This privacy notice for American Consumer Credit Counseling, Inc. (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our mobile application or websites (collectively, the “Services”), such as when you:
- Download and use our mobile application (“CreditU ™”), or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Section 10 of this Policy contains provisions describing rights applicable to California residents under the California Shine the Light Act, and provides information on how to contact us to exercise those rights in Section 12.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us in the manner described in Section 12 below.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- CALIFORNIA’S SHINE THE LIGHT LAW
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us. We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. We may collect the following categories of information:
- phone numbers
- email addresses
- mailing addresses
- job titles
- contact preferences
- contact or authentication data
- billing addresses
- debit/credit card numbers
- demographic information
- information from your social media accounts
- social security numbers or other government identifiers
- financial account, debit card, or credit card numbers
- geolocation data
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. Payments may be made through ACH, credit cards, or debit cards. If you utilize Apple Store or Google Play (each an “App Distributor”) to access the Services, please refer to the links below for a list of additional privacy notices.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, such as your Facebook, X (formally known as Twitter), or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
- Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s contacts, social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
Biometric Authentication. At CreditU, we are committed to safeguarding your privacy and ensuring the
protect your biometric data when you use our biometric authentication features, such as Face ID and
Touch ID, within our app.
- Biometric Data Collection. When you enable biometric authentication, such as Face ID or Touch
ID, on CreditU, we may collect and store certain biometric data from your device. This data is
used solely for the purpose of securely verifying your identity and providing you with convenient
access to our app.
- Storage and Security. Your biometric data is securely stored on your device and is not
transmitted to our servers or stored on our systems. We use industry-standard encryption and
security measures to protect your biometric data from unauthorized access or breaches.
- Use of Biometric Data. CreditU uses your biometric data solely for the purpose of allowing you
to access and use our app securely. Your biometric data is not used for any other purpose, such
as marketing or third-party advertising.
- User Control. You have the option to enable or disable biometric authentication at any time
within the app’s settings. Disabling biometric authentication will revert access to traditional
authentication methods, such as a passcode or password.
- Sharing Biometric Data. We do not share your biometric data with third parties unless required
by law or with your explicit consent. Your biometric data is solely used for the purpose of
providing a secure and convenient user experience within CreditU.
- Retention of Biometric Data. We retain your biometric data on your device as long as you
choose to use biometric authentication within CreditU. If you disable biometric authentication,
the stored biometric data will be removed from your device.
reflect changes in our biometric authentication features or legal requirements. We recommend
reviewing this section periodically for any updates.
By using CreditU’s biometric authentication features, you agree to the terms outlined in this Privacy
Policy section. If you have any questions or concerns about the collection and use of your biometric data,
please contact us at email@example.com.
If you wish to change our access or permissions, you may do so in your device’s settings.
This information is necessary to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Any materially misleading information you provide may lead to the revocation or cancellation of your access to our Services.
Information collected from other sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information may include mailing addresses, demographic information, job titles, email addresses, phone numbers, intent data (or user behavior data), financial data, Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.
WHY DO WE PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts.
- To verify your identity.
- For customer service and quality control.
- To deliver and facilitate delivery of services.
- To respond to your inquiries/offer support to you.
- To send administrative information to you.
- To request feedback.
- To send you marketing and promotional communications.
- To post testimonials that may contain personal information.
- To create and maintain products and services.
- To update our consumer credit database.
- To prevent fraud and unauthorized disclosures of your personal information.
- To protect the confidentiality and security of your records.
- To provide information to persons assessing our compliance with industry standards, and our attorneys, accountants, and auditors.
- To record and demonstrate how we have conducted a dispute and complaint resolution process and arrived at a resolution.
- To comply with applicable laws.
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates and Service Providers. We may share your information with our affiliates and service providers, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. Service providers may include IT professionals, web hosting services, cloud computing service companies, accountants, and attorneys.
- Business Partners. With your prior consent, we may share information with business partners for marketing purposes.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook login). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will keep your personal information for as long as we are providing services to you and then for an additional period of up to 84 months unless a longer or shorter retention period is required by law (such as tax, accounting, regulatory, privacy or other legal requirements).
At the end of the retention period described above, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. We use commercially reasonable efforts to implement appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process and/or maintain. We expressly disclaim any warranty, express or implied, that guarantees that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from, or market to children under 18 years of age. By using the Services, you represent and warrant that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected without the consent of a parent or guardian, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org. To the extent that any Services are used by a minor through knowing or willful deception or misleading conduct or statements made by you, you shall be responsible for indemnifying and holding us harmless for any claims, damages or losses that are the result of such misconduct.
WHAT ARE YOUR PRIVACY RIGHTS?
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
CALIFORNIA’S SHINE THE LIGHT LAW
California Civil Code Section 1798.83, also known as the “Shine The Light” law, grants certain rights to California residents who are customers of companies that have disclosed their personal information to third parties for marketing purposes in the last year. We have not done so in our history.
As described in Section 8 of this Policy, we will not disclose personal information about you to unrelated third parties without your prior consent, which you may revoke at any time. If we were to change this policy regarding revocation of consent, we would revise this Policy to describe the additional rights that our California customers would then have under the Shine the Light law.
DO WE UPDATE THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE
If you have questions or comments about this notice or your privacy rights, you may email us at email@example.com, call us toll-free at (800) 769-3571 or contact us by mail at:
American Consumer Credit Counseling, Inc.
130 Rumford Ave, Suite 202
Auburndale, MA 02466-1317 United States
CreditU ™ is a trademark of American Consumer Credit Counseling, Inc.