Privacy Policy

Introduction

Self Financial, Inc. and its subsidiaries including Self Credit LLC, RentTrack, Inc. and Self Financial Insurance Services LLC (“Self”, “we,” “our,” and “us”) is at the center of a new and innovative financial ecosystem. Through an array of products and partnerships, we are committed to helping you build credit, save money, and achieve your long-term financial goals.

To that end, this Privacy Policy (“Privacy Policy”) outlines how Self collects and handles your personal information in order to provide you various financial products and services, through Self, its subsidiaries, and in collaboration with third parties. These offerings include: (i) products and services provided exclusively by Self through its technology platform, website, and applications (the “Platform”) using information provided by you; (ii) products and services provided on the Platform using information obtained from third parties; (iii) products and services provided on the Platform but issued by third-party banks or other financial institutions; (iv) third-party products and services available on the Platform; and (v) products and services provided at my.renttrack.com (collectively, the “Services”).

This Privacy Policy applies to information collected about you, online and offline, in connection with your use of the Platform and Services. This Privacy Policy also applies to your use of interactive features or downloads that: (i) we own or control; (ii) are available through the Services; or (iii) interact with the Services and state that they are bound by this Privacy Policy. However, it does not apply to any information that you disclose publicly. We are also not responsible for the accuracy, use or misuse of any content or information that you disclose or receive through the Services.

In certain circumstances, Self may be considered a service provider of third parties, and the privacy policy of the relevant third party will govern our processing of personal information. Also, to the extent third parties process your personal information, they may be independently subject to applicable information privacy laws and privacy policies.

This Privacy Policy is part of the terms and conditions set forth in our Terms of Service, which governs your use of our Services. By using this website and the Services, you consent to this Privacy Policy and the Terms of Service. We also refer you to our Gramm-Leach-Bliley Act (“GLBA”) Privacy Notice, which may apply to personal information we collect, use, and share in connection with offering you financial products or services, whether that information is obtained from you, from third parties, or by any other lawful means.

You also acknowledge that Self is an integrated financial technology platform offering a variety of proprietary and third-party services. By using this website and Services, you consent and agree that Self has the right to collect and use the data about you, whether provided by you, or provided by or for a third party (including a financial institution) whose services were on the Platform.

If you have questions or complaints regarding our privacy practices, please contact us at legal@self.inc.

1. How We Collect Information

We may collect data directly from you, when you interact with the Platform and Services, or from third parties. This enables us to deliver customized offers and recommendations that are tailored to your preferences and needs, as described below. We use data holistically – meaning, not always in one place or pertaining to one offering – so that we can provide you the most value. For instance, information we gather for one product might help us suggest another product that you are eligible for.

We recognize that our Services may involve the use of sensitive personal information and protecting its confidentiality and ensuring its security is a top priority. We will never sell or rent your personal information, and we use industry-standard policies, procedures, and safeguards designed to ensure your information is safe and secure.

Information You Provide Us Directly

When you register with Self or use our Services, we may ask you to provide various categories of information, including but not limited to the following:

• Contact information, such as your name, address, telephone numbers, email address, and household members.
• Demographic and other personal information, such as your age, gender, date of birth, marital status, employment and income information, and family information.
• Authentication information, such as your login credentials, Social Security number, driver’s license number, or other information that may allow us and credit bureaus to verify your identity.
• Payment information, such as your bank account number and other details.
• Other information you may choose to provide us, including when you contact us for support or feedback, identify your product preferences, respond to various offerings on the Platform, or otherwise when you use our Services.

The information Self asks you to provide may vary depending on the relevant offering on the Platform. For example, in the case of an offer for an auto insurance estimate, Self may ask that you provide additional personal information, such as details of your current insurance coverage or your driving record. Further, as described below, Self may tailor other offerings to you, and modify or optimize the Services, based on information you provide.

We may make message boards, chat rooms, and other interactive forums available on the Services. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

Information We Collect Indirectly From You

We and our service providers may also use technologies that automatically (or passively) collect certain technical information whenever you visit or interact with the Services and the Self website or app ("Usage Information"), which allows us to optimize your overall experience on the Platform. Usage Information includes your IP address or other unique device identifier ("Device Identifier"), location information, browser and operating system type, the date and time of access, and one or more cookies that may uniquely identify your browser from your computer or other device used to access the Services (any, a "Device").

Below are a few ways that we may gather Usage Information:

• SMS/Text Communication. If you provide us with your mobile number, we may send communications to you by SMS or text. Data rates from your mobile service provider may apply, and messages are subject to the terms and conditions of your provider.


• Cookies. A cookie is a data file placed on a Device used to access the Services. Cookies may be used for remembering you and your likes, improving your use of our Services, tracking your visits to our web pages, and identifying you when you return to our site, among other things. You may remove certain cookies by following directions provided by your Internet browser. However, disabling cookies may cause some features of the Services not to work properly.


• Embedded Scripts. An embedded script is a type of code that gathers information about your interactions with the Services. The code is downloaded onto your Device from our web server or a third-party service provider, is active only while you use the Services, and is deactivated or deleted thereafter.


• Web Beacons. We may use images or other web programming code known as web beacons. These may be used to count users of the Services, to monitor how the Services are used, to count how many sent emails were opened or how many links were viewed, among other things. Whereas cookies are stored on a user's computer hard drive, web beacons are embedded invisibly on web pages. We do not tie web beacons to personally identifiable information.

Certain web browsers may provide an option to disallow tracking by cookies or other identifiers. These are commonly called “do not track” signals. Self does not currently respond to “do not track” signals because there is no industry consensus or legal standard for responding to them. However, Self may update this Privacy Policy, as appropriate, to reflect developments in this area.

Information We Collect From Third Parties

We may collect outside records from third parties in order to enhance our ability to serve you, to personalize our content to you, and to offer you opportunities to purchase various products or services that we believe may interest you. We will protect this information consistent with this Privacy Policy and any additional restrictions imposed by the source of the information. Our sources may vary over time and may depend on how you use the Services.

We may collect information from the following:

Financial Institutions and Intermediaries. Self uses Plaid Inc. (“Plaid”) as an intermediary to gather your data from financial institutions. By using our service, you grant Self and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy. Self may also collect information directly from financial institutions to allow us to tailor product offerings to you.

Credit Bureaus and Other Third Parties. We may request and receive your credit reports and credit scores from credit bureaus. As explained in our Terms of Service, you understand that you are providing written instructions in accordance with the Fair Credit Reporting Act and other applicable law for Self or its affiliated companies to request and receive copies of consumer reports, scores and other information about you from third parties, including, but not limited to, Experian, TransUnion and Equifax. You further understand that your instructions let Self and affiliated companies obtain such information at any time for as long as you have a registered Self account to use as described in the Terms of Service and in this Privacy Statement. Other third parties may provide additional information, such as employment, income, vehicle or driver information, or other information based on your credit profile, that allows us to customize product offerings and better evaluate applicants.

Customer Service Providers. We may collect information about you from service providers pertaining to customer support or technical issues you may raise on the Platform or otherwise with respect to the Services.

Data and Analytics Service Providers. We may combine information we collect through the Services with information from third-party data and analytics service providers in order to personalize your experience on the Platform, market to you relevant products and offerings, and otherwise to maintain, monitor, modify, and improve the Platform’s offerings.

Business Partners, Advertisers, and Sponsors. We may collect information from our business partners, advertisers, and sponsors to promote and customize various offerings on the Platform, which may include co-branded or co-marketed products and services.

Service Providers to Verify and Supplement Your Information. We may rely on third parties to help us verify your identity, to confirm the accuracy of other information you may provide us, and otherwise to supplement your information. For example, we may use service providers to validate your mailing address or phone numbers. We may also use service providers to verify your identity through the collection and use of biometric data, in which case we will separately ask for your consent.

Security and Anti-Fraud Providers. We may collect information from service providers to help us evaluate fraud and other security risks, and to protect your personal information.

Social Networks and Communication Providers. We and our service providers may collect information from social networks and communications providers pertaining to Self, the Platform, or the Services, including to monitor public discussion about Self, the Platform, or the Services.

Information You Provide About A Third Party

If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Self stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. The information you provide (names, email addresses, etc.) is used for communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise.

Your friend may contact us at legal@self.inc to request that we remove this information from our servers.

2. How We Use Your Personal Information

We collect and process your personal information where:

• We have a contract with you and it is necessary to process your personal information to perform our contract with you, including to provide you with the benefit of Self’s Services and the Platform;
• We have your consent to process your personal information; or
• We need to comply with legal requirements, including applicable laws and regulations.

We may use your personal information for various purposes, including:

• Registering you for the Platform and verifying your identity;
• Managing your account and our relationship with you, including providing customer support, service announcements, and otherwise communicating with you;
• Evaluating your eligibility for financial offerings from Self, affiliates, or third parties;
• Maintaining, modifying, and optimizing the Services provided to you on the Platform;
• Developing insights into your preferences and needs, including by conducting data analytics and monitoring your interactions with the various Services offered on the Platform, so that Self can present targeted offers, recommendations, deals, and promotions to you;
• Marketing our Services to you, including delivering offers, promotional materials, and other communications via email, post, telephone, SMS or push notifications, in accordance with your marketing preferences;
• Combining and anonymizing information about your interactions on the Platform to create aggregate statistics for marketing, promoting, and improving the Platform;
• Servicing or administering your accounts with issuing banks or other third parties with whom Self collaborates;
• Otherwise running our business, including resolving billing, financial, and other disputes;
• Protecting the safety and security of your personal information and the Platform, and otherwise complying with our legal and regulatory obligations;
• Exercising our rights in the course of legal proceedings;
• Enforcing the Terms of Service or other contracts; and
• Processing your information for purposes that are compatible with the disclosed purposes as permitted by law.

3. How We Share Personal Information

Self may share personal information in the following ways:

With Your Consent. In accordance with the policies and principles described in this Privacy Policy, we only share your information with third parties when you have directed us to do so, or as outlined below.

With Service Providers or Agents. We may share your information with service providers or agents who work on our behalf, including companies that help us advertise and market the Services, provide technology (including web hosting, security, or anti-fraud services), and otherwise enable and enhance the Services. For example, we may share your credit reports or scores with service providers or agents to help tailor offerings to you, pursuant to Self’s Terms of Service. Self’s service providers or agents are required to implement privacy and security safeguards to ensure that information is kept safe and secure and are required not to use or disclose your personal information other than to provide the services requested by us.

With Our Issuing Banks and Other Business Partners.In order to generate offers, products, and services that you elect to review on the Platform, we may share your personal information with Self’s third-party business partners (a “Platform Partner”). Further, if you choose to sign up for products or services through a Platform Partner or otherwise interact with a Platform Partner, you consent and direct Self to share your personal information to that Platform Partner. You may also be required to furnish your information to the Platform Partner directly. Any such information provided to the Platform Partner is subject to its privacy policies and terms of use.

For Joint Product Offerings. We may share your personal information with third parties who provide co-marketed or co-branded products or services on the Platform.

For Credit, Debt Collection, and Anti-Fraud Purposes. We may share your personal information with credit bureaus, collection agencies, loan service providers, lawyers, government agencies, agents, and other companies in connection with our provision of the Services, including issues related to credit, debt collection, or fraud.

For Advertising and Analytics. Based on your interactions on the Platform or other browsing activities, Self and its service providers may display advertising that may be relevant to you. While we do not share your personal information with our analytics service providers, they may set and access their own cookies, web beacons, and embedded scripts on your Device, and they may otherwise collect or have access to information about you.

For Legal Reasons.We may disclose your personal information to third parties for legal reasons, including: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests, or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Terms of Service for any online Services or other policies applicable to any online Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property, or security of the Services or any third party; and/or (iv) to detect, prevent, or otherwise address fraud, security, or technical issues. Such disclosures may be carried out without notice to you.

With Affiliates and Subsidiaries: We may share your personal information with our affiliates and subsidiaries for everyday business purposes as described in this Privacy Policy, including enhancing our Services, developing offerings, and personalizing your experience on the Platform.

For Mergers and Acquisitions: We reserve the right to disclose and transfer your personal information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, acquisition, consolidation, restructuring, bankruptcy, the sale of substantially all of our membership interests and/or assets, or other corporate change, including during the course of any due diligence process.

4. Online Behavioral Advertising and Marketing Opt-Outs

As mentioned above, we work with third-party advertising networks, publishers, and other entities to advertise our products and services on websites not affiliated with us. Some of these ads are online behavioral advertising – which are advertisements that are more likely to be of interest to you using non-personal behavioral information. Such ads may contain cookies that allow monitoring of websites (including our own websites that are part of our own Services) and your engagement with our advertisements. We prohibit companies that place our ads from using information for any purpose other than to assist us in our advertising. If you would like to not receive targeted behavioral advertising relating to Self’s Services, you can opt-out of such advertising by logging into your account and visiting the “My Profile” page.

We may also send you information on products, services, special deals, or promotions via email. Out of respect for your privacy, we present the option not to receive these types of communications by logging into your account and visiting the "My Profile" page, or by following the unsubscribe instructions included in each promotional email.

In order for behavioral advertising opt-outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new Device, access our Services from a different device, login under a different screen name, or change web browsers, you will need to opt-out again.

5. Consent To Transfer Information To The United States

The Services are operated in the United States and intended for users located in the United States. If you are located outside of the United States, please note that information we gather, including personal information, will be transferred to and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States, including the USA PATRIOT Act. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States.

6. Automated Processing

To optimize your experience using the Platform and Services, we may process your personal information using both automated and manual methods. Automated methods may include artificial intelligence and a range of technologies that allow the Platform and Services to learn and improve, and will enhance our ability to provide recommendations, advice, and offers that are tailored to your needs and preferences.

7. Change or Inquire About Information And Communications Preference

It is your responsibility to maintain the accuracy of the information you furnish to us, such as your contact information provided as part of registration. You can access and make changes to the personal information you submit, including your marketing preferences, at any time by using the username and password you selected at the time of registration and making the change on our "My Profile" page. If you no longer desire our service, you may delete or deactivate it by following the instructions detailed in the Terms of Service.

8. Third Party Content And Links To Third Party Services

Self may post links to third-party websites that are not subject to this Privacy Policy. We do not exercise control over the external sites. These sites may place their own cookies or other files on your Device, collect or solicit data, web site usage information, and your Device Identifier when web pages from the Services are served to your browser, or solicit personal information from you. We are not responsible for the privacy practices employed by these third parties, which may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to read the privacy statements of all third-party web sites or applications before submitting any personal information to third parties. Please be aware that the terms of this Privacy Policy do not apply to these outside websites, or to any collection of data after you click on links to such outside websites.

9. Security

The security of all information associated with our Services is important to us. We enable our servers with Secure Socket Layer (SSL) technology to create a secure connection between your computer and our servers, creating a private session.

We use firewalls and other security solutions to protect our servers from outside attack and safely store your personal information. We control access to this information via secure web pages, and limit access only to employees or third parties on a need-to-know basis. We follow data security policies designed to protect nonpublic personal information in accordance with financial services industry standards, including compliance with the Payment Card Industry Data Security Standard

We use commercially reasonable safeguards to help protect and secure your personal information. However, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure.

The Internet is not a fully secure environment and we cannot ensure the security of any information transmitted to or generated by us in connection with our Websites. Notwithstanding our operational safeguards, there is no guarantee that your information may not be accessed, disclosed, altered or destroyed by breach. You play an important role in protecting your information by maintaining up to date computer security protections as well as ensuring the security of your computer passwords or other personal identifier authentication mechanisms. You agree that you are responsible for any additional verification procedures that you deem necessary.

Personal information that we will not retain will be securely destroyed by shredding, erasing, or otherwise modifying the Personal Information in the records to make the information unreadable or indecipherable through any means.

If you have any questions about security on our Website, you can send an email to us at legal@self.inc

10. California Residents

Because we value your privacy, we have taken the necessary precautions to comply with the California Online Privacy Protection Act and the California Consumer Privacy Act. We therefore will not distribute your Personal Information to outside parties without your consent or unless otherwise permitted by law such as to process your transaction or service your account.

If you are a resident of the state of California, you may request information regarding how we share certain categories of your Personal Information to third parties for their direct marketing purposes. In particular, you may have the right to request the following information: (a) the categories of information we have disclosed to third parties for their direct marketing purposes during the prior calendar year; and (b) the names and addresses of all of the third parties that received Personal Information for their direct marketing purposes during the preceding calendar year and, if the nature of the third parties' business cannot reasonably be determined from the third parties' names, examples of the products or services marketed, if known to us, sufficient to give you a reasonable indication of the nature of the third parties' business. To request this information, please contact us at legal@self.inc.

Our California Privacy Statement is available here.

11. Social Security Numbers

Social Security numbers are treated as “confidential” and may only be accessed by and disclosed to our employees and others with a legitimate business need in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to safeguards, and must be stored, transmitted, and disposed of in accordance with our internal policies created and maintained to protect confidential information from unlawful disclosure and to limit access. These restrictions apply to all Social Security numbers collected or retained by Self and related service providers and vendors.

12. Children’s Online Privacy Protection Act Compliance

The Services do not knowingly collect, use, or disclose personal information directly from children under the age of 13. If we are made aware we have collected personal information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act (COPPA), we will delete this information as soon as possible. You can find more information about the COPPA at https://www.ftc.gov/.

13. Changes to the Self Privacy Policy

We reserve the right to change this Privacy Policy at any time. We will take any steps required by applicable law to notify you of any material changes, by sending a notice to the primary email address specified in your marketing preferences or by placing a prominent notice on our site. Self will promptly post any policy changes to this page. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued use of the Platform or the Services following the update and notification means that you consent to our updated Privacy Policy. We encourage you to revisit the Privacy Policy that is posted on our web site from time to time to check for updates.

14. Find Out More

For additional information, or if you have questions regarding this policy or privacy practices at Self, please submit your questions or comments by writing to us at: Self Financial, Inc. Attention: Privacy Department, 901 E 6th Street, Suite 400, Austin, TX 78702, or log into your account at https://www.self.inc to chat with customer support.

To request deletion of any of your data, you may do so by either of the following means:

1. By following the relevant instructions as described on our Site,
2. By notifying Self in writing at 901 E 6th Street, Suite 400, Austin, TX 78702, and including your name, date of birth, and email address for your Self Account.

If you provided your email to Self through the Platform or on our Site but do not have a login and wish to request deletion, you may do so by either of the following means:

1. By sending an email to dataprivacy@self.inc from the email address you provided,
2. By notifying Self in writing at 901 E 6th Street, Suite 400, Austin, TX 78702, and including your name and provided email address.

Please note that removing the app or any other Self mobile app from your device will not cancel your Account(s) or delete your data.