Privacy Policy

Section 01Information We Collect

We collect information directly from you, automatically through your interactions with our website and mobile application, and from third parties such as identity-verification vendors, fraud-prevention partners, and consumer reporting agencies.

Information you provide

• Identifiers and contact information: full legal name, residential address, email address, telephone number, date of birth.
• Government identifiers: Social Security number, driver’s license number, and other identifiers required to verify your identity and meet our obligations under federal and state law.
• Financial information: bank account and routing numbers, employment status, sources of income, gross monthly income, and information you provide on a loan application.
• Authentication information: passwords, security questions, and other credentials you create to access your account.
• Communications: the content of emails, chat messages, telephone recordings, and feedback you send to us.

Information collected automatically

• Device and connection data: IP address, browser type, operating system, mobile device identifiers, time-zone setting, and approximate geolocation derived from IP address.
• Usage data: pages visited, links clicked, application steps completed, session duration, referring URL, and product interactions.
• Cookies and similar technologies: small data files placed on your device for session management, fraud prevention, analytics, and marketing attribution. You can disable non-essential cookies in your browser without affecting access to your account.

Information from third parties

• Consumer reporting agencies (Experian, Equifax, TransUnion, and specialty bureaus) for credit history, identity verification, and fraud screening.
• Identity-verification and fraud-prevention vendors, including knowledge-based authentication services.
• Bank-account verification providers that confirm ownership and balance information you authorize them to share.
• Public records, government databases, and OFAC sanctions lists for compliance screening.

Section 02How We Use Your Information

We use the information we collect for the following business purposes, each of which is necessary either to provide the financial product you have requested, to comply with applicable law, or to operate our business in a way that protects our customers and ourselves from loss:

• Evaluate your loan application, including underwriting, pricing, identity verification, and fraud screening.
• Originate, service, and collect on loans, including communicating with you regarding payments, statements, and account changes.
• Comply with our obligations under the Truth in Lending Act, the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Bank Secrecy Act, applicable state lending statutes, and other laws and regulations applicable to us.
• Detect and prevent fraud, identity theft, money laundering, and other harmful or illegal activity.
• Operate, maintain, secure, and improve our website, mobile application, and other systems.
• Provide customer support and respond to your inquiries, complaints, and requests.
• Send you transactional and servicing communications, and (where permitted) marketing communications about our products.
• Conduct internal research and analysis to better understand the customers we serve and to improve our underwriting and service.

We do not sell your personal information for monetary consideration to third-party data brokers, and we do not engage in cross-context behavioral advertising that targets you based on activity across unaffiliated websites.

Section 03Information Sharing and Disclosure

We disclose information about you only to the following categories of recipients, and only for purposes consistent with what you have authorized or with what applicable law allows:

• Affiliates: companies under common ownership or control with Volunteer Cash Advance, LLC, where applicable.
• Service providers and processors: cloud-hosting vendors, payment processors, mailing-house vendors, identity-verification services, customer-support platforms, and analytics providers, each subject to written agreements that limit their use of your information to providing the contracted service.
• Consumer reporting agencies: nationwide credit bureaus and specialty agencies, both to obtain reports about you and to furnish information about your account, including your payment history.
• Governmental authorities: regulators, law enforcement, courts, and other government bodies in response to lawful requests, subpoenas, or as otherwise required by law.
• Successors in interest: in the event of a merger, acquisition, asset sale, reorganization, or similar transaction, we may disclose information as part of the transaction or due-diligence process.
• Professional advisors: attorneys, accountants, and auditors retained to advise us, subject to professional duties of confidentiality.

Section 04Nonpublic Personal Information (GLBA)

The Gramm-Leach-Bliley Act and Regulation P (12 C.F.R. Part 1016) require us to provide an initial and annual notice describing our policies and practices regarding the collection and disclosure of nonpublic personal information (“NPI”) about consumers and customers. NPI includes any information about you that is not publicly available and that you provide to us in connection with obtaining a financial product or service, that we obtain about you in connection with providing the product or service, or that arises out of a transaction with us.

What we may share, and with whom. We may share NPI with affiliates and with nonaffiliated third parties as permitted by GLBA and Regulation P, including for the everyday business purposes of processing transactions, maintaining accounts, responding to court orders or legal investigations, reporting to credit bureaus, and protecting against fraud.

Your right to opt out. You have the right to direct us not to share NPI with nonaffiliated third parties for purposes other than those permitted by law. To exercise this right, write to us at [email protected] or by U.S. mail at the address listed in Section 14, including your full legal name, residential address, the last four digits of your Social Security number, and a clear statement that you wish to opt out. Your election will remain in effect until you revoke it.

Section 05Credit Reporting and FCRA Disclosures

To evaluate your application and to service your loan we obtain consumer reports about you from one or more consumer reporting agencies. By submitting an application you authorize us to obtain such reports for any “permissible purpose” under the Fair Credit Reporting Act, 15 U.S.C. § 1681b, including in connection with a credit transaction initiated by you and for the review or collection of an account.

If we take adverse action against you based in whole or in part on information contained in a consumer report, we will provide you the notice required by 15 U.S.C. § 1681m, including the name, address, and toll-free telephone number of the consumer reporting agency that provided the report and a statement that the agency did not make the adverse decision and is not able to explain why the decision was made. You have the right to obtain a free copy of your consumer report from the reporting agency identified in the notice within 60 days, and to dispute the accuracy or completeness of any information contained in the report.

We may furnish information about your account, including your payment history and any default, to consumer reporting agencies. Late or missed payments may be reflected in your credit report and may negatively affect your credit score.

Section 06Your Privacy Choices and Opt-Out Rights

You may exercise the following choices regarding your information at any time, free of charge and without affecting your access to our products or services:

• Marketing communications. You may opt out of marketing emails by following the unsubscribe link in any marketing message we send, or by writing to us. Transactional and servicing communications, which we are required to send, will continue until your account is closed.
• Cookies and similar technologies. You may disable non-essential cookies through your browser settings. Strictly necessary cookies cannot be disabled because they are required for fraud prevention, account security, and basic site operation.
• GLBA opt-out. See Section 4 for instructions on opting out of nonaffiliated information sharing.
• FCRA affiliate-marketing opt-out. Where the Fair Credit Reporting Act gives you the right to limit the use of certain information shared among our affiliates for marketing purposes, we will provide a separate notice and an opportunity to exercise that right; you may also exercise it at any time by contacting us.

Section 07California Privacy Rights (CCPA/CPRA)

If you are a resident of California, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, gives you the following rights with respect to personal information we have collected about you in the preceding twelve months:

• The right to know the categories and specific pieces of personal information we have collected, the categories of sources, the business or commercial purposes for collecting or sharing it, and the categories of third parties with whom we have shared it.
• The right to delete personal information we have collected from you, subject to legal exceptions, including exceptions for information we are required to retain to provide a product you requested or to comply with law.
• The right to correct inaccurate personal information we maintain about you.
• The right to opt out of sale or sharing of personal information. Although we do not sell personal information for monetary consideration and do not engage in cross-context behavioral advertising, we honor opt-out signals and provide a "Do Not Sell or Share My Personal Information" mechanism on this website out of an abundance of caution.
• The right to limit the use of sensitive personal information to that necessary to perform the services you requested.
• The right of non-discrimination: we will not deny you services, charge you a different price, or provide a different level or quality of services because you exercised your privacy rights.

You may exercise these rights by writing to us at [email protected]. We will respond within 45 days as required by the statute, and we will verify your identity using information we already have on file before we act on a request. An authorized agent may submit a request on your behalf with proof of authorization.

Personal information we collect or process in connection with originating, servicing, or collecting on a consumer loan is subject to a separate, federally-required privacy notice under the Gramm-Leach-Bliley Act (see Section 4) and is, to that extent, exempt from certain CCPA requirements; however, we honor the rights described above wherever applicable law allows.

Section 08Children’s Privacy (COPPA)

Our services are intended only for adults aged eighteen (18) or older. We do not knowingly collect personal information from children under the age of 13, and we do not direct any of our services or marketing to children. If you believe a child under 13 has provided personal information to us, please contact us at the address in Section 14 and we will promptly delete that information.

Section 09Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards include encryption of personal information in transit and at rest using industry-standard protocols, role-based access controls, multi-factor authentication for employees with access to sensitive systems, network segmentation, intrusion detection, written information-security policies, employee training, and periodic risk assessments.

No system can be made absolutely secure. We will notify you of a security incident affecting your personal information in the manner and within the timeframes required by applicable state and federal law.

Section 10Data Retention

We retain personal information for as long as it is needed for the purposes described in this Privacy Policy and as required by applicable law and our internal records-retention policies. In particular, we retain loan-application and servicing records for the longer of the period required by federal and state lending law (typically twenty-five months from the date of action under Regulation B, but longer for certain records) and the period that is reasonably necessary to defend against potential legal claims. Information used solely for marketing is retained only until you opt out or your account is closed, whichever is shorter.

When personal information is no longer needed, we securely delete or anonymize it.

Section 11Third-Party Services

Our website and mobile application may contain links to or embed services operated by third parties, such as bank-verification widgets, identity-verification flows, payment processors, and customer-support tools. Those services are subject to the third party’s own privacy policy, which we encourage you to read. We are not responsible for the privacy practices of services we do not control.

Section 12International Users

We operate exclusively within the United States. We do not direct our services to individuals outside the United States, and our services are not intended for individuals located outside the United States. If you access our website or services from outside the United States, you do so at your own initiative, and the information we collect about you will be transferred to and processed in the United States, where data-protection laws may differ from the laws of your jurisdiction.

Section 13Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, in technology, in legal requirements, or for other operational reasons. The "Effective" date at the top of this page indicates when the current version took effect. If we make material changes, we will provide notice by posting the updated policy on our website and, where appropriate, by sending you an email or other notice consistent with applicable law before the changes take effect.

Section 14How to Contact Us

If you have questions about this Privacy Policy, wish to exercise any of the rights described above, or wish to make a complaint, please contact us:

Volunteer Cash Advance, LLC
Attn: Privacy Officer
509 E Main St Ste A
Livingston, TN 38570-2047
USA

Email: [email protected]
Telephone: +1 (111) 111-1111

We will respond to your inquiry as promptly as we are reasonably able, and in any event within the timeframes required by applicable law.