Qualify Savings Direct

Effective: August 1, 2024

Last Updated: August 15, 2024

This Online Privacy Policy (“Privacy Policy”) applies to the website located at qualifysavingsdirect.com, Qualify Savings Direct mobile applications, and any other websites or applications associated with Qualify Savings Direct partners, subsidiaries or products that direct the viewer or user to this Privacy Policy (collectively “Qualify Savings Direct Services” or “Our Services”). In this Privacy Policy, the terms “Qualify Savings Direct” or “we” or “us” or “our” refers to Qualify Savings Direct and its respective subsidiaries and affiliated companies. The term “your device” refers to any computer, tablet, smart phone or other device you are using to access our websites or to operate the Qualify Savings Direct mobile applications. Websites that are owned and operated by Qualify Savings Direct may contain links to websites that are owned and operated by other companies. This Privacy Policy does not apply to websites and services that are owned and operated by third parties.

The Privacy Policy includes, but is not limited to:

- What information we collect through Our Services;

- How we collect your personal information;

- How your personal information is used and protected;

- When and with whom we share your personal information; and

- What choices you can make about how we collect, use, and share your personal information;

Please read this Policy carefully and contact us if you have any questions.

By using any of the Qualify Savings Direct services, you consent to the terms of the updated Privacy Policy.

Information We Collect through Our Services and How We Collect It

We collect both personally identifiable information and non-personally identifiable information.

We collect personal information that can identify a visitor or user, including, but not limited to, name, address, email address, state of residence, phone number, amount of unsecured debt, the visitor’s interactions with Our Services, how the visitor heard about us, and other information that the visitor chooses to provide to us, but only when the visitor voluntarily provide it.

The non-personal information we collect includes: the visitor’s browser type, device type, and operating system; area(s) of Our Services visited; date and time of access; host or Internet service provider (ISP) information; and identity of the referring site (any site from which the visitor accessed Our Services).

How We Use Your Information

We may use the information we collect about you through Our Services in order to, but not limited to:

- Provide you with Our Services

- Improve, renew or modify our products and services

- Provide customer service

- Enroll visitors or users who desire lending/debt relief services

- Provide information about Our Services or required notices

- Deliver marketing communications or promotional materials that may be of interest to you and to assist us in determining relevant advertising

- Personalize your experience when using Our Services

- Protect against, identify and prevent fraud, infringement and other potential misuse

- Comply with and enforce applicable laws and relevant industry standards and policies

How We Collect, Use and Protect Social Security Numbers

Qualify Savings Direct may collect Social Security numbers (“SSNs”) in the course of our business. We strive to protect the confidentiality and security of SSNs in our possession, custody or control by: (i) limiting access to SSNs and (ii) maintaining reasonable safeguards to protect against the loss, misuse or unlawful disclosure of SSNs.

How We Use Data Collection Tools

When you visit our website, we use site visit recordation technologies to memorialize site visits, third-party cookies, beacons, tags and scripts to help collect the categories of information above and aggregated information from your internet browser such as your behavior on our website.

Cookies

Qualify Savings Direct may place electronic “cookies” in the browser files of your computer or mobile device when you access Our Services. Cookies are small pieces of text sent by your web browser by a website you visit. Cookies may be either “persistent” cookies or “session” cookies. Persistent cookies are also known as a stored or permanent cookie because they remain on your device until you delete them or they expire. Session cookies do not stay on your device after you close your browser.

Our Services use both persistent and session cookies. Persistent cookies enable us to track and target the interests of our users to enhance the experience of Our Services. Session cookies make it easier for you to navigate Our Services.

We use cookies to improve the functionality of Our Services and to track information about how the website is used in order to continually improve it and tailor it to user preferences. In particular, we may use the information we obtain from your use of our cookies to: (i) recognize your computer when you visit the website; (ii) track you as you navigate Our Services; (iii) improve the usability of Our Services; (iv) analyze the use of Our Services; and (v) to personalize the website for the visitor, including targeting advertisements.

Web beacons and other technologies

In addition to cookies, we may also use other tools to collect non-personally identifiable data about your use of Our Services, such as through the use of “web beacons” (also known as an Internet tag, pixel tag or clear GIF) and analyzing “click stream” data. Web beacons link web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. “Click stream” data is the virtual trail you leave behind while browsing the Internet and viewing our web sites. We use web beacons and click stream data to gather data about visits to Our Services. The data may include information about your device, such as your IP address, but does not identify you by name.

Your Choices

Web browsers are usually set to automatically accept cookies. However, you can typically prevent cookies or selectively accept cookies by adjusting the preferences in the “Help” section of your browser. You can also delete cookies which have already been placed on your device.

If cookies are not accepted, there may be some features of Our Services that will not be available and some may not display properly, which may lead to a less smooth or less personalized browsing experience. Blocking cookies will also prevent web beacons from tracking your activity and prevent us from collecting certain other information, such as your IP address, but we still obtain a record of a visit.

For further general information on cookies and more detailed advice on how to disable and enable them, please go to http://www.allaboutcookies.org.

Site Recordation Technology

We use site visit recordation technology to memorialize site visits, including technology provided by third parties, including Jornaya’s Lead ID or Active Prospect’s TrustedForm, as applicable. We use LeadID and/or TrustedForm to independently document users’ consent to be contacted. We use LeadID and/or TrustedForm to independently document users’ consent to be contacted. The LeadID and/or TrustedForm Script is embedded on our website and collects the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the LeadID and/or TrustedForm Script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browse. For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at https://activeprospect.com/privacy-policy/. For more information about Jornaya’s data use and collection policies and practices, please review the Jornaya Privacy Policy, located at https://www.jornaya.com/consumer-privacy-policy/.

Chat Box Technology

We may also use third-party service providers, such as Intercom, to provide chat services for our clients to communicate with us through our client portal. As you navigate our websites and use the chat systems with Qualify Savings Direct, we attempt to protect your privacy to the maximum extent possible. However, some of the information that we receive through this website and your interactions with the chat systems may be tracked, such as the date you communicate with Qualify Savings Direct, the last day you contacted Qualify Savings Direct, and other messages, comments and conversations made through the chat messages. The chat system collects the information that you voluntarily type in the chat box when you initiate a query through the chat system and respond to a query from the chat system. Additionally, when you are using our chat system, it collects interactions that you have made into the chat system while communicating with a Qualify Savings Direct customer service representative. You can maximize the benefits of your privacy partnership with Qualify Savings Direct by making informed decisions about whether to share personally identifiable information with us through our website. Third party chat box systems may capture, record, or analyze your chat box communications with Qualify Savings Direct. For more information about Intercom’s data use and collection policies and practices, please review the Intercom Privacy Policy, located at https://www.intercom.com/legal/privacy.

Third Party Analytics

We use automated third-party analytics services, such as Google Analytics or Facebook Pixels, to evaluate use of Our Services and to help us improve Our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your name and contact information with these third-party analytics providers; however, the information generated by the cookies about your use of the Site (including your IP address) may be transmitted to and stored by these providers on servers in the United States. These service providers may use this information to evaluate your use of the website, compile reports on website activity for website operators and provide other services relating to website activity and internet usage.

Third Party Advertising Networks

We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash cookies and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this Privacy Policy. We may provide these third-party advertisers with information about you.

To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance www.aboutads.info and the Network Advertising Initiative www.networkadvertising.org. Please note that if you choose to opt out, you will continue to see ads on our Site, but they will not be based on how you browse and shop.

How We Respond to Do Not Track Signals

How do we respond to Internet browser Do Not Track (“DNT”) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services?

We do not currently respond to web browser “Do Not Track” because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses Qualify Savings Direct services?

No.

For more information about Do Not Track, please visit www.allaboutdnt.com.

Security of Internet Communications and Data

We take reasonable security precautions to secure the personally identifiable information that you choose to provide against the loss, misuse, alteration, or unauthorized access of such information. Unfortunately, no method of transmitting or storing data can be guaranteed to be secure, and we do not assume any responsibility for any harm, loss or damage you may experience from transmission of information by or to Qualify Savings Direct over the Internet.

If you believe that the security of any account you might have with us has been compromised, please contact us as provided in the “Contact Us” section below.

Children’s Privacy

Our Services are not directed to individuals under the age of thirteen (13), and Qualify Savings Direct does not seek or knowingly collect personal information from children under the age of 13. Qualify Savings Direct requests that children under the age of 13 not disclose or provide any personal information through Our Services. If you believe that we have received information from a child under the age of 13, please contact us at our email or mailing address listed in the “Contact Us” section below. If we learn that we have received information directly from a child who is under the age of 13, we will take appropriate action in accordance with applicable law. To learn more about the Children’s Online Privacy Protect Act (COPPA), please visit the Federal Trade Commission’s website at https://www.ftc.gov/.

TCPA Consent & Privacy

Notwithstanding any current or prior election to opt in or opt out of receiving telemarketing calls or SMS messages (including text messages) from us, our agents, representatives, affiliates, or anyone calling on our behalf, you expressly consent to be contacted by us, our agents, representatives, affiliates, or anyone calling on our behalf for any and all purposes arising out of or relating to your loan and/or account, at any telephone number, or physical or electronic address you provide or at which you may be reached. You agree we may contact you in any way, including SMS messages (including text messages), calls using prerecorded messages or artificial voice, and calls and messages delivered using auto telephone dialing system or an automatic texting system. Automated messages may be played when the telephone is answered, whether by you or someone else. In the event that an agent or representative calls, he or she may also leave a message on your answering machine, voice mail, or send one via text. You consent to receive SMS messages (including text messages), calls and messages (including prerecorded and artificial voice and autodialed) from us, our agents, representatives, affiliates or anyone calling on our behalf at the specific number(s) you have provided to us, or numbers we can reasonably associate with your account (through skip trace, caller ID capture or other means), with information or questions about your application, loan and/or account. You certify, warrant and represent that the telephone numbers that you have provided to us are your contact numbers. You represent that you are permitted to receive calls at each of the telephone numbers you have provided to us. You agree to promptly alert us whenever you stop using a particular telephone number. Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You also agree that we may contact you by e-mail, using any email address you have provided to us or that you provide to us in the future. We may listen to and/or record phone calls between you and our representatives without notice to you as permitted by applicable law. For example, we listen to and record calls for quality monitoring purposes.

Notice to California Residents

In response to a California law, we will automatically treat individuals with California addresses or telephone numbers (when disclosed to us) as if you requested us to not share your information with nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us.

California’s “Shine The Light” law permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.

In compliance with the California Consumer Privacy Act (“CCPA”), please see the California Privacy Notice.

Notice to Vermont Residents

In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we not share your information with nonaffiliated third parties, and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

Notice to Nevada Residents

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing to [email protected]. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: [email protected].

Governing Law

Business Transfers

In the event that all or a part of Qualify Savings Direct is merged, sold or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), your personally identifiable information will likely be among the assets transferred. We may, in our sole discretion, notify you via email and/or with a prominent notice on our website for 30 days of any such change in ownership or control of your personal information. You may have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Changes to this Privacy Policy

This Privacy Policy may change at any time and from time to time to reflect changing legal, regulatory or operational requirements. If we make material changes, we will post the updated policy on this page and change the “Last Revised” date at the top of this webpage. Any amendments or modifications to this Online Privacy Policy will become effective immediately upon posting. Your continued use of any of Our Services following the posting of an updated version of this Privacy Policy will constitute your acceptance of the updated Policy. If you do not agree with the revised Online Privacy Policy, please discontinue use of any of Our Services.

Contact Us

If you have a question or would like to access and correct personal information you have submitted to us through Our Services, please send a letter or email to the address below with your question or requesting to see your information.

Please address requests to:

Consumer Nsight LLC
Attention: Privacy Inquiries
10055 Yamato Rd
Boca Raton, FL 33498
E-mail: [email protected]