Trustnet Financial uses personal information as required by state and federal regulators to assure we are promoting safe and responsible lending.
When you first apply for a Trustnet Financial loan, we ask you to create an account and then ask you to supply certain personal information. We collect, use, and disclose this information:
- to verify (as much as reasonably possible) that it is you, rather than someone else, that is applying for the loan in your name
- to determine your eligibility for the loan under the law and whether you can afford it
- to maintain your account
- to communicate with you about your account
- to securely process the funding and repayment transactions to which you and we might agree
- to provide financial services to customers;
- to develop, manage and market products and services to meet the needs of customers;
- to obtain credit information and credit reports from credit reporting agencies to assess credit history and credit worthiness and to confirm accuracy of information provided by individuals (including by contacting employers and personal references);
- to confirm details of customer employment;
- to contact customers for products and services that may be of interest;
- to determine the eligibility of customers for different products and services that may be of interest;
- to extract certain information for the purpose of generating statistics and analysis for purposes of conducting and improving our business;
- to ensure a high standard of service to customers;
- to meet legal and regulatory requirements;
- to confirm the identity of a customer and to prevent and detect fraud; and
- to collect debt that may become owed to GoDay by a customer.
The types of personal information we collect for these purposes can include:
- basic profile information such as your name, address, phone number, email address, preferences, and other similar information
- identifying information such as social security number, date of birth, or other information
- information such as employment, income or similar information
- transactional information such as including bank account numbers, routing numbers, debit card numbers or similar information
Trustnet Financial may also obtain more information about applicants from third parties to help us validate this information. We also collect tokens from online services and payment systems.
After you become a customer by taking out a Trustnet Financial loan, we use your information for transaction processing and to communicate with you.
Types of data collected
As part of the application and approval process, Trustnet Financial may collect the following information from its clients: first and last name, email address, phone or cell number, country, province, postal code, profession, cookies, and other browsing data. Some of this information may be stored in our system so as to better identify clients for future transactions.
Failure to provide the information required for the assessment of a loan requested by the client may make it impossible for Trustnet Financial to offer its services.
Third party information collected through a client’s account remains the sole responsibility of the client.
The Personal Data may be freely provided by the User, or collected automatically when using this Application.
Failure to provide certain Personal Data may make it impossible for this Application to provide its services.
The User assumes responsibility for the Personal Data of third parties published or shared through this Application and declares to have the right to communicate or broadcast them, thus relieving the Data Controller of all responsibility.
Our processing method ensures that unauthorized users are prevented from accessing the system. All personal data is collected and processed from our headquarters. The data will be kept in the system according to need. Some information may be retained even after the client finishes repaying a loan. This will enable us to better identify users in the future.
Mode and place of processing the Data
Method of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request the Data Controller for their suspension or removal.
The use of the collected Data
The Data concerning the User is collected to allow the Application to provide its services, as well as for the following purposes: Analytics, Interaction with external social networks and platforms, Contacting the User, Advertising, Remarketing and Behavioral Targeting, Managing email addresses and sending messages, Geolocation, Content performance and features testing (A/B testing), Registration and authentication, Displaying content from external platforms and Social Applications.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
These services allow User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on the Application, possibly based on User interests.This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
- AdMob (AdMob Google Inc.)
AdMob is an advertising service provided by AdMob Google Inc.
Personal Data collected: Browsing and usage Data and Cookie.
- Bing Ads (Microsoft Corporation)
Bing Ads is an advertising service provided by Microsoft Corporation.
Personal Data collected: Browsing and usage Data and Cookie.
- Google AdSense (Google)
Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered. Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout?hl=en.
- Direct Email Marketing (DEM) (This Application)
This Application uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application. Personal Data collected: Email.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
- Google Analytics (Google)
- Analytics collected directly (This Application)
This Application uses an internal analytics system that does not involve third parties. Personal Data collected: Browsing and usage Data and Cookie.
- WordPress Stats (Automattic Inc.)
Contacting the User
- Contact form (This Application)
By filling in the contact form with their Data, the Users authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected: Email, First Name and Last Name.
- Mailing List or Newsletter (This Application)
By registering to the mailing list or to the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after performing a purchase. Personal Data collected: Email, First Name and Last Name.
- Phone contact (This Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests. Personal Data collected: Phone number.
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the Application.
- Google Website Optimizer (Google)
Displaying content from external platforms
These services allow you to view content within the Application hosted on external platforms directly from the Application’s pages and interact with them. If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.
- Vimeo video (Vimeo, LLC)
- Youtube video (Google)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application. Personal Data collected: Geographic position.
Trustnet Financial uses “website usage” information to help create a better user experience.
Trustnet Financial collects certain information from users’ browsers using small text files called “cookies.” Trustnet Financial uses session ID cookies to confirm that users are logged in. This type of cookie helps Trustnet Financial recognize a user if he or she visits multiple pages on our site during the same session, so that we do not need to require a password to access each page. Please note: If you do not accept cookies from Trustnet Financial, you will not be able to use our site.
We also use a persistent cookie that stores your login ID (but not your password) to make it easier for you to login when you come back to Trustnet Financial on future visits. We encode our cookies so that only we can interpret the information stored in them, but they do not contain personally identifiable information. Users can remove or block the persistent cookie using the settings in your browser if you want to disable the feature.
Registration and authentication
By registering or authenticating, Users allow the Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services.
In this case, the Application will be able to access some Data, stored by these third party services, for registration or identification purposes.
- Direct registration (This Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.Personal Data collected: Address, City, Country, Date of Birth, Email, Fax number, First Name, Genre, Last Name, Phone number, Profession, Province, Social Security number (SSN), Various types of data and postal code.
Remarketing and Behavioral Targeting
These services allow this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
- AdRoll (Semantic Sugar, Inc.)
- AdWords Remarketing (Google)
- Remarketing through Google Analytics for Display Advertising (Google)
These services allow the web site to access the data on your profile in the social networks, and to interact through your post. These services are not activated automatically, but require express authorization by the user.
- Access to the Twitter account (This Application)
Trustnet Financial does its best to provide a secure website for all of its clients. However, security breaches can happen at any time despite our best efforts. It is therefore crucial that you let us know if anything abnormal occurs.
If you suspect you are the victim of a fraud utilizing Trustnet Financial’s name, please notify us immediately to correct the mistake. You may be liable for an unauthorized transaction depending on the promptness of your response.
If you are contacted by phone number or by e-mail address through our website, please contact us immediately. We will inform you of the results of our investigation within ten (10) business days. We will correct any error we may have made, provided the error is brought to our attention promptly.
In the case of errors regarding monies owed by you (according to the loan agreement) that is not being paid, we reserve the right to correct the wrong amount, regardless of the nature of the error.
Through your signing up, you agree to give access to your registration information in order for the website to authenticate you. Third parties may require additional subscriptions which might use information already given by you, such as: Date of Birth, Contact Information (Email, Phone Number), Full Address (City, Country, Province, Zip/Postal Code), Full Name, Occupation, amongst others.
In order to tailor your experience, advertisement companies have access to some of your personal information (either given by you or inferred through clicks and past use of our website). More specifically, these will acquaint you with advertisements, selected according to your preferences, and presented in any way, shape or form the affiliated company decides.
We share some of your information with marketing companies in order to gain intelligence on our clientele. These points serve to construct critical analyses needed to further improve our services.
Our affiliated external social media services request your permission to post on your behalf and/or to log onto your account and/or to view their services from our website. They may collect data from cookies while you are using our website.
By registering, you agree to give Trustnet Financial and/or any of its affiliates permission to use your e-mail address and/or full address in order to send relevant and promotional correspondences. You also agree that the sender, whether Trustnet Financial or an affiliate, may collect data based on your reception of said electronic correspondence, whether date stamping (delivery and/or read notifications), clicks (opening links) and/or others.
As Trustnet Financial may use a third party to manage the e-mail database, said third party will have access to some personal information, including but not limited to: Full Name (First and Last Names) and Full Contact Information (E-Mail, Address, City, Country, Province, Zip/Postal Code).
Advertisement services enable us to use the data we collect from clients for advertisement purposes. Such advertisements may include banners based on the interest of users. Your personal data will not be used explicitly. It will simply be used as part of data collection for consumer advertisement purposes.
When a user completes an “information request form” the user is thereby agreeing to allow us to reply to a request using the user’s name and e-mail address as provided through the request form.
When you register your name to receive our newsletter and promotions, you consent to receive marketing information at your email address. To this end, your email will be added to our emailing marketing group. Your phone contact will be used mostly to address your request and to provide you with support.
Interaction with external social networks and platforms
These services allow interaction with social networks or other external platforms directly from the Application’s pages.
The interaction and information obtained by this Application are always subject to the User’s privacy settings for each social network.
If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.
- Facebook Like button and social widgets (Facebook)
- Twitter Tweet button and social widgets (Twitter)
- Google+ +1 button and social widgets (Google)
The user’s information is authenticated upon registration, enabling the user access to online services.
Personal data is collected when the user registers. This data may include any or all of the following: mailing address, city, country, birth date, first and last name, cell and home number, province, social security number (optional), and postal code.
We reserve all rights to monitor, collect, and analyze all the information that goes through the website in order to better understand the user’s behaviour for marketing purposes.
The geolocation application helps collect user location data in order to provide location-based services. You have the right and option to opt out from this application at any moment. Browsers will usually automatically opt out from this feature.
Managing Email addresses and sending messages
These services make it possible to manage a database of email contacts to communicate with the User via email.
The services are used to collect data concerning the date and time when the mail is viewed by the User, as well as when the user interacts with incoming mail, such as by clicking on links included in the email.
Rights and Personal
Data Trustnet Financial allows you to manage your account and information on www.Trustnet Financial.com. Once you login you may update your personal information, assuming your account is in good standing. In that case, we will retain only the personal information required by law or that we deem necessary.
Trustnet Financial may not be able to provide access to any or all of an individual’s personal information. If a request for personal information is denied, Trustnet Financial will notify the individual in writing, documenting reasons for refusal and resources available for redress.
Reasons for refusing access may include:
- that the personal information is unreasonably costly to provide;
- that the release of the personal information may threaten the life or security of a third party;
- that the personal information is subject to or generated in a formal dispute resolution process;
- that the personal information cannot be disclosed for legal, security, or commercial proprietary reasons; or
- that the personal information is subject to solicitor-client or litigation privilege.
You are also allowed to request a cancellation of our services at any point.
You are entitled to opt-out from our emailing list. Furthermore, you may request not to be contacted by Trustnet Financial at any instant provided that your file is in good standing with us. That means that you have made your payments on time.
All information provided will be used in the case of legal proceedings and/or in a Court of Law if situations arise that necessitate Trustnet Financial to pursue any lawful counselling. Additionally, Trustnet Financial will release any information if mandated by local, provincial, or national laws and/or law authorities.
The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances. An individual’s consent may be explicit or implied and consent can be given either orally, electronically or in writing. Use of products and services offered by Trustnet Financial constitutes implied consent for the collection, use and disclosure of personal information for all identified purposes.
Notice will be given and consent obtained when collecting, using and disclosing personal information, except when deemed inappropriate.
Trustnet Financial will make a reasonable effort to ensure that all customers have an understanding of the purpose(s) for which personal information is collected, used or disclosed.
Trustnet Financial will obtain consent to use and disclose personal information at the time the personal information is collected. Trustnet Financial may also obtain consent to use and disclose
personal information after it has been collected, but prior to the personal information being used or disclosed for a new purpose.
Consent shall not be obtained through deception. An individual’s consent may be explicit or implied. Consent can be given either orally, electronically or in writing. Use of products and services offered by Trustnet Financial consititutes implied consent for the collection, use and disclosure of personal information for all identified purposes.
Trustnet Financial may collect, use or disclose personal information without the individual’s knowledge and consent in certain circumstances. For example:
- When the collection, use, and disclosure is permitted or required by law;
- When the collection, use, and disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely manner;
- When seeking the consent of the individual may defeat the purpose of collecting the information;
- When use of the information is for an emergency that threatens the life, health or security of an individual;
- When needed to collect a debt, to comply with a subpoena, warrant or other court order, or as otherwise required or authorized by law;
- When the information is solely for Journalistic, Artistic, or Literary Intent; or
- When the information is publicly available.
An individual may withdraw consent at any time subject to legal or contractual restrictions and reasonable notice. Refusal or withdrawal of consent by a customer may prevent Trustnet Financial from providing a product or service to that customer. Trustnet Financial will not unreasonably withhold products or services from a customer who refuses or withdraws consent, but if the personal information is required to offer the product or service, Trustnet Financial may decline to deal with the customer who will not consent to the use of such personal information. Trustnet Financial maybe contacted for more information regarding the method by which consent can be withdrawn.
LIMITING USE, DISCLOSURE AND RETENTION
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
Trustnet Financial shares and stores customer personal and transaction information with affiliated companies of Trustnet Financial located in the USA for the purposes listed in the Identifying Purposes section above. In addition, Trustnet Financial may use and disclose personal information to third parties as follows:
- A Trustnet Financial affiliate seeking information as an agent of the individual;
- A Trustnet Financial agent that will evaluate the customer’s creditworthiness or to collect a potential debt;
- A credit reporting agency to obtain credit information and credit reports to assess credit history and credit worthiness and to confirm accuracy of information;
- The issuer and/or payer of negotiable items to confirm identity;
- A third party – where individual consents to disclosure;
- A third party – where disclosure is required by law;
- A public authority or agent of a public authority where there is imminent danger to the life or property of an individual which could be avoided or minimized by disclosure; and
- Conduct surveys in order to enhance our products and services to meet customer needs.
Where personal information is disclosed to a third party, Trustnet Financial will ensure that appropriate security measures are utilized to protect the use and disclosure of personal information.
Only Trustnet Financial employees are authorized or granted access to personal information about customers when responsibilities reasonably require.
Trustnet Financial will retain personal information only as long as necessary for the fulfillment of identified purpose, or as required by law.
Personal information will be protected by reasonable security safeguards appropriate to the sensitivity of the personal information.
Trustnet Financial is committed to the protection of personal information against loss, theft, unauthorized access, disclosure, duplication, use and modification regardless of the format in which the personal information is held.
Trustnet Financial will protect personal information disclosed to third parties by means of contractual agreements with respect to the confidentiality of the personal information and the purposes for which the personal information is to be used.
Trustnet Financial will use reasonable security measures in the disposal of personal information.
The protection of personal information is an ongoing process, and Trustnet Financial will update and review the reasonableness of the security safeguards as needed.
Trustnet Financial is under no obligation to inform of any modifications made to its policies via any correspondence (post mail or electronic mail) ; it is your responsibility to keep up to date. Even so, additions and modifications will be clearly marked on the current webpage.
Trustnet Financial may at any time interrupt its online services to perform needed managerial updates and improvements without prior notification.
Trustnet Financial may use your Internet Protocol address in case problems arise in order to determine the source of the problem.
Content collected through our system may be used in case of legal action levelled against a user due to improper use of the system.