How our Site Works. Our Site provides online marketplace and information services for personal financial products, including credit cards, personal loans, automobile (auto) loans and similar products (collectively, “Products”). In doing so, we act as intermediary between Users who are interested in such Products, and a variety of non-affiliated banks, lenders, and other financial services institutions (“Providers”) who provide opportunities to apply for such Products. Product opportunities are presented as display advertisements on our Site that, when clicked on, take you to the website of a Provider.
Part of our Service is to select Product opportunities that might interest you through our Inquiry process. An “Inquiry” occurs when you choose to submit Information to us through a form on our Site so we can retrieve and show you opportunities for credit cards, loans, or other Products. We are NOT a bank, lender, credit card issuer, or any other type of creditor, and therefore DO NOT make loans or credit decisions in connection with loans or issuing credit cards. We offer marketing and other business services to the Providers who advertise their Product opportunities through our Site. We do not endorse or recommend any particular Provider, or the Products of any such Provider.
Information We Collect
Personally Identifiable Information (“PII”): We collect personally identifiable information from you when you voluntarily provide such information, such as when you access, complete and/or use one of our online forms, tools or content items, contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Personally Identifiable Information is information that can identify you such as your name, address, social security number, telephone number, cell phone number, and email address. PII could also include information you may provide on others, such as co-signers.
Non-Personally Identifiable Information (“NPII”): We also collect demographic data, online activity data, and other information which could not be used to identify you.
How We Collect Information
- The Internet Protocol (IP) address and domain used. (The IP address is a unique numerical identifier assigned either to your Internet service provider or directly to your computer.)
- Type of browser and operating system used
- Device type and ID
- Date and time of your visit to the Site
- Web pages you visited
- Actions you performed or attempted, including clickstream data
- Codes that correspond to the status of your actions
- The geographic location of the computer or mobile device you use to access the Site
We may also capture your email address when you enter it on one of our application forms, regardless of whether you submit the entire form.
The above information is used to improve the content and/or layout of the Site and establish your Member Account. We do not sell or rent any information we collect automatically. We also do not share this information with third parties; provided, however, that we may share information with our Product Providers in order to process any services you have requested or other everyday business purposes such as fraud prevention. We may also engage in geo-tracking and/or geotagging activities. We may combine this automatically collected log information with other Information we collect about you.
Information You Provide to Us. We may collect, store, and use personal or financial information you provide to us when using the Site or our Services. This Information could be provided via an online form, over the phone, by text, or via other means in which you interact with our Services. This information may include your name, address, social security number, telephone number and e-mail address, if you have given us that information. Financial information includes any information you have provided using the Site regarding your bank accounts, credit or debit cards, loans, or other financial relationships or circumstances. We may use information you provide:
- To process and select Product opportunities to present to you
- To process any Services or Products you have requested or selected
- For fraud prevention purposes
- To make the Site more useful and easier to use
- For everyday purposes in operating our business
Information from Third Parties. In the course of providing our Services, Information about you may be collected from third party service providers, such as social networks, credit bureaus, and other data vendors who have data on your financial profile or other demographic information.
Local Device Storage and other Tracking Technologies. Our Site may place and/or store code or other types of information and/or devices (e.g., “cookies”) on your computer, mobile or other device (collectively “Local Device Storage”). We may use Local Device Storage for any lawful business purpose, including without limitation to determine which of our messages have been opened by recipients so we can gauge the effectiveness of marketing campaigns, to track usage patterns, the movements of individual users, your geographic location, to help diagnose problems with our servers, to gather broad demographic information, to analyze trends, to conduct research, to deliver editorial content, to record registration and personalization information, and to otherwise administer the Site and/or Services. For example, if you register on any part of the Site and are given the option to save your username and password, we may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your personally identifiable information, which may be shared with our parent, subsidiaries, and affiliates and other companies.
If you do not want us to use Local Device Storage, your computer, mobile or other device may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of our Services may not function properly.
In addition to Local Device Storage, we may use web beacons, web bugs, tracking identification codes, clear gifs, and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”). We use Tracking Technologies for all or some of the same lawful business purposes we describe above for use of Local Device Storage.
How We Use Your Information. We may use your Information to:
- Deliver the services you requested from us, including in the selection of Product opportunities that might interest you
- Transmit Information to Product Providers you select
- Improve our Site, customize your experience and otherwise operate our business
- Improve customer service
- Communicate with you about your online Paydayfly account (“Member Account”)
We also use your personal, demographic and profile data for statistical analysis and for editorial or feedback purposes for our advertisers and Product Providers. Information collected by us may be added to our databases and used for future e-mails or postal mailings regarding site updates, new products and services, upcoming events, and/or status of orders placed online. We often conduct research on our User demographics, interests and behavior based on the data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents, lenders and Product Providers. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective card issuers, lenders and other Product Providers, and to other third parties for other lawful purposes. We also have the right to use your name in connection with the submitted materials and other information as well as in connection with all advertising, marketing and promotional material related thereto.
We may also use your Information for certain legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any Information (including PII) as reasonably necessary to:
- Protect the rights, safety, and security of our Users, our Services or equipment, or any third party partner or Product Provider
- Detect, prevent, investigate, or otherwise mitigate fraud, security or technical issues related to our Services or our Product Providers
- Comply with any applicable law, regulation, subpoena or legal process; respond to any governmental requests; and/or cooperate with law enforcement, if we believe such action is required or permitted by law
Who Do We Share Your Information With? We are not in the business of selling your Information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Information with certain third parties without further notice to you, as set forth below:
Product Providers. Product Providers include the credit card providers, lenders and other third parties who provide Product opportunities to our Users. When you submit an Inquiry through the Site, you agree that we may share your Information with these Providers so that they can provide the products or services your requested. The Providers with whom we share your Information may retain or use your Information whether or not you buy their products or use their services. You should contact these Providers directly to learn about their own privacy and information sharing practices.
Paydafly Vendors. To the extent necessary, we may share your Information with vendors that perform certain services on our behalf. Vendors may include, but are not limited to, credit and other types of data bureaus, marketing companies, business analysis firms, email, texting and other communications firms, and technology providers.
When you publicly post information or content. We may provide opportunities on the Site for you to publicly post reviews, comments, or other content, which may include Personal or Member Profile Information, like your name or username. Please carefully consider what you decide to share in these public forums.
Other Situations. We may also disclose your Information in the following circumstances, at our sole discretion:
- In response to a court order, subpoena, or similar investigative demand; a request for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency; to establish or exercise our legal rights or defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right available to us.
- In order to detect, prevent, or otherwise address security or technical issues related to our Services or our Product Providers or other partners.
- In connection with state and/or federal licensing and registration requirements which may require the reporting of Information from loan inquiries we receive from you. You authorize us to obtain any and all required information from Providers whose products or services you have purchased in order for us to comply with current laws and regulations, as well as with any requests from state or federal regulators. This information could include, but is not limited to, the terms of the loan you selected.
- In connection with a corporate transaction, such as a sale, divestiture, merger, consolidation, asset sale, or bankruptcy of BMG or any entity, brand or division thereof.
We may share NPII (Non-Personally Identifiable Information) with third parties, at our sole discretion. There may also be certain situations in which we share your PII after receiving your express consent.
Interest-Based and Third-Party Advertising
How to Opt-Out of Third-Party Tracking Technologies. You may opt out of future advertisements by following the unsubscribe rules in the third-party privacy policies available on their websites. Advertising Vendors may also allow opt out through the Digital Advertising Alliance opt-out program (http://optout.aboutads.info/#!/).
Disclosure Regarding Tracking and Advertising Features. In addition to services from other analytics and advertising vendors, we use Google Analytics and other web-based services to analyze traffic on the Site. Google Analytics collects data including details about your web browser and the computer you use to access our Site, such as the hostname, browser type, referrer, language, and screen resolution. Google Analytics also sets and reads first-party cookies to obtain user session and ad campaign information from your page request.
Google provides users an opportunity to opt-out of Google Analytics Features through Google Ads Settings and their web browser opt-out plugin (https://tools.google.com/dlpage/gaoptout/). For additional information on opting out of interest-based ads by Google, please visit https://support.google.com/ads/answer/2662922?hl=en&ref_topic=2941003.
Do Not Track Signals. Our Site does not currently respond to automated signals regarding online tracking, such as “do not track” instructions from your web browser. Please note that blocking cookies or other tracking technologies may affect your browsing experience on the internet and may limit your use of certain parts of our Services, including many of the Product opportunity selection and other customized features we provide.
Other Third-Party Content. We may display other third-party content or links to third-party websites or applications on the Site, including links to our Product Providers. Such content could include features that allow you to connect your Paydayfly Member Account with your social media, financial institution, and other third-party accounts. Please be advised that when you leave our Services or interact with a third-party feature, you should read the applicable privacy policies and terms of service of those parties so that you understand their own information collection and sharing practices.
Accessing and Updating Your Information on the Site. The method(s) for accessing and updating your Information, if any, will depend on the Services you have used. You may have the ability to access and make changes to certain Information by logging in to your Member Account through our Site and updating your data. You can also update your Information by contacting us using our contact form.
You are responsible for maintaining the accuracy of the information you provide to us, such as your Member Profile information.
Due to regulatory recordkeeping and information retention requirements, we do not delete your Information when you deactivate your Member Account. We will, however, disable your account and stop sending you communications.
How We Protect Your Information. We maintain what we believe to be industry standard technical, physical and administrative security procedures and practices to protect your PII against unauthorized access, disclosure, destruction, use, alteration, or disclosure. We use encryption in the transmission of your Information between your system and ours and our Site and our Product Providers. We also use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your Information. We require any Product Providers that may have access to your PII to implement and maintain industry standard security procedures and practices. We also require employees to comply with our own internal information security policies.
Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the information you send to us; your communications or other activities on the Site; or the security of our servers, networks or databases, and by using the Site you agree to assume all risk in connection with the information sent to us or collected by us when you access, visit and/or use the Site, including without limitation your personally identifiable information or other Information, and we are not responsible for any loss of such information or the consequences thereof.
Moreover, if you elect to store information, such as your personally identifiable information or other user account information, where others may access it, we are not responsible for any loss of such information or the consequences thereof. If you lose a computer, mobile or other device, or it is stolen, that contains your personally identifiable information or other Information, it is up to you to take all the steps necessary to protect yourself.
In the unlikely event that we believe that the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you via your computer, mobile or other device.
You may also visit the website of the Federal Trade Commission at https://www.identitytheft.gov for free information to help you guard against identity theft and for guidance on the recovery steps you can take if you have been the victim of identity theft, including information on how to file an identity theft complaint.
Visiting our Site From Outside the United States. The Site is governed by the laws of the United States and is intended for use only by residents of the United States. We make no representation that the Site is governed by, or operated in accordance with, the laws of any other nation or jurisdiction.
Compliance with Children’s Online Privacy Protection Rule. We do not knowingly collect, use, or disclose PII from anyone under the age of 18. If we determine that a User is under this age, we will not use or maintain their PII without consent from a parent or guardian. If we become aware that we have collected PII from a child under the age of 18, we will make reasonable efforts to delete such information from our systems and records.