FinancialReliefCenter and Consumer Concierge Privacy Policy

FinancialReliefCenter and Consumer Concierge Privacy Policy

Last Updated: 8/29/2024

Thank you for visiting the FinancialReliefCenter and Consumer Concierge website located at FinancialReliefCenter.org (the "Website"). The Website is an Internet property of FinancialReliefCenter and Consumer Concierge (collectively, "Company," "us," "our" or "we"). We believe in 100% permission-based marketing. All visitors to, or Users of, the Website are referred to, individually, as "User," "you" or "your." Capitalized terms not defined herein shall have the meaning set forth in the FinancialReliefCenter and Consumer Concierge Terms and Conditions (the "Terms").

I. Introduction

We have created this FinancialReliefCenter and Consumer Concierge Privacy Policy (the "Privacy Policy") in order to disclose our information gathering and dissemination practices. In particular, this Privacy Policy will outline the following: (a) your acknowledgement and agreement to be bound by the terms of this Privacy Policy; (b) the means by which changes will be made to this Privacy Policy; (c) your privacy rights including - for all California state residents - your California Privacy Rights; (d) what information we collect and how we use it; (e) to whom we may share the information collected; (f) your choices regarding the sharing of information including, without limitation, your ability to opt-out of having your information shared; and (g) how to review the information collected about you. Please carefully review this Privacy Policy in its entirety. If you do not agree to abide by and be bound by all terms and conditions set forth in this Privacy Policy, you are NOT authorized to access and/or use the Website Offerings in any way.

II. Your Acknowledgement and Agreement

The Website is not intended for use by any individuals under eighteen (18) years of age (or the applicable age of majority if the age of majority in your jurisdiction is greater than eighteen (18) years of age) and/or those individuals who are not legal residents of the United States of America. Canadian residents are not permitted to participate in any Reward Program Offers.  For the avoidance of doubt, if you are a resident of a European Union Member State, you are not permitted to use the Website and/or Website Offerings.  If you are not eighteen (18) years of age or older (or the applicable age of majority if the age of majority in your jurisdiction is greater than eighteen (18) years of age), and/or you are not a valid resident of the United States of America, and/or you do not agree with the terms of this Privacy Policy in its entirety, then you are NOT authorized to access and/or use the Website Offerings in any way.

You agree to the terms and conditions contained in this Privacy Policy, in their entirety, when you: (a) access and/or use the Website and/or various registration forms, web pages and other online media (collectively, "Online Media"); (b) access certain text, images, video, audio and other content and information as made available by: (i) Company (collectively, "Company Content"); and (ii) third-parties including, but not limited to, content that is submitted by, or aggregated from, third-party sources ("Third-Party Content," and together with the Company Content and Member Content, the "Content"); (c) access links to third-party websites and resources ("Third-Party Links"); (d) register to establish a Company account ("Account"); (e) register for, and participate in, any of the drawings, contests, sweepstakes and Reward Program Offers that we may make available on the Website from time-to-time (collectively, the "Promotions"); (f) request information regarding certain products and/or services featured on the Website (collectively, "Services"), as offered by third party service providers, advertisers and marketing partners (collectively, "Partners"); and/or (g) utilize the contact form and/or other functionality as a means to request to be contacted by Company (collectively, "Contact Services," and together with the Website, Content, Third-Party Links and Promotions, the "Website Offerings").

III.  Your California Privacy Rights

Shine the Light.  If you are a resident of the State of California and would like to learn how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: [email protected]; call us at: (844) 435-3969; or send us U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at: [email protected]; call us at: (844) 435-3969; or send us U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.  Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 ("CCPA").  In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information.  Please see our "Privacy Provisions for California Residents" below for a more complete description of your rights under the CCPA as a California State resident.

IV.  Your Nevada Privacy Rights

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any "covered information" that the website operators have collected about the Nevada State residents to any third party data broker(s). Covered information includes a consumer's name, postal and email addresses, telephone number and Social Security Number, and includes the Information described below in the "Types/Categories of Information We May Collect and How We Use It" section. If you are a Nevada State resident and you wish to exercise your right to request that we to stop the sale of your Information to third party data brokers, please submit your request by: (a) clicking on the link "Do Not Sell My Personal Information"; (b) emailing us at: [email protected] with the subject line "Nevada Privacy Rights"; or (c) calling us toll free at: (844) 435-3969. In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the Website that you visited and the email address you registered with. Please allow thirty (30) days for a response.

Privacy Policy Quick Links

Below are links to key sections of our Privacy Policy:

Changes to this Privacy Policy

Types/Categories of Information We May Collect and How We Use It

How We May Disclose and/or Sell Information

Collection and Use of Your Non-Personally Identifiable Information

Privacy Provisions for California Residents

Unsubscribe/Opt-Out

Security

Children's Privacy

Accessing, Modifying and Deleting Your Information

Limitation of Liability

V. Changes to this Privacy Policy

We reserve the right, in our sole discretion, to change, modify, update and/or remove portions of this Privacy Policy at any time, simply by posting such changes to the Website, so we strongly encourage you to review this Privacy Policy periodically.

For the avoidance of doubt, all Privacy Policy changes or modifications will be posted on the Website and shall take effect immediately upon their posting; provided, however, that if the manner in which we use personal information changes, Company will notify Users by: (a) sending the modified policy to our Users via e-mail; and/or (b) any other reasonable means acceptable under applicable state and federal law.  You will have a choice as to whether or not we use your information in this different manner, and we will only use your information in this different manner where you opt-in to such use.

VI. Types/Categories of Information We May Collect and How We Use It

Please see our Privacy Provisions for California Residents below for more details regarding our collection and use of Personally Identifiable Information (as defined below).

·  Information that could reasonably identify a User, such as name, postal address, email address(es), mobile/landline phone number(s), date of birth and gender;

·  Information collected from a User's responses to survey questions, including preferences, products and services of interest, personal attributes such as marital status, home or auto ownership, political affiliation, views on various issues and responses to wellness questions, as further described below;

·  Information collected from our web server log files, including device type(s), User agent data, referring URL(s), and IP address(es);

·  Information collected from our customer support department and fulfillment vendors, including customer support inquiries, Promotion-related claims and emails and, as needed, proof of identification and Promotion completion;

·  Information collected from Cookies (as defined below), including whether a User has previously visited the Website.

·  Information related to a user's consent to receive telemarketing calls, SMS messaging, push notifications, commercial email, and other forms of communication (which may include the creation of a report and session recordation of a user interacting with page(s) that seek to obtain a User's prior express written consent (as defined in the Telephone Consumer Protection Act ("TCPA")) to receive telemarketing and text messages.

·  To carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for purposes of our Arbitration Agreement, and any inquiry specific to prior express written consent under the Telemarketing Sales Rule ("TSR") and/or the TCPA ("TCPA Consent");

We may be required to create, collect, maintain, and/or submit certain information requested and/or required by the government or other regulating authorities, including, without limitation, IRS Forms W-9 and 1099. This information, which may include your taxpayer identification number (collectively, "Sensitive Information"), will not be used, shared, transferred, or sold for any marketing purposes.

We collect and combine your Personally Identifiable Information and Non-Personally Identifiable Information (collectively, "Information") when you: (a) open, preview or click on any e-mail messages that we send on our behalf or on behalf of one of our Partners; (b) register on the Website to participate in any Promotions and/or utilize any other Website Offerings; and/or (c) otherwise provide personal information to us by and through the Website Offerings. For purposes of this Privacy Policy, "Personally Identifiable Information" refers to data collected that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household including, but not limited to, e-mail address, name, postal address, date of birth, gender and/or telephone number. Alternatively, for purposes of this Privacy Policy, "Non-Personally Identifiable Information" refers to data that cannot be used to identify, relate to, describe, associate with, or reasonably link, directly or indirectly, with a particular consumer or household. While the submission of any information is voluntary - and at your complete discretion - such submissions may be required in order to utilize certain Website Offerings, including the Promotions.

As noted above, we may use the collected Information for any legally permissible purpose in our sole discretion including, but not limited to, those explained below. Without limiting the foregoing, we may also use your Information to send you promotional messages regarding various Company products and/or services, as well as third-party products and/or services that we think may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or use any of the other options available in the "Opt-Out/Unsubscribe" section below

We may employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from our database, analyzing data, conducting drawings and other Promotion-related activities and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to your Information only as needed to perform their functions for us; and we do not permit them to use your Information for any other purposes.

We may also use your personal information for customer service functions, to provide you with information that you may request in connection with the Website Offerings to customize your experience with the Website Offerings, and/or to contact you - when necessary - in connection with transactions entered into by you through the Website Offerings, if any. We may also use your Information for internal business purposes, such as analyzing, managing and optimizing our business. We may combine any of the Information that we have gathered from you with information from other Users and sources.

We reserve the right to release current or past Information (including Sensitive Information) in the event that: (i) we believe that you are using, or have used, the Website Offerings in violation of this Privacy Policy, the Terms, or any of our other operating rules, policies, schedules now in effect or which we may later publish from time to time; (ii) we believe that you are using, or have used, the Website Offerings to commit unlawful acts; (iii) such Information is subpoenaed or requested pursuant to a judicial or regulatory proceeding or inquiry; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any of your Information pursuant to a subpoena; (iv) we are sold, merge with a third-party or are acquired by a third-party (collectively, "M&A Transactions") (including where we share your Information, in connection with the due diligence process associated with a potential M&A Transaction); (v) if we are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding and/or M&A Transaction, you will be notified via e-mail and/or a prominent notice on the Website of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information; and/or (vi) we deem it necessary or appropriate including, without limitation, sharing your e-mail address with third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.

By submitting your e-mail address to us by and through the Website Offerings or otherwise, you agree to receive e-mail marketing from us (including our other properties).

By registering with the Website, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the "TSR") and applicable state do-not-call regulations. Further, notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the TSR and applicable state do-not-call regulations.

Where you provide "prior express consent" within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time ("TCPA"), you consent to receive telephone calls from Company, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Website Offerings, and your consent simply allows Company to contact you via these means.

In connection with the Website Offerings, we may make available a service by which you can receive messages on your wireless device via short message service ("SMS Service"). Your wireless service provider´s standard data and messaging rates would apply to all such SMS correspondence. All charges are billed by, and payable to, your mobile service provider. You represent that you are: (I) eighteen (18) years of age or older (or the applicable age of majority if the age of majority in your jurisdiction is greater than eighteen (18) years of age); (II) the owner or authorized user of the wireless device on which SMS messages will be received; and (III) authorized to approve the applicable charges. Data obtained from you in connection with this SMS Service may include your name, address, cell phone number, service provider's name, and the date, time, and content of your SMS messages. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. The use of this information will be in accordance with this Privacy Policy. You may opt out of the SMS Service at any time, by replying with the keywords "STOP," "END," or "QUIT" to the SMS text message received from us or by using the Unsubscribe link on the Website. Please note, by unsubscribing from the SMS Service, you will not automatically be unsubscribed from other SMS programs to which you may have also subscribed. You may receive assistance for the SMS Service by replying with the keyword "HELP" to the message received.

You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. The SMS Service is provided on an "AS IS" and "AS AVAILABLE" basis. We are not responsible for incomplete, lost, late, damaged, illegible or misdirected SMS messages or for any technical problems, malfunctions of any telephone lines, computer systems, servers, providers, hardware/software, lost or unavailable network connections or failed, incomplete, garbled or delayed computer transmission or any combination thereof. Furthermore, we assume no responsibility for undeliverable SMS messages resulting from any form of active or passive mobile filtering by your wireless service provider or for insufficient space in your mobile phone account to messages. We also reserve the right, in our sole discretion, to cancel or suspend the SMS Service for any reason, including where a virus, bug or other cause beyond our control corrupts the administration, security or proper operation thereof. We do not guarantee that your use of the SMS Service will be private or secure, and we hereby disclaim all liability to you for any lack of privacy or security that you may experience. You are fully responsible for taking precautions and providing security measures best suited for your needs and intended use of the SMS Service.

VII. How We May Disclose and/or Sell Information

Please see our Privacy Provisions for California Residents below for more details regarding our use, sharing and sale of Personally Identifiable Information.

We may share and/or sell Information that we have about Users in many ways and for many purposes, for which we may be compensated, including the following:

· By submitting your Information by and through the Website Offerings, you agree that: (a) we may share, sell, rent, lease or otherwise provide that Information (other than Sensitive Information) to any third-party for any purpose permitted by law; and (b) we may work with other businesses to bring selected third-party offers to you. These businesses and third-parties may include, but are not limited to: (i) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (ii) e-mail marketers; (iii) telemarketers (where permitted by applicable law); and (iv) direct marketers.  

· We may share your Information with one or more vendors who provide independent verification of consent, including verification of consent under the TCPA;

·  We may share your Information to enable customer service vendors to perform their respective tasks, including for fulfillment of Promotions; and

·  We may share your Information to enable our Information verification and fraud detection vendors to perform contracted for services.

·  With one or more Vendors who provide independent verification of consent, including verification of TCPA Consent for purposes of the TSR and TCPA;

When we share and/or sell Information, we enter into agreements that describe the purpose for which the Information is shared/sold, restrict its use to the agreement's specified purpose and require that all Information remain confidential and protected from unauthorized disclosure.

VIII. Collection and Use of Your Non-Personally Identifiable Information

Please see our Privacy Provisions for California Residents below for more details regarding our collection and use of Non-Personally Identifiable Information.

Response Data.

Whenever you open, preview or click on the advertising portion of our e-mail messages, the Website or any of our other Online Media, we collect such response data and other Non-Personally Identifiable Information for our internal marketing purposes (collectively, "Response Data").

Ad-Serving.

We may serve advertisements to you based, in part, on your IP address, the demographic and geographic Information you submitted to us, as well as other socio-economic information, psychographic information, Internet behavior (i.e., browsing, searching, purchasing, ad-response behavior, etc.), and lifestyle information about you.

IP Address/Browser Type.

We may collect certain Non-Personally Identifiable Information about you whenever you visit the Website and/or our Online Media. This Non-Personally Identifiable Information may include, without limitation, the type of browser that you use (e.g., Safari, Firefox, Chrome, etc.), your IP address, the type of operating system that you use (e.g., Windows or Mac OS) and the domain name of your service provider. We use the Non-Personally Identifiable Information that we collect to improve our design and to personalize your experience. We also may use this Information in the aggregate to analyze usage. We also reserve the right to use aggregate or group data about our Users for any other lawful purposes. Aggregate or group data is data that describes the demographics, usage and/or characteristics of our Users as a group.

Behavioral Tracking.

Company, as well as third party entities such as Google® and Facebook®, use Cookies (as defined below), pixels and other tracking technology (collectively, "Tracking Technology") in connection with the Website for purposes of tracking Users' activities (such as websites visited, advertisements selected and pages viewed) after they leave the Website. Company, and its third-party partners, use this Tracking Technology to target applicable Users with advertisements featuring Company products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users.

In general, Users may be able to disable some, but not all, of this tracking activity by utilizing the "Do Not Track" setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.

Further, Users can opt-out of this tracking by emailing us at: [email protected].  Users can also opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Website.

 

Cookies.

We collect some information about you simply by virtue of you accessing the Website. Namely, when you visit the Website, receive emails/communications, and/or access any of our other Online Media, we, or a data provider that we have engaged, may place, recognize or send a unique cookie, single-pixel GIF files/images and/or similar technologies (collectively, "Cookie") to assign an anonymous, unique identifier to your Internet browser. A Cookie is a small piece of data stored on your computer's hard drive containing Non-Personally Identifiable Information about you.

Cookies are not designed to collect data from your hard drive, your e-mail account or any other Personally Identifiable Information about you. No Personally Identifiable Information is placed into these Cookies. Cookies are used to store information about an individual's preferences and history in order to better serve the User and/or present you with customized ads, content and/or services. Cookies may reflect de-identified demographic or other data linked to data that you have voluntarily submitted to us, e.g., your e-mail address, in hashed, non-human readable form. Cookies have many benefits including, enhancing the functionality of the Website Offerings, delivering a more personalized experience and improving and delivering certain content and offerings. We may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices.

If you do not want information collected through the use of Cookies, there is a simple procedure in most Internet browsers that allows you to accept or reject most Cookies. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Please note that if you reject our Cookies, it is possible that you will be prevented from accessing certain Website Offerings, some of the Website pages and other Online Media may not properly load, your access to certain information might be denied, and/or you might have to enter information about yourself more than once. We reserve the right to retain Cookie data indefinitely.

To protect your privacy, we do not use Cookies to store or transmit any Personally Identifiable Information about you on the Internet.

Cross Device Tracking.

Company tracks Users' use of the Website Offerings across various devices, including Users' personal computers and mobile devices, in order to optimize and personalize use of the Website Offerings. Company may collect certain User personal information across various devices.

Aggregate Data.

Company reserves the right to transfer and/or sell aggregate or group data about Users of the Website Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Website Offerings Users as a group, without disclosing Personally Identifiable Information.

No Spyware.

We do not install any spyware or adware in connection with the Website Offerings, or distribute any commercial message, or authorize any third party to distribute any commercial message, by means of spyware or adware. "Spyware" or "adware" is any software which has been downloaded to and/or installed on an Internet user's computer, without that individual's actual consent, and facilitates the distribution of any commercial message to that individual. If you feel that you may have spyware from another company installed on your machine, there are various anti-spyware/adware software applications available on the Internet to identify if this has occurred.

Website Tracking Software/Domain Addresses.

Our web servers, utilize certain tracking software to capture your domain address (the address of your Internet service provider) for purposes of tracking statistics. The capture of your domain address is a common practice among websites for measuring the number of hits, pages visited and length of time spent on a site. We use this information to measure the effectiveness of Website offerings in order to better serve you.

IX. Privacy Provisions for California Residents

These Privacy Provisions for California Residents ("Privacy Provisions") supplement, and do not limit in any way, the Privacy Policy set forth above.  These Privacy Provisions apply solely to residents of the State of California ("CA Users").  We adopt these Privacy Provisions in compliance with the California Consumer Privacy Act of 2018 ("CCPA").  Any terms defined in the CCPA have the same meaning when used in these Privacy Provisions.  CA Users with disabilities who wish to access these Privacy Provisions in an alternative format can contact us by: emailing us at: [email protected]; calling us at: (844) 435-3969; or sending us U.S. Mail to: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device ("personal information"). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.

YES

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

A name, signature, Social Security number, physical characteristics or description, postal 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. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

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

YES

D. Commercial information.

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

YES

F. Internet or other similar network activity.

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

YES

K. Inferences drawn from other personal information.

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

YES

 

Personal information does not include:

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

Use of Personal Information

We may use or disclose the personal information (including: (a) full name; (b) mailing address/state of residence; (c) e-mail address; (d) telephone number; (e) gender; and (f) date of birth) that we collect for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share your personal information (including: (a) full name; (b) mailing address/state of residence; (c) e-mail address; (d) telephone number; (e) gender; and (f) date of birth) for the other business purposes set forth above. 

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract.  Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age.  Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information including: (a) full name; (b) mailing address/state of residence; (c) e-mail address; (d) telephone number; (e) gender; and (f) date of birth) for a business purpose:

Category A     Identifiers.
Category B      California Customer Records personal information categories.
Category C      Protected classification characteristics under California or federal law.
Category D     Commercial information.
Category F      Internet or other similar network activity.
Category I       Professional or employment-related information.

We disclose your personal information (including: (a) full name; (b) mailing address/state of residence; (c) e-mail address; (d) telephone number; (e) gender; and (f) date of birth) for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

In the preceding twelve (12) months, we have sold the following categories of personal information including: (a) full name; (b) mailing address/state of residence; (c) e-mail address; (d) telephone number; (e) gender; and (f) date of birth) to third parties:

Category A     Identifiers.
Category B      California Customer Records personal information categories.
Category C      Protected classification characteristics under California or federal law.
Category D     Commercial information.
Category F      Internet or other similar network activity.
Category I       Professional or employment-related information. 

In the preceding twelve (12) months, we have sold the above referenced categories of personal information to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured by and through the Website.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt in data and consent; this information will not be shared with any third parties

Your Rights and Choices

The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties.  To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law), Category D (Commercial information) and/or Category K (Inferences drawn from other personal information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Website, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Website; (iv) involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Company.

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law), Category D (Commercial information) and/or Category K (Inferences drawn from other personal information). 

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either:

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Access to Specific Information and Data Portability Rights

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 twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract/relationship with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, but only if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

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 that the personal information relates to you.  Making a verifiable CA User request does not require that you create an account with us.  We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request.  The response that we provide will also explain the reasons that we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User 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

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Changes to these Privacy Provisions

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Website's homepage.

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

X. Unsubscribe/Opt-Out

Please see our Privacy Provisions for California Residents above for more details regarding opting-out from the sharing and/or sale of Information.

You may unsubscribe to opt-out from having your Information shared by us, or opt-out from our e-mail marketing program altogether at any time by: (a) sending us an e-mail at: [email protected]; or (b) calling us toll free at: (844) 435-3969.  We also include an unsubscribe/opt-out mechanism within every message that we send.

To opt-out of receiving SMS text messages from us, you can: (i) text "STOP," "END," or "QUIT" to opt-out from future messages; or ii) e-mail us at: [email protected].

We attempt to process all unsubscribe/opt-out requests in a prompt fashion. However, after unsubscribing, we cannot guarantee that you will never receive another communication from us because we may obtain your contact information in the future through a different entity that you have subscribed through. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Website Offerings, your participation in Promotions, as well as to respond to any inquiry or request made by you. To opt-out of receiving Website Offerings-related, Promotions-related and/or inquiry response-related messages from us, you must cease requesting and/or utilizing Website Offerings, cease participating in and/or entering Promotions and cease submitting inquiries to us, as applicable.

XI. Security

We endeavor to safeguard and protect our Users' Information. When Users make Information available to us, their Information is protected both online and offline (to the extent that we maintain any Information offline). Where our registration/application process prompts Users to enter Sensitive Information, and when we store and transmit such Sensitive Information, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your Personally Identifiable Information is strictly limited, and we take reasonable measures to ensure that your Personally Identifiable Information is not accessible to the public. All of our Users' Information is restricted in our offices, as well as the offices of our third-party service providers, as applicable. Only employees or third-party agents who need User Personally Identifiable Information to perform a specific job are granted access to User Personally Identifiable Information. Our employees are dedicated to ensuring the security and privacy of all Information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store Personally Identifiable Information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of Personally Identifiable Information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your Information, and technological bugs, errors and glitches may cause inadvertent disclosures of your Information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your Information will be absolutely secure. Any transmission of data at or through the Website, Online Media, other Website Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

XII. Security Breach

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that there has been an information security breach. You will be notified via e-mail in the event of such a breach of security. Please be advised that notice may be delayed in order to address the needs of law enforcement, to determine the scope of network damage, and/or to engage in remedial measures.

XIII. Children's Privacy

Please see our Privacy Provisions for California Residents above for more details regarding the Personally Identifiable Information of minors.

We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. We are very sensitive to the issue of children's privacy and, therefore, we strive to protect the privacy of children using the Internet. We do not knowingly solicit or collect personal information from persons under eighteen (18) years of age. If a person under eighteen (18) years of age has already provided us with any Information, his or her parent or guardian may contact us for the purpose of immediately deleting this Information.

XIV. Accessing, Modifying and Deleting Your Information

Please see our Privacy Provisions for California Residents above for instructions on how California Residents can access, modify and/or delete Personally Identifiable Information that we have collected.

If you would like to know if we have any of your Information in our database or would like to review and update or correct the Information that we have collected from you, simply: (a) send your request via e-mail to: [email protected]; (b) call us toll free at: (844) 435-3969; or (c) send us certified postal mail to FinancialReliefCenter at: FinancialReliefCenter, 2000 NE 42nd Ave PMB 1251, Portland, OR 97213.

To protect your privacy and security, we may take reasonable steps to help verify your identity before granting access or making corrections, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that requesting the deletion of your Information will terminate your right to access the Website Offerings and/or to participate in Promotions. Please be further advised that, after you request the deletion of your Information, residual copies may take a period of time before they are deleted from our active servers and may be remained in our backup systems. In addition, this deletion will not change or delete Information which may have already been shared with third parties, all as provided above in this Privacy Policy. You will need to contact the third parties that contact you directly to change your preferences regarding their use of your Information.

XV. Limitation of Liability

YOU HEREBY ACKNOWLEDGE AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, AS WELL AS THE TERMS AND CONDITIONS OF THIS WEBSITE (INCLUDING LIMITATIONS ON DAMAGES). YOU AGREE THAT COMPANY'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY COMPANY TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY THE TERMS.

XVI. Transfer of Personal Information Internationally

If you are accessing the Website or other online media from a country other than the country in which our servers are located, your communications with us may result in the transfer of Information across international boundaries. By accessing the Website or other Online Media, and/or otherwise communicating electronically with us, you consent to such transfers.  Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your Information as subject to the protections described in this Privacy Policy.

XVII.  Filing a Complaint with the Federal Trade Commission

See the Federal Trade Commission (the "FTC") website at https://www.ftc.gov/legal-library/browse/rules/can-spam-rule for updates on implementation of the CAN-SPAM Act of 2003, as amended. The FTC maintains a consumer complaint database of violations of the various laws that the FTC enforces. Consumers can submit complaints online at www.ftc.gov and forward unwanted and unsolicited commercial e-mail to the FTC at: [email protected]. The FTC works as a consumer advocate in order to prevent fraudulent, deceptive and unfair business practices. To file a complaint with the FTC or to request free information about consumer issues, please visit www.ftc.gov or call toll-free, 1-877-FTC-HELP.