PROTECTING YOUR PERSONAL INFORMATION
Borrower Information We Collect. We or our affiliates collect only relevant information about borrowers in order to establish and maintain your account and services as the law allows or requires us to collect. We or our affiliates may collect personal and financial information about you which is Nonpublic (borrower information). The borrower information collected varies depending on the accounts and services you request and use. We collect information about you from the following sources:
Application Information. We or our affiliates retain personal information we receive from you on any application you provide to us or our affiliates for loans or other related loan services. Application information includes: your name, address, e-mail address, social security number, birth date, phone number, drivers license number, employment, financial status, credit history and other loan related information.
You’re Transactions. We or our affiliates retain your transaction information any time you perform a transaction on one of your loan accounts, transactions through online banking, online loan payer, including over the phone. Transaction information includes: your account number, the date, the amount, the location of the transaction and other loan related information.
Credit Reports. When we or our affiliates evaluate your application for a loan, we or our affiliates may request a credit report about you from a consumer reporting agency. We or our affiliates retain the personal and credit history information about you and we/they may use it to evaluate your future account service requests.
Online. We or our affiliates obtain information online when you visit our website, www.freshstartloans.com. This includes retaining information you provide to us on an online application, through online loan payer, or related online loan information you provide, or by e-mail.
Our Sharing of Borrower Information. In order to provide financial services to you from the network of automobile lenders and car dealerships with whom we affiliate, we share certain information about you with our affiliates and third party service providers. However, we limit any information sharing to the extent necessary to establish and/or service your account or offer new services to you. If we share your information, in addition to doing so to support the loan application process, it is with the goal of bringing you quality services, more choices, and greater convenience. Information we may have about former borrowers is shared or disclosed only if it is required to enforce or administer an account or as required by law.
Sharing Information with Affiliates. We may share information from time to time with our affiliates; such affiliates may include companies that provide financial services, including financial planning, securities, and insurance products as well as auto-lending services and other loan related services. We may share personal information (name, address, account number, and phone number) and account information (type of accounts, account balances, and transaction history) with our affiliates so they can serve you more efficiently. Any affiliates of ours must maintain the same privacy standards as us.
Sharing Information with Third Party Service Providers. In order for us to conduct our operations, we need to share information with our service providers, including: loan service providers, credit reporting agencies, and service providers with whom we have marketing agreements. These service providers act on our behalf and have agreed in writing to keep the member information we provide to them confidential. We share the following categories of information to third party service providers depending on the specific services provided:
• Personal information (name, address, account number, and phone number)
• Account information (type of accounts, account balances, transaction history)
• Transaction information (dates, amounts, locations and type of transaction)
Other than for purposes of providing your information to affiliates as part of our marketing and promotion for the purposes of support in your loan application process, we do not sell borrower information nor share your account numbers with independent third party marketers offering their products and services.
Sharing Information as Legally Required or Permitted. We may share any borrower information of yours in response to a lawful request issued by a court, government agency, or regulatory authority or as permitted by law in order to administer or enforce your account. We may also share our experience information about you with credit bureaus. Our reporting to credit bureaus is governed by the Fair Credit Reporting Act, which affords you the right to make sure that your credit bureau reports are accurate.
Our Confidentiality and Security Safeguards. We maintain strict policies and security controls to assure that borrower information in our computer systems and files is protected. Our employees are permitted access to borrower information that they may need to perform their jobs, to provide service to you, and as necessary to conduct a transaction or respond to your inquiries. All employees are trained to respect borrower privacy. No one except our employees has access to the Fresh Start Auto Loan Affiliates, LLC computer system and records storage. Fresh Start Auto Loan Affiliates, LLC has established internal security controls, including physical, electronic and procedural safeguards to protect the information you provide us and the information we collect about you. We will continue to review our internal security controls to safeguard your borrower information as we employ new technology in the future.
Online Privacy Protections. At our website, www.freshstartloans.com, you may apply for loans and loan related services from the network of automobile lenders and car dealerships with whom we affiliate and you may communicate with us via e-mail. To protect the information you provide us online, we use multiple levels of security. The application information we accept online, our online bill payer service relies on industry standard Secure Sockets Layer (SSL) encryption to secure your transaction information and communication. Generally, our e-mails are not secure. However, if we ask you to e-mail us information other than your name, address, e-mail address, and phone number, it will be obtained using a secure (SSL encryption) e-mail form.
Protecting Children’s Information Privacy. Our online financial services are not designed for or directed toward children. We do not knowingly solicit or collect data from children and we do not knowingly market to children online. We recognize that protecting children’s identities and online privacy is important and that responsibility rests with us and with parents.
PROTECTING YOUR PERSONAL INFORMATION