Effective Date: January 1, 2020
Last Updated: December 20, 2019
(to view archived versions, click here)
Information We Collect
Easyway Advance collects several types of information that may identify a particular individual (“personally identifiable information”). Easyway Advance collects personally identifiable information when you provide it to us through your use of this Website, such as completing one or more steps of a request form to request a loan from a lender participating in our lender network. In particular, our Website may have collected the following categories of personally identifiable information in the last twelve (12) months:
|Identifiers||First name, last name, date of birth, email address, phone number, home address, driver’s license number and state of issue, Social Security Number, Internet Protocol (IP) address, or other similar identifiers.||Yes|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, residential history, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note: Some personal information included in this category may overlap with other categories.||Yes|
|Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|Commercial information.||Records of personal property, products, or services purchased, obtained, or considered, or other consuming histories or tendencies.||Yes|
|Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|Internet or other similar network activity.||Browsing history, browser, device, search history, information on a consumer's interaction with a website, timestamp, IP address, application, or advertisement.||Yes|
|Geolocation data.||Physical location or movements.||Yes|
|Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|Professional or employment-related information.||Employment history, employment status, income, payroll, benefits.||Yes|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
Easyway Advance obtains the categories of personally identifiable information listed above from the following categories of sources:
- Directly from you (i.e., from forms you complete on our Website)
- Indirectly from you (i.e., IP address, browser, device information obtained by your use of our Website)
Non-Personally Identifiable Information
Personally identifiable information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver's Privacy Protection Act of 1994.
Use of Your Information
Easyway Advance may also use the information you provide to verify your identity and protect against possible fraudulent transactions pursuant to Section 326 of the USA PATRIOT ACT in order to help the government fight identity theft, the funding of terrorism and money laundering activities, and to help verify a customer's identity. Easyway Advance may also use the information you provide to investigate complaints regarding your use of the Website, to receive payment from third party lenders in the event of a dispute, and for internal security purposes such as fraud detection and internal reporting. Lenders who receive the information you provide may obtain, verify, and record that information in order to identify the customer.
Disclosing Personally-Identifiable Information
Easyway Advance will share your personally identifiable information (including, without limitation, your financial account information and Social Security Number) with third parties for a business purpose including, without limitation, transferring or licensing, subject to your right to opt-out of such use by us of your personally identifiable information described herein. We may share your personally identifiable information with the following categories of third parties:
- Lenders participating in our lender network.
- Third party lenders with whom we have a business relationship.
Easyway Advance will disclose your personally identifiable information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement agency or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. We will disclose your personally identifiable information when we believe disclosure is necessary to investigate, prevent, or take action regarding illegal activity, suspected fraud or other wrongdoing, to protect and defend the rights, property, or safety of our company, our employees, our Website users, or others, or to enforce our Website terms and conditions or other agreements or policies.
Disclosures of Personally-Identifiable Information For a Business Purpose
In the preceding twelve (12) months, Easyway Advance has transferred and licensed personally identifiable information for business purposes.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Easyway Advance discloses certain information to you about our collection and use of your personal information over the past twelve (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 third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that the we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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 information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Your Choices About The Use of Your Information and Opting Out
Exercising Access, Data Portability, and Deletion Rights
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Provide proof of California residency.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personally identifiable information if we cannot verify your identity or authority to make the request and confirm the personally identifiable information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personally identifiable information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
Personal Information Transfer and Licensing Opt-Out and Opt-In and Email Unsubscribe Rights
Easyway Advance is not intended for use by anyone under 18 years of age. The foregoing provisions nonetheless apply in the event we unintentionally obtain information from someone under 18 years of age.
If you are sixteen (16) years of age or older, you have the right to direct us to not transfer or license your personally identifiable information at any time (the "right to opt-out"). We do not transfer or license the personally identifiable information of consumers we actually know are less than sixteen (16) years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between thirteen (13) and sixteen (16) years of age, or the parent or guardian of a consumer less than thirteen (13) years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing firstname.lastname@example.org and by using the subject line “right to opt-out.”
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personally identifiable information sales. However, you may change your mind and opt back in to personally identifiable information transfers or licensing at any time by emailing email@example.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personally identifiable information provided in an opt-out request to review and comply with the request.
When you submit your information on Easyway Advance, you may receive email messaging or third party marketing messages. You will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. You may also opt out of receiving commercial emails by using the 'Unsubscribe' link on our site. Please allow for up to ten (10) business days for your request to be processed. If you remove your information from our database it will no longer be used for secondary purposes, disclosed to third-parties, or used by us or third-parties to send promotional correspondence to you. If your information has already been shared with a third party, it may be necessary to contact the third party directly to opt out of receiving information from them.
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personally identifiable information ’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Further, you can choose not to provide us with certain personally identifiable information, however doing so may result in limited access to certain features and services provided on this Website and affect your ability to obtain a loan.
California Privacy Rights
California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits users who are residents of California to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and would like to make a request, please submit your request in writing to firstname.lastname@example.org.
Wireless Privacy Rights
We may use personal information you've provided on this site to administer the services you've requested, including wireless services that display customized content and advertising. In addition to any fee of which you are notified of, your wireless provider's standard message rates are applicable to our confirmation and all subsequent SMS correspondence. You may opt out from further SMS messages and remove your SMS information from our database by responding 'STOP', 'END' or 'QUIT' to the SMS text message you received. If you remove your SMS information from our database it will no longer be used by us for secondary purposes, disclosed to third-parties, or used by us or third-parties to send promotional correspondence to you.
Children Under The Age of 16
Security - How We Protect Your Information
Easyway Advance takes appropriate and reasonable security measures to help safeguard your personal and sensitive information. The information you enter into this Website is protected using industry-compliant 256-bit encryption technology, keeping your information safe from unauthorized access, use, modification and disclosure. Transmission is also secured by secure socket layer technology (SSL). Please be advised that, although we take every reasonable technological precaution available to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure.