Privacy Policy
Effective January 1, 2024
This privacy policy (“Privacy Policy”) generally describes the information CIVIC Financial Services, LLC (“we” or “us” or “CIVIC”) collects when you use or access its website and any of its platforms, products or services (collectively, the “Services”). It also explains how we use and share the information and what steps we take to protect it. By visiting and using the CIVIC’s website or using its Services, you consent to our collection and use of your personal information as described in this Privacy Policy. Please read this Privacy Policy in its entirety. We reserve the right to modify, alter, or otherwise update this Privacy Policy at any time to address changing legal obligations, technologies, business practices and our users’ needs, and we encourage you to check back periodically so that you are always aware of the most current policies and practices that CIVIC has in place to protect your personally identifiable information.
Please also review the (herein contained) Terms & Conditions that govern your use of our Services.
CIVIC complies with all applicable federal and state privacy laws and regulations.
1. Information we collect
What types of information we gather from you depends on the product or Services you have with us. This information may include:
- Your name, contact information, home/business address, driver’s license number and social security number;
- Your date of birth, gender, and marital status;
- Your log-in information when you log into our (or our affiliate’s) platform;
- Business ownership information, including profit sharing and ownership interests;
- Your financial information, including without limitation, your net worth and your bank statements and tax returns.
If you use our (or our affiliate’s) platform, we may also collect information about the browser you are using. This information can include:
- Your IP address or other device identifying information, browser type, browser language, the date and time of your request;
- One or more cookies that may uniquely identify your device; and
- Information obtained through the use of cookies, flash cookies, web beacons, embedded script, or other similar tracking technologies.
We may supplement this information with data from third parties.
This information may include:
- Information from other sources, such as financial records, employment history, background information (including,
without limitation, criminal background/history), medical records, or other third-party data; and - Information from other reporting agencies, state and federal government agencies such as state motor vehicle
departments, and credit reporting agencies (including credit reports/history/scores). - Third party data collected from using internet sites and mobile applications.
We treat all information about you, whether received from you or from a third-party, in accordance with this Privacy Policy and our Terms and Conditions (contained herein).
2. How we use the information we collect.
We use the information we collect to provide, maintain, protect, optimize and improve our Services, and to enhance your user experience. We may also use the information we collect in the following ways:
Regular Business Purposes
We use the information you provide to update your account(s), process or service requested or authorized transactions, and evaluate and underwrite loan requests and applications. ]
For Our Own Analytic Purposes
CIVIC may also use your information to develop new Services, conduct research, and create anonymous or aggregated reporting for its (or its affiliates’) own use.
For Our Own Marketing Purposes
CIVIC may use your information to offer our products or Services to you, including products and services from our parent company, Roc360.
To Comply with Legal Requirements
It may be necessary to provide information collected from you to respond to subpoenas, other discovery requests, legal investigations, court orders or to otherwise comply with the law.
We may share information pursuant to a governmental agency or investigatory body request. CIVIC may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
3. How your information is shared.
CIVIC does not share, sell, rent or otherwise distribute your personal information except:
With Our Service Providers
We may share your personal information with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this Site, sending email messages, making phone calls, and processing requests for background and credit checks. These parties are contractually or otherwise restricted from using any personal information for purposes other than providing services for CIVIC (or its affiliates) or on our behalf.
For Administrative and Legal Reasons
See Section 2 above. Additionally, CIVIC also reserves the right to disclose or use information if it has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or liability of CIVIC or its affiliates, other users of this platform, or the public; (b) enforce the Terms and Conditions; (c) respond to claims that any content violates the rights of third-parties; (d) respond to claims of suspected or actual illegal activity; (e) detect, address or prevent fraud, security or technical issues; or (f) respond to an audit.
With Business Partners
We may disclose personal and other sensitive information, as necessary, in connection with providing our products andservices. In order to originate, sell and/or service our loans/loan products/related products, we may disclose your information to loan buyers, financing providers, insurers, reinsurers, insurance intermediaries, brokers, lenders, underwriters, insurance reference bureaus, medical service providers, fraud detection agencies, our other advisers, lawyers, accountants, and other third parties involved in the loan origination, sale and/or servicing process(es).
With Your Consent
We may disclose personal and other sensitive information after receiving your consent for such disclosure. Such consent may be provided via written, electronic, or verbal means, subject to CIVIC’s ability to reasonably validate your identity and determine the authenticity of such request.
4. How can you limit the sharing of your data?
CIVIC respects your privacy and your right to limit the sharing of your information. The following identifies ways in which you can limit the sharing of your information and data:
- You can contact us at any time to limit our sharing by using the contact information at the bottom of this Privacy Policy. Please note, however, that federal law gives you the right to limit only:
- Sharing for affiliates’ everyday business purposes;
- Affiliates from using your information to market to you; and
- Sharing for non-affiliates to market to you.
- State laws may give you additional rights to limit sharing.
- You can also opt out of receiving marketing emails by following the opt out instructions in any marketing email or text message you receive.
- If you do not wish to allow our website to use cookies or similar tracking tools, you may configure your browser to block them. Please understand that blocking cookies may reduce the functions and Services our website makes available to you.
For more information on how to reject or delete cookies, you should consult with your browser’s or device’s help documentation or visit www.aboutcookies.org. At this time, CIVIC does not (a) respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser; or (b) allow third parties to install software to track users’ identities on its website.
To limit the use and disclosure of your personal information, please submit a request to info@civicfs.com.
5. What steps does CIVIC take to protect your information?
Secure Internet Connectivity. CIVIC protects your personal/private information through the use of encryption technology. We use industry standard security protocol (Secure Sockets Layer or “SSL”) to ensure that the connection between your browser and our server remains protected. Unfortunately, no data transmitted over the Internet or data storage system can be guaranteed 100% secure. If you believe your connection with us is no longer secure for any reason, please notify us immediately.
Information Security. Personal information and user-specific settings and preferences are stored using commercially standard database and website security software. User passwords and other sensitive user information are saved in a secure manner to prevent unauthorized access or disclosure and accidental loss, alteration, or destruction.
Evaluation of Information Protection Practices. Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality, and quality of our information.
Employee Access, Training and Expectations. Our employees are required to protect confidential third party information in general as a condition of employment at CIVIC (or its affiliates), and our business practices limit the use and disclosure of such information, including personal information, to authorized persons, processes, and transactions.
6. Additional concerns
Updating and Correcting Your Information
Keeping your information accurate and up to date is very important since inaccurate or incomplete information could impact our ability to deliver Services to you. Please let us know about any changes that may be required to your personal information by updating your account profile or by contacting your account manager.
Continued Use of Information
Even if you are no longer our customer or client, we may continue to share your information as described in this Privacy Policy.
External Links and Third-Party Privacy Policies
CIVIC may post links to third-party websites that are governed by their own terms and are not subject to this Privacy Policy. We do not exercise control over these third-party sites and are not responsible for the privacy practices of any third-party. We encourage you to read the privacy policies and terms of use of any third-party web sites you visit.
International Users
The Services are operated in the United States and intended for users located in the United States. If you access this Site from a location outside of the United States, your information may be transferred to the United States and you agree to such transfer. Furthermore, you acknowledge that the United States may not provide the same level of protections as the laws of your country.
Children
The Services are not intended for anyone under the age of 18. We do not knowingly collect, use or disclose information of children under the age of 18 without the consent of their parents or legal guardians. We will delete any personal information
collected that we determine to be from a user younger than the age of 18.
Rights of California Residents
Residents of the state of California have the right to request certain information from us with respect to the types of personal information we share with third parties for their direct marketing purposes, as well as the identities of the third parties we have shared such information with during the immediately preceding calendar year. To exercise your choices, please contact us at info@civicfs.com and reference “Shine the Light.”
Communications
For additional information, or if you have questions regarding this Privacy Policy or privacy practices at CIVIC, please send correspondence to info@civicfs.com or via postal mail to:
CIVIC LLC
645 Madison Avenue, 19th Floor
New York, NY 11022
Changes to Privacy Policy
This Privacy Policy may be revised at any time to reflect changes in the law or in CIVIC’s business operations. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Sometimes there may be material changes to this Privacy Policy that we want to apply retroactively. If so, we will notify you and obtain your consent to the extent required by applicable law.
