Online Privacy Policy

Effective: January 1, 2019
Last Updated: January 1, 2023

This Online Privacy Policy (“Privacy Policy”) applies to the website located at credit9.com, credit9 mobile applications, and any other websites or applications associated with credit9 affiliates, subsidiaries or products that direct the viewer or user to this Privacy Policy (collectively “credit9 Services” or “Our Services”). In this Privacy Policy, the terms “Credit9” or “we” or “us” or “our” refers to credit9 and its respective subsidiaries and affiliated companies. The term “your device" refers to any computer, tablet, smart phone or other device you are using to access our websites or to operate the credit9 mobile applications. Websites that are owned and operated by credit9 may contain links to websites that are owned and operated by other companies. This Privacy Policy does not apply to websites and services that are owned and operated by third parties.

The Privacy Policy includes, but is not limited to:

Please read this Policy carefully and contact us if you have any questions.

By using any of the Credit9 Services, you consent to the terms of the updated Privacy Policy.

Information We Collect through Our Services and How We Collect It

We collect both personally identifiable information and non-personally identifiable information through Our Services.

We collect personal information that can identify a visitor or user, including, but not limited to, name, address, email address, state of residence, phone number, amount of unsecured debt, the visitor’s interactions with Our Services, how the visitor heard about us, and other information that the visitor chooses to provide to us, but only when the visitor voluntarily provide it.

The non-personal information we collect includes: the visitor’s browser type, device type, and operating system; area(s) of Our Services visited; date and time of access; host or Internet service provider (ISP) information; and identity of the referring site (any site from which the visitor accessed Our Services).

How We Use Your Information

We may use the information we collect about you through Our Services in order to, but not limited to:

  • provide you with Our Services;
  • improve, renew or modify our products and services;
  • provide customer service;
  • enroll visitors or users who desire lending/debt relief services;
  • provide information about Our Services or required notices;
  • deliver marketing communications or promotional materials that may be of interest to you and to assist us in determining relevant advertising;
  • personalize your experience when using Our Services;
  • protect against, identify and prevent fraud, infringement and other potential misuse; and
  • comply with and enforce applicable laws and relevant industry standards and policies

How We Collect, Use and Protect Social Security Numbers

Credit9 may collect Social Security numbers (“SSNs”) in the course of our business. We strive to protect the confidentiality and security of SSNs in our possession, custody or control by: (i) limiting access to SSNs and (ii) maintaining reasonable safeguards to protect against the loss, misuse or unlawful disclosure of SSNs.

How We Use Data Collection Tools

When you interact with our Services, we may obtain certain information using data collection tools, such as cookies, web beacons, and other technologies. We do not link the information gathered by these data collection tools to any personally identifiable information you submit while using Our Services.

Cookies.

Credit9 may place electronic “cookies” in the browser files of your computer or mobile device when you access Our Services. Cookies are small pieces of text sent by your web browser by a website you visit. Cookies may be either “persistent” cookies or “session” cookies. Persistent cookies are also known as a stored or permanent cookie because they remain on your device until you delete them or they expire. Session cookies do not stay on your device after you close your browser.

Our Services use both persistent and session cookies. Persistent cookies enable us to track and target the interests of our users to enhance the experience of Our Services. Session cookies make it easier for you to navigate Our Services.

We use cookies to improve the functionality of Our Services and to track information about how the website is used in order to continually improve it and tailor it to user preferences. In particular, we may use the information we obtain from your use of our cookies to: (i) recognize your computer when you visit the website; (ii) track you as you navigate Our Services; (iii) improve the usability of Our Services; (iv) analyze the use of Our Services; and (v) to personalize the website for the visitor, including targeting advertisements.

Web beacons and other technologies.

In addition to cookies, we may also use other tools to collect non-personally identifiable data about your use of Our Services, such as through the use of “web beacons” (also known as an Internet tag, pixel tag or clear GIF) and analyzing “click stream” data. Web beacons link web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. “Click stream” data is the virtual trail you leave behind while browsing the Internet and viewing our web sites. We use web beacons and click stream data to gather data about visits to Our Services. The data may include information about your device, such as your IP address, but does not identify you by name.

Your Choices.

Web browsers are usually set to automatically accept cookies. However, you can typically prevent cookies or selectively accept cookies by adjusting the preferences in the “Help” section of your browser. You can also delete cookies which have already been placed on your device.

If cookies are not accepted, there may be some features of Our Services that will not be available and some may not display properly, which may lead to a less smooth or less personalized browsing experience. Blocking cookies will also prevent web beacons from tracking your activity and prevent us from collecting certain other information, such as your IP address, but we still obtain a record of a visit.

For further general information on cookies and more detailed advice on how to disable and enable them, please go to http://www.allaboutcookies.org.

Third Party Analytics.

We use automated third-party analytics services, such as Google Analytics or Facebook Pixels, to evaluate use of Our Services and to help us improve Our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your name and contact information with these third-party analytics providers; however, the information generated by the cookies about your use of the Site (including your IP address) may be transmitted to and stored by these providers on servers in the United States. These service providers may use this information to evaluate your use of the website, compile reports on website activity for website operators and provide other services relating to website activity and internet usage.

Third Party Advertising Networks.

We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash cookies and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this Privacy Policy. We may provide these third-party advertisers with information about you.

To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance www.aboutads.info and the Network Advertising Initiative www.networkadvertising.org. Please note that if you choose to opt out, you will continue to see ads on our Site, but they will not be based on how you browse and shop.

How We Respond to Do Not Track Signals

How do we respond to Internet browser Do Not Track (“DNT”) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party websites or online services?

We do not currently respond to web browser “Do Not Track” because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer's online activities over time and across different websites when a consumer uses Credit9 Services?

No.

For more information about Do Not Track, please visit www.allaboutdnt.com.

Security of Internet Communications and Data

We take reasonable security precautions to secure the personally identifiable information that you choose to provide against the loss, misuse, alteration, or unauthorized access of such information. Unfortunately, no method of transmitting or storing data can be guaranteed to be secure, and we do not assume any responsibility for any harm, loss or damage you may experience from transmission of information by or to Credit9 over the Internet.

If you believe that the security of any account you might have with us has been compromised, please contact us as provided in the “Contact Us” section below.

Children’s Privacy

Our Services are not directed to individuals under the age of thirteen (13), and Credit9 does not seek or knowingly collect personal information from children under the age of 13. Credit9 requests that children under the age of 13 not disclose or provide any personal information through Our Services. If you believe that we have received information from a child under the age of 13, please contact us at our email or mailing address listed in the “Contact Us” section below. If we learn that we have received information directly from a child who is under the age of 13, we will take appropriate action in accordance with applicable law. To learn more about the Children’s Online Privacy Protect Act (COPPA), please visit the Federal Trade Commission's website at https://www.ftc.gov/.

TCPA Consent & Privacy

Notwithstanding any current or prior election to opt in or opt out of receiving telemarketing calls or SMS messages (including text messages) from us, our agents, representatives, affiliates, or anyone calling on our behalf, you expressly consent to be contacted by us, our agents, representatives, affiliates, or anyone calling on our behalf for any and all purposes arising out of or relating to your loan and/or account, at any telephone number, or physical or electronic address you provide or at which you may be reached. You agree we may contact you in any way, including SMS messages (including text messages), calls using prerecorded messages or artificial voice, and calls and messages delivered using auto telephone dialing system or an automatic texting system. Automated messages may be played when the telephone is answered, whether by you or someone else. In the event that an agent or representative calls, he or she may also leave a message on your answering machine, voice mail, or send one via text. You consent to receive SMS messages (including text messages), calls and messages (including prerecorded and artificial voice and autodialed) from us, our agents, representatives, affiliates or anyone calling on our behalf at the specific number(s) you have provided to us, or numbers we can reasonably associate with your account (through skip trace, caller ID capture or other means), with information or questions about your application, loan and/or account. You certify, warrant and represent that the telephone numbers that you have provided to us are your contact numbers. You represent that you are permitted to receive calls at each of the telephone numbers you have provided to us. You agree to promptly alert us whenever you stop using a particular telephone number. Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You also agree that we may contact you by e-mail, using any email address you have provided to us or that you provide to us in the future. We may listen to and/or record phone calls between you and our representatives without notice to you as permitted by applicable law. For example, we listen to and record calls for quality monitoring purposes.

Notice to California Residents

In response to a California law, we will automatically treat individuals with California addresses or telephone numbers (when disclosed to us) as if you requested us to not share your information with nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us.

California’s “Shine The Light” law permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.

In compliance with the California Consumer Privacy Act (“CCPA”), please see the “Supplemental Privacy Notice to California Residents” below.

Notice to Vermont Residents

In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we not share your information with nonaffiliated third parties, and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you. 

Notice to Nevada Residents

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing to [email protected]. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: [email protected].

Governing Law

Unless otherwise indicated herein, Our Services are governed and operated in accordance with the laws of the United States and are intended for the use of residents of the United States.

Business Transfers

In the event that all or a part of Credit9 is merged, sold or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), your personally identifiable information will likely be among the assets transferred. We may, in our sole discretion, notify you via email and/or with a prominent notice on our website for 30 days of any such change in ownership or control of your personal information. You may have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy. 

Changes to this Privacy Policy

This Privacy Policy may change at any time and from time to time to reflect changing legal, regulatory or operational requirements. If we make material changes, we will post the updated policy on this page and change the “Last Revised” date at the top of this webpage. Any amendments or modifications to this Online Privacy Policy will become effective immediately upon posting. Your continued use of any of Our Services following the posting of an updated version of this Privacy Policy will constitute your acceptance of the updated Policy. If you do not agree with the revised Online Privacy Policy, please discontinue use of any of Our Services.

Contact Us

If you have a question or would like to access and correct personal information you have submitted to us through Our Services, please send a letter or email to the address below with your question or requesting to see your information.

Please address requests to:

Credit9
Attention: Privacy Inquiries
18200 Von Karman Avenue, 6th Floor
Irvine, CA 92612
Telephone: 1-800-291-0172
E-mail: [email protected]


SUPPLEMENTAL PRIVACY NOTICE TO CALIFORNIA RESIDENTS

Effective: January 1, 2020
Last Updated: January 1, 2020

This section of the Online Privacy Policy provides additional information solely for California residents, as required under the California Consumer Privacy Act of 2018 (“CCPA”). As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information described below.

The information below applies to personal information as defined in the CCPA collected both online and offline. For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household.

Personal information does not include publicly available information, information that has been de-identified, aggregated consumer information, and information excluded from the CCPA's scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

Categories of Personal Information We Collect & Disclose

In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure. Some personal information included in the categories may overlap with other categories.

Category Examples Collected Disclosed for a business purpose(s)

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

YES

YES

B. Personal information categories as described in the California Customer Records statute – Cal. Civ. Code § 1798.80(e)

A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

YES

YES

C. Characteristics of protected classifications under California law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, genetic information, and veteran or military status.

YES

YES

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

YES

E. Biometric Information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO for customers

YES for certain employees

NO for customers

YES for certain employees

F. Internet or other similar network activity

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

YES

G. Geolocation Data

Physical location or movements.

YES

YES

H. Sensory Data

Audio, electronic, visual, thermal, olfactory, or similar information, including call recordings and photographs.

YES

YES

I. Professional or Employment-Related Information

Current or past employment history, qualifications, licensing, and disciplinary record.

YES

YES

J. Non-Public Education information

Education records directly related to a student maintained by an educational agency or institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes and student disciplinary records.

NO

NO

K. Inferences drawn from other personal information

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

YES

Categories of Sources from Which Personal Information Is Collected

We may collect the categories of personal information listed above from the following categories of sources:

  • Information directly or indirectly from you or your agent, including, but not limited to, information from applications, worksheets, questionnaires or other documents (such as name, address, driver’s license number, Social Security number and amount of unsecured debt);
  • Information directly and indirectly from activity on Our Services, including, but not limited to, submissions through our website portal or website usage details collected automatically;
  • Information about your transactions with us, our affiliates or others (such as products or services purchased, claims made, account balances and payment history);
  • Information from Americor subsidiaries or affiliates;
  • Information from third parties, including, but not limited to, service providers, advertising and marketing affiliates, credit reporting agencies, credit and charge card companies;
  • Information from public sources (such as information you submit in a public forum, a blog, chat room, or social network).

Business or Commercial Purposes for Using Personal Information

We may use or disclose the personal information we collect for one or more of the following “business purposes” or “commercial purposes” (as defined in the CCPA):

  • Auditing Interactions with Consumers.  For example: monitoring traffic to our Websites, counting ad impressions, and auditing legal and regulatory compliance;
  • Security. For example, maintaining the safety, security, and integrity of our Website, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations;
  • Debugging/Repair. For example, identifying and repairing errors in our Websites’ functionality;
  • Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling;
  • Performing Services. For example, creating, maintaining, customizing and securing your account with us, processing your purchases, transactions, and payments, hosting our Websites, fulfilling subscription orders, managing databases, performing analyses, billing, and marketing services such as managing promotions and contests;
  • Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our Website, products, and Services;
  • Quality and Safety Maintenance and Verification.  For example, improving, upgrading or enhancing our products, Services or Websites, and verifying the quality or safety of our Websites or Services;
  • Other Commercial Purposes.  For example, as described to you when collecting your Personal Information such as for promotions or contests, or to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred.

Categories of Third Parties Personal Information Is Shared With

We may disclose personal information to the following categories of third parties for a “business purpose” or “commercial purpose” (as defined in the CCPA):

  • Americor affiliates and subsidiaries;
  • Vendors and service providers;
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you;
  • Government agencies as required by laws and regulations.
  • An entity involved in the sale of our business.

Sale of Personal Information

In the past 12 months, we have not “sold” personal information subject to the CCPA, including personal information of minors under the age of 16. For purposes of this Notice, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration. As noted elsewhere in this Notice, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information. However, we support consumer choice regarding use of consumers’ personal information and for this reason, refer you to the “Right to Opt-out of Sales” section immediately below for more information on how to register your choice with us  with regard to future uses of your personal information.

Your CCPA Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights under the CCPA and explains how to exercise those rights.  Subject to certain exceptions, California consumers have the right to make the following requests:

Right to Opt-out of Sales:  We are not selling personal information of California residents. Further, we will not sell personal information if we have actual knowledge that the consumer is less than 16 years of age, unless we receive affirmative authorization (“opt-in”) from either the consumer between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. 

If you would like to register your choice with regard to future uses of your personal information, please visit our CCPA Request form by clicking here, and we will register your details for this purpose. 

Right to Access:  You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  Once we receive and confirm your verifiable request, we will disclose to you:

  • the categories of personal information we collected about you;
  • the categories of sources of personal information we collected about you;
  • our business or commercial purposes for collecting or selling that personal information;
  • the categories of third parties with whom we have disclosed or shared that personal information; and
  • the specific pieces of personal information we collected from you.

Right to Delete:  You have the right to request that we delete and direct any service providers that have received that personal information to delete, the personal information that we have collected and retained, subject to certain exceptions, including if we need the personal information for a reason related to our business, such as:

  • providing goods or services to you;
  • detecting and resolving issues related to security or functionality;
  • complying with legal obligations;
  • conducting research in the public interest;
  • exercising free speech or ensuring another’s exercise of free speech; or
  • using the information for internal purposes that a consumer might reasonably expect. 

Once we receive and confirm your verifiable request, we will delete (and, if applicable, direct our service providers to delete) your personal information from our records, unless an exemption applies.

Submitting Requests:  You can submit an access request and/or deletion request by either:

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or other information needed to verify your identity depending on the sensitivity of the Personal Information in question.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Response Timing and Format: We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.

We will deliver our written response by email if one is attached to your account with us. If no email is on file, we will deliver our written response by first class mail to the mailing address attached to your account with us.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.  We will not discriminate against you for exercising any of your CCPA rights or impose unreasonable requirements on financial incentives offered to California consumers related to your personal information. We may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of your personal information.

Changes to this Notice

This Notice may change at any time and from time to time to reflect changing legal, regulatory or operational requirements. If we make material changes, we will post the updated notice on this page and change the “Last Revised” date at the top. Any amendments or modifications to this Notice will become effective immediately upon posting. Your continued use of any of Our Services following the posting of an updated version of this Notice will constitute your acceptance of the updated Notice. If you do not agree with the revised Notice, please discontinue use of any of Our Services.

Submit a Request

FOR CALIFORNIA RESIDENTS ONLY

As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information under the California Consumer Privacy Act ("CCPA") as described in our Privacy Policy and the Supplemental Privacy Notice to California Residents.

If you would like to submit a request under the CCPA, please complete and submit the form below.

Please note that while we will comply with any applicable obligations under the CCPA, we may not have an obligation to, or may not be able to, honor your request.

In certain circumstances, we may require additional information if we are unable to verify your request based on the information you have provided. The personal information submitted in connection with this request will be used for the purpose of processing your request.