1. We collect personally identifiable information that can identify you such as your name, address, telephone number, mobile number, e-mail address and Social Security Number (“Personally Identifiable Information” or “PII”). We also collect information such as demographic data and data about your online activity on our website that does not identify you (“Non-Personally Identifiable Information” or “Non-PII”). PII and Non-PII are known together as “Information”. We may also collect and store Information that you provide to us about other people (such as co-borrowers), including their name, address, telephone number, mobile devices, email address and Social Security Number. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested, for example job applicants who submit resumes.
2. Information from Third Parties. We may obtain information about you from vendors, contractors, and other third parties. You authorize EAFCC and Lenders to obtain a personal credit profile from credit bureaus for credit pre-qualification and identity verification. You further agree that we may verify your identity and the information you provide us with third parties.
4. We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our website, to improve its usability and for evaluating our marketing effectiveness as described above. We may also use that information to recognize your computer when you visit our website (if you select the “remember me on this computer” option), and to personalize our website for you. We may also use that information to recognize your computer and display certain marketing messages when you or someone using your computer visit(s) our website and/or other websites. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools,” “Internet Options,” “Privacy,” and selecting “Block all cookies” using the sliding selector). However, blocking cookies can also have a negative impact on the usability of our website.
7. Responding to “Do Not Track” Signals. Some web browsers have a “Do Not Track” function that allows you to tell websites that you do not want to have your online activities tracked. EAFCC is not currently set up to respond to these “do not track” signals.
8. Other Technologies. We may use web beacons and other standard Internet technologies to track your use on our websites. Web beacons (also known as clear gifs, pixel tags, targeting and re-targeting pixels, third party pixels or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon.
9. We may use Information to:
- Deliver the products and services you requested;
- Manage your customer relationship and provide you with customer support;
- Research and analyze your use of, or interest in, our products, services and content and the products, services and content offered by others;
- Communicate with you via e-mail, telephone, postal mail and/or mobile devices about products or services that may be of interest to you;
- Develop and display content and services tailored to your interests on our website and other websites;
- Enforce our terms and conditions;
- Develop and deliver targeted advertisements;
- Measure the overall effectiveness of our online advertising, content, programming and other activities;
- Verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;
- Manage and operate our business; and
- Enable our financial services partners to implement automatic payments and fund transfers;
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account; or
- Comply with our legal obligations or as otherwise permitted by law.
10. Certain personal information must be supplied during the registration processes, as indicated below, in order to (a) enable users to login to the website, (b) determine eligibility for loans using our proprietary credit scoring process, (c) verify your identity and the identity of any proposed cosigners, (d) establish borrowers’ ability to request loans by verifying that they are at least 18 years of age, (e) identify or guard against potential fraud, and (f) abide by anti-terrorism laws and regulations.
11. We may use your financial information to provide loan offers to you from Lenders or to match you with potential loans and services that you may be eligible to receive.
How and When Information Is Shared
We may share your information with:
12. Service Providers. EAFCC shares your personal information with authorized service providers that perform services on our behalf. These entities include credit bureaus, fraud databases, collection agencies, electronic payment service providers, customer support call centers, and companies that support surveys, marketing services, or other services and features that we offer. We share information with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services on our behalf. These third parties are not permitted to share or use such information for any other purpose. Third parties or their servers may be located within or outside of the United States.
14. Special Notice to California Residents. We will not share any personal information about you with any of our affiliated companies to the extent prohibited by applicable California law or to the extent your prior consent to share is required by applicable California Law.
15. You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choice.
16. We are required by the California Financial Information Privacy Act to provide this notice to you annually. We will also send you an additional notice each year that tells you about your privacy rights under federal law.
17. This Privacy Notice applies to EAFCC.
19. The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
20. The names and addresses of the third parties that received that information; and
21. If the nature of the third party’s business cannot be determined from its name, examples of the products or services marketed.
22. We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is .
23. Special Notice to Vermont Residents. We will not share any personal information about you with our affiliated companies to the extent prohibited by applicable Vermont law or to the extent your prior consent to share is required by applicable Vermont law. For purposes of compliance with the Vermont Consumer Protection Act, if you are a resident of the State of Vermont and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please contact us at . In addition, under Vermont’s Fair Credit Reporting Statute, 9 V.S.A. Section 2480e, and the Fair Credit Reporting Rule CF 112, each lender is required to obtain your consent prior to assessing a credit report. EAFCC only performs a soft inquiry and its lenders generally may obtain a soft inquiry prior to posting back an offer, not all lenders will do a soft inquiry and you should note that each form provides that you are providing such express consent upon clicking any “button” for submission of the inquiry and to be matched. While Stairway Lending will not perform a hard inquiry into credit, read each disclosure carefully for each product and/or service sought to ensure you are providing the appropriate consent and that for certain products lenders/providers may in fact perform a hard inquiry of credit and you are providing express consent to the same. EAFCC
24. Additional Disclosure. We may disclose your personal and financial information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to establish, protect, or exercise our rights, defend against legal claims, or as otherwise required by law. We may also disclose your personal and financial information to respond to a subpoena or similar investigative demand, court order or request for cooperation from a law enforcement or other government agency, or legal process served upon us. We may also share your information with third parties in connection with a substantial company transaction, such as the potential or actual sale of all or a portion of our business, a merger, consolidation, asset sale, or bankruptcy.
25. Updating and Accessing Your Information. You can access all of your personal and personally identifiable information that we collect from you through this website by visiting your profile in the My Account section of our website. This section of the website is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone number, and financial account information at any time on the website, and if you need to change any other information in your profile, you can contact us at .
26. Non-Personal and Aggregate Information. We may retain and share non-personal information we collect and information about you and other customers collectively that is not personally identifiable. This includes (for example) information about your computer and visits to our website and/or other websites. We may combine it with non-personal information we obtain from other sources, and may share any aggregated information in any form with third parties. You may not access or correct your non-personal or aggregate information.
28. We take industry standard security measures (including physical, electronic and procedural measures) to help safeguard your PII from unauthorized access and disclosure. In addition to the restrictions outlined above, we require employees to comply with information security safeguards, we use encryption in the transmission of your PII between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your PII.
29. No system can be completely secure, and we do not warrant and you should not expect that your personal information, transactions, or communication will always remain secure. Users should also take care with how they handle and disclose their PII. Please refer to the Federal Trade Commission’s website for information about how to protect yourself against identity theft.
30. Safeguards. We use appropriate physical, technical, and procedural safeguards to protect your personal information from unauthorized access and disclosure. We encrypt the transmission of your personal information over the internet and only permit authorized employees, business partners, Lenders, and third-party service providers to have access to your personal information. We encourage you to take care when you handle or disclose your personal information, including passwords.
31. Children’s Privacy. We do not knowingly collect, maintain, or use personal information from our website about children under age 18. If we learn that we have collected information from a child under the age of 18, we will promptly take all reasonable steps to delete the information. Choices
32. You may choose not to provide us with personal information. However, we will be unable to provide you with our Services if you do not provide us with personal or financial information. Furthermore, due to the nature of our services, you may not opt out of the transfer of personal information to Lenders.
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