Privacy Policy

WithClutch Inc and it’s subsidiaries and affiliates value customers' privacy.

 

Privacy Policy


Effective: 16th of April, 2021


This Privacy Policy (“Policy”) describes how WithClutch Inc. (“WithClutch,” “we,” “our,” “us”) collects, uses, and discloses certain personal information obtained through our website (“Site”), which is located at www.withclutch.com, as well as information that we collect in other contexts in relation to our lending/refinancing services. By visiting our Site, using the features made available to you on the Site, and/or by utilizing our lending/refinancing services (collectively, the “Services”), you are agreeing to the terms of this Policy.


Please note that information we collect in relation to our lending/refinancing services is subject to the federal Gramm-Leach-Bliley Act (GLBA) and, in some cases, the Fair Credit Reporting Act (FCRA). Please review our GLBA notice to learn more about how we comply with federal law. 
 

What Information We Collect and Maintain About You


We collect personal and other information from you directly when you provide it to us through the website. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Site. We also collect information offline related to our lending/refinancing services. 


Personal information collected in relation to our lending/refinancing services. In order to connect you with the right lenders or financial institutions, users of our lending/refinancing services are required to provide certain personal information such as name, address, e-mail address, social security number and income. This and other information such as your credit history and credit score may be obtained and provided to certain participating lenders or financial institutions for an offer decision. You may provide this information when you go through our loan application process; sign up for other products or services through WithClutch; when you provide information to us through a third-party application, service or website; when you communicate with us regarding our services through email or other means; or when you participate in any of our marketing initiatives. We may also collect this information (such as consumer reports) from third parties (such as consumer reporting agencies). 


Depending on the product, we may collect the following information about you from either your directly or from third parties: 

 

  • Application Information: You provide this on your application, through your agent or broker, by phone, or online. We may also obtain it from directories and other outside sources. It includes your name, street and e-mail addresses, phone number, driver's license number, Social Security number, date of birth, gender, marital status, and type of vehicle. It also includes information about other drivers. 
     

  • Consumer Reports: We obtain NPI from consumer reporting agencies. Reports include your claims history with other insurers and driving record. We may obtain credit information for some insurance coverage, but not for personal auto and certain other personal insurance products. We do obtain name and address information from credit reporting agencies for these products. Consumer reporting agencies keep this information and disclose it to others as permitted by law. 
     

  • Transaction Information: This is information about your transactions with us, our affiliated lenders, or others. It includes your insurance coverages, limits and rates, and payment and claims history. It also includes information that we require for billing and payment.

 

Personal information collected in other contexts. If you are not utilizing our lending/refinancing services and are instead using other features on the Site, such as our “Careers” section, or if you contact us with any questions, we may collect personal information from you, such as your name, contact information, and any other information related to your request. 


Server logs.  Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to the Site on a particular time and day and collect information such as your device ID or IP address. 
 

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement, or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email. 
 

Cookies.  We also use cookies on the Site.  Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information.  For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site.  If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it.  You can also delete cookies from your computer.  However, if you choose to block or delete cookies, certain features of the Site may not operate correctly. 


Third-party online tracking.  We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section.  For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us.  This information may be used for a variety of purposes, including website analytics, as discussed below (see the section entitled “How we share your information”).


Aggregated and deidentified information.  From time to time, we may also collect and share aggregated or deidentified information about Site users, such as by publishing a report on trends in the usage of the Site. Such aggregated or deidentified information will not identify you personally.


How We Use Your Information


The purposes for which we may use your information include to:  

 

  • Provide you with our Services;

  • Respond to your questions or requests concerning the Services; 

  • Fulfill the terms of any agreement you have with us; 

  • Fulfill your requests for our Services or otherwise complete a transaction that you initiate;

  • Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails; 

  • Improve our artificial intelligence and machine learning; 

  • Deliver confirmations, account information, notifications, and similar operational communications; 

  • Improve your user experience and the quality of our products and Services; 

  • Comply with legal and/or regulatory requirements; 

  • Aggregate and deidentify information; 

  • Serve advertisements;  

  • Count and recognize visitors to the Services; 

  • Analyze how visitors use the Services and its features; 

  • Improve the Services and enhance users’ experiences with the Services; 

  • Create new products and services or improving our existing Services; 

  • Enable additional analytics and research concerning the Services; and

  • Manage our business.


We may link information gathered through Site with information that we collect in other contexts. In that event, we will handle the combined information in a manner consistent with this Policy.

With Whom and Why We Share Your Information 


We share your information with other parties for a variety of purposes, as described below.


With lenders/financial institutions to offer our Services. Your submitted application through WithClutch starts the processing of finding you the best possible interest rate from our lending base. Our technology will match your credit profile and needs to the correct borrower profile and send to appropriate lender first. By submitting your application to us., you consent us to the use of your credit report for the purpose of obtaining a credit offer from one of our lenders.


Third-party service providers.  WithClutch uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers.  These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.


We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.


Analytics.  We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.  


Interest-based Advertising. The Services also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use the fact that you visited our Site to target online ads to you about our Services. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your mobile activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.


The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here.  Although our Site currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.


You can opt-out of interest-based by adjusting the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads). You can also opt out for companies that participate in the Digital Advertising Alliance's AppChoices tool by downloading it here and following the instructions in the app. 


Legal purposes.  We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

To comply with applicable law or a court order, subpoena, or other legal process; 

  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
     

  • To establish, protect, or exercise our legal rights or defend against legal claims; or  
     

  • To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.  

 

Your Choices


To the extent that we process your information pursuant to the GLBA or FCRA, you may have rights available to you under federal law. Please review our GLBA notice to learn more. 
If you wish to opt-out of marketing emails you receive from us, you may do so by following the instructions in those emails or by contacting us at refi@withclutch.com.


If you wish to access, correct, or delete the personal information we have on file, you may contact us by phone at 650-842-0703 or by email at refi@withclutch.com.


If you are a California resident, please review our California Privacy Addendum below for additional information and rights that may be applicable to you. 


External Links


This Site may contain links to third-party websites. If you use these links, you will leave the Site.  We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
 

Data Security
 

We employ physical, technical, and administrative procedures to safeguard the personal information we collect. However, we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.
 

Data Retention
 

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it.  When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.
 

International Users
 

The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence.  By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing.

 

Children
 

Content regarding the Services is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.
 

Changes to this Policy
 

We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice. 
 

How to Contact Us
 

Should you have any questions or concerns about this Policy, you can contact us by phone at 650-842-0703 or by email at refi@withclutch.com.

 

CALIFORNIA PRIVACY ADDENDUM


Date Last Updated: 16th of April, 2021
 

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to opt-out of the sale of your personal information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also visit our general privacy policy above to learn more about how we protect your information.  

Please note that if we process your information subject to certain federal laws, such as the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act, it may be exempt from the scope of the CCPA. To learn more about how we comply with federal law, please review our GLBA notice

Collection of Personal Information 

If you use the Services, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may have collected the following categories of personal information about you over the past 12 months:

  • Identifiers, such as your real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
     

  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
     

  • Characteristics of protected classifications under California or federal law, such as your age, marital status, and gender.
     

  • Commercial information, such as your records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
     

  • Internet or other electronic network activity information, such as your cookies, web logs, pixels, and IP addresses.
     

  • Geolocation data, such as information about your physical location. 
     

  • Sensory data, such as information collected in audio recordings. 
     

  • Professional or employment related information, such as information about your current or past employment experiences. 
     

  • Education information, such as your education history. 
     

  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

We collect the personal information listed above from the following sources:

  • Directly from consumers or from our observations with consumers. 

  • Consumer reporting agencies. 

  • Service providers. 

  • Data vendors. 

  • Lead sources and aggregators. 

  • Advertising networks. 

  • Data analytics providers.

  • Third-party lenders.  

  • Government entities. 

 

We collect your personal information for the purposes described in our privacy policy, under the section titled “How We Use Your Information.”
 

Disclosure or Sale of Personal Information

In the last 12 months, we may have disclosed or sold the following categories of personal information subject to the CCPA:  

 

  • Identifiers, such as your real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
     

  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
     

  • Characteristics of protected classifications under California or federal law, such as your age, marital status, and gender.
     

  • Commercial information, such as your records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
     

  • Internet or other electronic network activity information, such as your cookies, web logs, pixels, and IP addresses. 
     

  • Geolocation data, such as information about your physical location. 
     

  • Sensory data, such as information collected in audio recordings. 
     

  • Professional or employment related information, such as information about your current or past employment experiences. 
     

  • Education information, such as your education history.
     

  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

We may have shared any of the information listed above with: 

  • Directly from consumers or from our observations with consumers. 
     

  • Consumer reporting agencies. 
     

  • Service providers. 
     

  • Data vendors. 
     

  • Lead sources and aggregators. 
     

  • Advertising networks. 
     

  • Data analytics providers.
     

  • Third-party lenders.  
     

  • People and entities involved in insurance claims, litigation, fraud prevention, and detection.
     

  • Government entities. 

We disclose your personal information to the entities listed above for the purposes described in our privacy policy above, under the section titled “With Whom and Why We Share Your Information.” 
 

Your Rights 

If we maintain personal information about you that is subject to CCPA, you may exercise certain rights in connection with this data if you are a California resident. 

 

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months (“Right to Know”).  Once we receive and confirm your verifiable consumer request, we will disclose to you: 
 

  • The categories of personal information we collected about you. 
     

  • The categories of sources for the personal information we collected about you.
     

  • The categories of personal information that we have disclosed for a business or commercial purpose.
     

  • Our business or commercial purposes for collecting or selling personal information.
     

  • The categories of third parties with whom we share that personal information.
     

  • The specific pieces of personal information we collected about you (i.e., a data portability request).

 

Right to Delete
 

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers/vendors to delete) your personal information from our records, unless an exception applies. 
 

Right to Opt-Out of Sale
 

The CCPA provides California residents with the right to opt-out of the sale of their personal information. 
 

We do not sell your personal information.  
 

Right to Nondiscrimination


The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. 
 

Exercising Your Rights


If you are a California resident and wish to request for us to provide you with your Right to Know or Right to Delete, you may submit a request by us by email at refi@withclutch.com or by phone at 650-842-0703. 


When you submit a request, we will confirm your identity by asking you to provide your name, the email address, and phone number associated with your account. We will verify your identity by matching the information you provide with what we have on file for you. We may ask you for additional information to verify your identity or to comply with your request.
 

Authorized Agent
 

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.
 

Contact for More Information 


If you wish to contact us regarding this California Privacy Notice, you may do so through the following methods: