Privacy Policy

We value your privacy. Below details how we respect privacy when we deal with personal information collected by our organization. If you have any questions regarding this policy or privacy practices at finEQUITY.org, please submit your comments directly to hello+policies@finequity.org or call at +1 (646) 760-6655

This Privacy Policy describes how finEQUITY.org (referred to as “finEQUITY,” “we,” us,” or “our”) collects, uses, and discloses your personal information. This Privacy Policy applies to www.finequity.org and variations using the domain of finequity.org (collectively, our “website”), our mobile application, in-person events, and any communications we may send to you. The words “user,” “you,” and “your” mean users of this website or our other services. To the extent permitted by applicable law, you consent to the use of your personal information as described in this Privacy Policy each time you visit our website or use our services.

CATEGORIES OF INFORMATION WE COLLECT ONLINE

We collect information when you interact with us online, in person, or on a mobile device, for example, when you visit our website, mobile tools or resources, contact us, send us a text message or make a donation online. We may collect the following categories of information from or about you:

  • Information you provide to us: We collect the information you provide when you choose to contact us, submit an application through us, make payments to us, make a donation, or submit an online or mobile form (this includes customer support interactions, completed questionnaires, surveys, participation in user research or other feedback written or oral communication). This may include personally identifying information, such as your name, form of identification, email, address, phone number, birth date, geographic location, credit score, payment information, income, debt, employment history, information about your incarceration history, your government issue ID or passport, and other financial information necessary to process your request. We may also collect and store information that you provide to us about other people. By submitting information about someone other than yourself, you represent that you are authorized to provide us with that person’s information for the purposes identified in this Privacy Policy and/or in connection with the Service. Disclosure of this information is voluntary; however, if you choose not to provide the requested information, you may be unable to access some of our services, for example, the soft inquiry or access to loan through our partner. We may also aggregate or de-identify your personal information so that it can no longer be used to identify you. We may share this aggregate or de-identified information with third parties, and we or such third parties may use aggregate or de-identified information for testing, research, analysis, and product development.

  • Information about your use of our website and mobile application: finEQUITY employs third-party services, such as Google Analytics, to passively collect general user information so we can calculate how many visitors come to our website or mobile application, how they find us and how they interact with our services while there. We use this information to help us make the website and mobile application more responsive to your needs. Such information may include IP address, location information, type of device, platform-related information, and browsing history.

  • Messages and phone calls: We may also retain any messages you send through the Service, customer service correspondence (via telephone, chat, text, email or otherwise), and may collect information you provide in User Content you post to the Service. Calls to finEQUITY or to third-parties through finEQUITY by you or to you may be recorded or monitored for quality assurance, customer service, training purposes.

  • Information from third-party sources with your consent: We may receive information about you from publicly and commercially available sources, as permitted by law and with your consent, which we may combine with other information we receive from or about you. For example, we will ask your permission to conduct a soft credit inquiry to support the financial coaching services we offer to you. 

INFORMATION THAT IS COLLECTED AUTOMATICALLY

In addition to the information you provide to us directly, we may automatically collect information about your use of the Service, as described below.

  • Log file information. Log file information is automatically reported by your browser each time you access the Service. When you use our Service, our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.

  • Location information. When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, features and/or products made available via the Service.

  • Cookies and other technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, beacons, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, deliver tailored advertising, and improve the products and services we provide. You can choose to accept or decline certain cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the Services.

    1. Cookies. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser or stores information or settings on your device. Cookies let us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. Our Service may use HTTP cookies, HTML5 cookies and other types of local storage (such as browser-based or plugin-based local storage).

    2. Clear gifs/web beacons. When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened, which links are clicked by recipients, and whether our emails are forwarded. The information allows for more accurate reporting and improvement of the Service.

    3. Web analytics. We may use third-party Web analytics services on our Service, such as those of Google Analytics. These service providers use the technology described above to help us analyze how users use the Service. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

    4. Third-Party Ad Targeting. We sometimes use the above technologies for interest-based advertising, which may be based on your device or browser’s signals received across websites or applications, and over time. To opt out of tracking , please click here.

We may use this information in a number of ways, including: (a) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) to provide custom, personalized content and information; (c) to provide our Service and monitor its effectiveness, including on or through our affiliates and/or other third party service providers; (d) to monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in and; (g) to deliver advertising to you.

HOW WE USE INFORMATION WE COLLECT

Generally speaking, we use personal information to communicate with you, to inform you of programs and services that may be of interest, to provide, improve, and develop our services, and to protect us and our users. finEQUITY collects and processes your personal information for the following purposes:

  • Communicating with you: We may use your personal information to communicate with you, process your requests, applications or donations, send you payment reminders, and to inform you about our policies and terms. If you participate in our programs, you agree that all communications from finEQUITY relating to your use of the website and participation in our programs may be provided or made available to you electronically via the e-mail address you provide us or via the website. You may withdraw your consent to receive communications electronically by contacting finEQUITY in the manner described below. However, if you withdraw your consent to receive communications electronically from finEQUITY (other than for optional promotional emails described below), finEQUITY will not have the ability to fully participate in our programs that require email communication. The withdrawal of your consent will not affect the legal validity and enforceability of electronic communications provided by finEQUITY prior to the time you withdraw your consent. It is your responsibility to keep finEQUITY informed of any changes in your email address so that you don’t miss important communications. finEQUITY will not disclose your email address to other borrowers or lenders unless you opt-into their service through an application process. finEQUITY may also communicate with you through physical mail, and, with your prior consent, by text message at any telephone number that you have provided to us, and in a manner as described further below; if you do not want to receive text messages from finEQUITY, please contact us at hello+privacy@finequity.org or as described below in the SMS Notification section.

  • Informing you about programs or services that may be of interest: We may use your personal information to send you finEQUITY promotional communications; for example, we may periodically send you emails or text messages about new finEQUITY programs and services, content or services that may be of interest to you, or upcoming events. If you do not wish to receive such emails in the future, you can contact us at hello+privacy@finequity.org to opt-out of receiving such communications. Note that if you decide to opt-out, we may still send you non-promotional communications, such as communications about your existing loan, donation, or online account.

  • Providing, improving, and developing our services: We use your information to help us provide, improve, and develop our services, which is necessary for us to pursue our legitimate interest, provide you with quality services, and to further finEQUITY’s mission. This includes using aggregate, non-personally identifiable information for purposes such as data analysis, research, and education. The information we receive allows us to tailor our service offerings, improve your online experience, educate and inform you, and customize the content and layout of our pages.

  • Promoting safety and security: We use your information to pursue our legitimate interest in helping verify accounts and user activity, as well as in promoting safety and security, such as by monitoring fraud, investigating suspicious or potentially illegal activity or violations of our terms or policies, protecting our rights, or pursuing available remedies.

  • SMS Notifications: finEQUITY may also communicate with you, with your prior consent, through text message to inform you about your participation in our programs, or to notify you about programs or services that might be of interest for you. You can cancel the SMS service at any time. Just text message us the word “STOP”, or email us athello+privacy@finequity.org. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at hello+privacy@finequity.org. Carriers are not liable for delayed or undelivered messages. As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive up to 10 to 50 messages per month. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

THIRD PARTIES TO WHOM WE DISCLOSE INFORMATION

finEQUITY will not rent or sell your personal information to third parties. We may disclose personal information we collect online to the following categories of third parties:

  • Vendors and Service Providers: We use third-party companies to help us provide our services to you, for example, to process payments and transactions, operate our mobile application, interface with credit bureaus or financial institutions, communicate with you, and send finEQUITY promotional materials. Some of these companies are given access to some or all of the information you provide to us. All such access shall be under appropriate confidentiality agreements and limited to use to provide services to finEQUITY to help finEQUITY further its mission. Personal information will not be shared with these third parties for their own marketing purposes. finEQUITY may specifically collect and use your personal information on behalf of IRC-CEO.org (finEQUITY’s “Loan Partner”) to facilitate the provision of loan services. Federal law requires our Partner to provide notice to certain consumers to explain what personal information they collect, how they share it, and how consumers may limit our Partner’s sharing of the information. The privacy practices of our  Partner are subject to their privacy notices, which we strongly suggest you review.  finEQUITY is not responsible for our Partner’s information practices or privacy notices.

  • Credit Bureaus: finEQUITY may disclose some or all of the information you provide us to credit bureaus (i.e. Equifax, Experian, and TransUnion) to provide our services and help you build a credit history. This may include your name, address, and information about your loan balance and payments. The information provided to credit bureaus may be used in consumer credit reports. Credit bureaus are regulated by federal, state, and local laws, rules, and regulations intended to protect consumers’ privacy, including the Fair Credit Reporting Act, and credit bureaus may only use and disclose personal information subject to applicable legal restrictions and requirements.

  • Other Website and Mobile Application Users: finEQUITY may publicly display and disclose aggregate, non-personally identifiable, anonymous loan information for educational, informational or promotional purposes in furtherance of finEQUITY’s mission. finEQUITY will never include any personally identifying information without your express consent.

  • Marketing partners. We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with. Marketing partners also include those entities who maintain a link to our Services on their site.

  • Legal Compliance and Security: In certain special cases, we may disclose your personal information when we have reason to believe that disclosing this information is necessary to identify or contact you or bring legal action against someone who may be causing injury to you, finEQUITY, or someone else. We may disclose your personal information when we believe the law requires it, in response to any demand by law enforcement authorities in connection with a criminal investigation, in response to civil or administrative authorities in connection with a pending civil case, governmental authorities or administrative investigation, or in connection with an investigation conducted by finEQUITY.

  • Consent: We may share personal information with your consent, including to third-party credit reporting agencies when we request a credit report on your behalf or to any potential third party source of funding that you elect to use through the Services.

  • Affiliates: We may share information with a future parent organization or future subsidiary of finEQUITY.org.

COMPANIES OTHER THAN finEQUITY

Our website and mobile application may contain links to or the ability for you to access third-party websites, products, and services (e.g. HappyMango.com, IRC-CEO, Facebook, Twitter, ec). We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their products and services contain. This Privacy Policy applies solely to information collected by finEQUITY. We encourage you to read the privacy policies of any third parties before proceeding to use their websites, products, or services.

If you use finEQUITY web features that are integrated with third-party websites or services (e.g. Twitter and Facebook) to share information about your activity (e.g. information about recently completed loan payments or distributions and whether you “like” finEQUITY), finEQUITY will share this information with the third-party website or service and additional information, if any, that you choose to provide to finEQUITY to use these features (for example, your username for the third party website or service). If you use interactive features on finEQUITY to indicate that you “recommend” a particular feature or listing on finEQUITY, that information will be collected, may be displayed on the website, and may be shared on any applicable third-party websites and services to which you have authorized such information sharing.

CHILDREN

We do not knowingly collect information directly from children under the age of 13. To access and use our services under our program requirements, you have to be over the age of 18. In certain limited circumstances (e.g., when an individual is applying for a Petition for an Immigrant Relative and the relative is a minor), we may collect the first and last name of a minor under the age of 13, but we collect that information from the minor’s parent or legal guardian. If you believe that we have any information from a child under age 13 without consent from a parent or legal guardian, please contact us at hello+privacy@finequity.org.

WEBSITE VISITORS LIVING OR LOCATED OUTSIDE OF THE UNITED STATES; OUR DATA LOCATION

The Site is intended for use in and by individuals located in the United States. finEQUITY is headquartered in the USA. Personal information collected from you, including via the Site, will be transferred to finEQUITY in the United States where this Site is hosted, and may also be stored in finEQUITY’s data centers located outside of the United States. You hereby consent to the transfer of your personal information to the United States or to other locations where finEQUITY may store and manage information in connection with the Site. Please do not use the Site if you do not agree to the transfer and processing of your personal information by finEQUITY as described in this privacy policy or if it is illegal to do so in your home country. 

YOUR RIGHTS

Depending on where you live, you may have the right to:

  • See what data we have about you, if any, and access the data

  • Change/correct any data we have about you.

  • Have us delete any data we have about you.

  • Receive your personal information in a structured and standard format.

  • Express concerns you have about our use of your data.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. finEQUITY does not share personal information with third parties for their own marketing purposes.

You may contact us at hello+privacy@finequity.org to exercise your rights. We will respond to your request in a reasonable timeframe, and in any event in less than one month or 45 days, depending on the law applicable where you live. You may also lodge a complaint with the competent data protection authority regarding the processing of your personal information. To protect the privacy and the security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.

SECURITY

finEQUITY is committed to protecting the privacy and confidentiality of your personal information. We have implemented reasonable physical, technological, and organizational safeguards and security measures designed to protect against the loss, misuse, or unauthorized access or disclosure of your personal information under our control. Please be aware that, despite our efforts, no security measures are perfect or impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law. We will retain your personal information for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. 

CHANGES TO THIS PRIVACY POLICY

We may periodically change this Privacy Policy. Any non-material changes will take effect immediately upon posting of an updated Privacy Policy. For any significant changes to the Privacy Policy, we will provide you with a prominent notice of such changes. To the extent permitted by applicable law, your continued use of our website and services after the effective date of such notice means that you accept the revised Privacy Policy.