers accept cookies by default until you change your settings. But most browsers let you remove or reject cookies, including cookies used for interest-based advertising. If you would prefer not to receive cookies, you can follow the instructions in your browser settings to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our Website will not function properly when you view them. If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser:
For Internet Explorer™: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
For Microsoft Edge™: https://support.microsoft.com/help/4027947
For Safari™: https://support.apple.com/en-us/HT201265
For Chrome™: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
For Firefox™: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html
You can also block websites from setting cookies used for interest-based ads by using a browser with privacy features or installing browser plugins and configuring them to block third-party cookies/trackers.
7. Embedded content from other websites
Articles on this Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that Website.
8. Analytics
We may implement and use display advertising including remarketing with Google Analytics to advertise online. These platforms will use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your visits to our Website. These platforms will receive no information about you, your loan information, or anything other than that you visited our Website. There are a number of ways to opt out of having your online activity and device data collected through these services. If you wish to opt out, you can use Google’s Ads Preferences Manager or you can click here for the Google Analytics opt-out browser add-on.
9. Opting Out of Communications
We provide users with the opportunity to opt out of receiving communications from us at any time. Review the following options to not receive future communications.
· For email newsletters, marketing emails, and information you sign up for, you can click on the “Unsubscribe” link included at the bottom of such e-mails and follow the instructions on the web page.
· You can manage your communications preferences by visiting your account profile and selecting which types of monitoring alerts you want to receive.
· You may also have the ability to adjust app- or browser-specific communications settings (e.g., for things like push or browser notifications) within the settings screen of your mobile app or browser.
· You may opt out of our marketing or automated text messages by replying "stop" to any message.
· You can also email privacy@apriorityfinancial.com to be removed from certain communications.
When using one of the above methods your request is processed immediately. As required or allowed by law, even if you opt out of communications, we may continue to contact you for certain important informational messages about your account.
10. Contact Information
If you have any questions about this Policy or if you believe that your Personal Data has been processed or disclosed in violation of this Policy, please contact us by sending an email to privacy@apriorityfinancial.com.
11. Changes to this Privacy Policy
Apriority has the discretion to update this Policy at any time. When we do, we will revise the date at the top of this page. You are encouraged to check this page periodically for changes in order to stay informed about how we strive to protect the information we collect. You acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of modifications.
12. Compliance with Children’s Online Privacy Protection Rule
Our Website and the Services we provide are not intended for individuals under 18 years of age, and we do not knowingly collect Personal Data from individuals under 18. If we learn we have collected or received Personal Data from a person under 18 without verification of parental consent, we will delete the information.