Privacy Policy

Transform Credit Inc. and its affiliates (“Transform Credit” or “we”) respect your privacy and are committed to protecting your personally identifiable information (“PII”) that may be collected through your use of our website or mobile application (together, “Site”) or in applying for or receiving any of our products or services (“Services”). This privacy policy (“Policy”) describes how we collect and use your PII and how you can control that use. If you apply for a loan, we will provide you with a separate notice, entitled “What Does Transform Credit Do With Your Personal Information?” (the “Notice”) which describes our policies with respect to the use, maintenance, and disclosure of the non-public PII that we learn about you in connection with providing you with a financial product or service. To the extent that there is any conflict between this Policy and the Notice, the Notice will control.

Please read this Policy carefully. By using our Site or Services, you agree to our collection, use, and sharing of your PII as described in this Policy.

Information that We Collect
Through your use of our Site and Services, we may collect PII, which is information that identifies an individual or relates to an identifiable individual. PII may include, but is not limited to, your first and last name, physical address, Social Security number, date of birth, and checking account information. We collect the following types of information:

Information Provided by You
If you express interest in one of our Services, we will collect certain PII from you, including contact information (such as name and email), which we will use to contact you. We may request additional PII that is necessary to process any application submitted by you, such as your physical address, Social Security number, mobile phone number, date of birth, bank account information and numbers, employment and income information. Additionally, we may collect PII to verify your identity, for security-related purposes, or other administrative purposes. In order to provide Services to you, we may on occasion supplement the PII you submit to us with information from third-party sources, such as consumer report information. If you contact us and / or provide us with information about yourself, including any questions, comments, or suggestions, we will maintain a record of these communications.

Account & Transaction Information
We collect information about your use of our Services. For example, in processing a payment with you, such information would include your name, amount of payment, and your bank account information, including account numbers, routing numbers, debit card numbers and similar information. Other information that we collect includes your transaction history, payment history, and account balance. We also collect tokens from online services and payment systems.

Device and Usage Information
We may automatically collect the following types of information as you use our Site and Services:

Usage Information: We collect certain information automatically through your use of the Site, such as which of our web pages you access, the frequency of access, and what you click on while on our Site.

Location Information: We may collect information about your actual location which may be determined from: IP address, GPS, and other sensors that may reveal information on nearby devices, Wi-Fi access points, and cell towers.

Device Information: We may collect information about the device you are using such as: hardware model, operating system, application version number, browser, and IP addresses.

Mobile Device Information: In addition to the Device Information listed above, when you access our Site or Services via a browser on your mobile device or through the use of our mobile application, we may also collect mobile network information including phone number, the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.

Cookies and Other Tracking Technologies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes:

Session Cookies: We use session cookies to make it easier for you to navigate our Site. The session ID cookie expires 24 hours after you sign in to our Site.

Persistent Cookies: We use persistent cookies that remain on your hard drive for an extended period of time. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our Site. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

If you reject cookies, you may still use our Site, but your ability to use some areas of our Site may be limited. For example, you may be unable to take out a loan or other product without accepting cookies. We may use a software technology called tracking pixels (a.k.a. web beacons or clear gifs) that help us better manage content on our Site by informing us what content is most effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may also use other website or mobile tracking technologies, such as device fingerprinting, to identify you and keep track of your preferences, prevent fraudulent activity or improve Site security, assess the performance of the Site, and deliver content to you based on your interests on our site and third-party sites.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our site through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Site usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Aggregate Information
Statistical or aggregated information does not directly identify a specific person, but it may be derived from your PII. For example, we may aggregate PII to calculate the percentage of users in a particular ZIP code

Third Party Data Collection
Some content or applications on the Site may be provided by third parties, including advertisers, ad networks and servers, analytics companies, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your PII or they may collect information, including PII, about your online activities over time and across different websites and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising.

How We Use and Share Information
We use PII and we collect information in the following ways:

Process Transactions: We use PII to provide our Services, including to consider loan applications, make loans, process payments, and keep track of your points.

Communicate: We use PII to communicate with you about our Site and Services. This may include payment reminders, information that you have requested, or notification of important changes to our Site and Services.

Marketing: We may occasionally send you information about products and services that we believe will be of interest to you. During any such communication, we will provide you with the option not to receive any future marketing communications.

Specific Purposes: You may be asked to provide information for a specific purpose. For example, if you participate in our referral program, you will be asked for information about your contacts. We will only use the information that you provide for the purpose for which you provided it to us.

Customer Support: We may use your PII to provide you support or other services you have ordered. For example, we may need your information in order to provide technical support or answer questions about your account.

Post Testimonials: If you choose to tell us your story or otherwise give a testimonial, we will review such information and may post such testimonial on our Site along with your name and any other PII that you choose to disclose on your testimonial. By submitting a testimonial, you consent to posting any information and content, including video content, you provide in such testimonial on our Site. If you submit a testimonial, you may revoke such consent at any time by calling 470-435-6300 or emailing us at hello@transformcredit.com

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Site Maintenance: We analyze how our users interact with our Site and Services in order to maintain and improve our Site and Services. We also use information that we collect to diagnose problems with our Site or Services to improve the user experience.

We reserve the right to share information, including PII, with third parties, as described below:

Service Providers: We may share information with service providers that help us perform functions and process your transactions.

Affiliates: Subject to applicable law, we may share information with a parent company, subsidiaries, joint ventures, or other companies under common control with us.

Other Companies: Subject to applicable law, we may share information with other companies for purposes of marketing our products to you or for analyzing our business and transactions.

Corporate Structure: We may share information in connection with a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation.

To Prevent Harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.

As Required by Law: We will share information where we are legally required to do so, such as in response to court orders or legal process, to establish, protect, or exercise our legal rights, or to defend against legal claims or demands.

With your Consent: We may request your permission to share your PII for a specific purpose. We will notify you and request consent before you provide the PII or before the PII you have already provided is shared for such purpose.

Without Identifying You: We may share information in a manner that does not identify you. For example, we may share anonymous, aggregate information about your use of our Site and Services with our service providers or other third parties.

Transform Credit Inc. provides you with certain “opt-out” rights from having your PII used or shared for certain purposes. For more information regarding your rights related to our sharing of your non-public personal information, please refer to the Notice that we will provide to you if you apply for a loan or, contact us using the methods described at www.TransformCredit.com/Contact.

Credit Report Authorization
As part of your application for a loan with Transform Credit Inc. we request your authorization to obtain your credit report(s). You understand that by applying for a Transform Credit Inc. loan and clicking on the appropriate disclosure, you are providing “written instructions” to Transform Credit Inc. under the Fair Credit Reporting Act authorizing Transform Credit Inc. to obtain information from your personal credit profile or other information from one or more consumer reporting agencies.

You authorize Transform Credit Inc. to verify information in your application, and you agree that Transform Credit Inc. may contact third parties to verify any such information. Transform Credit Inc. may use consumer reports to authenticate your identity, to make credit decisions, and for related purposes. You authorize Transform Credit Inc. to obtain consumer reports each time you request a loan, during the processing or closing of a loan to you, or at various times during the term of your loan in connection with the servicing, monitoring, collection or enforcement of the loan.

You further acknowledge that we may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. You understand that pulling credit and furnishing information to consumer reporting agencies may affect your credit score.

Correction
If your PII changes, or if you no longer desire our Services, you may correct or update your PII by contacting us at: 470-435-6300 or hello@transformcredit.com If you have an account with us and your account is in good standing, you may also correct or update your PII by logging into to your account on our Site and updating your information there.

Your rights and choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right of Access
You have the right to request that Transform Credit Inc. disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you;

• The categories of personal information the business collects about the consumer
• The categories of sources of the consumer's personal information
• The business or commercial purpose for collecting or selling the consumer's personal information
• The categories of any third parties with whom the business shares the consumer's personal information
• The specific pieces of personal information collected about the consumer

Right of Non-Discrimination
You have the right to not be discriminated against for having exercised your rights under the CCPA. In particular, we may not;

• Deny you goods or services
• Charge you different prices for goods or services, whether through denying benefits or imposing penalties
• Provide you with a different level or quality of goods or services
• Threaten you with any of the above

Right to deletion
You have the right to request the deletion of personal information that Transform Credit Inc. holds on you.
Under the CCPA, this right does not apply when Transform Credit Inc. need to retain the personal information in order to any on the following;

• Provide goods or services to the consumer
• Detect or resolve issues security or functionality-related issues
• Comply with the law
• Conduct research in the public interest
• Safeguard the right to free speech
• Carry out any actions for internal purposes that the consumer might reasonably expect

How to exercise your rights
To exercise your the access, non-discrimination and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 470-435-6300
• Emailing us at hello@transformcredit.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with the personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Security
The security of your PII is important to us. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your PII. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. If you have any questions about the security on our Site, you can contact us at 470-435-6300 or hello@transformcredit.com

Other Websites
The Site may contain links to or links from third party sites that are not owned or controlled by Transform Credit Inc. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to review the privacy policies of these third party sites before you disclose your PII.

Browser Do Not Track

The Site is not currently configured to respond to Do Not Track signals.

Children’s Privacy
Our Site and Services are not intended for use by children. We do not knowingly collect personal information from children under the age of 13 years. If we become aware that a child under 13 has opened an account or otherwise provided us with PII, we take steps to terminate the child’s account and delete such PII. If you believe that we have inadvertently received any such PII, please contact us at 470-435-6300 or hello@transformcredit.com

Applicable Law
This Site is based in the United states and is subject to United States law. This Site is controlled, operated, and administered by Transform Credit Inc. from its offices within the United States. This Policy is provided in accordance with and subject to applicable U.S. law. If you are accessing this Site from a location outside the United States, you hereby agree that your use of this Site and our collection and use of your PII is subject to this Policy.

SMS terms

Why do you need to contact me?

We contact you for things like updates on your application, notifications and alerts such as payment reminders and monthly statements, so message frequency varies. This could be about your loan application, or if we change or update something that could affect you. This could be app updates to make your life easier, or the possibility to top-up your loan amount.

By submitting your contact information to us, you are expressly consenting to be contacted by us (and our affiliates, agents, assigns and service providers) twenty-four hours a day, seven days a week even if you have opted into the national Do Not Call List administered by the Federal Trade Commission, any state equivalent Do Not Call List or the Do Not Call List of any specific institution.

How do I opt out?

If you choose that you don't want to hear from us then you can tell us anytime and we will always respect your decision, just reply STOP to unsubscribe. We will then send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to resubscribe again, Reply START at anytime.

Help, I'm having issues!

If you are experiencing issues with the messages you can reply with the keyword HELP for more assistance, or you can get help directly at hello@transformcredit.com

Fee disclosure: We don't charge for messaging us but you may incur costs from your messaging provider, each provider is different. Transform Credit, also known as 'Transform Credit Inc.' offers updates to existing applications. Message frequency varies. Message and data rates may apply. Reply HELP to any message for help. Reply STOP to unsubscribe. Carriers are not liable for any delays or undelivered messages.

Updates to this Policy
We reserve the right to modify this Policy at any time, so please review it frequently. If we decide to make material changes to this Policy, we will post those changes to this Site in a manner that we deem is appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You agree to these future updates by continuing to use our Site or Services after they have been posted. You can always obtain a copy of the most updated Policy by reviewing this Site.