Your privacy and the protection of your sensitive personal information are important to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information. If you have a 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.
INFORMATION WE COLLECT
When you interact with us through the Services, we may collect personal data and other information from you, as further described below:Personal Data That You Provide Through the Services
We collect personally identifiable data including financial information (“Personal Data”) from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, apply for a Point product, or use certain Services. Most of the collection occurs when you register with the Site to apply for a Point product.
We will retain your Personal Data as long as your account is active or as needed to provide you the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Point may still need to keep certain personal details of customers to ensure that systems reflect your preferences even if a customer has chosen to opt out of allowing Point to use that customer’s personal details for marketing purposes. Point may keep records of any transaction a customer enters into on the Site for a minimum of seven years from the end of Point’s relationship with the customer. Point may keep other information about a customer only to the extent necessary to comply with applicable laws and to further legitimate business needs.
When you interact with Point through the Services, we receive and store certain personally non- identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Point may store such information itself or such information may be included in databases owned and maintained by Point affiliates, agents, or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, IP addresses, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.
In an ongoing effort to better understand and serve the users of the Services, Point often conducts research on its customer demographics, interests, and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Point may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. Point may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.
OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION
OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION
Point is 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 Personal Data with certain third parties without further notice to you, as set forth below:
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets.
- Agents, Consultants, and Related Third Parties: Point, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
- Legal Requirements: Point may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Point, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
CALIFORNIA PRIVACY RIGHTS AND DISCLOSURES
This summary of California privacy rights and disclosures (“California Notice”) applies solely to residents of the State of California and provides additional information about how we collect, use, and disclose personal information of California residents in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Notice.
For the purposes of this California Notice, “personal information” has the meaning provided by the CCPA and does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. For clarity, CCPA does not apply to personal information we collect, use, or disclose about consumers who initiate or complete the process of applying for our Services as well as consumer financial data, such as financial accounts and credit information.
Collection and Use of Personal Information
We collect personal information from and about you for the following purposes: provide Services to you; to communicate with you; for marketing and advertising purposes; to monitor, improve, and develop our products and Services; to protect the security and integrity of our business; comply with regulatory requirements and obligations; for our business and operational purposes; and/or as otherwise permitted or required by law.
In the past 12 months, we have collected the following categories of personal information:
|Category of Personal Information Collected||Sources of Personal Information||Business or Commercial Purposes for Collection of Personal Information|
|Identifiers, including your name, address, and phone number.||
|Internet/Network Information, including your device information, logs, and analytics data.||
|Geolocation Data, such as precise location information||
|Inferences about your interests and preferences generated from your use of our Site.||
Disclosure of Personal Information for a Business Purpose
In the preceding 12 months, we have disclosed the categories of personal information detailed in the table above to service providers. When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose other than providing the services under the contract.
Sale of Personal Information
We have not sold your personal information in the past 12 months.
Your Rights and Choices
The CCPA provides you, as a California resident, with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
If you are a California resident whose information is covered by the CCPA, 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 and confirm your verifiable consumer request (see the Exercising Access, Data Portability, and Deletion Rights section below), 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 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).
You have the right to request that 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 (see the Exercising Access, Data Portability, and Deletion Rights section below), 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 providers to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our Services 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 that consumer’s free speech rights, or exercise another right provided for by law.
- 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 the information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above,please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Household Information: There may be some types of personal information that can be associated with a household (a group of people living together in a single home). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above. If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request.
Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
We will not discriminate against you for exercising any of your CCPA rights.
LINKS TO OTHER WEBSITES
INTEGRATION SOCIAL NETWORKING SERVICES
You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.
TELL-A-FRIEND AND OTHER USER REFERRAL ACTIVITIES
Users may choose to refer friends to the Site via email.
If this referral occurs independently of our Site or a partner’s site, we do not track the referral other than as a unique page view. Since we do not collect any information from the referring party or the recipient of the external email referencing our site, we do not capture or store any information about either party. If friends refer each other to our Site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities that contributed to the referral. Our users can also refer friends to the Site by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular Point product request, and the sender will not know whether you are an applicant, investor, or customer. The information collected in this process is only kept long enough to monitor whether the referral program is achieving the desired results in terms of attracting new visitors to the Site and converting them into applicants. Again, these are messages initiated by friends of the recipients, and the recipients will not be added to any mailing list or contacted by Point apart from this referral process, which may include invitation reminders. In the case where a bonus is offered to a member in return for the referral, Point will only retain the information about the referred parties to properly credit the account of the member initiating the referral. The information is not used for any other purpose.
Your friend may contact us at email@example.com to request that we remove this information from our database.
Point takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. All data entered into the Point site is encrypted using industry-standard 128-bit AES cipher and transported over secure TLS protocols. TLS allows sensitive information such as social security numbers to be transmitted securely. Your information is unreadable to anyone except Point. Additionally, Point does not store the login details of your linked accounts, such as usernames and passwords. No one at Point has access to the login details of your linked accounts.
Despite our efforts, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Point via the Internet.
You can take several precautions to protect the security of your computer and Personal Data:
- Use a unique password that you do not use for any other service.
- Use a strong password, by avoiding using any information that others can easily learn about you, such as a family member’s name or birthday, and use special characters in place of letters.
- Change your password frequently.
- Do not share your password with anyone.
- Restrict access to the email account you registered with on the Site.
- Install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users.
- Do not log onto your account in public areas where the internet is unsecured.
- Logout and close the browser window when you are finished with a session on the Site.
OTHER TERMS AND CONDITIONS
ACCESS TO INFORMATION; CONTACTING POINT