Information We Collect
Personally Identifiable Information (“PII”): Subject to your specific knowledge and consent, we collect personally identifiable information that can identify you such as your name, address, social security number, telephone number, cell phone number, and email address. PII could also include information you may provide on others, such as co-signers.
Non-Personally Identifiable Information (“NPII”): We also collect demographic data, online activity data, and other information which could not be used to identify you.
PII and NPII are collectively referred to as “Information.”
How We Collect Information
Information Collected Automatically: We use third party server log analysis tools (such as Google Analytics) to gather statistics from your computer, mobile phone, or other access device regarding the Site’s usage, such as the number of hits received and errors experienced through browsers and platforms used to connect to our Site. The Site may place and/or store code or other types of information and/or devices (e.g., “cookies”) on your computer, mobile or other device (collectively “Local Device Storage”). We may use Local Device Storage for any lawful business purpose, including without limitation to determine which of our messages have been opened by recipients so we can gauge the effectiveness of marketing campaigns, to track usage patterns, the movements of individual users, and your geographic location, to help diagnose problems with our servers, to gather broad demographic information, to analyze trends, to conduct research, to deliver editorial content, to record registration and personalization information, and to otherwise administer the Site and/or Service.
The following are examples of information about you that we may collect whenever you visit the Site:
- The Internet Protocol (IP) address and domain used. (The IP address is a unique numerical identifier assigned either to your Internet service provider or directly to your computer.)
- Type of browser and operating system used
- Device type and ID
- Date and time of your visit to the Site
- Web pages you visited
- Actions you performed or attempted, including clickstream data
- Codes that correspond to the status of your actions
- The geographic location of the computer or mobile device you use to access the Site
- We may also capture your email address when you enter it on one of our application forms, regardless of whether you submit the entire form
The above information is used to improve the content and/or layout of the Site. We do not sell or rent any information we collect automatically. We also do not share this information with third parties; provided, however, that we may share information with our service providers in order to process any Services you have requested or other everyday business purposes, such as fraud prevention. We may also engage in geo-tracking and/or geotagging activities.
In addition to Local Device Storage, we may use web beacons, web bugs, clear gifs, and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”). We use Tracking Technologies for all or some of the same lawful business purposes we describe above for use of Local Device Storage.
Information You Provide to Us: We may collect, store, and use personal or financial information you provide to us when using the Site or our Services. This Information could be provided via an online form, over the phone, or via other means in which you interact with our Services. Financial information includes any information you have provided using the Site regarding your bank accounts, credit or debit cards, or other financial relationships or circumstances. We may use information you provide to:
- process any Services you have requested;
- for fraud prevention purposes;
- to make the Site more useful and easier to use; and
- for everyday purposes in operating our business.
We may share the information you provide with our service providers in connection with any of the foregoing uses. We do not sell or rent such information to third parties and, except as described in this paragraph, we do not share such information with third parties.
Information from Service Providers and other Third Parties: In the course of providing our Services, Information about you may be collected from third party service providers, such as contractors, social networks, credit bureaus, and other data vendors who have data on your financial profile or other demographic information. Any Information we collect through these sources is treated the same as Information we collect automatically and Information you provide to us.
How We Use Your Information
We may use your Information to:
- Deliver the Services you requested and otherwise operate our business
- Improve our Site and customize your experience
- Improve customer service
- Communicate with you about your online Headway account (“User Account”), credit requests, or other products or services that may be of interest to you
We may also use your Information for certain legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any Information (including PII) as reasonably necessary to:
- Protect the rights, safety, and security of our Users, our Services or equipment, or any third party partner or service provider
- Detect, prevent, investigate, or otherwise mitigate fraud, security or technical issues related to our Services or our business partners
- Comply with any applicable law, regulation, subpoena or legal process; respond to any governmental requests; and/or cooperate with law enforcement, if we believe such action is required or permitted by law
Who Do We Share Your Information With?
Network Partners: Network Partners include credit brokers and similar third parties who provide products and services to our Users. When you submit your Information to us on the Site, you agree that Headway may share your Information with these Network Partners so that they can provide or assist in providing the products or services you requested. Our Network Partners may submit your Information to lenders that they partner with to provide the products or services you requested. The Network Partners with whom we share your Information may retain or use your Information whether or not you buy their products or use their services. You should contact these Network Partners directly to learn about their own privacy and information sharing practices.
Headway Vendors and Contractors: To the extent necessary, we may share your Information with vendors that perform certain services on our behalf. Vendors may include, but are not limited to, credit and other types of data bureaus, marketing companies, business analysis firms, and technology providers. We may also share your Information with our partner contractors to the extent necessary to provide the Services offered through the Site.
When you publicly post information or content: We may provide opportunities on the Headway Site for you to publicly post reviews, comments, or other content, which may include Personal or User Profile Information, like your name or username. Please carefully consider what you decide to share in these public forums.
Other Situations: We may also disclose your Information in the following circumstances, at our sole discretion:
- In response to a court order, subpoena, or similar investigative demand; a request for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency; to establish or exercise our legal rights or defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right available to us.
- In order to detect, prevent, or otherwise address security or technical issues related to our Services or the services of our Providers or other partners.
- In connection with state and/or federal licensing and registration requirements which may require the reporting of Information from loan inquiries we receive from you. You authorize Headway to obtain any and all required information from Providers whose products or services you have purchased in order for us to comply with current laws and regulations, as well as with any requests from state or federal regulators. This information could include, but is not limited to, the terms of the loan you selected.
- In connection with a corporate transaction, such as a sale, divestiture, merger, consolidation, asset sale, or bankruptcy of Headway or any entity, brand or division thereof.
- We may share NPII with third parties, at our sole discretion.
- There may also be certain situations in which we share your PII after receiving your express consent.
If you no longer wish to receive marketing communications from Headway, you may use the unsubscribe link at the bottom of emails that we send to you.
Interest-Based and Third-Party Advertising
How to Opt-Out of Third Party Tracking: For those Advertising Vendors who are members of the Network Advertising Initiative, you may opt out of future advertisements by visiting: http://optout.networkadvertising.org/#!/. Other Advertising Vendors may allow opt out through the Digital Advertising Alliance opt-out program (http://optout.aboutads.info/#!/).
Disclosure Regarding Google Analytics Tracking and Advertising Features: In addition to services from other analytics and advertising vendors, we use Google Analytics to analyze traffic on the Site. Google Analytics collects data including details about your web browser and the computer you use to access our Site, such as the hostname, browser type, referrer, language, and screen resolution. Google Analytics also sets and reads first-party cookies to obtain user session and ad campaign information from your page request.
Google provides users an opportunity to opt-out of Google Analytics Features through Google Ads Settings and their web browser opt-out plugin (https://tools.google.com/dlpage/gaoptout/). For additional information on opting out of interest-based ads by Google, please visit https://support.google.com/ads/answer/2662922?hl=en&ref_topic=2941003.
Do Not Track Signals: Our Site does not currently respond to automated signals regarding online tracking, such as “do not track” instructions from your web browser. Please note that blocking cookies may affect your browsing experience on the internet, and may limit your use of certain parts of our Services, including many of the personalized offers and other customized features we may provide.
Other Third-Party Content: We may display other third-party content or links to third-party websites or applications on the Headway site. Such content could include features that allow you to connect your Headway User Account with your social media, financial institution, and other third-party accounts. Please be advised that when you leave our Services or interact with a third-party feature, you should read the applicable privacy policies and terms of service of those parties so that you understand their own information collection and sharing practices.
Accessing and Updating Your Information on the Site
The method(s) for accessing and updating your Information, if any, will depend on the Headway Services you have used. You may have the ability to access and make changes to certain Information by logging in to your User Account through our Site and updating your data. You can also update your Information by contacting our Customer Care Department by email at firstname.lastname@example.org.
You are responsible for maintaining the accuracy of the information you provide to us, such as your User Profile information.
Deactivating Your User Account
If you decide you no longer want to use our Services, you can deactivate your User Account by contacting our Customer Care Department by email at email@example.com.
Due to regulatory recordkeeping and information retention requirements, we do not delete your Information when you deactivate your User Account. We will, however, disable your account and stop sending you communications.
How We Protect Your Information
We maintain what we believe to be industry standard technical, physical and administrative security procedures and practices to protect your PII against unauthorized access, disclosure, destruction, use, alteration, or disclosure. We use encryption in the transmission of your Information between your system and ours, and we use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your Information. We require any service providers that may have access to your PII to implement and maintain industry standard security procedures and practices. We also require employees to comply with information security safeguards.
Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, however, we cannot guarantee the security of the information you send to us or the security of our servers, networks or databases, and by using the Service you agree to assume all risk in connection with the information sent to us or collected by us when you access, visit and/or use the Service, including without limitation your personally identifiable information or other information, and we are not responsible for any loss of such information or the consequences thereof.
Moreover, if you elect to store information, such as your personally identifiable information or other user account information, where others may access it, we are not responsible for any loss of such information or the consequences thereof. If you lose a computer, mobile or other device, or it is stolen, that contains your personally identifiable information or other information, it is up to you to take all the steps necessary to protect yourself.
In the unlikely event that we believe that the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you via your computer, mobile or other device.
If you are, or believe you have become, a victim of identity theft, or if you become aware that your personal information has been compromised, you may want to contact one of the three nationwide credit reporting agencies identified below to report possible fraudulent activity under your name and learn more about fraud alerts and security freezes that you can place on your credit reports, your right to obtain a free copy of your credit report from each of the credit reporting agencies, and other preventive measures you can take now to help detect and prevent the improper use of your information:
P. O. Box 105788, Atlanta, GA 30348
P. O. Box 9554, Allen, TX 75013
P. O. Box 6790, Fullerton, CA 92834-6790
You may also visit the website of the Federal Trade Commission at https://www.identitytheft.gov for free information to help you guard against identity theft and for guidance on the recovery steps you can take if you have been the victim of identity theft, including information on how to file an identity theft complaint.
Visiting our Site From Outside the United States
The Site is governed by the laws of the United States, and is intended for use only by residents of the United States. We make no representation that the Site is governed by, or operated in accordance with, the laws of any other nation or jurisdiction.
Compliance with Children’s Online Privacy Protection Rule
We do not knowingly collect, use, or disclose PII from anyone under the age of 18. If we determine that a User is under this age, we will not use or maintain their PII without consent from a parent or guardian. If we become aware that we have collected PII from a child under the age of 18, we will make reasonable efforts to delete such information from our systems and records.
How to Contact Us
Headway Sales Inc.
2600 Capitol Ave, Suite 320
Sacramento CA 95816
or by email at compliance@Headwaysales.com
Date of last revision: May 10, 2018