Effective Date: January 11, 2022
Our Sites and online services are not intended for individuals under the age of 18. No one under the age of 18 is allowed to submit personal information through our Sites. We do not knowingly collect personal information from individuals under the age of 18 without parental consent.
If you are a California resident, you may have rights and choices under the California Consumer Privacy Act associated with your personal information, as more fully described below.
Information We Collect
When you visit or use our Site and online services, we may collect personal information from or about you, such as your name, age, email and mailing address, telephone number(s), account numbers, limited location information (for example, a zip code or mobile location information to help prevent potential fraud),. We may also collect and ask you to provide other information, such as bank account information, commercial information (such as a record of Insurance products you may have purchased), social security numbers, and driver's license numbers when you use our Site and online services and we believe the information is reasonably required for ordinary business purposes.
We may also collect audio, electronic, or visual information from and about you, such as recorded telephone conversations and photographic images. We may require you to provide us with documentary identification, such as government-issued identification, which includes photographic images and other information that will be used to verify your identity, confirm the identification is valid, prevent fraud, and for other reasons allowed by law. We will keep information from your documentary identification while you and we have an ongoing business relationship, and for up to two years after any such relationship ends, but we will not keep photographic images from your documentary identification.
Usage and Other Information
Additional Sources of Information
Use of Information
We use the information discussed above in a number of ways, such as:
Processing applications and transactions;
Verifying your identity (such as when you access your account information);
Preventing fraud and enhancing the security of your account or our online services;
Responding to your requests and communicating with you;
Managing your preferences;
Performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view;
Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);
Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
For any other purposes that we may specifically disclose at the time you provide or we collect your information.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.
Disclosure of Information
We may share the information we collect from and about you with outside companies that we do business with and other third parties. For example, we may share your information with:
Providers of financial and other products or services you obtain through us;
Third-party service providers and vendors to Inclined;
Inclined-branded websites and other companies we do business with to improve the online services and related products that you request and obtain from us through the Site, when permissible under relevant laws and regulations;
Third parties in connection with a corporate transaction, such as a sale, consolidation or merger of Inclined's businesses; and
However, we will limit sharing of your information as described in an applicable U.S. Consumer Financial Privacy Notice.
We may share anonymous or aggregated information with third parties to help deliver products, services, and content that are better tailored to the users of our Sites and online services and for other purposes.
Understanding Cookies, Web Beacons and Other Tracking Technologies
"Cookies" are small amounts of data a website can send to a visitor's web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our online services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies, but doing so may degrade your experience with our online services.
Clear GIFs, pixel tags or web beacons—which are typically one-pixel, transparent images located on a webpage or in an email or other message—or similar technologies may be used on our sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns and measure site or campaign engagement.
Local Shared Objects, sometimes referred to as "flash cookies" may be stored on your hard drive using a media player or other software installed on your device. Local Shared Objects are similar to cookies in terms of their operation, but may not be managed in your browser in the same way.
Linking to Third-Party Websites
We use reasonable physical, electronic, and procedural safeguards that comply with federal standards to protect and limit access to personal information. This includes device safeguards and secured files and buildings.
The information you send to us electronically is collected by way of secure mechanisms, such as https or TLS, when it is transmitted to us. Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the personal information you send to us or the security of our servers, networks or databases. By using the Site and our online services, you agree to assume all risk in connection with the personal information sent to us or collected by us when you access, visit or use the Site and the online services, and agree that we are not liable to you for any loss of this personal information or related consequences. Please do not use insecure channels or methods to communicate sensitive or confidential information (such as your Social Security number or bank account numbers) to us.
Updating Your Information
Keeping your account information up-to-date is very important. You may review, or update certain account information by logging in and accessing the "Settings" section. If you cannot change the incorrect information online, or you prefer to request changes offline, please use the Contact Us option on our Site, or call or write to us using the contact information listed on your account statements, records, or other account materials.
If you are a California resident, the California Consumer Privacy Act ("CCPA") provides you certain rights and choices regarding how we collect, share, use, and protect your personal information and how you can exercise those rights. The CCPA defines personal information as information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Certain information that we collect may be exempt from the CCPA because it is considered public information or covered by financial privacy laws, such as the Gramm-Leach Bliley Act, the California Financial Information Privacy Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
The information we collect is described above. To the extent that the information we collect is "personal information" subject to the CCPA, our practices and your rights are described below.
Sale of Personal Information
We do not sell "personal information," nor have we sold it, in the last 12 months.
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 12 months from the date we receive your request. Once we receive and confirm your request and verify that it is coming from you, or someone authorized to make the request on your behalf, we will disclose to you or your representative:
The categories of "personal information" we collected about you.
The categories of sources for the "personal information" we collected about you.
Our business or commercial purpose for collecting or selling that "personal information."
The categories of third parties to whom we sold or disclosed the category of "personal information" for a business or commercial purpose.
The business or commercial purpose for which we sold or disclosed the category of "personal information."
The specific pieces of "personal information" we collected about you in a form that you can take with you (also called a "data portability request").
Right to Delete
Under certain circumstances, you have the right to request that we delete any "personal information" that we have collected directly from you. We are required to verify your identity before we can act on your request. We may have a reason under law why we do not have to comply with your request or why we may comply with it in a more limited way than you anticipated. If so, we will explain that to you in our response.
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability and deletion right described above, please submit a verifiable consumer request to us by either calling us at 1 (855) 282-0441 or emailing us at firstname.lastname@example.org. You may only make a verifiable consumer request twice within a 12 (twelve) month period.
Making a verifiable consumer request does not require you to open an account with us. We must be able to verify your identity or authority to make the request and confirm the personal information relates to you. We will only use information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits to verify the identity of the authorized agent and confirm that you have authorized that person to act on your behalf.
We will try and respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period, not to exceed 90 days, in writing. Any disclosure we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. We do not charge a fee to process or respond to your verifiable consumer request.
Right of Non-Discrimination
Nevada residents have the right to opt out of the sale of certain pieces of their information. We do not sell "personal information" of Nevada residents, but, if you are a Nevada resident who has questions or who wants to make this type of request, please send your email to email@example.com.
If you live in Vermont, we will share information only as permitted by law. We will not share your personal information with non-affiliates for their marketing purposes, unless you authorize us to do so. We will not share consumer report information about you with joint marketing partners or with affiliates, except with your consent or to the extent otherwise permitted by law.