Statement of Policy: CareFund Holdings LLC (“CareFund”) values the importance of protecting consumers’ nonpublic personal information (NPI), and CareFund recognizes the necessity of implementing policies and procedures with respect to sharing such NPI with other companies. Therefore, CareFund has adopted this Privacy Policy (the “Policy”), pursuant to Title V of the Gramm-Leach-Bliley Act (the “GLBA”).
Policy
For the purposes of this policy, “NPI” means (i) personally identifiable financial information, and (ii) any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available. NPI does not include (i) publicly available information, except as included on a list described in clause (ii) of the preceding sentence, or (ii) any list, description or other grouping of consumers (and publicly available information pertaining to them) that is derived without using any personally identifiable financial information that is not publicly available. “Personally identifiable financial information” means information (i) that a consumer provides to CareFund to obtain a financial product or service from CareFund, (ii) about a consumer resulting from any transaction involving a financial product or service between CareFund and the consumer, or (iii) CareFund otherwise obtains about a consumer in connection with providing a financial product or service to that consumer. Personally identifiable financial information does not include (i) a list of names and addresses of customers of an entity that is not a financial institution and (ii) information that does not identify a customer, such as aggregate information or blind data that does not contain personal identifiers such as account numbers, names, or addresses. “Publicly available information” means any information that CareFund has a reasonable basis to believe is lawfully made available to the general public from (i) federal, state, or local government records, (ii) widely distributed media, or (iii) disclosures to the general public that are required to be made by federal, state or local law.
Pursuant to the GLBA, CareFund has provided consumers with the approved GLBA Privacy Disclosure Form (the “Form”). The Form accurately describes the information sharing practices of CareFund with other affiliated and nonaffiliated companies.
CareFund shall provide the Form to each customer no later than when the customer relationship is established (the “Initial Notice”), but in any event no later than the signing of the loan contract.
Pursuant to Section 503(f) of the GLBA, CareFund is not required to provide an annual privacy notice if: (i) CareFund only shares consumer information within the listed GLBA exceptions (i.e., CareFund does not give customers the right to opt out of information sharing), and (ii) CareFund has not changed its information sharing practices from its most recent Initial Notice sent to customers. If either clause (i) or (ii) of the previous sentence changes with respect to any customer, CareFund shall send an annual privacy notice to such customer for each year that the customer has a relationship with CareFund, provided that the Initial Notice shall satisfy this requirement for the first year of the customer relationship.
For the purposes of this Policy, a customer relationship terminates upon full repayment of a closed-end loan; however, if that customer applies for a new loan, CareFund shall provide a new Initial Notice.
In the event that CareFund ever shares NPI regarding consumers (before the consumer becomes a customer) to nonaffiliated parties outside of the permitted GLBA exceptions, CareFund will provide an Initial Notice to all consumers.
CareFund shall periodically review the Form to ensure that it is in compliance with the law and reflective of the practices of CareFund. In the event that the practices of CareFund change, especially with respect to disclosure of NPI, CareFund shall update this Policy and the Form accordingly. If any such change results in any disclosure of NPI not otherwise described in the Form, CareFund shall send an updated Form (the “Revised Form”) to customers.
CareFund may use Plaid, Inc. (“Plaid”) to connect your CareFund account with your bank account, verify your bank account, confirm your bank account balance and use such information obtained from your bank account including balances and transaction history as part of the loan application and underwriting process to determine credit worthiness and approve or decline credit applications. Information shared with Plaid is treated by Plaid in accordance with its Privacy Policy, available at https://plaid.com/legal/#consumers.
CareFund shall not share consumer NPI except as described in the Form and as permitted by law.
CareFund adopts this Policy in addition to other policies required by federal and state laws.
