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Online Privacy Policy

Effective Date: January 11, 2022

Your privacy is important to Inclined Technologies Inc., ("we," "us," "our" and "Inclined"). This Online Privacy Policy explains how we collect, share, use, and protect information when you visit or use our websites and social media sites that we administer or that are linked to this Online Privacy Policy (each, a "Site"), particularly when you use any Site to request or obtain any online services from or through us (collectively, our "online services").

By using any Site, and by requesting or using any of our online services, you agree that we may collect, share, use, and protect information from and about you as described in this Online Privacy Policy. This Online Privacy Policy describes the types of information we may collect from and about you when you visit, use and obtain services through our Sites.

Our Sites and online services are intended only for a U.S. audience. If you visit or use a Site and our online services, your information may be transferred or processed in the United States, in a state other than the one where you live. If you access a Site or use our online services from a location outside of the U.S., you understand and agree that we may collect, share, use, and protect your information as described in this Online Privacy Policy.

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 request or obtain a financial product or service through us, we will use and share any information that we collect from or about you in accordance with the applicable lender's U.S. Consumer Financial Privacy Notice. This Online Privacy Policy covers privacy matters not covered by an applicable U.S. Consumer Financial Privacy Notice. Any other party or financial institution that directly provides a financial product or service to you will obtain, use, and share information collected about you in accordance with its own privacy notices and policies.

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

Personal Information

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

In addition to the personal information described above, we may collect certain information about your use of our Site and online services. For example, we may capture the IP address of the device you use to connect to the Site and online service, the type of operating system and browser you use, the make and model of a mobile device, and the parts of our Site and online services you access and use. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our Site and online services. In addition, we may later associate the usage and other information we collect online with personal information about you.

Additional Sources of Information

We may also collect information about you from additional online and offline sources including from co-branded partner sites or commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Privacy Policy.

 

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

  • Other third parties to comply with legal requirements, such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

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

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects and other tracking technologies for various purposes, such as fraud prevention and monitoring our advertising and marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services. We are unable to respond to Do Not Track signals from your browser and devices at this time.

  • "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

Inclined may provide links to websites that are owned or operated by other companies ("third-party websites"). When you use a link online to visit a third-party website, you will be subject to that website's privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.

 

Security

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.

 

Changes to This Online Privacy Policy

This Online Privacy Policy was last updated on January 11, 2022. We may change this Online Privacy Policy from time to time. When we do, we will let you know by appropriate means, such as by posting the revised policy on this page with a new "Last Updated" date. Any changes to this Online Privacy Policy will become effective when posted unless indicated otherwise.

 

Questions

If you have any questions about this Online Privacy Policy, you may contact us at support@inclined.com.

 

California Residents

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.

Exceptions

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 support@inclined.com. 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

We will not discriminate against you for exercising any of your rights in this Online Privacy Policy and under applicable laws.

 

Nevada Residents

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 support@inclined.com.

 

Vermont Residents

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.