(effective August 7th, 2015)
This notice of our privacy practices is provided to you on behalf of Headway Capital, LLC (“Headway Capital”) and its parent company, CNU Online Holdings, LLC, and their respective family of companies, and all of their respective subsidiaries and affiliates, (hereafter collectively referred to as the “Headway Capital Related Companies,” “we,” “our,” or “us”). The Headway Capital Related Companies include, but are not limited to: Headway Capital and all of its respective subsidiaries and affiliates, including those that operate under the trade names CashNetUSA. “You” or “Your” means you as a participant in or as a user of the products and/or services offered by a Headway Capital Related Company.
All information transmitted, printed or otherwise submitted to us shall be deemed to be our property and we shall be free to use such information for any lawful purpose described herein, and for other purposes as required or permitted by law.
Please read this policy carefully. This Policy provides important information about the way we collect, share, and protect your information and governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Policy (including, without limitation, both mobile and online versions of our site), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a site and that posts a link to this Policy regardless of how you access or use them, whether via personal computers, mobile devices or otherwise regardless of how you access or use the site, whether via personal computers, mobile devices or otherwise. This Policy applies to anyone who applies for or uses our products or services, or visits our websites, including, but not limited to, current and former customers. A customer relationship begins when you obtain a financial product or service from us. A customer relationship terminates when you pay off a transaction in full. This Policy does not govern the data practices of third parties that may interact with our site. To the extent we provide you notice on our site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.Information We Collect
We collect business and personal information that you submit through our online application, including:
- Business name and address
- Personal name, address, date of birth, SSN, employment information, and residence rental or ownership information
- Business legal entity type, industry, years in business, EIN/TIN, number of employees, and annual gross revenue
- Telephone number
- E-mail address
- Business bank account information
(collectively, “Your Information”). Our primary goal in collecting Your Information is to provide you with efficient, accurate, and customized financial products and services. Your Information also helps us personalize and improve your customer experience with us. We collect and/or track the following types of information:
- Information we receive from you on applications or other forms, such as transaction documents, sales documents, online forms, e-mails, registration forms, surveys, or other documents or submissions related to the products and services we provide, including your name, your business name, address, telephone number, social security number, email address, employment information, and bank account information and information about your income.
- Information about your transactions with us, our affiliates, or others, such as your account history, transaction balances, payment history, overdraft history, parties to transactions, and your reasons for doing business with us;
- Information we receive from third parties, such as other lenders, regarding your credit worthiness and credit history, and to verify the existence and good-standing of your business;
- Information we obtain to verify representations made by you, such as your legal entity type and employee identification number and/or taxpayer identification number;
- Information obtained from specialized marketing information firms;
- Information obtained from Web page http headers (home server domain names, IP address, type of client computer, and type of Web browser);
- Information, user specific or aggregate, we receive from our web pages recording visitor’s access;
- Information you provide when you contact our customer service department; and
- Information you provide to us when you communicate with us via email.
We use your information to:
- Enhance our product and service offerings;
- Further other business purposes through data analysis, audits, enhancing our website, and identifying usage trends;
- Assess customer demographics, payment history, and preferences;
- Process your registration with the site, including verifying your information is active and valid;
- Comply with all reporting and other legal requirements;
- Process payments and update account records;
- Personalize your online experience or to improve our website by customizing the content and/or layout based on feedback and information that we receive from you; and
The Headway Capital Related Company delivering this Policy to you (the “Headway Capital Provider”) may share or sell Your Information with any other Headway Capital Related Company (collectively, its “Affiliated Companies”) and with other companies with whom any Headway Capital Related Company does business (“Non-Affiliated Third Parties”) as permitted by law and as described in this Policy. These Affiliated Companies and Non-Affiliated Third Parties may be: (1) financial service providers, such as mortgage bankers, mortgage brokers, consumer lenders, small business lenders, small loan lenders, tax refund anticipation loan lenders, loan brokers, deferred deposit providers, check cashers, supervised lenders, delayed deposit providers, deferred presentment providers, collection agencies, consumer reporting agencies, banks, credit card providers, debit card providers, store valued card providers, insurance agencies, bill payment agencies, ATM providers, pawn and title pawn providers, automobile dealers, automobile financing providers, automobile leasing providers, money transfer and remittance providers, sellers and remitters of money orders, insurance services providers, and financial service provider holding companies, or agents, contractors, or representatives of any of the foregoing; (2) non-financial companies, such as retailers, tax preparers, payroll service providers, advertisers, marketing companies, lead generators, advertisers on our websites, companies or individuals that do industry-related research, surveys or polls, automobile dealers, and any person who offers a non-financial product or service, and holding companies, or agents, contractors, or representatives of any of the foregoing; and (3) other businesses, such as non-profit organizations, trade associations, and industry analysts or agents, contractors, or representatives of any of the foregoing.
Affiliated Companies and Non-Affiliated Third Parties may use Your Information for any legal purpose, including, but not limited to, developing and promoting new or joint products, improving existing products and services, and contacting you to offer products and services that may be of interest to you. We may also disclose Your Information, as described above, to companies who perform services on our behalf or to other financial institutions with which we have joint marketing agreements.
The Headway Capital Provider may also disclose Your Information to Affiliated Companies and Non-Affiliated Third Parties that provide services to us or you (collectively, “Service Providers”). We contract with Service Providers to perform certain functions on our behalf. Examples include database providers who assist in business and identity verification, credit scoring companies, magazine publishers, retailers, and direct marketers. Service Providers’ access is limited only to the business and personal data needed to perform their functions, and only for the purpose of performing those functions, and they are prohibited from using or disclosing Your Information for other purposes.
Third-party analytics and other Service Providers such as Google Analytics may set and access their own Tracking Technologies on your personal computer, laptop, tablet, mobile phone or other device and they may otherwise collect or have access to information about you. These Service Providers use the technology described above to help us analyze how users use the website. We are not responsible for those third party technologies or activities arising out of them. However, some third parties may offer you certain choices regarding their practices. For example, to learn about opting out of Google Analytics, please click here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
We also may share Your Information if it becomes necessary for compliance with the law or to protect the rights, property, or safety of our websites, our users, or third parties. We reserve the right to release such personal data to law enforcement or other governmental officials as we, in our sole and absolute discretion, deem necessary to comply with the law. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. In addition, we reserve the right to use and disclose Your Information that is not in individually identifiable form as we deem appropriate, in our sole discretion.Automatic Information and Cookies
In addition to any business or personally identifiable information or other information that you choose to submit to us via our site, we and our Service Providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our site.
This Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the site, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our site;
- the areas within our site that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day, among other information.
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the site. A web browser is usually set to accept cookies automatically but can be changed to decline them. The Help section of the toolbar on most web browsers will tell you how to prevent your browser from accepting new cookies, how to have the web browser notify you when you receive a new cookie or how to disable cookies altogether. In most cases, a visitor may refuse a cookie and still fully navigate our websites. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s web site www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our site may not function properly, and that when you revisit our site your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the site, to monitor how users navigate the site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party Service Provider, is active only while you are connected to the site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
We may use Tracking Technologies for a variety of purposes, including:
Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our site and third-party sites based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements or content that has been delivered to you.
There may be other Tracking Technologies now and later devised and used by us in connection with the site. Further, third parties may use Tracking Technologies with our site and this may involve the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our site and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms. If you would like more information on self-regulatory programs that permit you to exercise choice, see the Section entitled “Interest-Based Advertising” below.Correcting or Changing the Personal Information We Have Collected
The accuracy, currency, and completeness of the personal information we collect is very important to us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. If you wish to review, amend, correct, update, or delete the business or personal information that we have collected about you, please let us know by contacting us at: 866.698.8494. We reserve the right not to allow access to your information if we believe in good faith that law prohibits such disclosure or if the rights of another individual might be violated. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).
Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your personally identifiable information or change your preferences on the site, information that you remove may persist internally for our administrative purposes.Interest-Based Advertising
We restrict access to Your Information to those employees who need to know that information to provide products or services to you. We maintain commercially reasonable physical, electronic, and procedural safeguards that comply with federal regulations to guard Your Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our site and provide us with your information at your own risk.Our Right to Contact You
We reserve the right to contact you regarding your account status and changes to subscriber agreements, our Policy, or any other policies or agreements relevant to you. By visiting our websites, you understand and agree that we may contact you at the phone number or email address you provide to us through our websites or on your transaction agreements, applications, loan documents or any other document to assist you with your product or to discuss other products and services that a Headway Capital Related Company may provide for you.We Do Not Collect Data from Children
The information and services provided by us or by our affiliates, sponsors, and advertisers, are not intended to be viewed by children (under 18 years old). No information collected from children is knowingly collected or used for any purpose whatsoever, including marketing and promotional purposes, either inside or outside the Headway Capital Related Companies.Transfer of Information to the United States