PRIZM FINANCIAL CO., LLC

PRIVACY AND DATA POLICY

PROTECTING YOUR PERSONAL INFORMATION

Our Privacy Pledge. At Prizm Financial Co., LLC and its subsidiaries, including 722 Redemption Funding, LLC, we respect the privacy of our borrowers. We recognize the importance of maintaining the confidentiality of your personal financial information. This notice describes the privacy policy and practices followed by Prizm and its subsidiaries. This notice explains the types of borrower information we collect and under what circumstances we may share it.

Borrower Information We Collect. We collect only relevant information about borrowers in order to establish and maintain your account and services as the law allows or requires us to collect. We may collect personal and financial information about you, which is Nonpublic (borrower information). The borrower information we collect varies depending on the accounts and services you request and use. We collect information about you from the following sources:

Application Information. We retain personal information we receive from you on any application you provide to us for loans or other related loan services. Application information includes: your name, address, e-mail address, social security number, birth date, phone number, drivers license number, employment, financial status, credit history and other loan related information.

Your Transactions. We retain your transaction information any time you perform a transaction on one of your loan accounts, transactions through online banking, online loan payer, including over the phone. Transaction information includes: your account number, the date, the amount, the location of the transaction and other loan related information.

From affiliates, dealers and other business partners. For example, credit applications, retail installment contracts, third-party servicing agreements, and other forms you complete with such entities. This applies to the following categories: identifiers; California Customer Records personal information categories; commercial information; internet or other similar network activity; geolocation data; audio, visual, electronic, or similar information; professional or employment related information; educational information that is not publicly available; inferences drawn from other personal information.

Credit Reports. When we evaluate your application for a loan, we may request a credit report about you from a consumer reporting agency. We retain the personal and credit history information about you and we may use it to evaluate your future account service requests.  By accepting our terms and conditions you authorize Prizm Financial Co., LLC and its subsidiaries to gather any necessary credit information on your behalf, including obtaining a credit report, for the sole purpose of determining credit worthiness.

Online. We obtain information online when you visit our websites, www.prizmfunding.com and www.722redemption.com. This includes retaining information you provide to us on an online application, through online loan payer, or related online loan information you provide, or by e-mail.

Disclosure of Information. To see how Prizm may share Personal Information and how you may be able to limit certain types of sharing, please see our Privacy Notice.

Our Sharing of Borrower Information. In order to provide financial services to you, we may share certain information about you with our affiliates and third party service providers. However, we limit any information sharing to the extent necessary to service your account or offer new services to you. If we share your information, it is with the goal of bringing you quality services, more choices, and greater convenience. Information we may have about former borrowers is shared or disclosed only if it is required to enforce or administer an account or as required by law.

Sharing Information with Affiliates. We may share information from time to time with our affiliates; such affiliates may include companies that provide financial services, including financial planning, securities, insurance products as well as auto-lending services and other loan related services. We may share personal information (name, address, account number, and phone number) and account information (type of accounts, account balances, and transaction history) with our affiliates so they can serve you more efficiently. Any affiliates of our must maintain the same privacy standards as us.

Sharing Information with Third Party Service Providers. In order for us to conduct our operations, including servicing your account and processing your transactions, we need to share information with our service providers, including: data processing companies, check, ATM and other payment processing companies, payment networks, loan service providers, insurance companies, collection agencies, credit reporting agencies, securities brokerage and financial planners and service providers with whom we have marketing agreements. These service providers act on our behalf and have agreed in writing to keep the member information we provide to them confidential. We share the following categories of information to third party service providers depending on the specific services provided:

  • Personal information (name, address, account number, and phone number)
  • Account information (type of accounts, account balances, transaction history)
  • Transaction information (dates, amounts, locations and type of transaction)

We do not sell borrower information nor share your account numbers with independent third party marketers offering their products and services. While we may assist in offering the financial products and services of our affiliates or third party service providers, we control the borrower information used to make such offers.

Sharing Information as Legally Required or Permitted. We may share any borrower information of yours in response to a lawful request issued by a court, government agency, or regulatory authority or as permitted by law in order to administer or enforce your account. We may also share our experience information about you with credit bureaus. Our reporting to credit bureaus is governed by the Fair Credit Reporting Act, which affords you the right to make sure that your credit bureau reports are accurate.

Our Confidentiality and Security Safeguards. We maintain strict policies and security controls to assure that borrower information in our computer systems and files is protected. Our employees are permitted access to borrower information that they may need to perform their jobs, to provide service to you, and as necessary to conduct a transaction or respond to your inquiries. All employees are trained to respect borrower privacy. No one except our employees have access to the Prizm’s computer system and records storage. Prizm established internal security controls, including physical, electronic and procedural safeguards to protect the information you provide us and the information we collect about you. We will continue to review our internal security controls to safeguard your borrower information as we employ new technology in the future.

Online Privacy Protections. At our website you may apply for loans and loan related services and you may communicate with us via e-mail. To protect the information you provide us online, we use multiple levels of security. The application information we accept online, our online bill payer service relies on industry standard Secure Sockets Layer (SSL) encryption to secure your transaction information and communication. Generally, our e-mails are not secure. However, if we ask you to e-mail us information other than your name, address, e-mail address, and phone number, it will be obtained using a secure (SSL encryption) e-mail form.


When you visit our web site, you can access site information, without revealing your personal identity. However, in order to help us identify you for future site visits, we use cookies to track your visit. A cookie is a piece of information that our web server stores on your computer hard drive and retrieves later. The cookie will not request, require, or collect personal identity information and you remain anonymous. Your borrower information is not accessed by or stored within a cookie in any way.

 

Protecting Children’s Information Privacy. Our online financial services are not designed for or directed toward children. We do not knowingly solicit or collect data from children and we do not knowingly market to children online. We recognize that protecting children’s identities and online privacy is important and that responsibility rests with us and with parents.

Privacy Policy Inquiries. If you have any questions about our privacy practices, contact us by calling (513) 721-2800, sending us an e-mail at, support@prizmfunding.com or writing to us at: Prizm Financial Co., LLC 3700b Park 42 Drive Suite 150 Cincinnati, OH 45241

Michigan Disclosures: Accounts financed pursuant to License No. RL-0019899 effective 01/01/16 are regulated by the Office of Consumer Finance - Michigan Department of Insurance and Financial Services, 530 W. Allegan St. 7th Floor, Lansing, MI, 48933, 877-999-6442. Customers may make payments 24/7 through the online customer portal or by phone Mon-Fri 7 AM-7 PM, Sat 8 AM-12 PM EST*.

*Payments made after 5pm EST Mon-Fri and on Saturdays may not be processed until the following business day.

California Residents: Your Rights and Choices under the California Consumer Protection Act

For California Residents, the California Consumer Protection Act (CCPA) provides consumers with specific rights regarding their Personal Information as defined by the act. This section describes your CCPA rights and how to exercise those rights. Prizm is a financial institution regulated by the Gramm Leach-Bliley Act (see 15 USC 6801-6809) as well as other state and federal privacy regulations which may impact your rights under the CCPA.

You have a right to notice, at or before the point of collection, the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS – CALIFORNIA CONSUMERS

You have the right to request that Prizm disclose certain information to you about our collection, use, disclosure, and sale of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request Prizm will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

To exercise the access and data portability rights described above, please submit a verifiable consumer request to us by contacting us at support@prizmfunding.com or 855-747-2700.

Only you, or a person authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

DELETION REQUEST RIGHTS – CALIFORNIA CONSUMERS

You have the right to request that Prizm delete any of your personal information that we collected from you or maintained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information.
  • Provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the deletion request rights described above, please submit a verifiable consumer request to us by contacting us at support@prizmfunding.com or 855-747-2700.

Only you, or a person authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

RESPONSE TIMING

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the need for an extension period.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we provide your personal information in a format that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance either in writing, electronically, or through your account.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION – CALIFORNIA CONSUMERS

You have the right not to receive discriminatory treatment by Prizm for the exercise of any of the privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

CONTACT INFORMATION

If you have any questions or comments about your choices and rights regarding the use of your Personal Information under California law, please do not hesitate to contact us at:

support@prizmfunding.com or 855-747-2700.

We reserve the right to amend our Privacy Policy at anytime and we will notify you as required by law. Please note that our General and Associate Corporate Counsel acts solely on behalf of, and represents the sole interests of Prizm Financial Co., LLC. We are not a law firm, or licensed to practice law. The information and or forms, reference materials, etc., contained herein are for attorney reference only. Prizm Financial Co., LLC. does not provide you or your client with legal advice; we represent the lender, you represent the borrower. No attorney-client relationship is intended or implied; you and/or your client(s) are advised to seek out independent counsel for any and all legal advice upon which you or they intend to rely (other than upon your own legal advice), and no representation or warranty is made by Prizm Financial Co., LLC or its General or Associate Corporate Counsel), whether expressed or implied, upon which you or your client(s) may rely upon as any form of legal advice.