BY CONTINUING TO USE THE ONLINE SERVICES, YOU CONSENT TO THE TERMS OF THIS PRIVACY NOTICE
Effective Date: October 19, 2018
This Launch Servicing, LLC (“Launch”) Privacy Notice (“Notice”) describes how Launch may collect, share, and use information regarding your loan and your loan account that we receive on behalf of your lender when you use the Launch website, mobile application, or other online service as applicable (collectively, the “Online Services”). The use of “we,” “our,” and “us” herein refers to LAUNCH, and “you” and “your” refers to you as the consumer utilizing LAUNCH’s Online Services.
This Privacy Notice applies to your use of the Online Services. This Notice does not apply to information that we may collect through offline channels, which include but are not limited to phone calls and physical correspondence.
International Users: This Notice is intended to cover only customers and other users of the Online Services residing in the United States. Any international users of the Online Services should be aware that by using the Online Services, your information will be transferred to, stored on, and/or processed on servers located in the United States of America. You also understand that U.S. data protection laws may not offer the same protections or rights, including judicial redress, with regards to your personal information as the laws of the country in which you reside. By using the Online Services or providing us with your personal information, you consent to this transfer.
What Information Does LAUNCH Collect and How Does LAUNCH Collect that Information?
We collect Personal Information that you provide to us in connection with your loan account through the Online Services via forms, applications, surveys, and other fillable online fields. This “Personal Information” may include your name, address, date of birth, Social Security number, email address, telephone numbers, loan number, username (if different than your email), and password.
If you choose to use the Online Services, we may also collect information from third parties, such as credit reports or employment information as authorized by you.
We also collect information on behalf of your Lender, such as your transaction history, account balance, and payment information.
Information Collected Automatically
In addition to the Personal Information that we collect from you as described above, we may automatically collect certain information, including Personal Information, from your use of the Online Services. This information may include:
- usage information, such as which features of the Online Services you access or use or the frequency of access;
- device information, such as hardware model, operating system, application version number, browser type, or IP address; or
- mobile device information, such as the unique device identifier assigned to your device, mobile carrier, operating system, and other device attributes.
The information described above may be collected through cookies (defined below), pixel tags (defined below), clear gifs, or other technologies.
For What Purposes Do We Use Your Information?
The information LAUNCH collects is used to improve your experience on the Online Services. We may use your information:
- to provide you with Online Services, fulfill your requests, and process your transactions;
- to communicate to you important information regarding the Online Services, your loan application, and/or other information related to your use of the Online Services;
- for our business purposes, such as data analysis, audits, developing new products, enhancing and improving the Online Services, identifying usage and web traffic trends, and determining the effectiveness of our communications and marketing and promotional campaigns;
- to respond to your inquiries or provide you with customer service or technical support;
- for risk control, to help protect the security and integrity of the Online Services, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements;
- to help us identify and resolve issues that may arise on the Online Services;
- to contact you, if you register a profile with us, via telephone or email;
- to personalize your experience or to improve the Online Services and our offerings by allowing us to customize the content and/or layout of the Online Services based on feedback and information we receive from you; and
- for specific purposes for which we obtain your consent.
Who Do We Share Your Information With?
We do not sell, trade, or otherwise transfer your Personal Information to third parties without your consent, except as described in this paragraph. We may, without your consent, disclose your Personal Information:
- To your lender and other trusted third parties who assist us in operating the Online Services, processing transactions (such as processing loan payments), conducting our business, or servicing you, so long as these parties agree to keep this information confidential, consistent with this Notice;
- As a corporate asset in the event of a company sale of assets, merger, bankruptcy, or similar corporate transaction;
- When we have reason to believe that such disclosure is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, customers, other users of the Online Services, or anyone else who could be harmed by such activities; or
- To respond to judicial process, to provide information to law enforcement agencies, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, such as to comply with a subpoena or similar legal process.
We may also request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
How Do We Protect Your Personal Information?
We employ reasonable security measures, designed to maintain the confidentiality and security of your Personal Information to protect against the loss, misuse, or alteration of information that we have collected from you through the Online Services. For example, LAUNCH employs policies and procedures to designed to protect Personal Information in accordance with applicable law, and your lender’s requirements. Unfortunately, no security technology is completely secure, and you should remember that email and the Internet generally may not be a secure means of communication and/or transmitting Personal Information. Personal Information that you share via email is done so at your own risk.
Do We Track Our Visitors Online?
Some web browsers may transmit “do-not-track” or similar signals to the websites with which a user communicates. There currently is no industry standard for how websites must respond when they receive such a signal. The Online Services do not respond to do-not-track signals sent by web browsers.
What About Third Party Links in the Online Services?
How Will We Inform You of Changes to this Notice?
We may update this Notice from time to time. Any material changes to this Notice will be prominently posted on our website along with the date of the revision. The changes to this Notice will become effective as soon as they are published on the Online Services. We encourage to you to review this Notice periodically. Your use of the Online Services once a revised Notice has been posted constitutes your acceptance of the revised Notice.
What are Cookies?
The Online Services also use “cookies” (small data files stored on your device) and other tracking technologies to collect information about your use of the Online Services. The information that is captured about your use of the Online Services may be used in a variety of ways, such as to monitor and maintain information about your visits to the Online Services, to help us identify and address problems, to improve the Online Services, to analyze web traffic trends, and to help protect the security and integrity of the Online Services.
You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use the Online Services, but your experience may be degraded.
What are Pixels?
We may also use pixel tags (also known as “clear gifs,” “Web beacons,” or “1-by-1 gifs”) on our site. These may be used in connection with certain pages of the Online Services or with email messages to measure the effectiveness of our communications and to assist us in resolving issues that may arise on the Online Services.
Some of the content, advertisements, and functionality on the Online Services may be provided by third parties. We also use third-party service providers to provide us with analytics services so we can improve the Online Services. These third parties may collect information about your use of the Online Services through technologies such as cookies and web beacons, and this information may be collected over time and combined with information collected across different websites. These third parties will only collect Personal Information if you provide it directly to them. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. For example, some of these third parties may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”), which provide websites where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit https://www.networkadvertising.org/managing/opt_out.asp or https://www.aboutads.info.
NOTICE REGARDING SOCIAL MEDIA USE
Children’s Privacy Protection
We do not knowingly collect Personal Information from individuals under 13 years of age without parental consent. If we become aware that a child under 13 is attempting to submit Personal Information, we will inform the minor that he or she is ineligible to do so. We will then remove this information from our records. Our Online Services are not intended for children under 13 years of age.
Do You Have Questions?
If you have any questions about this Notice, please contact our Chief Compliance Officer at (619) 273-3994 or by email at email@example.com.