Privacy Policy

1. Information We Collect

We collect information that is necessary to evaluate loan applications, provide our services, and comply with legal requirements. The information we collect falls into several categories:

1.1 Personal Identification Information

When you apply for a loan or use our services, we collect:

• Identity Information: Full name, date of birth, Social Security number, driver's license or state ID number
• Contact Information: Email address, phone number, physical address (current and previous)
• Employment Information: Employer name and address, job title, length of employment, work phone number

1.2 Financial Information

• Income Details: Gross monthly income, income source, pay frequency
• Banking Information: Bank name, account type, routing number, account number
• Credit Information: Credit score, credit history, existing debts and obligations
• Loan Information: Requested loan amount, intended use, payment history

1.3 Information from Third Parties

We obtain information from third-party sources to verify your identity and assess creditworthiness:

• Credit Bureaus: Credit reports and scores from Experian, TransUnion, and Equifax
• Identity Verification Services: Information to verify your identity and prevent fraud
• Employment Verification: Confirmation of employment and income (when applicable)
• Banking Verification: Confirmation of account ownership and transaction history

1.4 Automatically Collected Information

When you visit our website or use our services, we automatically collect certain technical information:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, links clicked, referring website
• Location Information: General geographic location based on IP address
• Cookies: Small data files stored on your device (see Section 6 for details)

2. How We Use Your Information

We use the information we collect for specific, legitimate business purposes:

2.1 Loan Processing and Servicing

• Evaluating loan applications and making credit decisions
• Verifying the information you provide
• Processing approved loans and disbursing funds
• Servicing your loan, including processing payments
• Communicating with you about your account
• Reporting your payment history to credit bureaus

2.2 Legal and Regulatory Compliance

• Complying with federal and state lending laws
• Meeting regulatory reporting requirements
• Preventing fraud and identity theft
• Responding to legal processes (subpoenas, court orders)
• Conducting internal audits and quality assurance

2.3 Business Operations

• Improving our website and services
• Analyzing trends and customer behavior
• Developing new products and services
• Marketing our services (with your consent)
• Customer service and support

2.4 Communications

• Sending you account statements and payment reminders
• Notifying you of changes to terms or policies
• Responding to your inquiries and requests
• Providing customer support
• Sending promotional communications (you can opt out)

3. Information Sharing and Disclosure

We share your personal information only with specific categories of third parties, and only for legitimate purposes. We never sell your personal information to marketers or data brokers.

3.1 Lending Partners

Our loans are provided by partner banks (Capital Community Bank and Transportation Alliance Bank). We share your application information with these banks to process and service your loan.

3.2 Service Providers

We work with third-party companies that help us provide our services. These companies are contractually required to protect your information and use it only for specified purposes:

• Payment Processors: Processing loan disbursements and payments
• Identity Verification: Confirming identity and preventing fraud
• Credit Reporting: Obtaining credit reports and reporting payment history
• Technology Providers: Website hosting, data storage, and security
• Customer Service: Call center operations and support

3.3 Credit Bureaus

We report your payment history to credit bureaus (Experian, TransUnion, Equifax) as required by law. This helps you build or rebuild your credit when you make on-time payments.

3.4 Legal Requirements

We may disclose your information when required by law or to protect our rights:

• In response to subpoenas, court orders, or legal processes
• To comply with regulatory investigations or requests
• To prevent fraud or other illegal activity
• To protect the rights, property, or safety of Integra Credit, our customers, or others
• In connection with a merger, acquisition, or sale of assets

3.5 With Your Consent

We may share your information with other parties when you explicitly consent, such as when you authorize us to share information with a co-applicant or financial counselor.

4. Data Security

We take the security of your personal information seriously and employ multiple layers of protection:

4.1 Technical Security Measures

• Encryption: 256-bit SSL encryption for all data transmission
• Secure Storage: Encrypted databases with restricted access
• Firewalls: Network security to prevent unauthorized access
• Intrusion Detection: Real-time monitoring for suspicious activity
• Regular Security Audits: Third-party penetration testing and vulnerability assessments

4.2 Organizational Security Measures

• Access Controls: Only authorized employees can access personal information
• Employee Training: Regular security and privacy training for all staff
• Confidentiality Agreements: All employees and contractors sign confidentiality agreements
• Vendor Management: Due diligence and contractual protections for third-party providers

4.3 Data Breach Response

In the unlikely event of a data breach affecting your personal information, we will:

• Investigate and contain the breach immediately
• Notify you within the timeframe required by applicable law
• Provide information about what data was affected
• Offer assistance such as credit monitoring if appropriate
• Report the breach to relevant regulatory authorities

5. Your Privacy Rights

You have specific rights regarding your personal information. The extent of these rights may vary based on your location.

5.1 Right to Access

You have the right to request a copy of the personal information we hold about you. We will provide this information in a commonly used electronic format.

5.2 Right to Correction

If you believe any information we have about you is inaccurate or incomplete, you can request that we correct or complete it.

5.3 Right to Deletion

You may request deletion of your personal information, subject to certain exceptions. We may need to retain some information to comply with legal obligations or complete transactions you requested.

5.4 Right to Opt-Out

• Marketing Communications: You can opt out of promotional emails by clicking "unsubscribe" in any marketing email
• Phone Calls: You can request to be placed on our do-not-call list
• Data Sharing: In some states, you can limit certain types of information sharing (see Section 7 for California rights)

5.5 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. You will not be denied service, charged different prices, or provided different quality of service.

5.6 How to Exercise Your Rights

To exercise any of these rights, you can:

• Email us at privacy@integracredit.com
• Call us at 1-800-XXX-XXXX
• Write to us at the address listed in Section 10
• Submit a request through your online account portal

Verification Process: For your protection, we will verify your identity before processing requests that involve accessing or deleting personal information.

6. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience on our website and understand how our services are used.

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and track your activity.

6.2 Types of Cookies We Use

• Essential Cookies: Required for the website to function (login, security, payment processing)
• Performance Cookies: Help us understand how visitors use our website
• Functionality Cookies: Remember your preferences and settings
• Advertising Cookies: Deliver relevant advertisements and track campaign effectiveness

6.3 Third-Party Cookies

We work with third-party service providers that may set cookies on our website:

• Google Analytics (website analytics)
• Facebook Pixel (advertising)
• Identity verification services

6.4 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may affect website functionality. Most browsers allow you to:

• View and delete cookies
• Block all cookies
• Block third-party cookies
• Receive notifications when cookies are set

7. California Privacy Rights (CCPA)

If you are a California resident, you have additional privacy rights under the California Consumer Privacy Act (CCPA).

7.1 Categories of Personal Information

We collect the following categories of personal information as defined by CCPA:

• Identifiers (name, SSN, address, email, phone)
• Financial information (bank account, credit information)
• Commercial information (loan history, payment records)
• Internet activity (website usage, IP address)
• Employment information (employer, income)

7.2 Your California Rights

• Right to Know: Request details about personal information we've collected, used, or shared
• Right to Delete: Request deletion of your personal information (with exceptions)
• Right to Opt-Out: Opt out of the "sale" of personal information (we don't sell data)
• Right to Non-Discrimination: Equal service regardless of privacy choices

7.3 How to Exercise California Rights

California residents can submit requests:

• By email: privacy@integracredit.com
• By phone: 1-800-XXX-XXXX (toll-free)
• Through our website: [Privacy Request Form]

We will respond to verified requests within 45 days. You may designate an authorized agent to make requests on your behalf.

7.4 Do Not Sell My Personal Information

We do not sell your personal information to third parties. We share information only as described in Section 3 of this policy, which does not constitute a "sale" under CCPA.

8. Children's Privacy

Our services are not directed to individuals under 18 years of age (or under 19 in certain states). We do not knowingly collect personal information from minors.

If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@integracredit.com, and we will delete the information promptly.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors.

9.1 Notification of Changes

When we make changes to this policy, we will:

• Update the "Last Updated" date at the top of this page
• Post the new policy on our website
• Notify you by email if the changes are material (for existing customers)
• Provide prominent notice on our website for 30 days after changes

9.2 Your Acceptance

By continuing to use our services after changes are posted, you accept the updated Privacy Policy. If you do not agree with the changes, you should discontinue using our services.

10. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Privacy Officer

Integra Credit / Deinde Financial, LLC
120 S La Salle St, Suite 1600
Chicago, IL 60603

Email: privacy@integracredit.com
Phone: 1-800-XXX-XXXX (toll-free)
Hours: Monday-Friday, 8am-8pm ET

Regulatory Contacts

You also have the right to file a complaint with regulatory authorities:

• Consumer Financial Protection Bureau: www.consumerfinance.gov/complaint
• Your State Attorney General: Contact information varies by state
• Federal Trade Commission: www.ftc.gov/complaint