CCPA Privacy Policy
Effective: January 1, 2020
Last Updated: July 1, 2024
INTRODUCTION
We (subsidiaries of Enova International, Inc., operating under the CashNetUSA brand) respect the privacy of your information. This California Consumer Privacy Act (“CCPA”) Privacy Policy is designed to assist California residents in understanding how we collect, use, disclose, share, and retain their personal information both online and offline.
SCOPE AND APPLICATION OF THIS CCPA PRIVACY POLICY
This CCPA Privacy Policy contains information about our privacy practices that is useful to all of our customers regardless of location. However, the CCPA only applies to California residents. Therefore, the rights described herein only apply to California residents.
If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your personal information in that capacity.
NOTICE AT COLLECTION OF PERSONAL INFORMATION
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this CCPA Privacy Policy we will refer to this information as “Personal Information.”
Personal Information Collected
As of June 28, 2022, we no longer offer loans to California residents; however, we continue to service loans that we previously provided to California residents. In the 12 months prior to the Last Updated Date of this CCPA Privacy Policy, we collected the following categories of Personal Information:
- Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, other similar identifiers)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Other type of state identification card number
- Physical characteristics or description (only if we request your driver’s license for identity verification purposes)
- Debit card number
- Telephone number
- Signature
- Bank account number
- Other financial information
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Geolocation data
- Commercial information (records of products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies)
- Professional or employment-related information (including employment history)
- Characteristics of protected classifications under California or federal law (gender, age (40 and older), disability, citizenship status, military status)
- Audio, electronic, visual, or similar information
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, behavior, and abilities
Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). We use Cookies to: (1) estimate audience size and usage patterns; (2) understand and save your preferences for future visits, allowing us to customize our website and services to your individual needs; (3) advertise new content and services that relate to your interests; (4) keep track of advertisements and search engine results; (5) compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and (6) recognize when you return to the website.
Hotjar
We use Hotjar to better understand our users’ needs and to optimize the service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information, please view Hotjar’s privacy page by clicking here.
LiveRamp Authenticated Traffic Solution
When you use our website, we share information that we collect from you, such as your email (in hashed form), IP address, or information about your browser or operating system, with our identity partners/service providers. These partners return an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with service providers to enable interest-based and targeted advertising. To opt out of this use, please click here.
We may use Cookies and similar technologies third-party vendors provide to collect information on user behavior (e.g., screens and pages visited, buttons and links clicked, limited information entered, and user taps and mouse movements). This information enables us to monitor and improve the user experience.
Please see our Terms of Use for additional information about our use of Cookies.
Opt Out Preference Signals
The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt-out and this will be indicated by the “Do Not Sell of Share My Personal Information” button switched on and the “Targeted Advertising” button switched off when clicking on the Cookie Preferences link at the bottom of the website. You can manually indicate your preferences via the Cookie Preferences button linked at the bottom of the website. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
Sources of Personal Information
We collect Personal Information directly from California residents and credit reporting agencies, third-party data providers, marketing partners, advertising partners, web browsers, internet service providers, government entities, operating systems and platforms, and data brokers. We do not collect all categories of Personal Information from each source. In addition, because we no longer offer loans to California residents, we do not actively collect Personal Information from all of these sources but have done so in the past. California customers can still log into their accounts with us in which case we will collect information such as their Internet Protocol address.
Business and Commercial Purposes for Collection
We collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use
- Performing services or offering products on our behalf or for our partners, such as processing credit applications and servicing credit products
- Undertaking internal research for technological development
- Undertaking activities to verify or maintain the quality or safety of our products and services
- Advancing our commercial or economic interests
Disclosure of Personal Information
The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.
We disclosed Personal Information for all of the business and commercial purposes described above. We have not sold or shared Personal Information subject to the CCPA in the twelve (12) months preceding the Last Updated Date of this Privacy Policy. We do not knowingly collect or sell or share the Personal Information of consumers under 16 years of age. We do not collect or process sensitive personal information for the purpose of inferring characteristics about individuals.
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
Your Rights
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, or correct through our interactive webform available here or by calling us toll free at 1-888-994-1389.
Please note that the CCPA’s privacy rights described above do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
The CCPA’s privacy-related rights also do not apply to certain types of Personal Information subject to the federal Fair Credit Reporting Act (“FCRA”). Some of our services are subject to the FCRA and, therefore, exempt from the CCPA on that basis.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
To verify your request, we will match the personal information you submit with the information we have about you. If we cannot conclude your information matches what we have, you may be directed to contact us with further instructions to assist us in responding to your request. To verify your request, you must submit:
- Your first and last name;
- Your Social Security number;
- Your date of birth; and
- Your email or mailing address (depending on delivery preference).
ACCESSIBILITY
Individuals with disabilities who require an accommodation to access this policy or to make a request under the CCPA should contact us via email at support@cashnetusa.com, by telephone at 1-888-801-9075, or by mail at 175 W. Jackson Blvd., Suite 600, Chicago, IL 60604. Please note that we may need advance notice to provide certain accommodations.
CHANGES TO THIS PRIVACY POLICY
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.
HOW TO CONTACT US
To contact us for questions or concerns about our privacy policies or practices please email us at support@cashnetusa.com or by telephone at 1-888-801-9075.