This Policy describes how we collect, use, disclose, and process personal information within the scope of the CCPA. “Personal information” is defined as information that identifies, relates to, describes, or is reasonably capable of being associated with, or could be reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information, or consumer information that is deidentified or aggregate consumer information.
Please note that some of the personal information we process about you may be exempt from the scope of the CCPA because it is subject to other federal privacy laws, such as the Gramm-Leach-Bliley Act (GLBA). Learn more about how we protect your information under the GLBA.
Collection and Disclosure of Personal Information
We collect and disclose personal information to our service providers, contractors, and affiliates in order to perform business purposes such as making or servicing student loan refinance and other credit products, for marketing products we or our affiliates or marketing partners offer, to identify and repair errors that impair our systems and processes, and for analytic purposes to determine the effectiveness of our advertisements and to improve our website (“Site”) and services.
We collect and use personal information that you provide us when you apply for a product or service with us to service your account. We disclose such information to service providers and contractors for business purposes and in accordance with GLBA as described above. In addition, we have collected, shared (as defined below) with third parties, or disclosed to third parties for business purposes, the following categories of personal information subject to the CCPA from consumers in the previous 12 months:
|Category of Personal Information||Collected?||Shared?||Disclosed for a Business Purpose?||Category of Third Party to Whom the Personal Information was Disclosed for a Business Purpose|
|Identifiers, such as name, address, email address, and IP address||Yes||No||Yes||Business affiliates|
|Personal Information Categories Listed in the California Customer Records Law, such as telephone number, financial information such as income and credit bureau information, bank account number, and medical information||Yes||No||Yes||Business affiliates|
|Protected Classification Characteristics Under California or Federal Law, such as age, citizenship, marital status, and veteran or military status||Yes||No||Yes||Business affiliates|
|Commercial Information, such as records of products or services purchased||Yes||No||Yes||Business affiliates|
|Biometric information, such as physiological, biological, or behavioral characteristics that are used to establish individual identity||No||No||No||N/A|
|Internet/Electronic Network Activity, such as browsing history and interactions with our websites||Yes||No||Yes||Analytics providers|
|Geolocation data, such as the physical location of your device.||Yes||No||Yes||Business affiliates|
|Sensory information, such as audio, electronic, visual, or other information that is capable of being used to identify a particular customer||No||No||No||N/A|
|Professional/Employment-related Information, such as employment history||Yes||No||Yes||Business affiliates|
|Non-Public Education Information, such as school completion status, grade point average, college plans, and student financial information||Yes||No||Yes||Business affiliates|
|Inferences, such as profiles generated from visits to our websites||Yes||No||Yes||Business affiliates|
|Sensitive Personal Information, such as social security number, driver’s license number, state identification card number, account log-in credentials, credit or debit card number in combination with security code||Yes||No||Yes||Business affiliates|