Effective Date: November 1, 2021
TABLE OF CONTENTS
- Transfer of Information to the United States
- Collection of Personal Information
- Information Provided by You
- Information Automatically Collected
- Information from Other Parties
- Aggregate Information
- Sources of Personal Information
- Use and Disclosure of Personal Information
- Protection of Personal Information
- Third-Party Information Collection
- Do Not Track
- Links to Third-Party Websites
- Your California Privacy Rights
- Consent and Changes to the Policy
TRANSFER OF INFORMATION TO THE UNITED STATES
This Site is controlled, operated, and administered by OPA from its offices within the United States and is intended to serve individuals interested in services from or employment with OPA in the United States. If you are accessing this Site from a location outside the United States, you acknowledge and consent to the collection, storage, processing, and transfer of your Personal Information to our facilities in the United States and to any other parties with whom OPA share it as described in this Policy. Please note that privacy laws in the United States may not offer the same protections as the laws of other countries. Without limiting the above, for the avoidance of doubt we do not have an establishment or target people in the EEA or UK.
COLLECTION OF PERSONAL INFORMATION
Through your use of the Site or when you contact us to inquire about or apply for services (collectively, “Interactions”), OPA may collect “Personal Information,” which is any information that, either on its own or together with other collected or known information, can reasonably be used to distinguish or trace your identity. OPA may collect the following categories of Personal Information:
- Personal or government identifiers, such as your first and last name, alias or previous name, postal address, telephone number, facsimile number, unique personal identifier, signature, Social Security number, national identification number or other government-issued identification number, driver’s or operator’s license number, passport number, and alien registration number.
- Device and online identifiers and related information, such as email address, account username and password, cellular, mobile, or wireless number, and social media profile.
- Demographic information, such as your date of birth, gender, physical characteristics or description, language skills, number of children, and household income data.
- Financial information, such as your credit or debit card information, bank account number, and other financial information.
- Protected characteristics, such as your gender, race, sexual orientation, age, or any other protected classifications under applicable law.
- Commercial information, such as records of your current or past addresses.
- Geolocation data, such as current location, address, and location history.
- Communications, such as call logs, the content of text messages or emails that you send to us, message board or forum posts, poll or survey answers, reviews, or information you may share when you contact us with questions or feedback.
Information Provided by You
OPA collects the Personal Information that you provide to us. If you choose to contact us to learn more about our services, OPA may collect information such as your full name, telephone number, and email address. OPA will also collect any other information that you provide to us, such as your questions, comments, or feedback as well as any responses you provide in surveys that OPA may send to you from time to time.
If you are a current or prospective borrower, OPA may collect additional information as part of your application or in the course of your loan, such as your current or prior address(es); contact information, such as your telephone number or email address; date of birth; Social Security number or other national identification number.
If you apply for employment with us through the Site, OPA collects information associated with your application, such as your contact information and resume.
Information Automatically Collected
OPA may automatically collect the following types of information when you use the Site, which is not Personal Information:
- Usage Information: We collect certain information automatically through your use of the Site, such as your Internet Protocol address, which pages of the Site that you access, the frequency of access, and what you click on while on the Site.
- Location Information: We may collect information about your location which may be determined from your IP address.
- Device Information: We may collect information about the device you are using to access the Site, such as your unique device identifier and serial number, hardware model, operating system, application version number, browser, and other device attributes.
- Mobile Device Information: In addition to the Device Information listed above, when you access the Site via a browser on your mobile device, we may also collect mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.
Information from Other Parties
OPA may also collect information from other parties, such as identity and Office of Foreign Assets Control verification services.
Aggregate Information. OPA may collect statistical or aggregated information that does not directly identify a specific person but is derived from your Personal Information. For example, OPA may aggregate Personal Information to calculate the percentage of Site visitors in a particular ZIP code. To the extent any non-Personal Information is aggregated with Personal Information, we will treat the aggregated data as Personal Information.
SOURCES OF PERSONAL INFORMATION
- OPA collect the Personal Information described above from the following categories of sources:
- Other parts of our business, including subsidiaries, and affiliates, some of which do not share our name or branding.
- Our service providers, such as loan servicers, donation services, payment processors, or website hosting providers.
- Financial institutions.
USE AND DISCLOSURE OF PERSONAL INFORMATION
We use the Personal Information that we collect for the following purposes:
- In connection with the loan application or employment application process, such as determining your eligibility for financing for a loan or suitability for employment, confirming your identity, or completing the loan process.
- To provide services that you request or fulfill our contractual obligations to you, such as completing transactions on the Site.
- To communicate with you, such as notifying you about updates to the Site or your loan or employment application.
- For marketing or promotional purposes, such as informing you of special promotions or offering you additional products or services that may be of interest to you.
- For specific purposes for which you provide consent, such as if you consent to fill out surveys regarding products and services provided by us, our affiliates, or partners.
- To provide customer service or technical support, such as contacting you in response to your inquiries, comments and suggestions or when otherwise necessary.
- To debug, maintain, and improve our services, such as tracking use of the Site for internal market research or Site improvement; and
- To protect the OPA, its employees, or others, such as to detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activities.
We disclose the following categories of information for our or our service providers’ operational purposes, or other notified purposes:
Personal or government identifiers
- Device and online identifiers and related information
- Demographic information
- Financial information
- Protected characteristics
- Internet, application, or network activity information
- Commercial information
- Biometric information
- Sensory information
- Geolocation data
- Household information
- Inferences drawn from Personal Information
We may disclose this information, for the following purposes:
- With our service providers or independent contractors: We may share information with other parties that help us perform functions and process your transactions.
- Within our corporate family: We may share information with our affiliates, joint ventures, or other companies under common control with us, to the extent permitted by law.
- If there is a change in corporate structure: We may share information in connection with a proposed or actual merger, acquisition, consolidation, change of control, or sale of all or a portion of our business or property or if we undergo bankruptcy or liquidation.
- To prevent harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
- For legal purposes: We will share information where we are legally required to do so, such as in response to court orders or legal process; to establish, protect or exercise our legal rights; to defend against legal claims or demands; or to comply with applicable legal requirements.
- For legitimate business purposes: OPA reserves the right to share information with other parties for our legitimate business purposes, to the extent permitted by law.
- With your consent: We may request your permission to share your Personal Information for a specific purpose. OPA will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
- Without identifying you: OPA may share information in a manner that does not identify you. For example, we may share anonymous, aggregate information about your use of our Site and products with our service providers.
We may share Personal Information with the following categories of third parties for valuable consideration (which may be “sales” in some jurisdictions):
- Members of our corporate family, including our affiliates.
- Service providers, such as advertising and marketing providers, payment processors, and analytics companies
- Management companies
We do not engage in these disclosures for Personal Information of minors under age 18 without affirmative authorization.
PROTECTION OF PERSONAL INFORMATION
The security of your Personal Information is important to us. We maintain reasonable physical, technical and administrative security measures to protect and limit access to your Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
OPA may, directly or through our third-party service providers, collect information through “cookies.” Cookies are small strings of text sent by our Site to your browser and then stored by your browser on your device’s hard drive. Cookies help us understand how you use our Site and other linked sites so that we can personalize and improve your experience on our Site. Most web browsers automatically accept cookies, but you may change your browser settings, so it won’t accept cookies. In order to create a profile on our Site, you must have your cookies turned on.
THIRD-PARTY INFORMATION COLLECTION
DO NOT TRACK
Certain web browsers may allow you to select a Do Not Track privacy setting that requests websites to disable tracking when you visit them. The Site does not currently respond to Do Not Track signals sent by web browsers. Third parties, such as analytics service providers, may collect data that relates to you on our Site. We cannot control whether such third parties respond to Do Not Track signals.
LINKS TO THIRD-PARTY WEBSITES
Our Site may offer links to other websites operated by third parties for your convenience. Such third-party websites may have information, policies, and practices different from our Site. OPA does not control and is not responsible for the privacy policies, practices and/or content of such third-party websites. Please contact such third-party websites directly for information regarding such websites.
The Site is not directed to, nor do we knowingly collect information from, children under 18 years of age. In compliance with the Children’s Online Privacy and Protection Act, if you become aware that your child or any child under your care that is under the age of 13 has provided us with information without your consent, please contact us at 617-404-9797.
YOUR CALIFORNIA PRIVACY RIGHTS
In addition to the rights described above, California residents who provide Personal Information to us in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information that we disclosed, if any, to other businesses for their own marketing purposes in the immediately prior calendar year. This request may be sent electronically by email to supportOPA@onepercentforamerica.org or by phone at 617-404-9797. We will respond to these requests within 30 days. Requests for this information that come to us through other channels may result in a delayed response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
CONSENT AND CHANGES TO THE POLICY
By using this Site and providing us with Personal Information, you have consented to our contacting you by email to provide you with information relating to your inquiry. You may opt out of any future commercial email messages from us by choosing the link in our emails with instructions on how to remove yourself from our email list.
We reserve the right, at any time, to make changes to this Policy. Please check this page periodically for the most recent version of this Policy. Unless otherwise stated, any changes will be effective immediately upon posting to the Site. Your continued use of this Site after any changes have been made will constitute acceptance of the revised Policy.
Should you have other questions or concerns about this Policy, please send us an email at supportOPA@onepercentforamerica.org.