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Privacy Policy

Last update Effective as of: January 30, 2025. 

All Points Financial (“All Points Financial”) is the operator of this web site. This Privacy Policy (hereinafter sometimes referred to as the “Notice” or “Privacy Policy” or “Privacy Notice”) applies to this All Points Financial online interface (i.e., website or mobile application (“App(s)”)) (the “Site”). The term “All Points Financial” or “we” or “us” or “our” in this Notice refers to All Points Financial, and any of All Points Financials affiliates or subsidiaries that may adopt this Notice or certain applicable portions of this Notice. This Notice describes how this Site, or any All Points Financial landing pages linked to this Site (All Points Financials landing pages and this Site shall collectively refer to as “Sites”), may collect, use, store, and share information from or about you, and explains how information collected from or about you may be, used for advertising purposes or shared with third parties. All Points Financial may provide other online interfaces not covered by this Notice, which shall be subject to their own privacy notices. If you visit or access your services from one of these sites, please review the online privacy practices of that site to understand how your online information may be collected, used and shared. 

Agreement to this Policy: This Privacy Policy is incorporated by reference into All Points Financials Terms and Conditions, including the obligation to arbitrate your claims under this Privacy Policy pursuant to your agreement to arbitrate in Section XVI titled DISPUTE RESOLUTION BY BINDING ARBITRATION. See Section XVI  Dispute Resolution by Binding Arbitration section of this Agreement. By using, interacting with, entering information, or viewing information on this Site, you expressly acknowledge and consent to this Privacy Policy in it’s entirety, including providing you your consent to our use and disclosure of information collected from, or about, you in the manner described herein. You agree that All Points Financial will rely on your use and interaction with this Site as your express consent to the terms of this Privacy Notice. YOU AGREE THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY THE TERMS AND CONDITIONS AND THIS PRIVACY POLICY. 

Outline 

  1. INFORMATION WE MAY COLLECT 
  1. HOW WE MAY COLLECT YOUR INFORMATION 
  1. HOW DO WE USE YOUR PERSONAL INFORMATION 
  1. HOW YOUR INFORMATION MAY BE SHARED 
  1. YOUR DATA RIGHTS 
  1. DATA SECURITY 
  1. MISCELLANEOUS 

    I. INFORMATION WE MAY COLLECT 

    All Points Financial may collect certain information, including Personally Identifiable Information (“PII”), in accordance with the law and to provide you with exemplary services. 

    In particular, All Points Financial may collect the following categories of PII: 

    1. General Identifying Information: General Identifying Information may include, but not limited to, you full name, postal address, e-mail address, telephone number, social media account ID, profile photo, other data made publicly available, or data made available by linking your social media or other similar identifiers. 
    1. Demographic Information and Important Dates: Demographic Information and Important Dates may include, but not limited to, you gender, language preferences, nationality, and/or date of birth. 
    1. Financial Information: Financial Information may include, but not limited to, your credit, debit, or other payment data, bank account information, personal financial statements, or other financial personal information about you or your household. 
    1. Credit Information: Credit Information may include, but not limited to, your credit score, credit accounts status, and other creditworthiness information about you or your household. 
    1. Internet or Other Electronic Information: Internet or other Electronic Information may include, but not limited to, your web history, search history, interactions with a website, email, applications, or advertisements, IP address, IP Host location, enabled cookies, or any other information that may be automatically obtained from you while making use of the Sites. 
    1. Geolocation information: Geolocation information may include, but not limited to, your real-time location or GPS coordinates data provided by your computer or mobile device or web browser, data derived from your IP address, general location based on nearby Wi-Fi networks or cell towers, location history records, geotags in content uploaded to the Site, or other user location information entered by you. 
    1. Inferences drawn from the above information about your predicted characteristics. 
    1. Categories that may be considered Sensitive Personal information: Such information may include Government Identifiers, Financial Information, Credit Information, or other sensitive information as defined by applicable law. 

    Notice Regarding Sensitive Personal Information 

    “Sensitive Personal Information” means any information that could be used to identify you individually and that relates to your finances or financial accounts with us. This includes, but is not limited to: 

    • Social Security number. 
    • Account numbers. 
    • Transaction history. 
    • Credit score and credit reports. 
    • Investment information. 
    • Personal financial statements. 
    • Any other information which is used or associated with a financial account belonging to you or your financial well being. 

    Purposes of Collection: 

    We collect Sensitive Information for the following purposes: 

    • Providing and maintaining financial services and products (e.g., processing transactions, managing accounts, recommending financial relief services). 
    • Verifying your identity and protecting against fraud. 
    • Complying with legal and regulatory requirements. 
    • Improving our services and offerings. 
    • Marketing products and services by us or third-parties service providers (subject to your opt-out choices). 

    Third Parties with Whom Personal Identifiable Information or Sensitive Personal Information May Be Shared. 

    We may share your PII and/or Sensitive Information with the following types of third parties: 

    • Affiliates: Companies within our corporate family for the purposes outlined in this policy. 
    • Our Service Providers: Companies that perform services on our behalf, such as data processing, marketing, and customer support. We contractually require these providers to protect the confidentiality and security of your Sensitive Information. 
    • Third Party Financial Service Providers: Companies that preform financial services for consumers to whom consumers who use our Site may be referred to. 
    • Other Financial Institutions: Other financial institutions with whom we partner to offer specific products or services. 
    • Government Agencies: As required by law or legal process. 

    Consent and Opt-Out Options: 

    We may share your PII and/or Sensitive Personal Information for marketing purposes with our affiliates and third-party partners. You have the right to opt out of this sharing at any time. To opt out, please visit our visit our Data Rights Request page. 

    We may share your PII and/or Sensitive Personal Information with third party service providers and financial institutions as necessary to provide you with financial services and products. You may not opt out of this sharing, as it is essential for us to fulfill our contractual obligations to you. 

    Other Information We Collect Online 

    Other Information is any information, other than Personal information, PII, or Sensitive Personal Information, which does not reveal your specific identity, such as browser information, information collected through cookies, pixel tags, web beacons and other technologies, demographic information, and aggregated and de-identified data. Other Information may also include geographic information, referral information and URL information.  Although such information may not by itself reveal your specific identity, it could be used by third parties that have independent relationships with you to identify you, your web activities and your interests.  

    We may also install cookies, web beacons or other technologies, including technologies that identify the dialing, routing, addressing and signaling information generated by Sites users, that provide access to third parties to your information, including but not limited to your IP address and browsing activity on pages of our Sites where these devices are placed. Cookies may be active for a period of anywhere from 30 to 90 days, however, you may remove cookies using your browser settings. You understand that we do not control any information gathered by such devices or its use by such third parties. These third parties are required to handle your personal information in accordance with their own privacy policies and applicable data protection laws and regulations. 

    You agree that any such PII, Sensitive Personal Information, or Other Information collected through cookies, pixel tags, web beacons and other technologies, including any technologies that identify the dialing, routing, addressing and signaling information generated by website users may be used and shared by All Points Financial as provided in this Notice. 

    In general, we may use or use these different types of cookies: 

    • Strictly Necessary Cookies: These cookies are necessary to enable the basic features of our Sites and Apps, such as providing a secure log-in or booking a stay. 
    • Functional Cookies: These cookies allow our Sites to remember your site preferences and choices you make on the site. We also use functional cookies to facilitate navigation, to display content more effectively, and/or to personalize your experience. 
    • Advertising Cookies: Advertising cookies allow us to select which advertisements or offers are most likely to appeal to you. We also use them to track responses to online advertisements and marketing, and we may use them to better understand your interests so we can present you with relevant messages and offers. These cookies may also allow you to share certain pages with social networks. 
    • Analytics Cookies: Analytics cookies help us improve our Sites and Apps by collecting and reporting information on how you use it. 
    • Instant Debt Advisor’s Essentials and Non-Essentials Cookies: 
    • Essential Cookies: Cookies necessary for the core functionality of the application and cannot be disabled without impacting the user experience. In our application essential cookies include: 
    • Authentication Cookies: Used to manage user sessions and ensure secure access to the application. 
    • Application Performance Cookies: Necessary for maintaining service reliability, such as load balancing and ensuring smooth operation of the app. 
    • Compliance Cookies: Used for functionality like screen recording to capture user actions for TCPA compliance and acceptance certificates. 
    • Load Balancing Cookies: Ensure efficient distribution of network traffic across servers. 
    • Security Cookies: Protect the website and user from malicious activities. 
    • Non-Essential Cookies: Cookies that enhance the user experience but are not required for the application to function. Users can accept or reject these cookies without impacting the application’s core functionality. Examples include: 
    • Analytics Cookies: Google Analytics for tracking user behavior, understanding usage patterns, and improving the application. 
    • Marketing or Personalization Cookies: (If applicable) Used for targeted advertising or customizing user experience based on preferences. 

    You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html↗. 

    Cookie Choices. 

    There are several ways to manage cookies: 

    1. Browser settings: You can opt out of cookies on your browser. Every browser is different, please check the instructions provided by your browser. Note should you choose to opt out of cookies on your browser or disable cookies, such action may impact your use of our Site. 
    1. Cookies Preferences: Through our “Cookie Preferences” tool. Currently you can only accept or reject the use cookies on our site. However, please note that currently essential cookies cannot be rejected, and only non-essential cookies will be rejected. 
    1. Google and Adobe Analytics: We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about the use of Online Services. These services also collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/↗ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout↗. 

    Advertising Choices 

    We may use third-party advertising companies to serve advertisements on our Site. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn about your choices in connection with it, please visit: 

    1. http://www.networkadvertising.org/managing/opt_out.asp↗ ; 
    1. http://www.aboutads.info/↗,  or 
    1. https://business.safety.google/privacy/↗. 

    II. HOW WE COLLECT YOUR INFORMATION 

    1.  

    We may collect PII and/or Sensitive Personal Information from you in the following ways: 

    1. Directly from you when you visit our Sites or contact us regarding our products or services. 
    1. From third parties such as credit reporting data (accounts, pay history, balances)or lead generation data. 
    1. Indirectly from you such as through your interactions with our Sites or through the use of cookies or other related tracking software. 
    1. From marketing or analytics partners, such as Google, Meta, or other third-party partners. 
    1. From government agencies or public records. 
    1. Various third parties, such as public databases, joint marketing partners, financial service providers. 
       
       

    III. HOW DO WE USE YOUR PERSONAL INFORMATION 

    We may use your PII and/or Sensitive Personal Information for the following purposes: 

    1. to respond to your inquiries and fulfill your requests. 
    1. to inform you about important information regarding the Site, products or services for which you may apply or in which you are enrolled, changes to terms, conditions, and policies and/or other administrative information. 
    1. to deliver marketing communications that we believe may be of interest to you, including, ads or offers tailored to you, including ads on other websites, or from affiliated or unaffiliated third parties. 
    1. to personalize your experience on the Site. 
    1. to refer you to various financial service providers that may offer you various financial services independently of our Site. 
    1. to allow you to apply for various products or services and evaluate your eligibility for such products or services. 
    1. to verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to services you may enroll in, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of your Personal information. 
    1. to allow you to participate in surveys and other forms of market research, sweepstakes, contests and similar promotions, and to administer these activities. These activities may have additional rules of participation, which may also contain additional policies about how the PII or Sensitive Personal Information provided is used and/or shared. 
    1. to allow us to verify your identity or other information collected from or through our social media pages or campaigns and other interaction with online forms generated on our behalf. We may combine and use PII and/or Sensitive Personal Information you provide in this Site with the information collected from our social media pages or from your interaction with online forms generated on our behalf. 
    1. to allow you to enter and participate in our live chat, forums, and/or other types of bulletin boards that we may have on the site from time to time. 
    1. for business purposes, including data and marketing analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns. 
    1. for risk control, fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements. 
    1. to allow you to utilize features within our Sites by granting us access to information from your device, such as contact lists or geolocation, when you request certain services. 

    IV. HOW YOUR INFORMATION MAY BE SHARED 

    We may share your PII and/or Sensitive Personal Information for commercial, marketing, and business purposes, all in compliance with this Privacy Policy. 

    Information Disclosed for Business Purposes. In the previous 12 months, we have disclosed the information that may includes the following categories of personal information for business purposes: 

    1. General Identifying Information 
    1. Demographic Information and Important Dates 
    1. Financial Information 
    1. Credit Information 
    1. Internet or Other Electronic Information 
    1. Geolocation information 
    1. Inferences drawn from the above information about your predicted characteristics 
    1. Information that may be considered Sensitive Personal information 

    Categories of Third Parties Who Receive Information for Business Purposes: 

    1. Affiliates 
    1. Our Service Providers 
    1. Third Party Financial Services Companies and Financial Institutions 
    1. Marketing and Research Companies 
    1. Regulatory Authorities or Law Enforcement 
    1. Technology/Computer Software Companies 
    1. Telecommunications Companies 

    Information Sold or Shared for Non-Business Purposes. In the previous 12 months, the following categories of Personal Information, PII, or Sensitive Personal Information were sold or disclosed to third parties for non-essential business purposes. 

    1. General Identifying Information 
    1. Demographic Information and Important Dates 
    1. Financial Information 
    1. Credit Information 
    1. Internet or Other Electronic Information 
    1. Geolocation information 
    1. Inferences drawn from the above information about your predicted characteristics 
    1. Information that may be considered Sensitive Personal Information 

    Categories of Third Parties to Whom Personal Information, PII, or Sensitive Personal Information Has Been Sold: 

    1. Affiliates 
    1. Non-affiliated financial services organizations 
    1. Targeted marketing providers 
    1. Financial services organizations, including debt settlement, credit repair, credit counseling, bankruptcy, and debt management companies; other debt relief service providers. 
    1. Marketing and Research Companies 

    Sale of Personal Information and Targeted Marketing 

    All Points Financial may engage in the “Sharing” or “Sale” of your personal information. All Points Financial may also engage in “targeted advertising” in its use of your personal information. We do not knowingly collect, “sell” or “share” the personal information of individuals under the age of 18. If you are below the age of 18, you are prohibited from making use of our Sites and providing personal information on our Sites. See also COPPA Disclosure in Section VIII below. 

    V. YOUR DATA RIGHTS 

    Depending on where you reside, you may have certain rights regarding the personal information we collect and share. Residents of applicable states, including California, Virginia, Colorado, Connecticut, Iowa, Indiana, Tennessee, Texas, Montana, Minnesota, Oregon, Delaware, New Hampshire, New Jersey, Kentucky, Nebraska, and Rhode Island, may be provided the right to make the following request, depending on applicable law. 

    a) Request to Know. You may request to know whether we process your Personal information and to access such Personal information. You may request to receive the specific pieces or a copy of your Personal information, including, where applicable, a copy of the Personal information you provided to us in a portable format. Depending on where you reside, you may request that we disclose to you the following information: 

    1. The categories of Personal information we collected about you and the categories of sources from which we collected such Personal information; 
    1. The business or commercial purpose for collecting, selling, or sharing (if applicable) Personal information about you; 
    1. The categories of Personal information about you that we sold or “shared” and the categories of third parties to whom we sold or “shared” such Personal information (if applicable); and 
    1. The categories of Personal information about you that we otherwise disclosed and the categories of third parties with whom we disclosed such Personal information (if applicable). 
    1.  

    b) Request to Delete. You may request that we delete your Personal information. 

    c) Request to Appeal. If we refuse to act on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. 

    d) Request to Correct. You may request that we correct inaccuracies in your Personal information. 

    e) Request to Opt-Out of Sale, Targeted Advertising, Limit Disclosure of Sensitive Information and/or Sharing. You may request to opt-out of the “sale” of your Personal information and/or targeted advertising, including the “sharing” of your Personal information for cross-context behavioral advertising purposes. You may also limit the Disclosure and Sharing of your Sensitive Information. 

    Submitting a Data Request 

    To submit a data rights request in accordance with the above, please visit our Data Rights Request page. 

    Automated Decision-Making Tools 

    1. In the event that automated decision-making processes are used on our Site in connection with an application or request by you, depending on where you reside, you may request that we disclose to you the following: That the decision regarding your request was made using an automated decision making systems or processes; 
    1. If you are unsatisfied with the decision, you have the right to request an explanation of how the decision was made using our automated decision-making process and how you may proceed to have the decision changed or fixed. 
    1. Certain features on our Site(s) are subject to automated decision making. Any information you provide in using those features will translate to automated decision regarding your inquiry or request. You understand and agree that these automated decision making features are developed by third party technology providers which will have access to your personal information you may provide on our Site when using the automated decision making features. Your use of these features expressly authorize the share of the information with these third parties. Furthermore, you understand that the mechanisms or processes of the automated decision making features are not controlled by All Points Financial, nor does All Points Financial has the ability to effect the decision results. 
    1. The Instant Debt AdvisorSM (“Debt Advisor”): The Debt Advisor asks you simple questions and obtains from you certain personal identifiable information, including but not limited to: your full legal name, address, phone number, social security number, approval to do a soft pull to your credit, current finances, and other relevant information regarding your debt and financial situation. You understand and agrees that All Clear, as the developer of the Debt Advisor platform, may have access to the information you enter or provide the Debt Advisor, and may share it with independent service provides with whom the consumer is matched. In addition to All Points Financials privacy policy, the information shall be also subject to All Clear’s privacy policy. For more information regarding All Clear’s Privacy Policy, please visit All Clear Privacy Policy. 

    Sensitive Personal Information 

    We may collect and disclose certain information that may be considered ‘sensitive information’ under the applicable data privacy laws. We may disclose this information to affiliates, and non-affiliated third parties for various purposes, including marking or to provide you with services that you have. Depending on where you reside you may have the right to limit the disclosure of this information to non-related third parties for marketing purposes. To submit a request to limit the disclosure of your sensitive information, visit our Data Rights Request page. 

    All Points Financial Managed Direct Marketing: If you prefer that we not deliver you marketing offers in email, postal mail or through telemarketing you may manage your direct marketing choices by emailing us your requests at [email protected].  

    Opt-Out Policy for Newsletter and Email Subscriptions 

    You may opt-out or unsubscribe from a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails which you receive. Please allow five to ten (5-10) business days for changes to take effect. Please be advised that all opt-out requests will be honored by the 10th business day. You understand and agree that during that period and while your request is pending you may still receive newsletters and emails. Client service-related communications are an integral part of the services you receive from us, and you may continue to receive such service-related emails unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided. You may also opt-out of receiving our newsletter or marketing emails by contacting us at [email protected] or by replying to an existing email with your request to be removed from the mailing list. 

    VI. DATA SECURITY  

    At All Points Financial, the security of your Personal Information is extremely important to us. We take commercially reasonable precautions to protect your personal information and only provide employees access to it on a need-to-know basis. In an effort to prevent the unauthorized access, disclosure, dissemination, misuse, loss, alteration or destruction of your personal information, we have employed commercially reasonable physical, electronic, and managerial measures to protect your data and we periodically review these policies and procedures to prevent these types of acts. However, despite our best efforts, no security policy, procedures or practices are adequate to protect against all types of threats or data losses and no type of data transmission method is impenetrable to interception. 

    Links to other sites: We may provide links to third-party sites. If you follow links to sites not affiliated or controlled by All Points Financial, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Site. All Points Financial does not guarantee and is not responsible for any interaction between you and the third-party sites, including but not limited to the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. You acknowledge that the availability of third-party site links is merely for convenience purposes, and that All Points Financial does not endorse, support, acknowledge, agree with, or otherwise promote the contents of the third-party sites linked to our Site. 

    Security: To protect Personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third-party service providers to ensure information remains confidential and secure. While we follow generally accepted industry standards to protect the Sensitive Personal Information and PII submitted to us (both during your submission and after we receive it), please be advised that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal information and PII, we cannot guarantee its absolute security. If you have any questions about security on our website, you can e-mail us at [email protected].  

    Data Retention: We retain Personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include: 

    • The length of time we have an ongoing relationship with you and as necessary to provide requested services to you; 
    • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and  
    • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations). 

    VII. STATE PRIVACY DISCLOSURES: 

    This section provides state specific disclosures which apply solely to consumers who reside in the states listed. If you are a resident of one of these states, you have certain rights with respect to personal information collected and the processing of your personal information which are subject to the applicable state privacy laws. 

    Notice to California Residents: As a California resident, you have the following rights regarding your personal information 

    1. Access. You have a right, twice in a 12-month period, to request that our Company disclose to you the personal information that we collected about you, and any additional information about our collection, use, disclosure, or sale of such personal information, which is also contained in this privacy policy. 
    1. Correction. You have the right to request that we correct inaccurate personal information under certain circumstances, subject to a number of exceptions provided under California law. For information how to request the correction of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request.   
    1. Deletion. You have the right to request that we delete your personal information under certain circumstances, subject to a number of exceptions, subject to a number of exceptions provided under California law. For information how to request the deletion of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request.  
    1. Opt-Out of the Selling or Sharing of your Data or Joint Marketing. You have the right to opt out of the selling or sharing of your data. You also have the right to opt-out of joint marketing effort that Company has with other financial service providers. The CCPA requires to describe the categories of personal information our company sell or share to third parties and how to opt-out of future sales or share of said information. The CCPA defines a “Sale” broadly to include the mere making of your personal information available to third parties in some cases. Under the CCPA the term “Share” is defined as providing personal information to a third party to target advertising to a consumer based on information about their activity on multiple websites across the internet. For information how to request an opt-out of the selling or sharing of your personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Disclosure Request. You have the right to request that we provide you with (i) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (ii) the identity of those third parties. For information how to obtain a disclosure request of your personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Appeal. You have the right to appeal Company’s decision to refuse to act on a CCPA data privacy request within a reasonable period after you receive our decision. To appeal our decision, you should send your objection to our denial via email to [email protected] and to allow Company to review your data subject request. Within 45 days, Company will provide you with a written explanation of the justification for declining to act on your request. 
    1. Authentication/Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (except for a request to opt-out of sales or sharing). Company may require you to provide any of the following information: your name, date of birth, your phone number, your Social Security number, the email and physical addresses. If you request that we provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request, or authorized personnel of the consumer making the request. You understand that Company may decline to process your request where: (i) Company is unable to authenticate that you are the person to whom the data relates; (ii) the request is unreasonable or excessive; (iii) or where otherwise permitted by applicable law. 
    1. Retention. We retain personal data for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different Services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. 
    1. Notice of Financial Incentives. Company may offer rewards or prizes for participation in certain activities that may be considered a “financial incentive” under California law. These activities may involve the collection of personal information. The categories of personal information we collect is limited to what information you provide us, but may include: identifiers, protected class/demographic information, commercial information, online activities, geolocation information (general and precise), sensory information, employment information, and inferences. Activities we engage in that may be considered a financial incentive include surveys where we may provide compensation such as a gift card or bonus in exchange for your time and responses, or a prize through your participation in promotions and sweepstakes. Participation in these programs may be subject to separate terms and conditions. Your participation in these programs is voluntary and you can terminate at any time as explained in any applicable terms. If we offer gift cards in exchange for your participation in a survey or when we engage in promotions or sweepstakes, the amount provided is reasonably related to the value of the data you provide, which takes into account a number of factors, including, the anticipated benefit we receive such as product improvement, better understanding how you use our products, to enhance our understanding of consumer and market trends, increased consumer engagement, and the anticipated expenses we incur in relation to the collection, storage, and use of the information we receive. The value may vary across surveys, promotions, and sweepstakes. 
    1. Declining Requests. You understand that we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting. Also, where permitted by law if you send us a request to exercise your rights or the choices in this section, we may charge a fee or decline requests in certain cases. 
    1. Non-Discrimination. You have the right to not be discriminated against for exercising any of your privacy rights.  

    Notice to Nevada Residents. We are providing you this Notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions set forth above. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: [email protected]. 

    Notice to Colorado Residents. If you are a Colorado resident, you have the following rights regarding your personal information: 

    1. Access. You have a right, twice in a 12-month period, to request that our Company disclose to you the personal information that we collected about you, and any additional information about our collection, use, disclosure, or sale of such personal information, which is also contained in this privacy policy. 
    1. Correction. You have the right to request that we correct inaccurate personal information under certain circumstances, subject to a number of exceptions provided under Colorado law. For information how to request the correction of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request.   
    1. Deletion. You have the right to request that we delete your personal information under certain circumstances, subject to a number of exceptions, subject to a number of exceptions provided under Colorado law. For information how to request the deletion of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Opt-Out of the Selling or Sharing of your Data or Joint Marketing. You have the right to opt out of the selling or sharing of your data. You also have the right to opt-out of joint marketing effort that Company has with other financial service providers. The Colorado law requires to describe the categories of personal information our company sell or share to third parties and how to opt-out of future sales or share of said information. The Colorado law defines a “Sale” broadly to include the mere making of your personal information available to third parties in some cases. Under the Colorado law the term “Share” is defined as providing personal information to a third party to target advertising to a consumer based on information about their activity on multiple websites across the internet. For information how to request an opt-out of the selling or sharing of your personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Disclosure Request. You have the right to request that we provide you with (i) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (ii) the identity of those third parties. For information how to obtain a disclosure request of your personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Appeal. You have the right to appeal Company’s decision to refuse to act on a Colorado law data privacy request within a reasonable period after you receive our decision. To appeal our decision, you should send your objection to our denial via email to [email protected] and to allow Company to review your data subject request. Within 45 days, Company will provide you with a written explanation of the justification for declining to act on your request. 
    1. Authentication/Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (except for a request to opt-out of sales or sharing). Company may require you to provide any of the following information: your name, date of birth, your phone number, your Social Security number, the email and physical addresses. If you request that we provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request, or authorized personnel of the consumer making the request. You understand that Company may decline to process your request where: (i) Company is unable to authenticate that you are the person to whom the data relates; (ii) the request is unreasonable or excessive; (iii) or where otherwise permitted by applicable law. 
    1. Retention. We retain personal data for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different Services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. 
    1. Declining Requests. You understand that we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting. Also, where permitted by law if you send us a request to exercise your rights or the choices in this section, we may charge a fee or decline requests in certain cases. 
    1. Non-Discrimination. You have the right to not be discriminated against for exercising any of your privacy rights.  

    Notice for Vermont Residents. As a Vermont resident, you have the right to opt out of the selling or sharing of your data. You also have the right to opt-out of joint marketing effort that Company has with other financial service providers. 

    Notice for Connecticut Residents. As a Connecticut resident, you have the following rights regarding your personal information: 

    1. Access. You have a right, twice in a 12-month period, to request that our Company disclose to you the personal information that we collected about you, and any additional information about our collection, use, disclosure, or sale of such personal information, which is also contained in this privacy policy. 
    1. Correction. You have the right to request that we correct inaccurate personal information under certain circumstances, subject to a number of exceptions provided under CTDPA. For information how to request the correction of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request.   
    1. Deletion. You have the right to request that we delete your personal information under certain circumstances, subject to a number of exceptions, subject to a number of exceptions provided under CTDPA. For information how to request the deletion of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Opt-Out of Targeted Advertising. You have the right to opt-out of targeted advertising and the sale of personal data. For information how to request an opt-out of targeted advertising, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Appeal. You have the right to appeal Company’s decision to refuse to act on a CTDPA data privacy request within a reasonable period after you receive our decision. To appeal our decision, you should send your objection to our denial via email to [email protected] and to allow Company to review your data subject request. Within 60 days, Company will provide you with a written explanation of the justification for declining to act on your request. If you disagree with our explanation you have the right to contact or file a complaint with the Connecticut Attorney General. 
    1. Authentication/Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (except for a request to opt-out of sales or sharing). Company may require you to provide any of the following information: your name, date of birth, your phone number, your Social Security number, the email and physical addresses. If you request that we provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request, or authorized personnel of the consumer making the request. You understand that Company may decline to process your request where: (i) Company is unable to authenticate that you are the person to whom the data relates; (ii) the request is unreasonable or excessive; (iii) or where otherwise permitted by applicable law. 
    1. Declining Requests. You understand that we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting. Also, where permitted by law if you send us a request to exercise your rights or the choices in this section, we may charge a fee or decline requests in certain cases. 

    Non-Discrimination For Exercising Your Rights. You have the right to not be discriminated against for exercising any of your privacy rights. 

    Notice to North Dakota Residents. As a North Dakota resident you have the right to opt-out of joint marketing with other financial institutions. For information how to request an opt-out of Joint Marketing, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 

    Notice to Utah Residents. As a Utah resident, you have the following rights regarding your personal information: 

    1. Access. You have a right, twice in a 12-month period, to request that our Company disclose to you the personal information that we collected about you, and any additional information about our collection, use, disclosure, or sale of such personal information, which is also contained in this privacy policy. 
    1. Obtaining a portable copy of your personal data. To obtain a copy of your personal data that you previously provided to us in a portable format, please submit an “Access” request as described above. While these requests are distinct, we have not identified any technically feasible and readily usable format that would allow you to transmit this data to another controller. Therefore, we will provide you a copy of your personal data so that we honor your request as best is technically feasible. 
    1. Deletion. You have the right to request that we delete your personal information under certain circumstances, subject to a number of exceptions, subject to a number of exceptions provided under Utah law. For information how to request the deletion of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Opt-Out of Targeted Advertising. You have a right to opt-out of targeted advertising and the sale of personal data. For information how to request the opt out of targeted advertising, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Authentication/Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (except for a request to opt-out of sales or sharing). Company may require you to provide any of the following information: your name, date of birth, your phone number, your Social Security number, the email and physical addresses. If you request that we provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request, or authorized personnel of the consumer making the request. You understand that Company may decline to process your request where: (i) Company is unable to authenticate that you are the person to whom the data relates; (ii) the request is unreasonable or excessive; (iii) or where otherwise permitted by applicable law. 
    1. Declining Requests. You understand that we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting. Also, where permitted by law if you send us a request to exercise your rights or the choices in this section, we may charge a fee or decline requests in certain cases. 
    1. Non-Discrimination. You have the right to not be discriminated against for exercising any of your privacy rights. 

    Notice to Virginia Residents. As a Virginia resident, you have the following rights regarding your personal information: 

    1. Access. You have a right, twice in a 12-month period, to request that our Company disclose to you the personal information that we collected about you, and any additional information about our collection, use, disclosure, or sale of such personal information, which is also contained in this privacy policy. 
    1. Correction. You have the right to request that we correct inaccurate personal information under certain circumstances, subject to a number of exceptions provided under Virginia law. For information how to request the correction of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request.  
    1. Deletion. You have the right to request that we delete your personal information under certain circumstances, subject to a number of exceptions, subject to a number of exceptions provided under Virginia law. For information how to request the deletion of personal information, please see section V of this policy, and specifically subsection titled Submitting a Data Request.  
    1. Opt-Out of Targeted Advertising. You have a right to opt-out of targeted advertising and the sale of personal data. For information how to request the opt out of targeted advertising, please see section V of this policy, and specifically subsection titled Submitting a Data Request. 
    1. Obtaining a portable copy of your personal data. To obtain a copy of your personal data that you previously provided to us in a portable format, please submit an “Access” request as described above. While these requests are distinct, we have not identified any technically feasible and readily usable format that would allow you to transmit this data to another controller. Therefore, we will provide you a copy of your personal data so that we honor your request as best is technically feasible. 
    1. Appeal. You have the right to appeal Company’s decision to refuse to act on a CTDPA data privacy request within a reasonable period after you receive our decision. To appeal our decision, you should send your objection to our denial via email to [email protected] and to allow Company to review your data subject request. Within 60 days, Company will provide you with a written explanation of the justification for declining to act on your request. If you disagree with our explanation you have the right to file a complaint with the Virginia Attorney General. 
    1. Authentication/Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request (except for a request to opt-out of sales or sharing). Company may require you to provide any of the following information: your name, date of birth, your phone number, your Social Security number, the email and physical addresses. If you request that we provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request, or authorized personnel of the consumer making the request. You understand that Company may decline to process your request where: (i) Company is unable to authenticate that you are the person to whom the data relates; (ii) the request is unreasonable or excessive; (iii) or where otherwise permitted by applicable law. 
    1. Declining Requests. You understand that we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting. Also, where permitted by law if you send us a request to exercise your rights or the choices in this section, we may charge a fee or decline requests in certain cases. 
    1. Non-Discrimination. You have the right to not be discriminated against for exercising any of your privacy rights.  

    Notice to Users Outside of the United States. This Online Privacy Policy is intended to cover collection of information on our Sites from residents of the United States only. If you are visiting our Site from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third-parties with whom we share it as described in this Notice. We do not sell, offer, or otherwise provide services to individuals outside of the United States. 

    VIII. MISCELLANEOUS 

    Social media sites. All Points Financial provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. Any content you post on official All Points Financial managed social media pages, such as pictures, information, opinions, or any Personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. By allowing you to post or share information on All Points Financials social media pages, you acknowledge that All Points Financial does not endorse, support, acknowledge, or otherwise agree with the posted information and any such posts shall be your sole responsibility. You also agree that All Points Financial may use any information posted by you on All Points Financials social media for any purpose provided in this Notice. Please refer to them to better understand your rights and obligations with regard to such content. In addition, please note that when visiting any official All Points Financial social media pages, you are also subject to All Points Financials Privacy Notices, in addition to any social media platform’s Privacy Notice to which you may be subject to. 

    Short Message Service. Note that this policy notice does not replace your opt in requirements. We may make available a service through which you can receive communications your wireless device via short message service (“SMS Service”). Data obtained from you in connection with this SMS service may include your name, address, cell phone number, your provider’s name, and the date, time, and content of your messages. By providing your contact information, you affirmatively represent that you are 18 years of age and the owner or authorized user of the wireless device on which messages will be received, and that you understand that such communication may be subject to certain applicable charges, and that you approve all such applicable charges. In addition to any fee of which you are notified, your provider’s standard message and data rates may apply to our SMS confirmation and all subsequent SMS correspondence. All charges for data rates are billed by, and payable to, your mobile service provider. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. We will not be liable if SMS are received after hours due to such transmission delays. SMS message services are provided on an AS IS basis. We may also obtain the date, time, and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service in accordance with this Privacy Policy. We may provide your carrier with your applicable information in connection with your consent to receive SMS. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. We will not be liable for any data use or misuse by your wireless carrier. 

    You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. You must have a two-way text-enabled phone with compatible carrier and plan. Compatible major carriers include Alltel Wireless, AT&T, Boost Mobile, Nextel, Sprint, T-Mobile, Verizon Wireless and Virgin Mobile USA. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. 

    SMS and Phone Call Opt-In. Note that this policy notice does not replace your express written consent and opt in requirements. By completing a lead or contact form and affixing you electronic signature, in compliance with the E-SIGN act and disclosure which is available to you in the link above or in the footer of our Site, you have agreed to give All Points Financial your express signed prior written consent and authorize All Points Financial, and direct representatives calling on its behalf to contact you via telephone calls, or mobile device messages, online live chat and chatbots (including marketing calls and messages through by autodialing, text and pre-recorded messaging, AI generative voice, SMS, and MMS), even if my telephone number is currently listed on any internal, corporate, state or federal Do-Not-Call list. Msg. and data rates may apply, and you may opt out of text messages at any time by texting “HELP” for help, and “STOP”, “END”, “QUIT”, “UNSUBSCRIBE”, “OPT OUT”, “REVOKE” or “CANCEL” to opt out from any future communications. You may also choose to opt-out and remove your authorization to receive such calls and/or text messages by emailing us your instructions at [email protected]. You also consent to the recording and monitoring of all calls to and from us. Further, by providing your e-mail above, you authorize and give All Points Financial your express written consent, to receive electronic communications, including periodic emails with important news, financial tips, tools and more from All Points Financial. You understand that you can always withdraw your consent or unsubscribe at any time at [email protected]. You are not required to obtain goods or services or to be connected with any of the service providers that can fit my needs and that I may choose to call All Points Financial representative instead at 1.800.810.0989. 

    Making Sure Information is Accurate. You understand and agree that All Points Financial presumes that the Personal Information you provided is, indeed, accurate. All Points Financial will not be responsible for verifying that Personal Information. You understand that if you use any automated decision making features on our Site, it is crucial that you provide accurate PII and/or Sensitive Personal Information being requested in order for the automated decision making feature to process and provide you with an accurate decision and/or result. It is your responsibility to ensure the information provided is accurate and up to date. If you have previously submitted information which is incomplete, inaccurate or not current, please email or write us at the appropriate address, or complete a data request form, with updated information which you would like us to use in our communication with you. 

    Business Transitions. You understand and agree that if All Points Financial goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal information, PII, and additionally collected information will likely be among the assets transferred. 

    Do Not Track Disclosures 

    How do we respond to Web browser “do not track” (also referred to as “DNT”) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services? 

    ANSWER: We currently do not respond to DNT signals in browsers because we do not track individual users across the web. 

    May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit www.allpointsfinancial.com. 

    ANSWER: Yes, we currently have technology partners that provide us with Site tools which the consumer may use while visiting our site, which when used share personally identifiable information with our technology Partners. For Example, should you use the Instant Debt AdvisorSM, certain information is shared with the technology provider, All Clear Decisioning, LLC, and may also be shared with third-party service providers. 

    Protecting Children’s Privacy Online (Children’s Online Privacy Protection Act (COPPA)) Disclosure. The Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personally Identifiable Information (PII) through the Site. We do not knowingly collect information from children under 18 years of age without parental consent. If you are a User under the age of 18, please do not send any PII to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected PII from a User under the age of 18 without parental consent, or if we learn a User under the age of 18 has provided us with PII beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 18 may have provided All Points Financial with PII in violation of this Privacy Policy, please contact us at our e-mail or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information. For more information about the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy. 

    English Language Govern this Privacy Notice. You acknowledge and agree that the text of this Privacy Notice, including any and all linked pages or other page Sites, have been written, and are offered, in both English and Spanish. Each version is authentic. In the event of any dispute regarding this Privacy Policy, however, the English version shall be given priority of interpretation and shall therefore be controlling. Additionally, all notifications shall be provided by one party hereunder to the other party in the English language. You may request a copy of this Privacy Notice in Spanish for your records. 

    Updates to this Privacy Notice. This Online Privacy Notice is subject to change at the sole discretion of All Points Financial. Please review the Privacy Policy periodically to see if there are any changes. If we make changes to the Privacy Notice, we will revise the “Last Updated” date at the top of this Notice. Any changes to this Notice will become effective when we post the revised Notice on the Site. You agree that your use of the Site following any changes to this Notice means that you accept the revised Notice and the Privacy policies therein. 

    CONTACT US 

    If you have any questions or suggestions regarding our privacy policy, please contact us: 

    All Points Financial dba of VYSYZ LLC 
    6360 NW 5TH WAY SUITE 302
    FORT LAUDERDALE, FL 33309 

    Via Email at: [email protected] 

    PLEASE PRINT AND RETAIN A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS.