Privacy Policy

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

 

Privacy Policy

 

At WithClutch Inc we work diligently to protect your privacy and personal information. Policy applies to all information collected through this WithClutch Inc. We want you to understand what information we collect about you, how we use it, and the methods we have to protect it. By accessing withclutch.com and using our services, you consent to this Policy including the collection, transfer, manipulation, disclosure, storage and other use of your information as described below. If you have questions or concerns regarding this Policy, you should call us at 650-842-0703.

Collected Information

In order to connect you with the right lenders and/or affiliates, you will 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, and/or affiliates 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 Inc 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.

Depending on the product, we collect the above described information from some or all of the following sources. 

 

  • 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 Informations: This is information about your transactions with us, our affiliates, 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.

 

We have provided a few examples for each source, but not all may apply to you.

 

We also may collect "Website Information" about you. This is unique to Internet activity. It may include how you linked to our website. It also may include your IP address and information about your device, time of visit, and what pages you visit on our website. When you visit our websites, we use cookies, web beacons, and other technology to collect information about you and your activities on our websites. We do this to provide services to you, enhance your online experience, and advertise our products and services.


In general, WithClutch Inc uses Information to provide the products and services you requested; research and analyze options to improve your existing loan or other products and services that may benefit you offered by WithClutch Inc or and/or affiliates; to communicate with you via telephone, mobile devices, email or postal mail regarding or services; to deliver targeted advertising; to analyze the effectiveness of WithClutch Inc advertising campaigns; and to operate our business. In addition, we may share the information we collect to companies that perform marketing services on our behalf, with whom we have marketing agreements, or with any companies we have other agreements that require the security of your Information. If for any reason you select to leave WithClutch Inc to a third party partner site you will be governed by their own privacy policies. When you leave WithClutch Inc to visit these sites, WithClutch Inc privacy policies are no longer valid.

WithClutch Inc uses Hotjar and Google Analytics in order to better understand our users' needs and to optimize this service and experience. Hotjar and Google Analytics are technology services that help us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar and Google Analytics use cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Any user inputs are anonymized and not tracked. Hotjar and Google Analytics store this information on our behalf in a pseudonymized user profile. Hotjar and Google Analytics are contractually forbidden to sell any of the data collected on our behalf. For further details, please see the 'about Hotjar' section of Hotjar's support site.

 

How do we share Your information

 

WithClutch Inc and/or affiliates: We may share your Information with affiliates. These affiliates adhere to this Privacy Policy. Your submitted application through WithClutch Inc will start the process of finding you the best possible interest rate from our lender base. Your Information is not sent to each lender for review. WithClutch Inc technology will match your credit profile and needs to the correct borrower profile and send to appropriate lender first. By submitting your application to WithClutch Inc, you consent us to the use of your credit report for the purpose of obtaining a credit offer from one of our lenders.

To Comply with the Law: We may disclose Information we collect if we determine in our sole discretion that such disclosure is necessary to comply with the law, including disclosure to law enforcement agencies and other government agencies and disclosure responsive to subpoenas. We also may disclosure information we collect if we deem it necessary to protect the rights, property, or safety of the WithClutch Inc, our customers or others.

Third-Parties: We may need to disclose your information to third parties vendors that provide services for WithClutch Inc to process your information for purposes of reviewing your loan application. Also, WithClutch Inc may share your Information with third parties that are interested in contacting you or providing offers to you that may be related to our products and services or about products or services you may find of interest, and we may be compensated for such disclosure.

Opt-out: At any time you can opt-out of our ability to share Information with unaffiliated third-parties that do not provide services to WithClutch Inc for processing your loan application by contacting customer service at 650-842-0703.

Regarding the Collection, Use and Distribution of Your Information


You have absolute control over the amount of personal information collected on this site. When you click on "Save" or "Continue" at each step in the application process, you affirmatively consent to WithClutch Inc's collection of Information for the application process. As WithClutch Inc continues to develop, it may sell or purchase other companies and/or assets. In such transactions, customer information is generally included in the transfer of business assets. In the unlikely event that WithClutch Inc or substantially all of its assets are acquired, customer information will be one of the transferred assets.

Safeguard your information

 

WithClutch Inc uses extensive and sophisticated secure technology to protect your data and transmissions between you, WithClutch Inc, participating Lenders, automobile dealerships and/or affiliates. Transmission between browsers and our web server is implemented using Secure Sockets Layer (SSL) technology. This technology requires an SSL-capable browser such as Microsoft Internet Explorer version 5.5 (or later) or Netscape Navigator version 4.7 (or later).

 

Transmissions between WithClutch Inc and participating lenders, automobile dealerships and/or affiliates are encrypted using public key cryptography algorithms with a minimum key size of 128 bits. Since ensuring your information is secure is important to us, we further limit access to your information to those employees who need access in order to perform their job. We maintain physical, procedural, and electronic safeguards to protect your information from unauthorized access.

 

Website
 

This Privacy Statement covers the information practices of the website. When sites are posted by WithClutch Inc, the site will link to this Privacy Statement, and this Privacy Statement applies. When sites are posted by third parties, the privacy statement of the third party applies, and this Privacy Statement does not apply.The website may contain links to other websites, including other WithClutch Inc websites. This Privacy Statement applies only to information submitted through WithClutch Inc and does not govern the information practices or the content of such other websites. WithClutch Inc encourages you to review the privacy statements of other websites to understand their information practices.

 

Cookies

WithClutch Inc uses cookies to store a unique user identifier (i.e. your user name). A cookie is a small data file that contains information such as a user ID. The data is written to your hard drive and is accessed each time you visit the site. Although, the only personal information a cookie can record is information you supply yourself, WithClutch Inc uses this ID to identify you anonymously in our database. The cookie is also required to reach certain parts of the WithClutch Inc site and is used to personalize the site for you. A cookie cannot read data off your hard disk or read other cookie files created by other sites that you visit.

 

Secure Web Pages


Every page on the WithClutch Inc website that asks for your personal financial information is delivered to your browser through "https", a secure mode of communication. You can verify this security by looking for Internet Explorer, Chrome, Firefox, Safari "lock" icon on your browser.

 

Encryption

 

WithClutch Inc protects the transmission of your personal financial information by SSL (Secure Sockets Layer) Technology. SSL does not allow anyone to intercept and read your personal information. When you send your information to us, SSL encrypts the data and only we can decode the encryption. Transmissions between WithClutch Inc and participating lenders are encrypted using public key cryptography algorithms with a minimum key size of 128 bits. This provides the most secure system available.

 

Amendments

 

WithClutch Inc may at any point or at any time, to add to, change, update, or modify this Privacy Policy by posting any modifications, updates or changes on the website. Any such modification, change or update will be effective immediately once posted to our site.

Third Party Agreements: 

Our apps and services may use third party data service and privacy agreements. By extension you are also agreeing to these policies such as those disclosed below:

Google Privacy Policy: https://policies.google.com/privacy

 

California Consumer Privacy Act Supplement

 

This Supplement ("Supplement") applies only to California residents. It describes our collection and use of Personal Information that is subject to the California Consumer Privacy Act ("CCPA") and your rights under that law. This Supplement does not apply to information that is exempt from or otherwise unregulated by CCPA.

Personal Information we may collect and the purposes for which we may use it

"Personal Information" is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer (a natural person who resides in California) or household in California. We collect some or all the following categories of Personal Information about you and your household:

  • "Identifiers" such as a 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.

  • "CCR Categories" may include the following categories of Personal Information described in the California Customer Records statute: 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.

  • "Protected Classification Characteristics " under California or federal law such as age, marital status, and gender.

  • "Commercial Information" may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • "Biometric Information" means an individual's physiological, biological, or behavioral characteristics that can be used to establish an individual's identity. Examples may include fingerprints; face, hand, palm or vein pattern imagery; voice recordings; or sleep, health, or exercise data that contain identifying information.

  • "Internet or Other Electronic Network Activity Information" may include, for example, website information, browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.

  • "Geolocation Data" about physical location or movements.

  • "Sensory Data" such as recorded phone call and other audio recordings.

  • "Professional or Employment-Related Information" such as information about current or past employment.

  • "Education Information" such as education level.

  • "Inferences" drawn from other Personal Information to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Our Personal Information practices

 

This section describes our practices with respect to Personal Information. For each category of Personal Information that we collected about consumers and may collect about you and your household, we describe the categories of (1) sources from which the Personal Information has been collected from and (2) Third Parties with whom the Personal Information has been shared.

 

Identifiers

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

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

  • Third-party product providers

  • Government entities

 

CCR Categories

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

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

  • Third-party product providers

  • Government entities

 

Protected Classification Characteristics

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Government entities

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

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

  • Third-party product providers

  • Government entities

 

Commercial Information

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

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

  • Third-party product providers

  • Government entities

 

Internet or Other Electronic Network Activity Information

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

 

Geolocation Data

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Service providers

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Government entities

Sensory Data

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

 

Third parties shared with:

  • Service providers

  • Data vendors

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

  • Government entities

 

Professional or Employment-Related Information

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Data vendors

  • Government entities

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Government entities

 

Education Information

 

Sources collected from:

  • Consumers or observation of consumers or their interactions with us

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Government entities

 

Inferences

 

Sources collected from:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

  • Ourselves

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

 

Inferences

 

Sources collected from:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

  • Ourselves

 

Third parties shared with:

  • Service providers

  • Data vendors

  • Lead sources and aggregators, social media, advertising networks, and other third-party sites, web browsers and search engines

  • Third-party product providers

  • Government entities

 

We also may collect Biometric Information about you or your household.

 

We have disclosed each category of Personal Information to one or more third parties for a business or commercial purpose. The business or commercial purposes for which we collected each category of Personal Information and the purposes for which we will use the Personal Information that we collect about you and your household may include the following:

  • communicating and interacting with consumers

  • consumer experience and service

  • marketing products and services offered by us or others

  • analytics, research, design, development, and pricing

  • counting ad impressions, verifying positioning and quality of ad impressions, auditing compliance, and other auditing

  • monitoring social media and other online references to us

  • litigation and claims handling

  • preventing, detecting and prosecuting malicious, deceptive, fraudulent or illegal activity

  • risk control, debugging and otherwise maintaining or protecting our data and systems and ourselves

  • to effect, administer, enforce, service, process, provide or maintain a product, service, account, or transaction with or for a consumer or business

  • in connection with a proposed or actual securitization, merger, acquisition, sale (including sale of servicing rights) or similar transaction related to, involving or impacting a consumer

  • providing information to regulators, law enforcement, other governmental entities and our attorneys, accountants and auditors

  • making disclosures required by and otherwise complying with legal requirements or legal, regulatory or other governmental investigations or process

  • any other purposes disclosed to or authorized or approved by a consumer

  • sharing information with other companies in our family of companies or in which we invest

 

We have disclosed for a business purpose all of the categories of Personal Information listed above.

 

Your rights to know and delete

 

To the extent provided by law, up to twice per year, you may request that we disclose to you free of charge:

  • the categories of Personal Information we collected about you in the past twelve months

  • the categories of sources from which it is collected

  • our business or commercial purpose for collecting or selling Personal Information

  • the categories of third parties with whom we share Personal Information

  • the specific pieces of Personal Information we collected about you

  • the categories of Personal Information about you that we disclosed for a business purpose

 

To the extent provided by law, you may request that we delete Personal Information that we collected from you.

To exercise the rights described above, please email your request to refi@withclutch.com.

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