Privacy Policy

Last Modified: January 18, 2024

I. INTRODUCTION

The Smart Loans (“Company,” “Us,” “Our,” or “We”) operates an online platform providing access to information about third-party financial services and products. We prioritize the protection of your privacy and are committed to upholding it through compliance with this privacy policy, along with the Privacy Notice for California Residents (referred to as this “Policy”).

This Policy delineates the types of information we may collect from you or that you may provide when utilizing our website at www.thesmartloans.com, including subdomains (referred to as our “Website”) and associated services (the “Services”), as well as our procedures for collecting, using, maintaining, protecting, and disclosing said information.

This Policy governs information collection:

  • On this Website.
  • In email, text, and other electronic communications between you and this Website, and between you and The Smart Loans.
  • When interacting with our advertising and applications on third-party websites and services, provided they include links to this Policy.
  • When engaging directly with us offline or through other means.

This Policy does not extend to information collected by any third party, including through applications or content (including advertising) that may be linked to or accessible from or on the Website, or through any communication with one of our partners, such as a financial service provider.

Kindly review this Policy thoroughly to comprehend our policies and practices concerning your information and how we intend to manage it. IF YOU DO NOT CONSENT TO OUR POLICIES AND PRACTICES, PLEASE REFRAIN FROM USING OUR WEBSITE OR ANY OF OUR SERVICES. By accessing or utilizing this Website or any of our Services, you agree to this Policy. This Policy may undergo revisions from time to time (see CHANGES TO OUR PRIVACY POLICY below). Your continued usage of this Website or any of our Services subsequent to such changes signifies acceptance of the revised terms, hence please monitor the Policy regularly for updates. Any capitalized terms not defined in this Policy are designated in our Terms of Use [thesmartloans.com/terms-conditions].

Please take note: Our Website and Services are solely intended for access and use by adults and are not directed towards or offered to minors. We do not knowingly collect personally identifiable information from individuals under the age of 18, and you should refrain from providing us with any information regarding such individuals.

II. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Personal Information Collected: We may gather personally identifiable information (“Personal Information”) to utilize as part of our Service. This Personal Information may encompass, but is not restricted to:

  • Name, postal address, email address, telephone number; and/or
  • Any other identifier enabling online or offline contact.

Other Information Collected: Additionally, we may collect the following information (alongside Personal Information, referred to as “User Information”):

  • Information that, while about you, does not singularly identify you, such as income and credit score;
  • Information provided by you about a third party not seeking financial information; and/or
  • Details about your internet connection, the devices you use to access our Website, and usage specifics.

Access to and usage of our Website and Services remain available even if you opt not to provide us with any of the aforementioned User Information. However, certain Website features and Services may not be accessible to you or may lack accuracy or completeness.

You may furnish information about other individuals, such as their name and email address. This information is utilized for its provided purpose. Third parties may contact us at [email protected] to request removal of this information from our database.

Collection Methods: We gather this information:

  • Directly from you upon provision.
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and data obtained through cookies, web beacons, and other tracking technologies.
  • From third parties, such as financial service providers we partner with to furnish information about specific financial products and services. The nature of information received from these third parties is contingent upon their respective policies.

Information You Provide to Us: User Information we collect on or through our Website or Services may encompass:

  • Information provided by filling out forms on our Website, including those for requesting matches to specific financial service providers or submitting material. We may also request information when you participate in contests or promotions sponsored by us, or when reporting issues with our Website or Services.
  • Records and copies of correspondence (including email addresses) if you contact us.
  • Your responses to surveys we may request for research purposes.
  • Details of transactions conducted through our Website or any of our Services.
  • Your search queries on the Website.

The information necessary to receive specific quotes and rates about financial services and products is submitted on a third-party service provider website and is not collected by The Smart Loans unless provided by said third party. The collection and utilization of this information will be subject to the privacy policies of the financial services providers, not this Policy. If you submit such a request to a financial service provider, you may be contacted directly through various means of communication. You may receive telemarketing calls, even if registered on the national do not call registry.

Additionally, you may provide information intended for publication or display (referred to as “posted”) on public areas of the Website or transmitted to other users or third parties, such as Website reviews (collectively known as “User Contributions”). Your User Contributions are posted and transmitted at your own risk. Despite our limitations on access to certain pages, please recognize that no security measures are infallible. Moreover, we cannot regulate the actions of other users with whom you may opt to share your User Contributions, and thus, we cannot guarantee that your User Contributions will remain inaccessible to unauthorized individuals.

Information We Collect Through Automatic Data Collection Technologies: As you navigate and interact with our Website, we may utilize automatic data collection technologies to amass certain information about your devices, browsing actions, and patterns, including:

  • Details of your Website visits, including traffic and location data, logs, and communication data, along with the resources accessed and used.
  • Information concerning your devices and internet connection, such as IP addresses, operating systems, and browser types.

Analytics: We may engage third-party service providers, such as FullStory, to collect non-personally identifiable data on behalf of The Smart Loans. These providers furnish us with information, reports, and analyses concerning the usage, general location, and browsing patterns of Website and Services users. All data collected by these providers on our behalf remains our property.

We lack control over these service providers' use of cookies or other tracking technologies, or how they may be employed. For more information regarding certain service providers, including their privacy policies and opt-out choices, please visit Segment's Privacy Policy, Intercom's Privacy Policy, QuantCast Measure's Privacy Policy, Facebook's Data Policy, Microsoft's Privacy Statement, FullStory's Privacy Policy, and Google Analytics Privacy Policy.

Use of Automatically Collected Information: The information collected automatically constitutes statistical data and may include Personal Information, or we may maintain or associate it with Personal Information acquired through other channels or received from third parties. This data aids us in enhancing our Website and delivering a better, more personalized service, facilitating endeavors such as:

  • Estimating audience size and usage patterns.
  • Storing preferences to customize Website content in accordance with individual interests.
  • Expediting searches.
  • Identifying you upon return visits to our Website.

Technologies: Technologies we may utilize for automatic data collection include:

  • Cookies (or browser cookies): These are small files placed on your computer's hard drive. You can opt to refuse browser cookies by adjusting the appropriate setting on your browser. Nonetheless, selecting this setting may render certain parts of our Website inaccessible. Unless your browser setting has been configured to reject cookies, our system will issue cookies upon directing your browser to our Website.
  • Web Beacons: Our Website pages and emails may contain small electronic files known as web beacons (also termed clear gifs, pixel tags, and single-pixel gifs). These enable The Smart Loans, among other functions, to tally users who have visited specific pages or opened emails, and facilitate related website statistics, such as recording the popularity of particular Website content and verifying system and server integrity.

III. THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Certain content or applications, inclusive of advertisements, on the Website are provided by third parties, including advertisers, ad networks and servers, financial service providers, content providers, and application providers. These third parties may employ cookies independently or in conjunction with web beacons or other tracking technologies to gather information about you while using our Website. The information they amass may be associated with your Personal Information or may include information, including Personal Information, pertaining to your online activities across various websites and other online services. This data may be utilized to furnish you with interest-based (behavioral) advertising or other tailored content.

We lack control over these third parties' tracking technologies or their utilization. For queries regarding advertisements or other tailored content, please contact the respective provider directly. For details on opting out of receiving targeted advertising from multiple providers, refer to CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION below.

IV. HOW WE USE YOUR INFORMATION

Use of Your Information: We employ, store, and process your information to provide and enhance our Services, ensuring a secure, safe, and trusted experience. For instance, we may use information we collect about you or that you provide to us, including any Personal Information:

  • To present our Website and its contents to you.
  • To furnish you with information and additional services you request from us.
  • To fulfill any other purposes for which you provide the information.
  • To discharge our obligations and enforce our rights arising from any contracts executed between you and us, including our Terms of Use, Advertising Disclosure, and Privacy Notice for California Residents.
  • To notify you about changes to our Website or any products or services we offer through it.
  • To enhance the Website and Services.
  • To enable participation in interactive features on our Website.
  • To address correspondence received from you.
  • To resolve disputes.
  • To safeguard against or deter fraudulent, illegal, or harmful activities.
  • In any other manner as may be specified when you provide the information.
  • For any other purpose contingent upon your consent.

We may also utilize your User Information to apprise you of our goods and services, as well as those of third parties, that may be of interest to you. If you prefer we refrain from using your information in this manner, please indicate your preference in the relevant box on the data collection form. For further details, consult CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION below.

We may leverage the information we have collected from you to enable the display of advertisements to our advertisers' target audiences. Although we do not disclose your User Information for these purposes without your consent, clicking on or otherwise engaging with an advertisement may lead the advertiser to presume you meet its targeting criteria.

Duration of Information Storage: We will retain your information for the duration necessary to provide you with the Services, maintain legitimate business operations, and/or assert, defend, or establish our rights.

The length of time we retain your personal information hinges on the purpose for which we collected it and how we utilize it. Nevertheless, we will not retain your personal information beyond what is necessary for our business objectives or legal obligations.

V. HOW YOUR INFORMATION MAY BE USED BY FINANCIAL SERVICE PROVIDERS

If you submit a request for information from a financial service provider matched through our Services, you explicitly consent to said provider conducting requisite research to furnish the information you seek. For instance, to provide more precise information, including specific quotes and rates, financial service providers may need to acquire additional background information about you, such as consumer and credit reports, to ascertain your eligibility for and the pricing of certain financial products and services. These reports may also be utilized for maintaining any purchased products or services going forward. The financial service provider may enlist third parties in connection with these reports. If you do not wish for service providers to conduct the necessary research for furnishing relevant information, refrain from submitting such a request. As the collection and use of this information fall under the purview of the privacy policies of the pertinent service providers, not this Policy, review those policies carefully.

VI. DISCLOSURE OF YOUR INFORMATION

We may divulge aggregated information about our users and information that does not identify any individual, sans restrictions.

We may disclose User Information we collect or you provide, along with information you furnish to us regarding third parties, as delineated in this Policy:

  • To our subsidiaries and affiliates.
  • To financial service providers or their agents or government entities.
  • To other service providers and third parties we engage to support our business, bound by contractual obligations to maintain personal information confidentiality and utilize it solely for disclosed purposes.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Smart Loans' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, wherein personal information held by The Smart Loans about our Website users constitutes transferred assets.
  • To third parties for marketing their products or services to you if you have not opted out of such disclosures. These third parties are contractually obligated to maintain personal information confidentiality and utilize it solely for disclosed purposes. For additional information, refer to CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION below.
  • To fulfill the purpose for which you provided it.
  • For any other purpose disclosed by us when you provided the information.
  • With your consent.

We may also disclose your User Information, along with information you provide regarding third parties:

  • To comply with any court order, law, or legal process, including responding to government or regulatory requests.
  • To enforce or apply our Terms of Use (thesmartloans.com/terms-conditions) and other agreements, such as our Advertising Disclosure (thesmartloans.com/advertising-disclosure) and our Privacy Notice for California Residents (refer to below).
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Smart Loans, our customers, or others, including exchanging information with other companies and organizations for purposes of fraud protection and credit risk reduction.

Telephone Consumer Protection Act Compliance: If you provide a cell phone number along with your contact information, The Smart Loans and/or specified third parties may dial your cell phone number, potentially using an autodialer, to furnish information about your request and/or solicit additional information from you. By providing a cell phone number, you consent to be contacted at that number, irrespective of whether you or another party possesses the cell phone when contact is initiated. Entering into this agreement is not contingent upon purchasing any goods or services.

VII. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We aim to offer you options regarding the User Information you provide to us and that we collect. We've established mechanisms to give you control over your information:

Tracking Technologies and Advertising. You have the option to configure your browser to reject some or all browser cookies or to receive alerts when cookies are sent. If you choose to disable or reject cookies, please note that certain parts of this site may become inaccessible or not function properly.

Promotional Offers from The Smart Loans; Disclosure of Your Information for Third-Party Advertising. If you prefer not to have your email address/contact information utilized by The Smart Loans to promote our own or third parties’ products or services, or if you do not want us to share your User Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending an email stating your request to [email protected]. In case you receive a promotional email from us, you can utilize the “Unsubscribe” link provided in the email to opt-out of such communications.

Targeted Advertising. If you do not want us to utilize the information we collect, or that you provide to us, to deliver advertisements based on our advertisers’ target-audience preferences, you can opt-out by sending an email stating your request to [email protected].

We do not have control over third parties’ collection or utilization of your information for interest-based advertising. Nonetheless, these third parties may provide you with options to opt-out of having your information collected or used in this manner. You can opt out of receiving targeted ads from Google by visiting https://adssettings.google.com/authenticated and from members of the Network Advertising Initiative (“NAI”) by visiting the NAI’s website.

California residents may have additional personal information rights and choices. Please see YOUR CALIFORNIA PRIVACY RIGHTS below for further details.

VIII. HOW WE RESPOND TO “DO NOT TRACK”

Currently, there is no standard or agreement on how to respond to “do-not-track” signals that may be sent by web browsers. Consequently, The Smart Loans presently does not take any action in response to these signals. You can opt out of many advertisers’ use of cookies for tailored advertising by visiting http://www.aboutads.info/choices/.

IX. ACCESSING AND CORRECTING YOUR INFORMATION

You may email us at [email protected] to request access to, correction, or deletion of any User Information that you have provided to us. We may not fulfill a request to alter information if we believe the change would violate any law or legal requirement or render the information inaccurate.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use (thesmartloans.com/terms-conditions).

California residents may have additional personal information rights and choices. Please see YOUR CALIFORNIA PRIVACY RIGHTS below for further details.

X. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see our PRIVACY NOTICE FOR CALIFORNIA RESIDENTS below.

XI. DATA SECURITY

We have implemented measures to secure your User Information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and encrypted using SSL technology.

We advise caution when disclosing information in public areas of the Website like message boards. The information shared in public areas may be viewed by any Website user. Although we employ best efforts to protect your User Information, we cannot guarantee the security of your User Information transmitted to our Website. Any transmission of User Information is at your own risk. We are not liable for circumvention of any privacy settings or security measures contained on the Website.

XII. CHANGES TO OUR PRIVACY POLICY

We follow the practice of posting any changes we make to the Policy on this page with a notice that the Policy has been updated on the Website home page. In case of material changes to how we handle User Information, we will notify you via email to the primary email address we have on file or through a notice on the Website home page. The date of the last revision of the Policy is indicated at the top of the page. You are responsible for ensuring that we have an up-to-date, active, and deliverable email address for you and for periodically visiting our Website and this Policy to check for any changes.

XII. CONTACT INFORMATION

For questions or comments about this Policy and our privacy practices, reach out to us at:

The Smart Loans

1007 N Orange St. 4th Floor

Wilmington, DE 19801, USA

(302) 316-6323

[email protected]

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Last modified: January 18, 2024

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“California Privacy Notice”) supplements The Smart Loans’s Privacy Policy. The Smart Loans has adopted this notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws. It applies only to visitors, users, clients, and other persons if they are California consumers, as defined in the CCPA, and only to “personal information” that is subject to the CCPA (“Personal Information”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

Personal Information We Collect and How We Use It

We may collect some or all of the following categories of Personal Information about California consumers:

Category A: Identifiers, such as a name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“CCR Data”), such as name, signature, contact information, education, employment, employment history, Social Security number, driver’s license number, passport number, financial information such as bank account number, medical information, or health information.

Category C: Protected Classification characteristics under California or federal law (“Protected Classification Characteristics”), such as age, citizenship, gender, marital status, physical illness, mental illness or disabilities, and veteran status.

Category D: Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Category E: Biometric Information, which means physiological, biological, or information that can be used to establish a person’s identity, including fingerprints; face, hand, palm or vein pattern imagery; voice recordings; or sleep, health, or exercise data that contain identifying information.

Category F: Internet or Other Electronic Network Activity Information (“Network Activity”), such as website information, browsing history, search history, or information relating to consumer’s interaction with an internet website, application, or advertisement.

Category G: Geolocation data, such as device location, IP location, or other information about a person’s physical location or movements.

Category H: Audio, electronic, visual, thermal, olfactory, or similar information (“Sensory Data”), such as images, or recorded phone call, audio, or video recordings.

Category I: Professional or employment-related information (“Employment Information”), such as current employment or past job history.

Category J: Education Information, such as your education level and school history.

Category K: Inferences, which are drawn from the other categories of Personal Information to construct a profile about a consumer's preferences, interests, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

How We Use and Disclose Personal Information

Category of Personal Information

Categories of Sources of Personal Information

Categories of Third Parties with whom Personal Information Has or May Be Shared

A. Identifiers

Consumers or observation of consumers or their interactions with us

Service providers Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Third-party product providers Government entities

B. CCR Data

Consumers or observation of consumers or their interactions with us

Service providers Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Third-party product providers Government entities

C. Protected Classification Characteristics

Consumers or observation of consumers or their interactions with us

Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Government entities

D. Commercial Information

Consumers or observation of consumers or their interactions with us

Service providers Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Third-party product providers Government entities

E. Biometric Information

Consumers or observation of consumers or their interactions with us

Government entities

F. Network activity

Consumers or observation of consumers or their interactions with us

Service providers Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Third-party product providers

G. Geolocation Data

Consumers or observation of consumers or their interactions with us

Service providers Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines

H. Sensory Data

Consumers or observation of consumers or their interactions with us

Service providers Data vendors People and entities involved in fraud prevention and detection Government entities

I. Employment Information

Consumers or observation of consumers or their interactions with us

Data vendors Government entities

J. Education Information

Consumers or observation of consumers or their interactions with us

Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines

K. Inferences

Service providers Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Third-party product providers Government entities Ourselves, based upon other Personal Information

Service providers Data vendors Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers, and search engines Third-party product providers Government entities

We have disclosed and may disclose each category of Personal Information listed above to one or more third parties for business or commercial purposes. These purposes may include, but are not limited to:

communicating with consumers

providing customer service and enhancing the customer experience

marketing products and services offered by us or others

analytics, research, design, and development

counting ad impressions, assessing the quality of ad impressions, and auditing compliance

monitoring social media and other online references to us

preventing, detecting, and prosecuting malicious, deceptive, fraudulent, or illegal activity

maintaining or protecting our data and systems and ourselves

providing information to regulators, law enforcement, other governmental entities, and our attorneys, accountants, and auditors

making disclosures required by and otherwise complying with legal requirements or legal, regulatory, or other governmental investigations or processes

any other purposes disclosed to or authorized or approved by a consumer

sharing information with affiliated companies

Your Rights Under the CCPA.

If you are a California consumer, you have the right to request that The Smart Loans disclose to you:

(i) the categories of personal information that we collected about you and the categories of sources from which we collected such information;

(ii) the specific pieces of personal information we collected about you;

(iii) the business or commercial purpose for collecting personal information about you; and

(iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months.

California consumers also have the right to request that we delete personal information we collected from you, subject to certain exceptions.

To make such a request, contact us at [email protected] and indicate in the subject line of your message that you are making a CCPA request. You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA), and certain other laws. Please note that we are only required to respond to two such requests per consumer each year.

You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. The Smart Loans does not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

Changes to this California Privacy Notice.

The Smart Loans may update its CCPA policies and practices from time to time. Any changes will be posted on this website at thesmartloans.com/privacy with an updated revision date.