Privacy Policy
Effective Date: August 17, 2022
This Privacy Policy is meant to help you understand how Creditly Corporation (“CreditGenie,” “we,” “us,” or “our”) collects, secures, uses, and discloses your personal information in connection with our services. This Privacy Policy applies to personal information we collect from you and from third parties, both online and offline.
This Privacy Policy applies to the use of creditgenie.com, a CreditGenie-owned and controlled web site (“Site”), Credit Genie's mobile applications, products, and services (collectively, the “Services”), or when you otherwise interact with us. By interacting with us, or otherwise providing us with personal information, you agree to the terms and conditions of this Privacy Policy and any updates we make. Our Terms and Conditions of Use for the Site (“Terms of Use”) take precedent over any provision conflicting with this Privacy Policy.
Changes to Our Privacy Policy
We update our Privacy Policy regularly; this version is effective as of the date indicated above. We reserve the right to change this Privacy Policy at any time without notice to you. If there are any material changes in the way we treat your personal information, CreditGenie will send a notice to the primary email address on your account or place a prominent notice on our platform before the change goes into effect. CreditGenie will also promptly make an updated Privacy Policy publicly available on our Sites. Changes will be effective as soon as the revised Privacy Policy is posted unless otherwise stated.
1. HOW AND WHY WE COLLECT INFORMATION ABOUT YOU
1.1. Information You Provide Us
1.1.1. Personal Information
We collect personal information from you to help you use our services. When we say, “personal information,” we mean information that specifically identifies you.
We collect this information in a number of ways. You are asked to provide personal information to us when you use our Site, authorize us to obtain information about you from a third party, communicate with us about our services, and provide feedback to us. Examples of personal information include:
- Name
- Address
- Telephone Number
- Email Address
- Household Composition
- Income Information
- Expense Information
- Credit Information
Please note that any information, photos, contact information, email addresses, videos, and other content you post to your profile on Credit Genie's Community site is available to everyone using that service. The information you share is available to everyone accessing that service, and may be read, collected or used by others for any purpose, including sending you unsolicited messages.
We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on a Site or on or through any of its features. If we learn we have collected or received personal information from a person under 18, we will close the account and delete all personal information relating to that account. If you believe we might have any information from or about a person under 18, please contact us via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new.
1.1.2. Information Collected
CreditGenie collects information about your computer or mobile device to improve and evaluate your use of our Site and our services. We may gather data such as your browser type, operating system, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device.
1.1.3. Cookie Information
CreditGenie uses “cookies” and similar tools to track your use of the Site when you use our services. We collect information such as the types of service used, and number of users we receive daily. Our web servers automatically log information about your computer or mobile device, but we do not use this information to identify you personally.
We and our vendors use cookies to improve our service, our Site and to provide more convenient and relevant experiences to you. Cookies are designed to transfer a small amount of data to your browser by servers within a domain. That data is only read by designated servers within that domain. It functions as your computer's identification card and enables CreditGenie to improve your experience by securely maintaining your authenticated session and preferences.
A web beacon embeds a small transparent gif image in a web page or email used to track when the page or email has been viewed. A similar device may be used where a product, service or functionality sends data to a server when a set of user-initiated events occur such as clicking a button on the Site or in an email. This is similar to a cookie – it tracks your visit and the data is only read by the server that receives the data. However, it differs because it is not browser-based, may not function as an ID card and does not store any data on your computer.
Most Internet browsers are set up to accept cookies automatically. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. For some web pages requiring an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages.
1.1.4 Contacting Us By Telephone
If you communicate with us by telephone, we may monitor or record the call. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of CreditGenie's services.
1.2. Information Third Parties Provide About You
As a company engaged in helping consumers manage their unsecured personal debt, CreditGenie receives data from consumer reporting agencies. We partner with these agencies to assess your current debt load and to prevent fraud and identity theft.
Information we collect in these reports includes, but is not limited to:
- Information about open and closed credit accounts, including the date opened, the date closed (if applicable), the latest reported monthly balance and monthly payment
- Information about credit inquiries
- Information about late payments and collection actions occurring on open and closed credit accounts
- Information regarding public records of bankruptcy, judgements, tax liens, and other payment statuses
- The credit score produced by the credit bureau providing the report
- Information about your bank account transaction history, assets, and account balances
Additionally, we may supplement the personal information you submit to us with information from third-party sources. For example, we ask you to connect your bank account with CreditGenie using a third-party service to verify your income and ascertain if you qualify for our advance services.
Finally, we contract with third parties to place advertisements for our services on web sites that are not our own. We place these advertisements where we think they are likely to be most relevant. These advertisements on third-party web sites allow us to track responses to our advertisements. We use this information to track the performance of our advertising and marketing campaigns by using tools like cookies, web beacons and similar technologies. We use these tools to collect and store information about the user's visit, page visits and duration, and the specific advertisement or link that the user clicked on to visit the site.
2. USE OF YOUR PERSONAL INFORMATION
2.1 How We Use Your Personal Information
We use your personal information to provide you with information or services you request, to inform you about other information and services we think will be of interest to you, to facilitate your use and our operation of our Site, and to improve our services. We do not forget about you once you have received our services — CreditGenie will continue to provide services to propel your financial future.
Here are some examples of ways in which we use your personal information:
- Creating and maintaining your login information on our Site
- Contacting you regarding issues with your online profile
- Sending you information about new services
- Generating a personal debt score
Part of how we use your personal information includes marketing other CreditGenie products and Services to you. You may choose to opt out of allowing Credit Genie to use your Customer Information for marketing purposes. If you have chosen to opt out of allowing Credit Genie to use your Customer Information for marketing purposes, Credit Genie may still need to keep your Customer Information to ensure that our systems reflect your preferences.
2.2. Aggregate Data
Aggregate data means records which have been stripped of information potentially identifying customers, landing pages or end-users, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information will be kept anonymous in aggregated data. Aggregate data is used to help us understand consumer trends, needs, interests, and preferences so we can improve our products and services.
CreditGenie also collects demographic information, and may include:
- Age
- Date of Birth
- Income
- Geographic Area
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share information, including personal information, with third parties in a variety of ways, such as:
- Third parties acting on our behalf: We may share information about you with service providers, partners or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Policy and our Terms of Use. This includes things like designing or operating features, helping us research and test feature improvements, identifying offers or personalized recommendations, performing analytics and marketing our services. These third parties are acting on our behalf so while they may have access to your information, including things like your credit reports and scores, they are required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them.
- Non-affiliated third-party creditors: We may share information with creditors with whom you already have a relationship in connection with providing our services.
- Affiliated third party partners: We may share information about you with affiliated third party partners, such as non-profit credit counseling organizations. Non-profit credit counselors do not work for CreditGenie, but instead work directly with you the consumer to provide financial education and impartial advice on debt management. In order to facilitate your interaction with a credit counselor, CreditGenie may share information about you with the counselor. CreditGenie works exclusively with high-quality, trusted credit counseling agencies that are members of the National Foundation for Credit Counseling. CreditGenie receives no incentive or bonus payment from a credit counselor should you choose to enroll in a debt management plan.
- Legal reasons: We reserve the right to transfer or disclose information about you to third parties for certain legal purposes. With your consent: There may also be other limited contexts in which we share specific types of personal information with your express consent.
4. PROTECTING YOUR PERSONAL INFORMATION
4.1. What We Do to Protect Your Personal Information
CreditGenie takes seriously the privacy and security of consumers' personal information. We maintain administrative, technical and physical safeguards designed to protect your information's security, confidentiality and integrity.
We protect personal information you provide online in connection with registering yourself as a user of our Site. Access to your own personal information is available through a unique user ID and password selected by you. This password is encrypted while transmitted from your browser to our servers and while stored on our systems. To protect the security of your personal information, never share your password to anyone. Please notify us immediately if you believe your password has been compromised.
Whenever we save your personal information, it's stored on servers and in facilities that only selected CreditGenie personnel and our contractors have access to. We encrypt all data that you submit through the Site during transmission using Transport Layer Security (TLS) in order to prevent unauthorized parties from viewing such information. Remember – all information you submit to us by email is not secure, so please do not send sensitive information in any email to CreditGenie.
4.2. Steps You Can Take to Help Us Keep Your Information Safe
There are many steps you can take to help us keep your information safe. First and foremost, choose complex, independent passwords for each website and service with which you maintain an account or profile. This helps keep any breach of any of your accounts or profiles isolated to one service.
CreditGenie urges your caution when using public computers or networks, like at a coffee shop or library. To best protect your personal information and login information, do not use such computers to access your sensitive accounts, and if you must, ensure that you log out of your account entirely.
When either you or we update information in your account, such as the status of a loan application, we typically send you notice of these changes via email or text message. In recent years, individuals, businesses and even governments have seen a rise in “phishing” attacks. Phishing occurs when someone attempts to obtain your password or other sensitive information. Scammers often do this by impersonating a trusted user or offering a compelling reason to open a malicious email attachment, click on a link or give over information. We never ask for your sensitive personal information, such as password, over email or other unsecure methods or through any site not under the CreditGenie.com domain. Please notify us via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new if you ever receive suspicious correspondence from us.
5. Summary of Personal Information Sharing
| FACTS | WHAT DOES CREDITGENIE DO WITH YOUR PERSONAL INFORMATION? |
|---|---|
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include
|
| How? | All financial companies need to share customer's personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer's personal information; the reasons CreditGenie chooses to share; and whether you can limit this sharing. |
| Reason we can share this information | Does CreditGenie share? | Can this sharing be limited? |
|---|---|---|
| For our everyday business purposes—such as to process your application or maintain your online profile, as well as to improve our products and services | Yes | No |
| For our marketing purposes—to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | Yes | No |
| For our affiliates' everyday business purposes -information about your transactions and experiences | No – CreditGenie has no affiliates | We don't share |
| For our affiliates' everyday business purposes -information about your creditworthiness | No – CreditGenie has no affiliates | We don't share |
| For affiliates to market to you | No – CreditGenie has no affiliates | We don't share |
| For nonaffiliates to market to you | No | We don't share |
| To Limit Our Sharing | We don't share your personal information in any way that gives you a legal right to limit our sharing. However, we still want to allow you to opt out of our marketing emails if you prefer not to receive them. If you wish to do so, contact us via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new |
| Questions? | Contact us via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new |
| Who We Are | |
|---|---|
| Who is providing this notice? | Creditly Corporation |
| What we do | |
|---|---|
| How does Creditly Corporation protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does Creditly Corporation collect my personal information? | We collect your personal information, for example, when you
|
| Why can't I limit all sharing? | Federal law gives you the right to limit only
|
| Definitions | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and non-financial companies.
|
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and non-financial companies.
|
| Joint Marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
|
6. Your Rights as a California Resident
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to that law. Effective January 1, 2020, the CCPA allows California residents, upon a verifiable consumer request, to request the following:
- For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may view a comprehensive list of the categories of information we have shared with corresponding categories of third parties within the last 12 months at https://www.creditgenie.com/vendor-sharing/
- The right to know the categories and specific pieces of personal information we collect, use and disclose about you, the categories of sources from which we collected your personal information, our purposes for collecting your personal information, the categories of your personal information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information. The business purpose for which we have collected your information.
- The right to request that we delete the personal information we have collected from you or maintain about you, subject to certain legal exceptions, for example, when the personal information is necessary to complete a transaction for which we collected it or to comply with a legal obligation.
- The right to opt out of our sale(s) of your personal information. Please be advised that we do not currently sell personal information. This opt-out, however, would apply to the extent we began to engage in sales of personal information governed by the CCPA.
- The right not to receive discriminatory treatmentfor the exercise of the privacy rights conferred by the CCPA.
To limit our sharing once your creditgenie.com account has been created, contact us via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new.
For example, CreditGenie has relationships with various service providers and partners whose services are available to you from our services, from other websites that are linked to our services, or in connection with our services. These partners offer services we think our customers may find useful or will improve our services. Those providers may require you to provide personal information to use their services. Personal information collected on other websites is not covered by this Privacy Policy. Unless stated otherwise, the policies of those partners will govern the collection, use, disclosure and security of your personal information.
At this time, we do not respond to “do not track” signals or similar mechanisms – where a visitor to our Site requests that we disable the collection of information about the visitor's online activities, including navigation around our Site and the service. We may also permit third parties to collect aggregate usage information on our Site, and they may also not respond to “do not track” signals.
7. Changing and Updating Your Personal Information
We want to provide you with the resources you need to keep your information with us correct and up-to-date. If you need to change any other information in your profile, please contact our customer service via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new.
8. Complaints and Concerns
CreditGenie takes your privacy seriously and maintains a process to respond to your concerns regarding violations of this policy. If you believe that we have not complied with this policy in regards to your personal information or have questions regarding your privacy with us, please contact us via a help request at the following link: https://creditgenie.zendesk.com/hc/en-us/requests/new. If you are reporting non-compliance with this Privacy Policy, please describe the issue in as much detail as possible without disclosing any sensitive information about you or third parties. We will respond to your request by email within 7-10 business days.
9. Retention of Personal Information
The Bank Secrecy Act and other federal statutes require CreditGenie to maintain certain records for a minimum of five years. CreditGenie may keep records of any transactions a customer enters on the CreditGenie App or Website for a minimum of six years from the end of CreditGenie's relationship with the customer. CreditGenie may keep other information about a customer only to the extent necessary to comply with applicable laws and to further legitimate business needs.