TheUnited States consumer financial companies within The Change Company CDFI, LLC, including its affiliates that are related by common ownership or control (collectively referred to herein as, “The Change Company”), values your patronage and protecting your confidential information is a priority. Our policies and procedures reinforce the fact that The Change Company strongly believes in protecting the confidentiality and security of the information we collect about you as a customer, potential customer, or former customer. We have adopted the following policies and procedures that apply to all internet websites that The Change Company operates to safeguard the personal information about you in our possession.
This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.
The Change Company takes strong steps to safeguard your personal and sensitive information through industry standard physical, electronic and operational policies and practices. All data that is considered highly confidential data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls and servers with tested operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.
We collect information about you to help us serve your financial needs, to provide you with quality products and services and to fulfill legal and regulatory requirements. We consider non-public information about you in our possession to be personally identifiable information, even if you cease to be a customer. The personally identifiable information we collect about you may include among other things:
In addition, we gather names and email addresses of people who contact us through our website with questions about our company or lending operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people.
Lastly, we (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies, and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website, as discussed further below.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
When you submit an application and/or create a profile on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and the bank accounts, and confirmation of successful submissions of loan requests and portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.
The Change Company may display personal testimonials of satisfied customers on our sites in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
We share personally identifiable information about you, as required or permitted by law, with third parties, such as service providers who assist us in the in the administration, processing, servicing, and sale of your loan. These third parties include among others, title companies, appraisers, insurance companies, underwriting services, processing services, printing companies, software providers, marketing services, and purchasers of loans. Our policy is to require third party service providers to enter into confidentiality agreements with us, prohibiting them from using any personally identifiable information they obtain for any other purpose other than those for which they were retained or as required by law. We may also disclose information about you, when necessary or required, in legal and arbitration proceedings and to government agencies.
For some of our online services, you can review and update certain account information by logging in and accessing your user profile on our website. If you cannot change your information online, or you prefer to request changes offline, please contact your representative listed on our correspondence or other account materials sent to you, or you can contact us at 1-833-CHM-0123.
If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your Apple mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. If you want to disable cookies and you’re using the Chrome browser, go to Settings > Privacy and Security > Cookies and Other Site Data, make the selection that provides the level of tracking you prefer. If you want to disable cookies and you’re using the Explorer browser, go to Settings > Internet Options > Privacy Tab > Advanced, make the selection that provides the level of tracking you prefer. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of The Change Company website will not be available once cookies are disabled.
Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites, to the extent the operator engages in that collection. At this time, we do not track our customer’s personal information over time and across third-party websites and therefore this requirement does not apply to us. California law also requires website and online service operators to disclose whether third parties may collect personal information about their user’s online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our site unless you directly provide it to us and we provide it to them with your consent.
The Change Company does not intend to knowingly collect or solicit any information from anyone under the age of 13. We do not knowingly allow minors under the age of 13 to disclose their personal information to us through our sites or otherwise. Our websites are directed to individuals who are permitted to share their personal information without parental consent. If you believe that we may have any information from a child under the age of 13, please contact us at 1-833-CHM-0123.
We also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our website you are actually on our site. SSL also ensures that all data entered into the website is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For encryption protection, we use 128-bit secure browser for login and transactions. The application process utilizes “CAPTCHA” technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering the text shown in the image. We subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.
We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.
At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an email purporting to come from Change Lending that asks for your password, you should immediately contact us.
You can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use specifically characters in place of letters. We also recommend that you change your password often. You can also install and update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.
To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this site and/or changing your password on that email account frequently.
If you use a computer that is accessed by other people, such as in a public library or internet café, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using your site, you should log out completely, then close the browser window and clear the browser’s cache file.
You should also be aware of fraudulent attempts to gain access to your account information known as “phishing”. Phishing is a tactic used by scammers in which unsuspecting people are brought to a website by a genuine-looking email purporting to be from a legitimate company. The phony or “spoof” email takes the person to a website that looks legitimate but in fact is not. Either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. The Change Company will never ask for login information to gain access to customer’s account and access sensitive information. The Change Company will never ask you for your login information in the context of any email, physical mail, phone call or otherwise. In general, you can protect yourself against phishing by never providing personal or login information via an email instead, go to the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain.
Our Do Not Call policy states that you may instruct us not to call you for marketing purposes by informing us at 1-833-CHM-0123. Our employees are trained through Policies and Procedures to take action on your instructions within thirty (30) days. Please note that we may still need to contact you for legitimate business reasons such as servicing of your loan or other non-marketing purposes.
The Change Company CDFI, LLC
16845 Von Karman Avenue, Suite 200
Irvine, California 92606
Effective Date of this Policy: 06/23/2021