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Direct
Lending Services Privacy Policy |
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Direct Lending, Inc.
(dba Direct Lending) believes that privacy is a cornerstone of
our customer relationship. In operating our business, we strive
to find methods to guard personal identity and information by
promoting the use of fair information practices. We have created
this privacy policy to demonstrate our firm commitment to
privacy and to inform you of our practices concerning the
collection and use of the information that you provide to us.
Direct Lending may amend this policy from time to time. If we
make any substantial changes in the way we use your personal
information, we will post an announcement on our web site.
Gramm-Leach-Bliley Act
Direct Lending
complies with the requirements of Title V of the
Gramm-Leach-Bliley Act, 15 U.S.C. §6801 through § 6810 ("GLB
Act"), and the Federal Trade Commission's implementing
regulation, Regulation P, 16 C.F.R. Part 313 ("Regulation P"),
in particular, as both related to the disclosure and protection
of Non-Public Personal Information ("NPI") for customers with
regard to the authorized distribution and intended use of
customers' financial information to other parties. Direct
Lending will substantially comply with the GLB Act and
Regulation P for all customer NPI received, transferred or
obtained from the use of this site or from a party.
Collection of Information
Direct Lending may
collect and use personal information to respond to requests for
our services or to provide information about our services that
may be of value. Certain personal information Direct Lending
collects may be publicly available via government records,
telephone books, or other widely available media however we
treat all information provided as non-public. Direct Lending
collects personal information from a variety of sources,
including:
1. Application Information (Information
provided from loan applications and other forms such as names,
addresses,
telephone numbers, birthday, social security
numbers, level of family income, employer's name, and employer's
address);
2. Credit Reports (Information from consumer
reporting agencies);
3. Correspondence (Information
provided when communicating in writing, online or by phone with
our customer service representatives); and
4. Marketing
partners and publicly available databases (We receive
information from our marketing partners, e.g., financial
institutions, auto dealerships and other businesses and public
databases which we use to help us serve our customers).
We use information that we obtain to evaluate auto loan
applications, locate an appropriate auto dealer and/or lender
for you, in order to provide high quality service, prevent fraud
and, with the customer's consent, inform customers of offers of
other Direct Lending services offered by third parties. We may
also use this information to confirm a customer's identity when
they call us to inquire about their account.
Technical Information
Direct Lending uses technology
to:
• Gather technical information from Web browsers (IP
address, operating system).
• Set cookies on your
computer. "Cookies" are small computer files which are
automatically placed on your computer's hard drive when you are
connected to a website or remote server so that the website can
recognize you upon your return to the website and tailor your
experience based on your earlier use of the site. Direct Lending
uses a cookie for each computer that visits its site. The cookie
is integral to the customer experience and is necessary in order
to use our online services. It allows Direct Lending to
customize the website presentation based on your accounts. While
cookies can be disabled, if you choose to disable our cookie you
will not be able to use some of our websites. We do not use
cookies to collect information from hard drives or to collect
personal identifiable information; rather, it allows us to
recognize you and know how you navigated through our site. It is
also part of our effort to detect and stop fraud.
• Keep
track of loan application statuses through the use of "Action
tags" (also known as Web Beacons, Trackers, or Bugs), which are
invisible pixel.gif files placed on web pages that are used to
track web navigation to those pages.
Security
Safeguard Procedures
Direct Lending uses a variety
of security safeguards to protect information from loss, misuse,
alteration or destruction. For example, customers are only able
to access information in their account by submitting their user
name and password they created during registration. We provide
access to personal information to Direct Lending employees and
other authorized parties on a "need to know" basis. In addition,
we require that all employees attend a privacy training program
and sign a Confidentiality Agreement that indicates that they
are aware of Direct Lending privacy policy regarding the use and
disclosure of information.
Direct Lending also uses
Secure Sockets Layer (SSL) technology supporting up to 128-bit
encryption to prevent unauthorized parties from viewing any
personal information transmitted to or from Direct Lending. We
maintain up-to-date firewalls and use anti-virus software that
updates automatically.
Sharing of Information
with Third Parties
Direct Lending may disclose
personal information to the following types of third parties:
Direct Lending partners (auto dealerships that meet customer's
criteria and financial institutions), Credit Bureaus and Service
Companies (companies that provide services to Direct Lending in
order to process auto loan applications). Personal information
is disclosed to the foregoing entities solely for the purpose of
locating a vehicle that meet the customer's criteria and to
obtain credit for the purchase of such vehicle. Outlined below
is the information we share with each type of third party.
Direct Lending Partners
Direct Lending
offers its services in conjunction with auto dealerships,
financial institutions and other businesses (collectively,
Direct Lending Partners). When a customer completes a credit
application with Direct Lending for the purpose of locating a
vehicle that meets their criteria and obtains credit for the
purchase of such vehicle, the customer may agree to the sharing
of information with that partner. The customer agrees that
Direct Lending and/or its auto dealers or lending partners may
forward their application to other auto dealers or lenders for
consideration. The customer authorizes any auto dealer or lender
who receives their application to retain it, to rely on it and
to obtain such other information as require, including credit
reports, to complete the processing of their request for credit.
The customer further authorizes that any auto dealer or lender
who receives this application to inform Direct Lending and its
lending partners of their credit decision. These relationships
are clearly stated in the application and by completing the
application the customer agrees to permit Direct Lending to
share their information, which may include the applicant's name,
address, phone number, e-mail address, and other personal
financial information with our partners. In addition, since we
do not service auto loan applications, we will sell loan
applications to auto dealerships. The customer will be notified
of the auto dealership that will be servicing their auto loan
application.
•Credit Reporting Agencies - Companies
involved in the loan process are a necessary part of the auto
loan process. When a customer applies for credit, he/she agrees
that we may request consumer credit reports from one or more
credit reporting agencies in connection with their application
and administration of the application. The customer may also
authorize us to exchange credit information concerning their
account with (and answer questions and requests from) others,
such as merchants, other lenders and credit reporting agencies.
•Service Companies -- In order to provide quality service,
Direct Lending contracts with service providers for the
essential role of processing loan applications. We may disclose
some or all of the information we collect to these service
providers but only in order to obtain credit for the customer.
All of Direct Lending service providers have entered into a
contract with Direct Lending that forbids them from using
information provided by Direct Lending for any purpose other
than providing the service for Direct Lending customers. These
service companies are required by law to adhere to federal and
state privacy regulations. Direct Lending takes security
precautions to monitor the use of the information and prevent
the use of the information for any other purpose. When we
contract with organizations to provide services to our
customers, we will require them to conform to our privacy
standards and to allow us to audit them for compliance.
•Merchants -- Direct Lending does not share any information with
external merchants for the purpose of extending offers of goods
and services without the customer's consent. Direct Lending does
NOT use third party advertising companies to provide
advertisements or allow third party advertisers to track web
browsing activities on its web sites.
•In addition,
Direct Lending does not knowingly offer its services to minors.
Similarly, Direct Lending does not collect information from
children. Our application approval process is designed to
identify applications submitted by children and to prevent their
use of our websites.
Exercising the Right to
Opt-Out of Information Sharing
Direct Lending
provides its customers with the opportunity to opt-out of
information sharing with affiliates and partners. A customer
must make their opt-out decision before completing the auto loan
application process. Customers can opt-out by clicking on the
link at the bottom of the auto loan application screen.
Storing of Information
We maintain
electronic loan application information and hardcopy data. We
also protect all personal information by storing the information
on tapes at an offsite facility in our Data Warehouse. The Data
Warehouse is disconnected from the production environment and
the information is used internally for reporting purposes.
Privacy Related Issues
Direct Lending is
committed to customer service and privacy. If you have any
questions, comments or concerns regarding our Privacy Policy and
its implementation, or you would like to report any known or
suspected privacy or security breaches, please do not hesitate
to contact our Security Compliance Officer at
Tcredit@frontiernet.net. |
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