BY ACCESSING OR USING THE ONLINE SERVICES, YOU CONSENT TO THE TERMS OF THIS PRIVACY NOTICE.
Effective Date: January 2, 2020
This Privacy Notice describes how Skills Fund, LLC, its affiliates, and subsidiaries (collectively referred to herein as “Skills Fund”) may collect, share, and use information that is captured while you use the Skills Fund website, mobile applications, and/or other online services related to learning about, applying for, or managing a loan, (collectively, the “Online Services”). The use of “we,” “our,” and “us” herein refers to Skills Fund, and “you” and “your” refers to you as the consumer utilizing Skills Fund’s Online Services.
This Privacy Notice applies to your use of the Online Services. This Privacy Notice does not apply to information that we may collect through offline channels, which include but are not limited to phone calls and physical correspondence.
International Users: This Privacy Notice is intended to cover only customers and other users of the Online Services residing in the United States. Any international users of the Online Services should be aware that by using the Online Services, your information will be transferred to, stored on, and/or processed on servers located in the United States of America. You also understand that U.S. data protection laws may not offer the same protections or rights, including judicial redress, with regards to your personal information as the laws of the country in which you reside. By using the Online Services or providing us with your personal information, you consent to this transfer.
What Information Does Skills Fund Collect and How Does Skills Fund Collect that Information?
Personal Information and Sources
We collect Personal Information that you provide to us on the Online Services via forms, applications, surveys, and other fillable online fields. This “Personal Information” may include your name, address, date of birth, Social Security number, email address, telephone numbers, loan number, account number, driver’s license number, username (if different than your email), password, and other identifying information.
If you choose to use the Online Services, we may also collect information from third parties, such as credit reports and employment information.
We also collect information about your use of the Online Services, such as your transaction history, account balance, and payment information.
Information Collected Automatically
In addition to the Personal Information that we collect from you as described above, we may automatically collect certain information, including Personal Information, from your use of the Online Services. This information may include:
· Usage information, such as which features of the Online Services you access or use or the frequency of access;
· Device information, such as hardware model, operating system, application version number, browser type, or IP address; or
· Mobile device information, such as the unique device identifier assigned to your device, mobile carrier, operating system, and other device attributes.
The information described above may be collected through cookies (defined below), pixel tags (defined below), clear gifs, or other technologies.
Who Do We Share Your Personal Information With?
We do not sell, trade, or otherwise transfer your Personal Information to third parties without your consent, except as described in this paragraph. We may, without your consent, disclose your Personal Information:
· To trusted third parties who assist us in providing the Online Services, processing transactions (such as your student loan application), conducting our business, or servicing you, so long as these parties agree to keep this information confidential, consistent with this Privacy Notice;
· As a corporate asset in the event of a company sale of assets, merger, bankruptcy, or similar corporate transaction;
· When we have reason to believe that such disclosure is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, customers, other users of the Online Services, or anyone else who could be harmed by such activities; or
· To respond to judicial process, to provide information to law enforcement agencies, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, such as to comply with a subpoena or similar legal process.
We may also request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
How Do We Protect Your Personal Information?
We employ reasonable security measures, designed to maintain the confidentiality and security of your Personal Information to protect against the loss, misuse, or alteration of information that we have collected from you through the Online Services. For example, Skills Fund employs policies and procedures to designed to protect Personal Information in accordance with applicable law, including but not limited to the Gramm-Leach-Bliley Act. Unfortunately, no security technology is completely secure, and you should remember that email and the Internet generally may not be a secure means of communication and/or transmitting Personal Information. Personal Information that you share via email is done so at your own risk.
Do We Track Our Visitors Online?
Some web browsers may transmit "do-not-track" or similar signals to the websites with which a user communicates. There currently is no industry standard for how websites must respond when they receive such a signal. The Online Services do not respond to do-not-track signals sent by web browsers.
Some of the content, advertisements, and functionality on the Online Services may be provided by third parties. We also use third-party service providers to provide us with analytics services so we can improve the Online Services. These third parties may collect information about your use of the Online Services through technologies such as cookies and web beacons, and this information may be collected over time and combined with information collected across different websites. These third parties will only collect Personal Information if you provide it directly to them. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. For example, some of these third parties may be members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA"), which provide websites where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit https://www.networkadvertising.org/managing/opt_out.asp or https://www.aboutads.info.
One of the third-party services that we use is Google Analytics, which is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the Online Services and may share this data with other Google services. We have also enabled Google Analytics Advertising features, including Remarketing, so Google may use the data collected to contextualize and personalize the ads of its own advertising networks. The Online Services and third parties, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to the Online Services and report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Online Services. You can learn more about Google’s privacy practices by visiting their website at http://www.google.com/policies/privacy/partners/.
What About Third Party Links in the Online Services?
For What Purposes Do We Use Your Personal Information?
Skills Fund handles your Personal Information for the following purposes:
· ]To provide you with Online Services, fulfill your requests, and process your transactions;
· To communicate to you important information regarding the Online Services, your loan application, and/or other information related to your use of the Online Services;
· For our business purposes, such as data analysis, audits, developing new products, enhancing and improving the Online Services, identifying usage and web traffic trends, and determining the effectiveness of our communications and marketing and promotional campaigns;
· To respond to your inquiries or provide you with customer service or technical support;
· For risk control, to help protect the security and integrity of the Online Services, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements;
· To help us identify and resolve issues that may arise on the Online Services;
· To contact you, if you register a profile with us, via telephone or email;
· For marketing purposes, such as notifying you of company news and promotions;
· To personalize your experience or to improve the Online Services and our offerings by allowing us to customize the content and/or layout of the Online Services based on feedback and information we receive from you; and
· For specific purposes for which we obtain your consent.
What Happens When this Privacy Notice Changes?
We may update this Privacy Notice from time to time. Any updated Privacy Notice will be accessible from the footer of the website or other convenient location. Your use of the Online Services once a revised Privacy Notice has been posted constitutes your acceptance of the revised Privacy Notice.
What are Cookies?
The Online Services also use "cookies" (small data files stored on your device) and other tracking technologies to collect information about your use of the Online Services. The information that is captured about your use of the Online Services may be used in a variety of ways, such as to monitor and maintain information about your visits to the Online Services, to help us identify and address problems, to improve the Online Services, to analyze web traffic trends, and to help protect the security and integrity of the Online Services.
You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use the Online Services, but your experience may be degraded.
What are Pixels?
We may also use pixel tags (also known as “clear gifs,” “Web beacons,” or “1-by-1 gifs”) on our site. These may be used in connection with certain pages of the Online Services or with email messages to measure the effectiveness of our communications and our marketing campaigns, to compile statistics about usage and response rates, to market to you, and to assist us in resolving issues that may arise on the Online Services.
Notice Regarding Social Media Use
Children’s Online Privacy Protection
We do not knowingly collect Personal Information from individuals under 13 years of age without parental consent. If we become aware that a child under 13 is attempting to submit Personal Information, we will inform the minor that he or she is ineligible to do so. We will then remove this information from our records. Our Online Services are not intended for children under 13 years of age.
If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information, including under the California Consumer Privacy Act of 2018 (“CCPA”).
Access to Specific Information and Data Portability Rights
Under the CCPA, you have the right to request Skills Fund 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:
· The categories of personal information we collected about you;
· The categories of sources for the Personal Information we collected about you;
· Our business or commercial purpose for collecting or selling that Personal Information;
· The categories of any third parties with whom we share your Personal Information;
· The specific pieces of Personal Information we collected about you (a “Data Portability Request”)
· If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
· Sales, identifying the Personal Information categories that each category of recipient purchased; and
· Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Deletion
Under the CCPA, you have the right to request the deletion of Personal Information. However, this right does not apply where we need to retain the Personal Information for any of the following purposes:
· Provide you with the Online Services;
· Detect or resolve security or functionality related issues;
· Comply with law;
· Conduct research in the public interest;
· Safeguard the right to free speech; or
· Carry out any actions for internal purposes that you or other consumers might reasonably expect.
We will not discriminate against you for exercising any of your rights under the CCPA. Discrimination under the CCPA includes but is not limited to:
· Denying you goods or services.
· Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Providing you a different level or quality of goods or services.
· Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How To Exercise Your Rights Under the CCPA
If you are a California resident and would like to exercise your access or and deletion rights or make a Data Portability Request under the CCPA, please submit a verifiable consumer request to us by either calling the Toll Free Number at +1 855-218-6733 or email us at firstname.lastname@example.org. If you are making a request under CCPA, only you, or a person registered with the California Secretary of State 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.
The verifiable request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
· Describe your request with sufficient detail that allows us to properly understand, evaluate and respond.
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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provide in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Do You Have Questions?
If you have any questions about this Privacy Notice, please contact the Toll Free Number at +1 855-218-6733 or email us at email@example.com.