Ccino Privacy Policy

Last updated on March 26, 2018

Ccino Inc. doing business as "ccino" and "ccino Brokerage" and its affiliated companies (“ccino,” “we,” “us,” and “our”), is a technology company that connects consumers with potential lenders. This online privacy policy (“Privacy Policy”) applies only to the information ccino collects through this website, and all of the associated content, functionalities and advertising (collectively the “Services”). This Privacy Policy governs the Services regardless of how you access them. Some Services may have a specific, separate Privacy Policy that will govern use of those Services. If you do not agree to the terms contained in this Privacy Policy, you must immediately exit the Services.

The Privacy Policy describes:

  1. The information we collect and how we collect it;
  2. What we do with the information we collect;
  3. How we share and disclose user information with third parties;
  4. ccino's use of online analytics and tailored advertising;
  5. California Do-Not-Track disclosure requirements;
  6. How you can access and update your information;
  7. How we protect information;
  8. Linked sites and advertisements;
  9. Use of the Services by users from outside the United States;
  10. Use of the Services by children;
  11. How to contact us;
  12. Your California privacy rights;
  13. No rights of third parties; and
  14. Changes to this Privacy Policy.

1. The information we collect and how we collect it.

How we collect and store information depends on the pages of this website you visit, the activities in which you participate and the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.

1.1 Information you provide

We may collect information about you during your use of the Services, including your first name, last name, email address, loan amount, phone number(s), zip code, employment status, annual income, credit score/FICO range, and information you provide or post on our Services or allow us to access when you do certain things, such as:

  • Enter registration information for one or more of our Services;
  • Request information from ccino's lending partners regarding their financial products;
  • Request certain features (e.g., newsletters, updates, and other products);
  • Sign up to receive SMS (text message) notifications;
  • Download or use one of our mobile applications;
  • Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS); or
  • Post user-generated content, including comments, to or on any of our Services.

    • We may collect information about you during your use of the Services, including your first name, last name, email address, loan amount, phone number(s), zip code, employment status, annual income, credit score/FICO range, and information you provide or post on our Services or allow us to access when you do certain things, such as: Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via a SNS, on message boards, chat areas or in advertising or notices you post, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties.

    1.2 Automatically-collected information

    1.2.1 Device/usage information We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information. We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique ccino identifier (that is not intended to be used by itself to identify you) for our internal use, in which case your ccino identifier will be considered ccino information and nothing in this Privacy Policy restricts how ccino may use this information. 1.2.2 Location information We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Chicago, the Services may be customized with Chicago-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details. 1.2.3 Cookies and other electronic technologies When you use the Services, we use persistent and session cookies and other similar tracking technologies to: (a) analyze the usage of our sites and Services by collecting the information discussed in section 1.2.1 above; (b) customize the Services to your preferences; and (c) control the advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications. The cookies may reflect de-identified data linked to or derived from data you voluntarily have submitted to us, e.g., a hashed version of your email address that we may share with service providers, solely in non-human readable form. We and our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, as well as serve you ads when you are using our Services and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. As we adopt additional technologies, we may also gather additional information through other methods. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browsers toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

    1.3 Information from third parties

    We may obtain additional information about you from third parties such as service providers, credit bureaus, marketers, partners, researchers, and others. We may also receive information from lenders regarding the status of your application including, but not limited to, the amount or disposition of your loan. This information may include your Social Security number, FICO score, credit report, transaction history, payment history, name, phone number, email address, ZIP code, whether you have received loan offers, and which loan offers you have received. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

    1.4 Aggregate or de-identified data

    We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

    2. What we do with the information we collect.

    • For the purposes for which you provided it;
    • To deliver the products and services you requested;
    • To match you with lenders or provide you with lenders’ conditional loan offers;
    • To verify your identity;
    • To protect against or identify possible fraudulent transactions;
    • To send you information about your relationship or transactions with us;
    • To send you alerts or other communications via SMS messages or other media or networks;
    • To notify you about new features of the Services, special events, or products, services, and special offers;
    • To administer sweepstakes and contests;
    • To process and respond to your inquiries and requests for customer support;
    • To contact you with information that we believe will be of interest to you;
    • To attribute content that you make available through the Services;
    • To generate and review reports and data about our user base and Service usage patterns;
    • To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;
    • To improve the content and features of the Services or develop new Services;
    • To allow us to personalize the content and advertising that you see on the Services and to understand how users interact with and use our advertisements and Services;
    • To enforce the legal terms that govern your use of the Services;
    • To administer and troubleshoot the Services; and
    • To associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications and websites).

    We may send you commercial emails regarding products you may be interested in. Each such email we send you will have an opt-out that you can use to stop receiving such communications. If you opt out of receiving commercial emails about products we think you may be interested in, we may still send you emails about any services you have requested or received from us.

    3. How we share and disclose user information with third parties.

    We will make your information available to other companies, websites, applications or people in the circumstances described below:

    We may rent, sell, or share your information with non-affiliated third parties: (a) in order to provide services or products that you have requested; (b) when we have your permission; or (c) as described in this Privacy Policy.

    We may share your information with any agent or company that is part of ccino in order to provide the Services or advertising or to communicate with you on our behalf.

    In submitting an inquiry for a loan product or other service offered through this website, you are acknowledging and agreeing to the disclosure of information you have provided or that we have received from third parties to lenders in our network ("Lenders") with whom you are or may be matched. We may also use the information you provide or that we obtain from third parties to submit to credit reporting agencies to conduct a soft credit pull inquiry. Please note that no hard inquiry of credit will be performed by ccino or its network Lenders unless you authorize us to do so by submitting a completed loan request. NOTE THAT even if you do not provide your Social Security number, we may access your credit file to assist in the prevention of identity theft and to verify your request is accurate and complete. Not all network Lenders will obtain your SSN and each Lender has its own requirements, disclosures and consent requirements. BE AWARE that the Lenders with whom you are matched may retain or use your information whether or not you use their services and you should contact these Lenders directly concerning their privacy and information sharing practices which may differ from ccino.

    When you express interest in other products, services, promotions that we offer (by, for example, completing an inquiry for such services), we will share your request or expression of interest with the businesses with which we partner to offer you those products, services and promotions, and, as applicable, with their affiliates and third party finder or marketing companies (collectively, “Business Providers”). When you choose to participate in a particular offer or program, you authorize us to provide information and other personally identifiable information to those Business Providers. Be aware the Business Providers with whom we share your information and other personally identifiable information may retain or use your information whether or not you use their services and you should contact these parties directly concerning their privacy and information sharing practices which may differ from ours.

    When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers, operators, or sponsors privacy policies or practices.

    We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.

    We may share your personal information with our authorized service providers that perform certain services on our behalf including, but not limited to service providers that perform services on our behalf in connection with your request for a loan or the funding, sale and/or servicing of your loan. These third parties include, without limitation credit bureaus, marketing and customer services firms, or entities that provide business analysis or website support. These third parties may have access to information and other personally identifiable information needed to perform their functions. We may also share your information with other third-parties with whom we have a contractual relationship for their own direct marketing or advertising purposes.

    We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service for the Services you accessed, and/or to protect the rights and property of ccino, our employees, users and the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

    We may disclose your information in connection with reporting required in connection with state and/or federal licensing requirements. You authorize ccino to obtain any and all necessary information required from the Lender or Provider you choose to report back any and all required information relating to the disposition of your request. For example, if the loan closed, if you withdrew the request, and/or if you were not approved. In addition, under current reporting requirements the lender may provide to ccino the loan you selected, the terms of the same, fees, rate, APR etc. in order to comply with current laws and regulations

    We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all ccino assets, or a financing or acquisition of all or a portion of our business by another company.

    We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose.

    We may employ third-party software provided by FullStory, Inc. to improve the quality of the Services. This allows ccino to review a video-playback of your use of Services and any other activity on ccino’s website. By using this site, you expressly consent to Onic’s use of FullStory Inc.’s service. If you would like to opt-out, please click here.

    We may employ third-party software provided by UXCam, Inc. to improve the quality of the Services. This allows ccino to review a video-playback of your use of Services and any other activity on ccino’s website. By using this site, you expressly consent to Onic’s use of UXCam Inc.’s service. If you would like to opt-out, please email us at [email protected].

    If you are a contractor and were referred to us by a third-party partner, we may share information about you, including but not limited to your subscription status, usage data, and information about any loans obtained or loan requests made by customers using your co-branded page.

    4. ccino's use of online analytics and tailored advertising.

    4.1 Online analytics

    We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.2 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

    4.2 Tailored advertising

    When you use the Service, ccino may serve you with ads based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests. Also, third parties, including without limitation those whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that tailored ads may be delivered to you when you are using other websites. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g., user-generated content) for purposes of delivering tailored advertising on the Services and/or other websites. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link available through the Services. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. When using a mobile application, you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

    6. How you can access and update your information.

    To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at [email protected].

    7. How we protect information.

    We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information, including as required by applicable federal law. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Although we take measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

    8. Linked sites and advertisements.

    The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit sites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the site or Services in connection with such content, products, services, or functionalities, we may share any information you provide or that is collected during your use of those Services with those providers. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.

    9. Use of the Services by users from outside the United States.

    The Services are hosted in the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy and processed in those facilities.

    10. Use of the Services by children.

    The Services are not intended for persons under the age of 18. We require that only persons 18 years of age or older use the Services. By using the Services, you hereby represent that you are at least 18 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.

    11. How to contact us.

    If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to [email protected].

    12. Your California privacy rights.

    California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to [email protected].

    13. No rights of third parties.

    This Privacy Policy does not create rights enforceable by third parties.

    14. Changes to this Privacy Policy.

    ccino reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.

    15. Assistance to Victims of Identity Theft

    If you suspect that someone has had unauthorized access to your Information or access to your personally identifiable information, you should report this crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free 1-877-IDTheft (1-877-438-4338). Or, to enter information about your complaint into a secure FTC online database, visit www.consumer.gov/idtheft. The site also provides links to consumer education materials.

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