4f Sales, Inc., a Delaware, USA corporation (hereinafter, “4f Sales” “we” or “us”), maintains and operates the various websites for the companies that are part of the 4finance group (collectively, the “Sites”). Please read the following policy to understand how we collect, use and safeguard the information you may provide to us via the Sites. It also describes your choices regarding use, access and correction of your personal information. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged 4f Sales.
- Compliance with Privacy Shield Framework
4f Sales participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. 4f Sales is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
4f Sales is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. 4f Sales complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, 4f Sales is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, 4f Sales may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
- Collected Information
2.1 The types of personal information that we will collect via the Sites are as follows (however in some circumstances we may ask for additional data or documents to support your application): name; identity/identification number; address; e-mail address; mobile phone number; date of birth; employment status; employer name; work phone number; monthly income; call records; information on your current and past liabilities and debts against us or third persons; your credit history and any other information you choose to provide to us through your use of the “LiveChat”, telephone, e-mail and fax facilities, and that may be relevant for fulfilment of liabilities and commitments.
2.2 Such information is collected and processed directly through the Sites. We may collect your personal information through the Sites in the following ways:
- Data regarding your visit(s) to the Sites and any resources used are collected, including, but not limited to: location data, weblogs, traffic data, and any other communication information. (See Section 8 on “Cookie Usage”)
- Any forms you filled out on the Sites (whether registering for information or when you complete an application) allows us to collect data contained in such forms.
- If for any reason you communicate (including e-mail, phone, “Live Chat” etc.) with our personnel, we may collect such information you provide to us.
- Requiring data on your credit history from relevant registers, agencies and other third persons. This information is associated with the personal information you provide to us or that we otherwise collect.
- Use of your Information
We may use the personal information we collect or otherwise receive about you in the following ways:
- to verify your identity, subsequently carry out credit checks and assess your ability to repay the loan and offer you appropriate services before establishment of a contractual obligation;
- to identify and avoid any fraud, money laundering and other criminal activities;
- to ensure and improve the quality of services and offer new services;
- to provide our affiliated companies with our services;
- to operate or improve the Sites;
- to monitor relevant Site visitor traffic patterns and Site usage;
- to comply with applicable laws, regulations and rules, and requests of relevant law enforcement and/or other governmental agencies.
- Our Use and disclosure of your Information
4.1 We may disclose your personal information to our affiliated companies and our service providers and contractors in order to provide our services, and as otherwise described herein. If we wish to use or disclose your personal information in a manner incompatible with the purpose for which it was originally collected or subsequently authorized by you, we will notify you and give you the opportunity to opt-out of such use or disclosure.
We may share your information with third parties who provide services on our behalf to help with our business activities such as identification, fraud detection, risk assessment, web hosting and development. When sharing any such information, we take reasonable actions to require that the data receiver follows the same level of privacy protection and security measures for storage and processing of personal information as we do. These companies are authorized to use your personal information only as necessary to provide these services to us.
4.2 We may also disclose your personal data to third parties in the following cases:
4.2.1. selling any or all of our business to a third party may result in sharing your information with any potential or actual purchasers of such assets and/or your personal information may be among those assets transferred. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information;
4.2.2. at any time when we are legally required to we may disclose information about you and your visits to the Sites such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
4.2.3 to prevent fraud and help in fraud protection in order to reduce credit risk and financial loss;
4.2.4 we may share your personal data with providers of similar services such as consumer loan companies, credit bureaus and databases, as well as the relevant national authorities and non-governmental organizations, in order to ensure a full assessment of your solvency;
4.3 We strive to maintain the accuracy of any personal information that may be collected from you, and will use our commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. It is your responsibility to ensure that such information is accurate, complete and up-to-date.
Upon request we will provide you with information about whether we hold any of your personal information. You may obtain from us, by email, the information in our records. If you wish to make any changes to any personal information in our records, you may do so at any time by contacting us at email@example.com. We will respond to your request within a reasonable timeframe.
4.5 As far as possible, upon request, where your personal data processing is no longer necessary for purposes they were collected for, including our contractual and legal rights enforcement, we will delete your personal data from our databases and will request that such data be deleted from the databases of our contractors. Please note, however, that removed information may persist in backup copies for a reasonable period of time but will not be generally available. We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
- Information Collected on Behalf of our Clients
4f Sales collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
4f Sales acknowledges that you have the right to access your personal information. 4f Sales has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the 4f Sales’ Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. 4f Sales will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Personal Data Storage and Protection
6.1 Information we are provided will be stored on secure servers. Transaction data is encrypted for your safety.
6.2 We make reasonable efforts to ensure the security of our systems. You should understand, however, that data transfer via online transmission is not completely secure. We can’t guarantee full protection and security of data, only that we take reasonable action to protect information sent to us electronically. Transmission of any data by you is at your own risk. Where applicable, you may be given access to sections of a Site that require a password. You are responsible for the passwords safety and confidentiality.
- Third Party Links
Third party links may be displayed on the Sites. These third party links have their own privacy policies, which you agree to when you click on the link. We are not responsible nor do we accept responsibility for third party links, and you should review the privacy policies posted on such sites. Our liability covers us only on our Sites, and thus we do not accept liability for third party links as we have no control over them.
- Commercial Communications; Opt Out
By visiting one or more of the Sites and providing us your personal details and contact information, you agree to our rights to use this information for commercial communication with you. You can always opt out of receiving future commercial communication in your user profile on the relevant Site. Also, at the bottom of each e-mail with commercial communication message we will provide link for opt-out from receiving subsequent commercial communication.
- Cookie Usage
9.2. Cookies on the Sites are used as follows:
9.3. We use two types of cookies on the Sites:
9.3.1. Session cookies. These are temporary cookies that are only active at a time when computer user accesses the relevant Site (or, more precisely, until the user leaves the Site and closes the browser). Session cookies help the Sites to memorize the steps that the visitor has made in the previous page, thus eliminating the need to re-enter information.
9.3.2. Persistent cookies. Persistent cookies remain on the visitor’s computer after visiting a particular Site. These cookies help us to identify you as a unique visitor (retaining this information as a randomly generated number). How long the cookie will remain on the user’s computer will depend on the types of cookie.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
While we keep track of the web pages our users visit within a particular Site, we do not engage in the collection of personal information about your online activities over time and across third party websites or online services. Accordingly, we do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third party websites. Further, we have not knowingly authorized third parties to collect personally identifiable information about your online activities over time and across different websites when you use the Sites.
- Contacting Us
4f Sales, Inc., 18851 NE 29th Avenue, Suite