Effective Date: 01/01/2020
2. Collection of your information
We may collect and store various information about you, including information that you provide to us, information that we automatically collect through your use of the Service, and information from publicly-available sources or third parties, as follows.
a) Information you provide us directly
The information we collect from you will vary depending on the product or service requested. We may ask for certain information such as your first and last name, birth date, telephone number, email address, social security number, income, employment history and other details related to your financial situation when you use our Service. All of the information that we collect from you directly is identified in the forms, other places where you respond to questions, or where you indicate preferences throughout the website.
We may also retain any messages you send through the Service, customer service correspondence (via telephone, chat, text, email or otherwise).
Calls to EBCL or to third-parties through EBCL by you or to you may be recorded or monitored for quality assurance, customer service and/or training.
b) Information That Is Collected Automatically
In addition to the information you provide to us directly, we may automatically collect information about your use of the Service, as described below.
- Log file information. Log file information is automatically reported by your browser each time you access the Service. When you use our Service, our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
- Location information. When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, features and/or products made available via the Service.
- Information from Third-Party Sources. We may obtain additional information from third parties and append it to information we have in our system.
2. Use of your information
We may use your information and/or combine any or all elements of your information for a number of purposes, including:
- To provide you with and manage the Service. We use your information to operate, maintain and provide to you the features and functionality of the Service.
- To communicate with you. We use the information we collect or receive to communicate directly with you. We may send you emails containing promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out.
- To improve the Service and advertise. We may use the information we collect to analyze and improve the Service and to provide advertising to you.
- To protect the rights of EBCL and others. We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of EBCL, its employees or agents, or other users and to comply with applicable law.
- When collecting information across personal devices, and applications. Sometimes, we (or our service providers) may use the information we collect – for instance, IP addresses and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computer), or work with providers that do this, in order to better advertising, content, and features, and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
- With your consent. We may otherwise use your information with your consent or at your direction.
3. How We Protect Your Information
We employ reasonable physical and electronic security measures to protect your Personal Information and other information under our control. We also require employees to comply with information security safeguards and we use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persona from gaining access to your Information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
4. Sharing your information
- Affiliates and Business Partners. We may share Personal Information with controlling entities, entities we control, and those under common control. We may also transfer Personal Information to participating companies in the event of a corporate sale, merger, acquisition, dissolution or similar event.
- Aggregate/Anonymous Sharing. We may also share information we collect about you in an anonymous or aggregated form with our business partners and others.
- As Required by Law. EBCL may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. In addition, we may share certain Personal Information when we believe that doing so is reasonably necessary to protect the rights, property and safety of us and/or others.
We may also share, as may be required or permitted by law, information about your loan to credit reporting agencies or pursuant to legal process.
5. Your Choices
You have certain choices when it comes to the collection, use and sharing of your Personal Information.
Email. If you have provided us with your email address and we use that email to send you promotional email messages, you can request that we stop sending such promotional messages by following the unsubscribe link at the bottom of each email.
SMS Messages. If you have provided us with your cellular telephone number and opted into receiving SMS Marketing Messages, you can subsequently opt-out by texting DND to any message.
Marketing. If you do not want us to share your Personal Information with third parties for marketing purposes, please download and complete the opt-out notice below.
Cookies. You have the ability to disable or delete cookies through your browser. If you disable or delete cookies, portions of the Site may not function properly or at all.
6. Right to Access Information
- You may have the right to access the Personal Information we maintain that pertains to you. In order to access your Personal Information, please submit a request in writing to email@example.com; The request should include your full name and address. Within 30 business days of our receipt of your request, we will send you a copy of your Personal Information by mail or email.
- In order to correct, amend or delete any of your Personal Information you should submit a request in writing to firstname.lastname@example.org; The request should include your full name and address and identify the specific information you are asking us to correct, amend or delete, and state the reason(s) for your request. Within 30 business days of our receipt of your request, we will notify you by mail or email either that we have made the correction, amendment or deletion, or that we refuse to do so, in which case, we will provide you with the reason(s) for our refusal, which you will have an opportunity to challenge.
- In order to limit our sharing of your Personal Information, except as permitted by law, you should submit a request in writing to email@example.com; The request should include your full name and address. Within 30 business days of our receipt of your request, we will notify you by mail or email either that we have stopped sharing your information.
- To learn more about how and who we share your information with, please download our federal notice.
7. Your California Privacy Rights:
The California Consumer Privacy Act (CCPA) gives California residents the right to make the following requests:
- Right to Know and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
Once we receive your request, we will disclose to you the following:
i. The categories of personal information we collected about you.
ii. The categories of sources for the personal information we collected about you.
iii. Our business or commercial purpose for collecting or sharing that personal information.
iv. The categories of third parties with whom we share that personal information.
v. The specific pieces of personal information we collected about you
We may deny your request for access if we are unable to verify your identity or have reason to believe that the request is fraudulent.
- Right to Delete. You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. Once we receive your request, we will delete (and direct our service providers and third parties to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the personal information is necessary for us or our Service Providers to:
vi. Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
vii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
viii. Debug to identify and repair errors that impair existing intended functionality.
ix. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
x. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
xi. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
xii. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
xiii. Comply with a legal obligation.
xiv. Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Additionally, we may deny your request to delete if we are unable to verify your identity or have reason to believe that the request is fraudulent.
- Right to Opt-Out. The CCPA provides consumers with the right to opt-out of the sale of your personal information. We do not and will not sell the Personal Information of minors under 16 years of age without affirmative authorization.
- Right Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
xv. Deny you services.
xvi. Provide you a different level or quality of goods or services.
TO SUBMIT A REQUEST PLEASE USE THE LINK BELOW TO COMPLETE THE REQUEST FORM. YOU WILL THEN RECEIVE A VERIFICATION EMAIL FROM US TO ENSURE YOUR IDENTITY BEFORE WE TAKE ACTION ON THIS REQUEST. BE SURE RESPOND TO THAT VERIFICATION EMAIL; OTHERWISE, WE CANNOT RESPONSIBLY FULFILL YOUR REQUEST.
8. Children’s Privacy:
EBCL does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
9. Changes to this Policy: