Privacy Policy
At ClearCreditPath.com, we are committed to protecting your personal data and ensuring compliance with privacy laws across the U.S. This Privacy Policy outlines how we collect, use,, and safeguard your personal data in accordance with state-specific laws (e.g., California CCPA/CPRA, Virginia Consumer Data Protection Act), sector-specific federal laws (e.g., HIPAA, Gramm-Leach-Bliley Act), and Federal Trade Commission (FTC) guidelines. By using our services, you agree to the practices described in this Privacy Policy.
- INTRODUCTION
This Privacy Policy applies to all users of ClearCreditPath.com. It explains how we collect, process, and protect your personal data and details your rights under various state and federal laws.
For questions, complaints, or to exercise your privacy rights, please contact our Data Protection Officer (DPO) at compliance@clearcreditpath.us.
- What personal data is collected by ClearCreditPath
By using ClearCreditPath services, you provide us with, and we collect, certain personal data relating to you. From the moment you interact with ClearCreditPath, we collect your personal data. In some cases, you directly provide your personal data to ClearCreditPath, but we may also collect your data automatically.
In addition, we also receive some personal data sent by partners that we hire for specific purposes, so that we can comply with legal obligations or applicable regulations and others that will be detailed later.
By accepting the terms of this Privacy Policy, you expressly agree to provide only true, current and accurate personal data and not to change your identity or your personal data in any way when accessing and using our products or services. You will be solely responsible for false, outdated or inaccurate information that you provide directly to ClearCreditPath.
These are your personal data processed by ClearCreditPath, divided by categories:
Personal data that may be requested and informed by the holder:
- Personal identification information: name, email and SSN/ITIN;
- Personal details: age, marital status and gender of the user;
- Family situation: who you live with;
- Education;
- Work situation: whether you are self-employed, self-employed, unemployed, employed or retired;
- Habits of consumption;
- Financial situation: if you are negative or with some financial restriction;
Personal data we collect from third parties:
- Registration data, such as: name, date of birth, SSN/ITIN, telephone number and address;
- Data on financial restrictions, such as: negatives, amounts due and due dates;
- Credit history information;
- Score generated by credit bureaus;
- Information on debts falling due or overdue, co-obligations and guarantees;
Browsing and device data:
- IP address of the mobile device used to access;
- Interactions made and website usage profile;
- Technical data, such as URL, network connection, provider, and device information;
- Cookies;
- Device attributes such as ID, operating system, browser, and model;
- Device geolocation data if you authorize collection from your device;
- Application access logs;
- Date and time of use of the application;
- Navigation data, reflecting the areas visited;
Personal data arising from the use of our services:
- Contracting data for our services;
- Data for contracting credit operations with partners, such as personal loans, negotiation of amounts due and debt installments;
- Credit history;
- Customer service history;
- How ClearCreditPath uses your personal data
ClearCreditPath uses your personal data to be able to promote and offer the best products for you.
ClearCreditPath undertakes to continuously implement physical, technical and administrative information security measures in the processing of your personal data, in accordance with the best market practices. Therefore, we seek to protect your data against unauthorized access, accidental or unlawful situations of destruction, loss, alteration of communication or any form of inappropriate or unlawful treatment.
We detail below the purposes for which we use your personal data:
Personal data informed by the owner
Purposes:
- The correct and precise identification of the user, thus ensuring greater security and protection for the users themselves;
- Access to the services and products provided by ClearCreditPath;
- The analysis of the profile of users with the aim of disclosing and indicating the best products and information according to their real needs and reality;
- Identification, authentication and verification of requirements for using ClearCreditPath services;
- Answering requests and doubts;
- Contact by phone, e-mail, SMS, WhatsApp, or other means of communication, including for sending notifications or push to use ClearCreditPath services;
- Improvement of the services provided by ClearCreditPath, including cross-referencing information on contracted products to offer new products and services;
- Marketing, prospecting, market research, opinion research and promotion of products and services from our partners, including offering offers and sending information about products, services, news, features, content, news and other events relevant to the maintaining the relationship with you;
- Credit protection, including credit granting and limit increase;
- Prevention and resolution of technical or security problems;
- Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of ClearCreditPath customers and the financial system;
- Collaboration or compliance with a court order, competent authority or supervisory body;
- Compliance with a legal or regulatory obligation;
- Solution of questions based on the information collected, in order to solve doubts, correct problems and improve the system, improving the user experience of ClearCreditPath.
Personal Data We Collect From Third Parties
Purposes:
- Improvement of our products and services;
- Marketing, prospecting, market and opinion research;
- Credit protection, including credit granting and limit increase;
- Prevention and resolution of technical or security problems;
- Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of ClearCreditPath customers and the financial system;
- Compliance with legal or regulatory obligations, keeping your registration up to date or complying with legal and/or regulatory obligations imposed on ClearCreditPath.
Browsing and device data
Purposes:
- Provision of services, dissemination and offering of products and improvement of the use and experience with the ClearCreditPath website;
- Operationalization of the dissemination of new products and services of interest to the user;
- Recommendation of new services, products or features, including services from other partners that may interest you;
- Display of advertising, whether on our website, social networks or on third-party websites;
- Generation of statistics, studies, surveys and surveys relevant to activities and behavior in the use of products or services;
- Credit protection, including credit granting and limit increase;
- Prevention and resolution of technical or security problems;
- Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of ClearCreditPath customers and the financial system;
- Compliance with a court order, competent authority or supervisory body;
- Compliance with a legal or regulatory obligation;
Personal data arising from the use of our partners’ products and services
Purposes:
- Provision of services and offering of contracted products;
- Improvement of the services provided by ClearCreditPath, including cross-referencing information about contracted products to offer new products and services
- Development of new products and services to be offered by partner companies of ClearCreditPath and generation of knowledge for innovation or development of new products;
- Tests to improve the models and services and products of ClearCreditPath;
- Marketing, prospecting, market research, opinion research and promotion of our partners’ products and services, including offering offers and sending information about products, services, news, features, content, news and other events relevant to the maintaining the relationship with you;
- Credit protection, including credit granting and limit increase;
- Prevention and resolution of technical or security problems and monitoring of use and performance of ClearCreditPath services and products;
- Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of ClearCreditPath customers and the financial system;
- Collaboration or compliance with a court order, competent authority or supervisory body;
- Compliance with a legal or regulatory obligation.
Public data
Purposes:
- Disclosure of products and services provided by ClearCreditPath on social networks, websites, applications or institutional and advertising materials;
- Credit protection, including credit granting and limit increase;
- Investigations and measures to prevent and combat illicit acts, fraud, financial crimes and guarantee the safety of ClearCreditPath customers and the financial system;
- Regular exercise of ClearCreditPath rights;
- Compliance with legal and/or regulatory obligations imposed on ClearCreditPath.
- COMPLIANCE WITH STATE-SPECIFIC PRIVACY LAWS
We comply with privacy laws enacted in various states, including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Utah (UCPA), and Connecticut (CDPA). Here’s how we protect your rights in each of these states:
California (CCPA/CPRA)
- Right to Know: You can request information about the personal data we collect, use, or safeguard.
- Right to Delete: You can request the deletion of your personal data.
- Right to Opt-Out: You can opt out of the sale or sharing of your personal information.
- Sensitive Data: You have the right to limit the use of sensitive personal data (e.g., racial origin, health information).
Virginia (VCDPA) & Colorado (CPA)
- Right to Access: You have the right to access, correct, and delete your personal data.
- Right to Opt-Out: You can opt out of processing your data for targeted advertising or profiling.
- Data Protection Assessments: We conduct assessments to evaluate risks associated with high-risk processing, such as profiling.
Utah (UCPA) & Connecticut (CDPA)
- Opt-Out Rights: You have the right to opt out of data sales and targeted advertising.
- Parental Consent: For residents under 16 in Connecticut, we do not process personal data without parental consent.
- FEDERAL LAW COMPLIANCE
While the U.S. does not have a unified federal privacy law, we comply with relevant sector-specific regulations:
Health Insurance Portability and Accountability Act (HIPAA) (for healthcare-related data)
If your personal data is related to healthcare, we comply with HIPAA’s data protection requirements. This includes ensuring the confidentiality of health information.
Gramm-Leach-Bliley Act (GLBA) (for financial data)
If your personal data relates to financial services, we comply with the Gramm-Leach-Bliley Act, which protects sensitive financial information through stringent data security measures.
Children’s Online Privacy Protection Act (COPPA)
Our services are not directed at children under 13. We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a minor, please contact us to have it removed.
- FEDERAL TRADE COMMISSION (FTC) GUIDELINES
We adhere to FTC guidelines for fair and transparent data collection practices. This includes:
- Transparency: Clearly disclosing how we collect, use, and safeguard your data.
- Fairness: Not engaging in deceptive practices or unfair methods in data usage.
- Security: Implementing strong security measures to protect your personal data from breaches or unauthorized access.
- TELEPHONE CONSUMER PROTECTION ACT (TCPA) COMPLIANCE
Under the TCPA, we only send marketing communications via phone or SMS if you have opted in. You have the following rights:
- Opt-In Consent: We will not contact you without your explicit consent.
- Opt-Out: You may opt-out of receiving communications at any time by following the instructions in the message.
- Do Not Call Registry: You may register with the National Do Not Call Registry, and we will respect your registration.
- DATA USAGE
We may use your data with trusted third-party service providers for operational purposes such as hosting, analytics, and marketing. These providers are obligated to use your data only as instructed by us and to comply with all applicable privacy laws.
Business Partners
We may use your data with business partners to offer services that may be of interest to you, provided you have given your consent.
Legal Obligations
We may disclose your personal data to legal authorities if required by law or in response to lawful requests (e.g., court orders or subpoenas).
- OPT-OUT AND DO-NOT-SELL REQUESTS
Residents of states such as California, Colorado, Virginia, Utah, and Connecticut have the right to opt out of the sale of personal data or the processing of personal data for targeted advertising. You may exercise these rights by:
- Do Not Sell My Personal Information: Click on the link provided on our website to opt out of the sale of your data.
- Opt-Out of Targeted Ads: Contact us at [Insert Contact Information] to opt out of targeted advertising.
- SENSITIVE DATA PROCESSING
We only process sensitive personal data (e.g., health data, racial origin, or biometric data) with your explicit consent, as required by state laws like the CPRA, VCDPA, and CPA.
- DATA SECURITY
We implement industry-standard security measures, including encryption, access controls, and continuous monitoring, to protect your personal data. However, no system is completely secure, and we cannot guarantee absolute security.
- DATA RETENTION
We retain personal data for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Once the data is no longer needed, we securely delete or anonymize it.
- COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies to enhance user experience and for analytics. You can manage cookie preferences in your browser settings. However, disabling cookies may affect certain functionalities of our website.
- GOOGLE ADSENSE AND ANALYTICS
We use Google AdSense to serve personalized ads and Google Analytics to analyze site traffic. Both services use cookies to collect data. You can manage your ad preferences or opt out of personalized ads through Google Ad Preferences.
- DATA PROTECTION ASSESSMENTS
For high-risk processing activities (e.g., profiling, automated decision-making), we conduct data protection assessments in compliance with state laws like Virginia’s VCDPA and Colorado’s CPA. These assessments evaluate risks and ensure legal compliance.
- CHILDREN’S PRIVACY
Our services are not intended for individuals under 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a child under 18, please contact us to have it removed.
- INTERNATIONAL DATA TRANSFERS
If your personal data is transferred outside the U.S., we ensure that appropriate safeguards are in place to protect your data during the transfer, in compliance with applicable laws.
- CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy to reflect changes in our practices or regulatory requirements. Any updates will be posted on this page, and we will notify users via email or a prominent notice on our website for significant changes.
- CONTACT US
If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact our Data Protection Officer (DPO):
Email: compliance@clearcreditpath.com
Last Updated: 02/10/2024