Last Updated: March 16, 2020
Our goal at MoneyBloom Inc (“Company”) is to match you with our network of third-party debt relief providers, lenders, financial service providers, aggregators, and marketers (“Network Partners”).
INFORMATION WE COLLECT
The Company collects Personal Information from you in order to support our service. The Personal Information we collect includes non-financial information such as name, phone number, email address, date of birth, mailing address and more. This information is typically collected through our homepage form and our Contact Us page. Additionally, we may collect financial information via our homepage form, including but not limited to, type of debt, estimated credit score, income source and amount, employment information, bank balances, bankruptcy status and more.
In order to offer you a more consistent and personalized experience in your interactions with the Company, information collected through one source may be combined with information we obtain through other sources. For instance, we may receive data from affiliates, aggregators, publishers, marketers, lead generators or other sources. This may include information that allows us to identify you across multiple devices through which you access our website. We may also supplement the information we collect with information obtained from other parties, including our business partners and other third parties.
How We Use Personal Information
The Company may use the Personal Information we collect to:
- Communicate with you including service confirmations, information about particular Network Partners programs in which you have chosen to participate, information about products and services available from the Company and promotional offers and surveys.
- Facilitate communications from Network Partners.
- Customize, analyze and improve our products, services (including the content and advertisements on our website), technologies, communications and relationship with you.
- Enforce our website terms and/or separate contracts (if applicable) with you.
- Prevent fraud and other prohibited or illegal activities.
- Protect the security or integrity of our website, our business, or that of our Network Partners.
- Otherwise, as disclosed to you at the point of collection.
The Company collects and subsequently stores all personal data within the United States.
Disclosing Personal Information
We may share your Personal Information with Network Partners to carry out transactions you request, or to make them aware that you are a candidate for their services. We will only share your Personal Information with third parties who agree to protect your Personal Information and use it solely for the purposes set forth by the Company.
By submitting your contact information to us, you are expressly consenting to be contacted by us or by one or more Network Partners by telephone, email or postal mail. Your information may be going to an aggregator or marketer and not a debt relief or other financial service provider. Your information can be sold multiple times leading to multiple offers from debt relief providers, lenders, financial service providers, aggregators, and other marketers.
In addition, we may share some or all of your information with third party marketers and list managers with whom we have a business relationship, and these third party marketers and list managers may use your Personal Information to communicate with you about other marketing or business offers via telephone, email, direct mail, text message (standard text message rates may apply), or other channels.
We may also disclose your Personal Information in connection with law enforcement, fraud prevention or other legal action; as required by law or regulation; if the Company (or a part of the Company) is sold or merges with another company; or if the Company reasonably believes it is necessary to protect the Company, its clients or the public.
Except as described above, we will not disclose your Personal Information to third parties solely for their own marketing purposes without your consent.
UNSUBSCRIBE FROM COMMUNICATIONS
If you no longer wish to receive promotional communications, you may opt-out of receiving them by following the instructions included in each communication or by emailing or calling us per the information contained on our contact page. If you do not wish to have your personal information collected by any third part, please contact our client service department to actively opt-out of having your personal information shared. To opt-out of our emails contact our client service department from the email address you used with us with “opt-out” in the subject line of your message.
SELL OR SHARE MY PERSONAL INFORMATION
The Company does not share personal information about its clients with third parties; however, if you elect to not employ our services, we may share certain information with carefully selected third party service providers such as your name, phone number, email address and physical address. Under California’s CCPA law, persons residing in California can request we not share their personal information with any third parties. We do not advertise or target our business to consumers who are under the age of 18. If personal information is collected and is discovered to be about an individual under the age of 18, we will immediately take steps to remove this information and cease utilizing any information about that person.
SECURING THE TRANSMISSION AND STORAGE OF INFORMATION
The security of your personal information is extremely important to us. We employ generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
Our site uses SSL (Secure Sockets Layer) security technology to encrypt information you provide to us through the site when entering Personal Information. This ensures that your information is encrypted as it travels over the Internet. SSL is an industry-standard protocol for encryption over the internet.
After information reaches us, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of the Company. Remember, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
If you have any questions about the security on our website, please feel free to email us.
To support the function of our website and to provide you with a personalized experience while visiting our site, we place small data files called “cookies” on your device.
Cookies allow you to take advantage of some of the Company’s essential features. Many browsers are set to accept cookies by default. You have the ability to accept or decline cookies as you prefer. The “Help” portion of your web browser, most likely found on the toolbar, typically tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to decline cookies, you may not be able to sign in or use other interactive features of our website and services that depend on cookies.
Additionally, our site employs “clear gifs” which are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users and help us better manage content on our site by informing us what content is effective. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.
As is true of most websites, the information we automatically gather from cookies and clear gifs is then stored in a “log file.” We use this information to analyze trends, administer the site, track users’ movements around the site and to gather demographic information about our user base as a whole, such as age, gender and income.
We do not link this automatically collected data to personally identifiable information.
LINKS TO OTHER SITES
While we try to link only to sites that share our standards and respect for privacy, we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the applicable privacy policies and terms of conditions of each and every Web site that collects personally identifiable information.
If you send us correspondence, including emails, voice mails, forms and the like, we may retain such information and may, over time, delete these records as permitted by law. Phone calls may be recorded or monitored for client satisfaction or training purposes.
Based upon the personally identifiable information you provide, we may communicate with you to provide the services you request and may communicate via email or telephone, in accordance with your wishes.
We reserve the right to disclose your personally identifiable information, as required, to comply with the law, applicable regulations, governmental and quasi-governmental requests, judicial proceedings, court orders or subpoenas, to enforce our agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others in our discretion.
In the event our company goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email and/or a prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.
RIGHT TO ANTI-DISCRIMINATION
The Company does not and will not discriminate against any customer or client that exercises their rights under the California Consumer Privacy Act. Those rights include requests to access personal information, to delete information, and to opt out of the sale of personal information.
The statutory language specifies that discrimination includes, but is not limited to:
(a) denying goods or services to consumers;
(b) charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
(c) providing a different level or quality of goods or services; and
(d) suggesting that a consumer will receive a different price or quality of goods or services if the consumer exercises rights under the law.
The CCPA provides certain exceptions to the general prohibition on discrimination. Businesses may charge consumers different prices or offer different levels of service if the difference is “reasonably related to the value provided to the consumer by the consumer’s data.” The CCPA also permits businesses to offer financial incentives—including payments to consumers as compensation for the collection, sale, or deletion of personal information—if the programs are not “unjust, unreasonable, coercive, or usurious in nature,” and if businesses notify consumers of these financial incentives, obtain opt in consent prior to enrolling a consumer in a financial incentive program, and provide consumers with the opportunity to revoke consent for such programs at any time.
The Challenge of Calculating the Value of the Data to the Consumer
Prohibited discrimination under the CCPA includes offering different prices, qualities of goods, or levels of service. But businesses are permitted to offer different prices or levels of service, if the difference is “reasonably related to the value provided to the consumer by the consumer’s data.”
The Practical Impacts on Businesses’ Data Sharing Relationships
In light of the broad definition of “sale,” consumers’ right to opt out of the sale of their personal information could disrupt many existing data sharing relationships. Businesses or affiliates exchanging data about their mutual customers, even as part of a broader relationship, could potentially be viewed as engaging in a “sale” if it could be viewed as in exchange for “other valuable consideration.” Such “sale” transfers would therefore be subject to consumer opt out. And this broadly framed right to opt out of the sale of personal information, combined with the anti-discrimination provision, has the potential to significantly impact data-supported business models.
NEW REQUIREMENTS ON CHILDREN’S AND TEEN’S DATA
The CCPA prohibits businesses from selling data of consumers that they have actual knowledge are under the age of 16, unless they have received opt-in consent (i.e., affirmative authorization) for such sale from: (1) for consumers under the age of 13, the consumer’s parent or guardian; or (2) for consumers aged 13-16, the consent of the consumer. A business that willfully disregards the consumer’s age is deemed to have actual knowledge of the consumer’s age. Cal. Civ. Code § 1798.120. The Company does not advertise or target its business to consumers that are under the age of 16. If personal information is collected and is discovered to be about an individual under the age of 16, the Company will delete the information.
ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
If your personally identifiable information changes, or if you no longer desire our products or services, you may correct, update, delete or deactivate same by emailing us, contacting us by telephone or postal mail at the contact information listed below.
REQUEST TO KNOW
You have the right to request that the Company disclose certain information to you about our collection and use of personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The collection of personal information we collected about you;
2. The categories of sources for the personal information we collected about you;
3. Our business or commercial purpose for collecting or selling that personal information;
4. The categories of third parties with whom we share that personal information;
5. The specific pieces of personal information we collected about you; and
6. If we sold or disclosed your personal information for a business purpose, and, if so, the following information: Sales, identifying the personal information categories that each category of recipient purchased; and disclosures of business purpose, identifying the personal information categories that each category of recipient obtained.
SUMMATION OF CONSUMER RIGHTS
The Company adheres to the California Consumer Privacy Act (“CCPA”) by offering the following rights to our consumers. The right to know what personal information we collect, maintain, disclose, or sell about you. The right to delete the personal information we maintain about you. The right to opt-out of the sale of your personal information. The right to non-discrimination for exercising these rights. The ability to use a designated authorized representative to exercise your rights on your behalf.
The Company also provides the ability for you to unsubscribe from marketing communications you may receive via phone, email, or postal mail.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to modify this privacy statement at any time. We will not jeopardize your privacy. The provisions contained in this privacy statement supersede all previous notices or policies regarding our privacy practices with respect to this site. Any and all changes will be made here, to this privacy statement.
We encourage you to check our site frequently to see the current privacy statement to be informed of how we are committed to protecting your information and providing you with improved content on our website in order to enhance your online experience. Upon any material changes to the policy statement, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.