Last Updated and Effective: January 1, 2020
NOTICE TO CALIFORNIA RESIDENTS
You are visiting a website owned and operated by ARENA PAY and its subsidiaries (collectively, “ARENA PAY ”, “us”, “we”, or “our”) are committed to maintaining your confidence and trust as it relates to the privacy and usage of your information. Please read below and learn how we collect, protect, share, and use your information as part of our technology platforms, and all of our products and services.
Information We Collect
Identifying Information: We collect information that could identify you such as your name, address, telephone number, mobile number, email address, and Social Security Number. We may also collect this type of information from you about others, such as co-borrowers.
Other Information: We also collect information such as demographic data, data about your online activity, and other information that is not used to identify you.
How We Collect Information
Information provided by you: We collect information from you when you enter it or otherwise provide it in connection with an inquiry into our Services. This information could be provided via an online form, over the phone, or via other means in which you interact with our Services.
Information from service providers: Information is collected from third-party service providers, such as credit bureaus and service providers who may have data on your financial profile, home, or other demographic information
How We Use Information
We may use collected information to:
Deliver the products and services you requested
Improve customer service
Improve our Site
Personalize your user experience
Communicate with you about products or services that may be of interest to you
Manage our business
Who Do We Share Your Information With?
ARENA PAY affiliates: We may share information about you or provided by you with the ARENA PAY affiliates.
Network Partners: In submitting an inquiry or using another other Service provided through the Website, you agree that ARENA PAY may share information about you or provided by you with lenders and other third parties which provide services to our consumers in our network (collectively, “Network Partners”) to deliver the products and services you requested. PLEASE NOTE: The Network Partners that interact with you may retain or use your information whether or not you use their services. You should contact these Network Partners directly concerning their privacy and information sharing practices. Pursuant to the contracts between ARENA PAY and its Network Partners, if you select a Network Partner through a ARENA PAY website, ARENA PAY may also receive information about you from that Network Partner including, but not limited to, the amount or disposition of your Loan. ARENA PAY and its Network Partners may exchange information about you, your loan terms, and your accounts for the purpose of providing you with information about financial services and products. ARENA PAY may maintain this information to assist with litigation, regulatory request(s), law enforcement requests, internal analytics, marketing purposes, and any other legally permissible purpose.
ARENA PAY Service Providers: We may share information with Service Providers that perform certain services on our behalf including, but not limited to, credit bureaus, marketing partners, or entities providing business analysis and/or website or product support.
Other Situations: We may also disclose information about you or provided by you at our sole discretion:
In response to a subpoena or similar investigative demand, a court order, a request for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waiveany legal objection or right available to us.
When we believe disclosure is appropriate in order to investigate, prevent, or take action regarding actual or suspected illegal activity or other wrongdoing; to protect and defend the rights, property, or safety of the ARENA PAY Business, our users, our employees, or others; or to enforce our Site’s terms and condition or other agreements or policies.
In connection with a substantial corporate transaction involving the ARENA PAY Business, such as a sale of ARENA PAY or any entity, brand or division thereof, a divestiture, merger, consolidation, asset sale, or bankruptcy.
In connection with state and/or federal licensing requirements regarding the reporting of information contained in the loan inquiries we receive from you. You authorize ARENA PAY to obtain any and all required information from the Network Partners that have interacted with you in order for ARENA PAY to comply with current laws and regulations as well as with any requests from state or federal regulators. This information could include, but is not necessarily limited to, the loan you selected and the terms of the loan you selected.
We may share information with third parties that is not personally identifying, such as aggregated or anonymized data, in our discretion, where not prohibited by law.
Cookies and Do Not Track
The Websites do not support Do Not Track browser settings and we do not participate in any frameworks that respond to Do Not Track signals.
Marketing and Communications
Communications: You may adjust your communications preferences through your My ARENA PAY profile. You may also modify your preferences by clicking on an unsubscribe link at the bottom of certain emails sent from ARENA PAY .
Advertising on third party sites: We may use third-party tracking technology. This technology allows targeted advertisements to you from ARENA PAY Businesses. Some of these advertising companies may be networks that are members of the Network Advertising Initiative which offers a single location to opt out of ad targeting from member companies. The opt-out is available at http://optout.networkadvertising.org/#!/
Updating and Accessing Your Information
The appropriate method(s) for accessing your information, if any, will depend on which Site or services you have used. Depending on the respective Site or service, you may have the ability to view or edit some of your information online using the respective Site or service’s interface. If you have submitted a loan request through us, you can update your information by contacting us at email@example.com. Our address is 4031 University Drive, Fairfax, VA 22030.
How We Protect Your Information
We follow industry standard security measures (including physical, electronic, and procedural measures) to help safeguard your information from unauthorized access and disclosure. We also require employees to comply with information security safeguards, we use encryption in the transmission of your information between your system and ours, and we use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your information.
No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will always remain secure.
Visiting our Websites From Outside the United States
The Site is governed by the laws of the United States and is intended for the enjoyment of individuals connected to the internet from a physical location within the United States only. We make no representation that the Site is governed by or operated in accordance with the laws of any other nation.
Compliance with Children’s Online Privacy Protection Rule
This Website and App are not intended for individuals under 18 years of age, and we do not knowingly collect personal information from individuals under 18. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete the information. If you believe we might have any information from or about a person under 18; please contact us at 1 (800) 555-8733.
Online Tracking Opt-Out Guide
Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org/?c=1
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
How to Contact Us
4031 University Drive
Fairfax, Va 22030
NOTICE TO CALIFORNIA RESIDENTS
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information (the “Notice”).
CCPA Scope and Exclusions
The description in this Notice of our Privacy Practices and your Privacy Rights apply only to California residents whose interactions with us are limited to:
Visiting our consumer websites,
Signing up for email alerts,
Commenting on or contributing to our blogs
Establishing an account that does not include financial products or services, or
The description in this Notice of our Privacy Practices and CCPA Privacy Rights do not apply to the personal information we collect, use or disclose about:
Consumers who initiate or complete the process of applying for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“FIPA”), or
Please note that we may also disclose all personal information (a) to comply with federal, state, or local laws; (b) to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) to cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
The CCPA grants individuals the following rights:
Information. You can request information about how we have collected, used and shared your Personal Information during the past 12 months.
Access. You can request a copy of the personal information that we maintain about you.
Deletion. You can ask us to delete the personal information that we collected or maintain about you. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request
To request access to or deletion of personal information: Email: firstname.lastname@example.org
Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We will ask you to verify your identity when you submit a request.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.