Last updated: December 2020
1. Collection of Your Information
We may collect and store various information about you, including information that you provide to us, information that we automatically collect through your use of the Service, and information from publicly-available sources or third parties, as follows:
A. Information you provide us directly
The information we collect from you will vary depending on the product or service requested. We may ask for certain information such as your username, first and last name, birth date, telephone number, email address, college or university, year of graduation, course of study, outstanding loan balances, social security number, income, employment history and other details related to your financial situation when you use our Service and/or register for a Splash Financial account. We may collect information that you voluntarily provide to us when using the Service. All of the information that we collect from you directly is identified in the forms, other places where you respond to questions, or where you indicate preferences throughout the Service, either online or communicated through our customer service representatives.
B. Information That Is Collected Automatically
In addition to the information you provide to us directly, we may automatically collect information about your use of the Service, as described below.
- Log file information. Log file information is automatically reported by your browser each time you access the Service. When you use our Service, our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from \which you accessed the Service, software and hardware attributes (including Device ID), referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
- Location information. When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, features and/or products made available via the Service.
Information from Third-Party Sources
We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.
2. Tailored Advertising
We may use third-party advertising technologies that allow for the delivery of relevant content and advertising on the Service, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Also, third-parties whose products or services are accessible or advertised via the Service may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Service as discussed above. We may also allow other third-parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Service, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service. Splash Financial does not sell, rent, or share the information we collect directly from you or about you from third-parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.
Please note that an advertiser may ask Splash Financial to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, Splash Financial determines the target audience and Splash Financial serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.
Please note that to the extent advertising technology is integrated into the Service, you may still receive advertisements even if you opt out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
3. Use of Your Information
We may use your information and/or combine any or all elements of your information for a number of purposes, including:
- To provide you with and manage the Service. We use your information to operate, maintain and provide to you the features and functionality of the Service. This may include customization and tailoring the Service features according to the information that you provide.
- To communicate with you. We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails.
- To improve the Service and advertise. We may use the information we collect to analyze and improve the Service and to provide advertising to you.
- To protect the rights of Splash Financial and others. We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of Splash Financial, its employees or agents, or other users and to comply with applicable law.
- When collecting information across personal devices, and applications. Sometimes, we (or our service providers (“Providers”)) may use the information we collect – for instance, log-in credentials, IP addresses and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computer), or work with Providers that do this, in order to better tailor advertising, content, and features, and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
- With your consent. We may otherwise use your information with your consent or at your direction.
- To aggregate/de-identify data. We may aggregate and/or de-identify information collected through the Service. We may use de-identified and/or aggregated data for any purpose and without any restrictions, including without limitation for research and marketing purposes, and may also share such data with any third-parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
Cookies. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser or stores information or settings on your device. Cookies let us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. Our Service may use HTTP cookies, HTML5 cookies and other types of local storage (such as browser-based or plugin-based local storage). Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the Service.
Clear gifs/web beacons. When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened, which links are clicked by recipients, and whether our emails are forwarded. The information allows for more accurate reporting and improvement of the Service.
Web analytics. We may use third-party Web analytics services on our Service, such as those of Google Analytics. These Providers use the technology described above to help us analyze how users use the Service. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these Providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on.
We may use this information in a number of ways, including: (a) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) to provide custom, personalized content and information; (c) to provide our Service and monitor its effectiveness; (d) to monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in and; (g) to deliver advertising to you.
5. Do Not Track Signals and Similar Mechanisms
We are unable to respond to Do Not Track signals or similar tools and settings at this time due to the limits of current Internet technology.
6. Sharing of Your Information
We may share the information we collect or receive from you in a variety of circumstances, including:
- Providers and co-signers. We may share your information with Providers for the purpose of providing the Service to you such that they may provide you with information about prequalified loan offers, and information related to other products and services they offer.
- You understand that Providers may keep your information that relates to any submission of information that you may make through your use of the Service and any other information provided by Splash Financial in the processing of any submission of information, whether or not you are eligible for the Provider’s products or services. You agree to notify any particular Provider directly if you no longer want them to keep your information.
- We may also share certain automatically-collected information, including information obtained through tools such as cookies, log files, and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with Providers as described in the section titled “Cookies and Other Tracking Technologies.”
- Affiliates. We do not have any affiliates.
- Providers. We may share information with third-parties that help us operate our business and provide our services, such as parties that provide us with technology, services, data or content. For example, we may share information with Providers who assist in the verification of your identity. This may include (but is not limited to); credit bureaus, Providers that provide access to your existing accounts (at your request), your school, and other parties. We also remind you that under our Terms of Service you authorize the use of your third-party Account Information to help complete your requests and submissions.
- Marketing partners. We may also share your information with marketing partners where the marketing partner maintains a link to our Service on their site and you click from their site to our Service.
- Other parties when required by law or as necessary to protect our users and services. Splash Financial may share your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) exercise or protect the rights, property, or personal safety of Splash Financial, our Users or others.
- Business transfers. We may buy or sell/divest/transfer Splash Financial (including any shares in Splash Financial), or any combination of its products, services, assets and/or businesses. Your information such as user names and email addresses, and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of Splash Financial.
- Aggregated or de-identified information. We may also aggregate or de-identify data and may share that data without restriction.
7. How We Store and Protect Your Information
Storage and Processing
Your information collected through the Service may be stored and processed in the United States or any other country in which Splash Financial or its subsidiaries, affiliates or service providers maintain facilities. Splash Financial may transfer information that we collect about you, including personal information, to affiliated entities, or to other third-parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
Keeping Your Information Safe
Splash Financial cares about the security of your information, and takes technical and organization measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures vary depending on the sensitivity of the information we have collected from you. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. Splash Financial is not responsible for the functionality or security measures of any third-party or Provider.
To protect your privacy and security, we take steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Splash Financial, at all times. Do not share your password with anyone and do limit your access to your computer or other devices by signing off after you have finished accessing your account.
For information about how to protect yourself against identity theft, please refer to the Federal Trade Commission’s website at www.ftc.gov/news-events/media-resources/identity-theft-and-data-security.
To find out more about Splash Financial’s security measures, review our security policy.
8. Your Choices About Your Information
Your Account Information and Settings
If you choose to set up a profile, you may update your account information at any time by logging into your account and changing your profile settings. You can also contact us at support@SplashFinancial.com to change your preferences.
You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, and technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at support@SplashFinancial.com.
9. How Long We Keep Your User Content
Following termination or deactivation of your User account, Splash Financial may retain your profile information for an additional period of time for backup, archival, or audit purposes. In certain circumstances, we are required by Federal and State regulations to store various information. In order to comply with those requirements, we may be unable to delete your information from our database until the expiration of the applicable period.
10. Children’s Privacy
Splash Financial does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at support@SplashFinancial.com.
11. Links to Other Web Sites and Services
12. Your California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits Users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third-parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third-parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:
Online Privacy Coordinator
Splash Financial, Inc.
812 Huron Rd. E. Suite 350
Cleveland, OH 44115
12A. California Consumer Protection Act (“CCPA”)
If you are a California resident, the CCPA provides you certain rights and choices regarding how we collect, share, use, and protect your “personal information” and how you can exercise those rights. The CCPA defines “personal information” as information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly, or indirectly, with a particular consumer or household.
To the extent that we collect “personal information” that is subject to the CCPA, that information, our practices, and your rights are described below.
Information: You can request information about our collection and use of your “personal information” over the past 12 months. Once we receive, and verify, that it is coming from you, or someone authorized by you, we will disclose to you or your representative: (1) The categories of “personal information” we collected about you; (2) The categories of sources for the “personal information” we collected about you; (3) Our business or commercial purpose for collecting or selling that “personal information”; (4) The categories of third parties to whom we sold or disclosed the “personal information” for a business or commercial purpose; (5) The business or commercial purpose for which we sold or disclosed; and (6) The specific pieces of “personal information” we collected about you.
Categories of Personal Information:
|Category||Collected||Sold||Shared (for business purposes)|
|Identifier: such as a real name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifier.||Yes||No||Yes|
|California Customer Records: such as your address and telephone number||Yes||No||Yes|
|Protected Classification: such as age, race, sex, religion, national origin, and marital status||Yes||No||Yes|
|Biometric Information: such as genetic, physiological, behavioral, and biological characteristics, or identifying information such as fingerprints, faceprints, and voiceprints||Yes||No||Yes|
|Internet or other electronic network activity: including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application or advertisement||Yes||No||Yes|
|Geolocation data: such as the physical location of your device||Yes||No||Yes|
You can ask us to delete the personal information that we collected or maintain about you. We are required to verify your identity before we can act on your request. We may have a reason under law why we do not have to comply with your request or why we may comply with it in a more limited way that you anticipated. If so, we will explain that to you in our response.
How to Submit a Request
To exercise rights described above, please submit a verifiable consumer request to us by either calling us at (800) 349-3938 or emailing us at support@SplashFinancial.com. You may only make a verifiable consumer request twice within a 12 (twelve) month period.
Making a verifiable consumer request does not require you to open an account with us. We must be able to verify your identity or authority to make the request and confirm the personal information relates to you. We will only use information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits to verify the identity of the authorized agent and confirm that you have authorized that person to act on your behalf.
We will try and respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period, not to exceed 90 days, in writing. Any disclosure we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. We do not charge a fee to process or respond to your verifiable consumer request.
13. Complaints and How to Contact Us