Privacy Policy

This Privacy Policy applies to your access and use of all services (i.e. the information, tools, features and functionality located on creditanddebt.org (together the “Services”)), that are made available by creditanddebt.org through our Websites and downloadable mobile applications, and describes the information that we gather from you, how we use your information, whom we share your information with, the choices you have and the steps we take to protect your information. By using this Website, you consent to the privacy practices described in this Privacy Policy.

In addition, please review our Terms of Use which governs your use of our Services and includes provisions on arbitration, limitation of damages and choice of law.

HOW WE COLLECT INFORMATION

WE COLLECT INFORMATION DIRECTLY FROM YOU

We may collect, both personally identification information and non-personally identifiable information directly from you when you use our Services — for example, when you register to become a Member, when you link your third-party financial accounts, when you transfer money, when you fill out calculators, forms or other fields on our Website, send us feedback, sign up for one of our mailing lists, participate in a survey, etc.  The types of information we collect may include, but not be limited to first and last name, mailing address, social security number, email address, employer, job title and department, mobile telephone and facsimile numbers, assets, liabilities financial account information such as ID and password and financial information such as investments, income, expenses, investible assets, investing risk tolerance or other similar types of information and age, gender, or other similar demographic information when such information is relevant to a particular financial product or service you may have requested.

WE COLLECT INFORMATION WHEN YOU VISIT OUR SITE

When you visit our Site, use our Services or open an email from creditanddebt.org, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation:

WE COLLECT INFORMATION FROM OUR THIRD-PARTY PROVIDERS

Information is collected from third-party service Providers such as our advertisers.

These third-party sources vary over time and include:

We may also, at your direction, receive credit reports or scores from consumer reporting agencies such as TransUnion®, Equifax® or Experian® that provide a mechanism to share your information.  If we combine or associate information from other sources with the information we collect through our Site, we will treat the combined information in accordance with this Privacy Policy and applicable law. However, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, where required by law, we store data we collect from you when you are unauthenticated (not signed in) separately from Member account information that directly identifies you, such as your name, email address or phone number.

WE COLLECT INFORMATION FROM COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technologies such as cookies and web beacons to collect information directly from your device about your browsing activities, your interactions with websites and the device you are using to connect to the internet.

Cookies

We may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device when your browser loads our Website.  We may use both session cookies and persistent cookies. Session cookies are used to store information about your website page activities so you can easily pick up where you left off and don’t have to start navigating a site all over again.  Cookies act as a sort of “bookmark” within the site.  For instance, session cookies can store ordering information needed to make shopping carts work instead of making you remember all the items you put in a shopping cart.  A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site, but you can always remove it (see below).  For instance , if you enter your city or postal code to get local news or weather information, depending on your settings, the data in the cookie is stored so that you will see the same relevant local information when you return to the site.  Saving your preferences with cookies, such as your preferred language, prevents you from having to set your preferences repeatedly.   Please review your web browser “Help” file to learn the proper way to modify your cookie settings.  If you delete, or choose not to accept cookies from our Site, you may not be able to utilize all our Services to their fullest potential.

Web Beacons

Some of our webpages contain web beacons which we use to help deliver cookies on our websites, count users who have visited those websites and deliver co-branded services.  In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us to, for example, develop statistics on how often clicking on an advertisement on creditanddebt.org results in a purchase or other action on the advertiser’s website. It also allows us to understand your activity on the website of a creditanddebt.org Provider in connection with your use of creditanddebt.org Services.

Creditanddebt.org Sites often contain web beacons or similar technologies from third-party analytics providers such as Google Analytics which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations.  Google Analytics helps us perform marketing analytics and to collect behavioral information about how you use our site or other websites.

In addition to cookies and web beacons, our Services can also use other similar technologies to store and read data files on your computer:

Location: We may collect and store information about your location if you enable your computer or mobile device to send us location information and provide us with your consent to do so.  This will enable us to collect, share and process information about your specific location to enhance our Services and provide better offers to you, using things like GPS or Wi-Fi access point information.  We may also use information like your IP address or other device identifiers for approximate location information, like your city or state.

Contacts: When you invite your friends to join our Site by providing their contact information or allowing us to use your address book from your computer, mobile device, or other sites, we may use and store your friends’ contact information.

HOW DO WE USE THE INFORMATION WE COLLECT

We may use your collected information, for example, to:

WHO DO WE SHARE YOUR INFORMATION WITH?

We may share your information with our Providers in connection with providing the products and services you requested. For example, we may share your personal information, such as your name, email, address and social security number with credit reporting agencies to verify your identity in obtaining your credit score or other financial information (when requesting your credit report and score on your behalf, we do not do a hard inquiry; rather, we do a soft inquiry of your credit report, however, if you apply for a line of credit or a loan directly with one or more of our third-party Providers, they may make a hard credit inquiry of your credit file before approving your application.).

We may share information collected directly from you, for example:

  1. When you request to prequalify for a loan or credit card on our Site.
  2. When you request additional or personalized information regarding financial products from third-party financial service aggregators we partner with.
  3. When you request access to your credit report or score.
  4. When you request access to banking, credit card, retirement or investment products on our Site.
  5. When you report a complaint about a product or Provider featured on our Site.
  6. When you request answers or advice through our Site in which case we may provide your information to third-party experts, advocates and advisors.

We may share automatically collected information from you such as your IP address with our Providers when you leave our Site and go to a third-party site to request information or apply for financial products.

We may share your credit report and other personal information with our Providers in order to provide you with recommendations on financial products and services that might be of interest to you.

We may share your information with third-party Providers to support our own internal and business operations. In such cases, service Providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure.

When you choose to share your information on a publicly accessible area of our Site such as a public profile page or any section where you can publicly submit questions to us or our third-party Providers, that information will be available to anyone who is able to access that content, including other users.  When you post things like photos or videos on our Site, if applicable, we may also receive additional related data (or metadata), such as the time, date, and place you took the photo or video.  Please also keep in mind that whenever you voluntarily make other personal information (e.g. your home address) available online for viewing by third parties by posting it on our Site, that information is public and can be seen, collected and used by others. We cannot be responsible for any unauthorized use of such information.

We may offer contests, sweepstakes or other promotions with third-party Providers. If you decide to enter a contest, sweepstakes or promotion that is sponsored by a third-party Provider, the information that you provide will be shared with us and with them. 

We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

We may share aggregate analytics with third-party Providers about how users interact with our Site, including usage patterns for certain programs, content, services, advertisements, promotions and/or functionality.

We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant or to otherwise cooperate with law enforcement activity.  We may also disclose your information when we believe it’s 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 our business, our users, our employees or others. We may disclose your information in connection with a substantial corporate transaction involving our business, such as a sale of creditanddebt.org or any entity, brand or division thereof, a divestiture, merger, consolidation, asset sale or bankruptcy

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

Some of our Websites may include features that are designed to permit interactions that you initiate between our Site and third-party websites or services, including third-party social networks.  For example, you may be able to “like” or “share” content from our Site on other websites or services, such as Facebook, Twitter, Instagram, YouTube, and LinkedIn.

If you use these social features on our Site, both creditanddebt.org and the third-party services that operate those social features may have access to certain information about you and your use of both our Site and theirs. The information we collect in connection with your use of social features, such as usage information, is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.

The collection and use of your information by Providers on our Site is subject to each Provider’s privacy policy and terms of use.  Creditandebt.org has no control over the means by which a Provider uses or discloses your information.  The privacy policies of our Providers may differ from ours. If you request products and services from a Provider on our Site, they may directly contact you with quotes or information via telephone, fax, and/or email. You may also receive telemarketing calls from them even if you are on the National Do-Not-Call Registry or any other similar registry. Please note that these Providers may retain or use your information whether or not you use their services.

HOW DO 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. We regularly back up the information we collect online to protect against loss.  We may keep your information as long as is required by law. If you terminate your Member account, we may retain your data for a period of time in our active systems in order to ensure our ability to satisfy the authorized uses under this Privacy Policy. For example, we may use retained data to prevent, investigate, or identify possible wrongdoing in connection with the Site or to comply with legal obligations. Please note that information may exist in backup storage even after it has been removed from our active databases

However, no data transmission over the internet or any wireless network can be guaranteed to be one hundred percent (100%) secure. As a result, while we strive to protect your information, you acknowledge that there are security and privacy limitations of the internet that are beyond our control; the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third-party. We make no warranty, express, implied or otherwise, that we will prevent unauthorized access to your private information.

ADVERTISING

Advertising allows us to provide, support, and improve some of our Services. Creditanddebt.org does not use what you say in email, chat, video calls or voice mail, or your documents, photos, or other personal files to target ads to you. We use other data for advertising in our Services and on third-party properties.

The ads that you see may be selected based on data we process about you, such as your interests and favorites, your location, your transactions, how you use our Services, your search queries, the content you view, demographic data, location data and the information we may collect about you from the sites and apps of our advertisers and Providers.

CHAT BOT DISCLOSURE

Our creditanddebt.org chat bot is enabled by Drift.com Inc.  The Drift Bot is a set of web-services that enable intelligent services and connections using conversation channels you authorize. As a service Provider, Drift will transmit content you provide to our bot/service in order to enable the service. Your interactions with the bot/service are subject to Drift’s applicable terms of use, privacy and data collection policies.

UPDATING YOUR MEMBER ACCOUNT INFORMATION

Corrections or updates to your Member account information, including your email address, mailing address and credit card information, can be made through your Member account.

OPT-OUT CHOICES

You can choose whether you wish to receive promotional communications from creditanddebt.org by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt-out, you can do so by following the directions in that message.  There are a number of other ways to opt-out of having your online activity and device data collected by us:

Opt-out directly with our Providers.  The following advertising partners offer opt-out features that let you opt-out of use of all or some your information for interest-based advertising:

Google: https://adssettings.google.com

Facebook: https://www.facebook.com/about/ads

Twitter: https://twitter.com/personalization

Opt-out directly with the advertising industry.  You can also opt-out directly with the following interest-based advertising 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

If you have any questions about this Privacy Policy, please contact us at 27762 Antonio Parkway, Suite L1 626, Ladera Ranch, California 92694; compliance@creditswag.com

CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may find it necessary or be legally obligated to update this Privacy Policy from time to time, so please review it frequently. When we do, we will post those changes on this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. You acknowledge that this Privacy Policy is part of our site Terms and Uses, and by accessing or using our Site, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use our Site. Your use of this Site after such modifications will constitute your acknowledgment of the modified Privacy Policy, and your agreement to abide and be bound by it. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

PRIVACY STATEMENT-CALIFORNIA 

This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) addresses how creditanddebt.org (collectively “we”, “us”, “our,” or “creditanddebt.org”) collect, use, and share your “Personal Information” as defined in the California Consumer Privacy Act (“CCPA”) Cal. Civ. Code §1798.100 et seq.  This CCPA Disclosure applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) and describes certain rights under the CCPA regarding your personal information, including:

We also must provide in this online disclosure certain details about our collection and handling of categories of personal information. The information that follows shows the types of personal information we may collect about California residents who are subject to the CCPA, the sources from which we collect it, and the ways in which we use and disclose it.

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have/will collect the following categories of personal information from consumers within the last/next twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, alias, postal address, 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.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.YES
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YES
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.YES
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NO
I. Professional or employment-related information.Current or past job history or performance evaluations.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO

Personal information does not include:

HOW DO WE COLLECT YOUR INFORMATION?

We obtain the categories of personal information listed above from the following categories of sources:

USE OF PERSONAL INFORMATION

Business and Commercial Purposes for Use of Personal Information:

We may also use personal information relating to California residents for one or more of the specific “business purposes” listed in the CCPA:

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

DISCLOSURE OF PERSONAL INFORMATION

In the past 12 months, we have/will disclose each of the above-listed categories of personal information for our business purposes to one or more of the following categories:

DO WE SELL ANY PERSONAL INFORMATION?

Creditanddebt.org does not sell any consumer personal information.

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service Providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service Providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time, we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the revised CCPA Disclosure on our website.

CONTACT INFORMATION

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 949-328-4905
Website: creditanddebt.org
Email: compliance@creditswag.com

Postal Address:

Credit Swag Ventures, Inc.
Attn: CCPA
27762 Antonio Parkway, Suite L1 626
Ladera Ranch, CA 92694

PRIVACY STATEMENT – NEVADA

This Nevada Data Privacy Statement, including any future modifications (the “Statement”), forms a material part of creditanddebt.org’s Privacy Policy. It applies to creditanddebt.org’s treatment of Nevada consumers’ personal information in accordance with Nevada Senate Bill 220 (“SB-220”).  If you are a Nevada “consumer” (as defined under SB-220), the purpose of this Statement is to briefly describe, a) your rights under SB-220; and b) how you may make a request for those rights to be enforced.

YOUR RIGHTS AS A NEVADA CONSUMER UNDER SB-220

SB-220 grants Nevada-based consumers the right to opt-out of the “sale” of their “covered information” by web “operators” to another person in exchange for monetary consideration. SB-220 defines a consumer as a person who seeks or acquires, by purchase or lease, any good, service, money or credit for personal, family or household purposes from the internet, website or online service of an operator.  Under SB-220, “sale” means the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons. The definition of “sale” under SB-220 does not include disclosures of covered information:

EXERCISING YOUR RIGHTS UNDER SB-220

If you are a Nevada consumer and wish to exercise your rights related to SB-220, please contact creditanddebt.org at compliance@creditswag.com.  Please note that if we receive a request from you to exercise your rights, credtianddebt.org has the right to have you take reasonable steps to confirm your identity.  Creditanddebt.org is not obligated to, and will not, give effect to data subject rights unless creditanddebt.org can reasonably verify that the request is a “verified request” (as defined under SB-220).