Privacy Policy

Introduction

This Privacy Policy (“Policy”) applies to Finturf, LLC. and its affiliates (“Finturf,” “we,” “us,” “Site,” and “App”). This Policy governs the services we provide to you (“You” and “Your”) regardless of how you access them and applies to the information Finturf collects through this website and all of its associated content, functionalities and advertising. This Policy informs You about our services, and how we collect, use, store, and share Your information. Please read this Policy in full before using this Site. Your use of this Site and Your sharing of Your personal information constitutes Your acknowledgement that You have read, understood, and agree to this Policy and all other policies presented on this Site.

Important Information Regarding Use of Our Site and Mobile Application

We own the information we collect on the Finturf Site (“Site”) and Mobile Application (“App”). The Site and App are intended for individuals located in the United States. The Site and App are governed solely by the federal and state laws in the United States. Users from outside the United States are advised not to disclose any PII, as defined below, to us through the Site or App. Information submitted to the Site and App may be housed on servers located in the United States.

By using the Finturf Site or App, You agree to the terms of this Policy. If You do not agree to the terms of this Policy, do not use the Finturf Site or App. Changes may be made to this Policy at any time without notice provided to You. Furthermore, by using the Site or App, You agree to the application of United States law and consent to the use and disclosure of Your information consistent with this Policy.

Definition of Personally Identifiable Information

“Personally Identifiable Information” or PII is any information that is reasonably likely to identify a specific, unique individual. PII may include, but is not limited to, the following: an individual’s name, address, e-mail address, income, financial and banking information (including banking account information and payment card data), Social Security number, Driver’s License number, telephone number, and date of birth.

Personal Information We Collect

We collect PII from You when You choose to provide it to us through the Site or App. The type of information we collect from you may differ depending on the type of service you receive from us. When You submit a request or sign-up for our services, the information we collect may include, but is not limited to:

Personal Identification Information: such as Your first name, last name, e-mail address, mailing address, phone number, birthdate, Social Security Number.
Financial Information: such as Your bank account information.

As a consumer, Your information may also be collected through merchants who submit Your personal information on our Site or App. This information may include, but is not limited to:

PII such as Your first name, last name, e-mail address, mailing address, phone number, birthdate, Social Security Number.
Employment status, annual income, credit score/FICO range.
Your applications and transactions with the Site or App, including those involving the lending partners or merchants.
Requests for pre-qualification for credit.
Purchase history information.

Automatically-Collected Information

Each time You visit the Site or App, the web server may automatically collect certain types of non-PII. Some examples of information automatically collected include:

Information about devices (including mobile devices) that you use to access the Services, Your Internet service provider, browser, operating system,;
Cookie information to recognize when You are visiting a website and as further described below;
Data related to Your location at the time of accessing the Site or App, and
Beacons to know if a certain page was visited, Your activity on particular pages, how long You spend on a particular page or portion of a page, or whether an email was opened.

Cookies

An HTTP cookie (also called web cookie, Internet cookie, browser cookie or simply cookie) is a small piece of data sent from a website and stored on Your computer by the web browser You use while browsing the Internet. When You use the services, we use cookies, along with other tracking technologies, to: a) collect certain types of de-identified data, non-PII to recognize You when You are visiting the Site; b) analyze Your use of our Site and services; c) tailor the services to your preferences; and d) manage the advertising we may display on the services. You can control the placement of cookies on Your device through the use of Your web browser’s cookie settings.

Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies via the Help section of your browser’s toolbar. Rejecting cookies may affect Your ability to use some of the features offered by the Site.We may use third-party providers of analytics tools or similar third-party services to analyze information about visits to the Site or App.

Information Obtained From Third Parties

We may acquire additional information about you from third parties such as service providers, credit bureaus, marketers, partners, researchers, and others. We may receive updates from finance providers regarding your application status, including but not limited to the loan amount or the outcome of your application. This information might include your Social Security number, FICO score, credit report, transaction history, payment history, name, phone number, email address, ZIP code, and details about finance offers you have received. We may combine the information we collect from you with data obtained from these third parties and information derived from any other subscription, product, or service we provide.

How We Use Your Information

We may use Your PII for the following purposes:

To process transactions at Your request;
To deliver the services you requested;
To verify your identity;
To assess Your creditworthiness when You apply to pre-qualify for credit;
To connect you with a finance provider who may provide you with offers;
To display Your historical transaction or other historical data;
To communicate with You about Your Finturf account;
To send you information and alerts about your relationship or transactions with Finturf;
To market goods or services offered by one of our merchants or other third-party affiliates;
For fraud prevention, fraud detection, and data security purposes;
To improve the Site, App, content, advertising, or our other products or services;
To enforce our Terms and Conditions or other applicable agreements or policies;
To personalize and facilitate Your use of our services;
To provide, maintain and improve our services; and
As may otherwise be permitted by law.

How We Share Your Information

We may share Your information in the following way:

Third-Party Services and Products: We may rent, sell, or share Your information with non-affiliated third parties to provide services or products You have requested or as described in this Privacy Policy.
Affiliated Companies: We may share Your information with entities affiliated with Finturf to provide services, advertising, or to communicate with You on our behalf.
Inquiries: By submitting an inquiry for services through our website, You acknowledge and agree to the disclosure of information provided by You or received from third parties to finance providers in our network. We may also use this information for soft credit pull inquiries. No hard credit inquiries will be performed without your authorization. Note that even if You do not provide your Social Security Number, we may access your credit file for identity verification and fraud prevention. Finance providers may retain or use Your information regardless of whether You use their services, and You should contact them directly about their privacy practices.
Product Interests: If you express interest in other products, services, or promotions, we may share your request with our partners and their affiliates and third-party marketers. By participating in specific offers or programs, You authorize us to share Your information with these other entities.
Service Providers: We may share your information with authorized service providers performing services on our behalf, including those involved in loan processing, marketing, customer service, business analysis, or website support. These third parties may access necessary information to perform their functions. We may also share Your information with other third parties for their direct marketing or advertising purposes.
Compliance: We may disclose your information to investigate, prevent, or take action regarding illegal activities, suspected fraud, potential threats to physical safety, violations of our Privacy Policy or Terms of Service, and to protect the rights and property of Hearth, our employees, users, and the public. This may include sharing information with law enforcement, government agencies, courts, and other organizations.
Regulatory Reporting: We may disclose Your information for state and/or federal licensing requirements. You authorize Finturf to obtain necessary information from your chosen finance provider to report on Your request’s disposition, such as loan closure or withdrawal. The finance provider may provide Finturf with details about your finance product to comply with laws and regulations.
Aggregated or De-identified Information: We may aggregate and/or de-identify Your information so it no longer identifies you individually. This information is not subject to this Privacy Policy and may be disclosed without limitation.
Contractor Referrals: If a third-party partner referred You, we may share Your subscription status, usage data, and loan information with them.
Consumer Services: If You use services on our website, we may share information about Your finance products, loans, loan requests, and prequalified loan options with third parties in an aggregated or de-identified form.
Legal Requirements: We may disclose Your information in response to subpoenas, court orders, legal processes, or to establish or exercise our legal rights or defend against legal claims.

California Residents: Other than as required or permitted by law, we will not disclose PII about You to other financial service providers with which we have joint marketing agreements, unless You authorize us to do so.

Merchants: SMS Consent and phone numbers will never be shared with third parties or affiliates under any circumstances.

Minors

Finturf does not knowingly collect information from minors under the age of 18, and does not knowingly use such information for any purpose, including marketing purposes. If You are a parent/guardian who knows of a minor who has provided our Site with PII, please contact us via email at: privacy@finturf.com, so that we can delete such information from our database.

Some states vary in the minimum age of consent required to obtain a loan or submit information to request an offer for a loan. Please do not use Finturf’s services if You are younger than the age of majority within the state You reside, required to use this service and/or obtain a loan.

How we Protect Your Information

We and our third-party service providers use reasonable technical, organizational, administrative, and physical safeguards to secure Your PII. We protect the confidentiality of Your PII, and prohibit the unlawful disclosure of such information. While we limit access to and work to protect Your PII, no technology is perfect. There is inherent risk involved in transferring data over the Internet, particularly if You send information to us through any unsecured means, such as email. The security of information depends also on the security of Your device, so we encourage You to take appropriate steps to safeguard Your computer and protect Your user ID and password

Opting In/Out of Information Sharing and Use

By submitting Your information on the Finturf Site or App, You consent to receive communications from the Site, our marketing partners, and lenders within our network. You may choose to opt-out of sharing Your PII for certain purposes when it is requested on this Site. To limit third-party use of Your information, please contact the third-party directly about Your information-sharing preferences. When completing the registration process, indicate Your preference on this Site or App or by following a link provided in our email communications. This Site and App, and our third-party marketing partners may also promote related product and/or service offerings to You via e-mail, SMS/text message, by telephone, and auto-dialed or pre-recorded messages to consumers who requested to be contacted either through our Site or through an opt-in process on a third-party affiliate’s site(s), even if Your number is on the federal Do Not Call list. Your provider's standard messaging rates may apply to our confirmation message and all subsequent SMS correspondence(s). You may opt-out and remove Your SMS information by sending "STOP," to the SMS/text message You receive. Your consent to receive communications is not required as a condition of using Finturf's services.

You may remove Your information from our database at any time. If You do not want to receive future communications or if You no longer wish to receive our service, contact us via email at: privacy@finturf.com or write to us at: 550 North Brand Blvd., 20^th Floor, Glendale, CA 91203.

Please be aware that Your participation in certain activities provided by Finturf may be limited if PII is not submitted. E-mail addresses and phone numbers received in an opt-out request will be added to our company’s Do-Not-Contact registry within ten (10) days after receipt. Unless You unsubscribe or opt-out, this Site assumes You consent to receive communications from it, its third-party marketing partners, and lenders. It is possible that a third-party may have purchased Your contact information and thus You may continue to receive contacts from those third parties. Finturf is not responsible for stopping all unwanted contact from sources beyond our immediate control. Please contact those third parties directly to inform them of your contact preferences.

Changes and Revisions to this Privacy Policy

By accessing the Site or App, You acknowledge that we have the right to revise and amend this Privacy Policy without notice to You. Any changes that we make to this Privacy Policy will be updated here. Your continued use of the Finturf Site or App following our posting of any such changes will mean that You accept such changes and the most recent version of this Privacy Policy.

Do Not Track Policy

Some browsers have a “Do Not Track” feature that may transmit “Do Not Track” signals to websites and other online services with which the browser communicates. At this time, we do not participate in any “Do Not Track” systems that would allow us to respond to browser “Do Not Track” signals.

Access, Updated Info, and Correction

If You would like to access or correct the PII that You have provided us through the Finturf Site or App, please contact us by email at: privacy@finturf.com.

California Privacy Rights Notice

This California Privacy Rights Notice is applicable to site visitors and users who reside in California, and supplements this Privacy Policy. California residents have specific rights regarding their personal information (“PI”) under the California Consumer Privacy Act (CCPA). This section describes your CCPA rights and explains how to exercise them. This Policy only pertains to PI that is subject to the CCPA. Much of the PI Finturf processes is subject to the Gramm-Leach Bliley Act (GLBA) and is not subject to the CCPA. Our handling of information not subject to the CCPA may not be fully described below.

Categories of Information Collected

Category	Examples	Collected [YES/NO]	Source of Collection	Purpose for Collection	Third Parties to Whom Disclosed
Personal identifiers	A real name, alias, postal address, online identifier, application ID, Internet Protocol address, email address, Social Security number, driver’s license number, and passport number.	YES	From consumer or consumer’s representative, merchant, and/or credit reports received from credit bureaus.	To make decisions about and provide services related to loans. To respond to consumer requests. To onboard merchants and facilitate their involvement in the Finturf program. To run credit reports. To advise consumers of promotions and sales.	To merchants with whom Finturf has connected customers seeking financing options. To lenders. To lending and leasing platform providers. To third parties for fraud prevention and data security purposes. To law enforcement if required by law or court order.
PI categories listed in the California Customer Records statute	A name, postal address, date of birth, signature, Social Security number, telephone number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, and debit card number	YES	From consumer or consumer’s representative, merchant, and/or credit reports received from credit bureaus.	To make decisions about and provide services related to loans. To respond to consumer requests. To onboard merchants and facilitate their involvement in the Finturf program. To run credit reports. To advise consumers of promotions and sales.	To merchants with whom Finturf has connected customers seeking financing options. To lenders. To lending and leasing platform providers. To third parties for fraud prevention and data security purposes. To law enforcement if required by law or court order.
Protected classification characteristics under California or federal law	Age (40 years or older), national origin, citizenship, marital status, medical condition, physical or mental disability, sex, veteran, or military status.	YES	From consumer or consumer’s representative, merchant, and/or credit reports received from credit bureaus.	To make decisions about and provide services related to loans. To respond to consumer requests. To onboard merchants and facilitate their involvement in the Finturf program. To run credit reports. To advise consumers of promotions and sales.	To merchants with whom Finturf has connected customers seeking financing options. To lenders. To lending and leasing platform providers. To third parties for fraud prevention and data security purposes. To law enforcement if required by law or court order.
Commercial information	Property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	From consumer or consumer’s representative, merchant, and/or credit reports received from credit bureaus.	To make decisions about and provide services related to loans. To respond to consumer requests. To onboard merchants and facilitate their involvement in the Finturf program. To run credit reports. To advise consumers of promotions and sales.	To merchants with whom Finturf has connected customers seeking financing options. To lenders. To lending and leasing platform providers. To third parties for fraud prevention and data security purposes. To law enforcement if required by law or court order.
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES	Indirectly from consumer and merchant by monitoring behavior.	To make decisions about and provide services related to loans.	To third parties for fraud prevention and data security purposes. To law enforcement if required by law or court order.
Geolocation data	Physical location or movements.	YES	Indirectly from consumer and merchant by monitoring behavior.	To make decisions about and provide services related to loans. To respond to consumer requests. To onboard merchants and facilitate their involvement in the Finturf program. To advise consumers of promotions and sales.	To merchants with whom Finturf has connected customers seeking financing options. To lenders. To third parties for fraud prevention and data security purposes. To law enforcement if required by law or court order.
Sensory data	Audio recordings of phone calls.	YES	From consumer.	To make decisions about and provide services related to loans. To respond to consumer requests for leads for home improvement contractors. To address consumer complaints. To provide proof of consumer authorization.	To Our lenders. To government agencies. To merchants.
Professional or employment- related information	Current or past job history.	YES	Directly from merchant.	To onboard merchants and facilitate their involvement in the Finturf program.	None.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that Finturf disclose certain information to You about our collection, use, disclosure, and sale of Your PI over the past twelve (12) months. Once We receive and confirm Your request, we will disclose to You:

The categories of PI we collected about You;
The categories of sources for the PI we collected about You;
Our business or commercial purpose for collecting that PI;
The categories of third parties with whom we share that PI;
The specific pieces of PI we have collected about You (i.e. a data portability request);
If we sold or disclosed Your personal information for a business purpose, two separate lists disclosing:
- Disclosures for a business purpose, identifying the PI categories that each category of recipient obtained; and
- Sales, identifying the PI categories that each category of recipient purchased.

Right to Request Deletion of Personal Information

You have the right to request that Finturf delete any part of Your personal information that we have collected from You and maintain. Once we receive and confirm Your request, we will delete, de-identify, or aggregate your personal information, unless retaining the information is necessary for us or our service provider(s) to: Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our 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; 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.

Right to Access or Modify Your Information

In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete their personal information. You may contact us directly to request access to, or modification or deletion of, Your information by emailing: privacy@finturf.com.

Non-Discrimination

Finturf does not discriminate against those who choose to exercise Your CCPA rights. Unless as otherwise allowed by the CCPA, we will not: deny You services, or provide or suggest that You may receive a different level or quality of services.

Contact Information

If you have any questions or comments about this Policy, please contact us via email at: privacy@finturf.com.