Privacy Policy - Accion Opportunity Fund
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Privacy Policy

Accion Opportunity Fund Community Development

Accion Opportunity Fund

Privacy Policy

October 25, 2023

Introduction 

Accion Opportunity Fund Community Development and Accion Opportunity Fund (collectively, “AOFCD” “we” or “us’’) offer small business loans to qualified small business owners in several states, including the State of California, and provide business development assistance and coaching. Loans originated by AOFCD are made in accordance with AOFCD’s credit criteria. AOFCD processes all applications for credit and manages the loans on an ongoing basis. AOFCD is a licensed California Finance Lender, a certified Community Development Financial Institution, and a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code.

Purpose 

AOFCD understands that the confidentiality of information is essential. Therefore, we have created this privacy policy to demonstrate our commitment to keeping personal information confidential. This policy describes the personal information AOFCD gathers from loan applicants and other site users, how we use and disclose information, and the steps we take to protect personal information.  AOFCD is committed to protecting the privacy and security of personal information.

Scope and Applicability 

This Privacy Policy applies to our website, www.AOFund.org, as well as all related websites, applications (whether paper or online), blogs, newsletters, email subscriptions and any process AOFCD may use to collect information.

This policy describes the personal information we gather, how we use and disclose information, and the steps to protect personal information. AOFCD is committed to safeguarding the privacy and security of all personal and sensitive information. By using AOFCD services, the individuals subject to this policy (“you” or “your”) understand and consent to the privacy practices described in this policy.  The information third-party partners provide us with will be governed by this policy.

Policy

Information We Collect

Information provided

AOFCDs collect personal information, such as contact information (e.g., name, email address, mailing address, and phone number), social security number, financial information (e.g., bank routing numbers and other billing information), demographic information (e.g., age, education, and geographic location), and preferences when our services are used by accessing our website, applying for a loan, using the services, or when sending customer service-related requests.

Cookies

Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after browsers are closed. A persistent cookie remains after browsers are closed and may be used by browsers on subsequent visits to AOFCD websites or services. Users can control the use of cookies through their browsers. If cookies are deleted or rejected, users may still use peruse services, but the ability to use some of the features or areas might be limited.

Automatically Collected Information

We may also automatically record certain information from various technologies, including “clear gifs” or “web beacons.” This information may include IP addresses, device addresses (MAC Address), ID’s, web browser, device type, features of apps used, web pages or sites visited before or just after using the service, pages or other content viewed or interact with on the service, as well as the dates and times of visits, access, or use AOFCD services.  AOFCD could also use technologies to collect information regarding interaction with email messages (whether messages were opened, clicked on, or forwarded). This information is gathered from all site users and all loan applicants and may be associated with personal information.

Third Party Web Beacons and Buttons 

AOFCD may implement third-party content or advertising on services which could use clear gifs or other forms of web beacons. This content allows a third-party content provider to read and write cookies to a user’s browser, in connection with the user viewing third-party content on the service.

AOFCD may implement third-party buttons (such as Facebook “like” or “share” buttons) that might allow third parties to collect your information through third parties’ browser cookies, even when users do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and we do not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

Information from Other Sources:

We may obtain personal information from third parties and sources other than the service, such as our advertisers and partners (including through referrals of borrower applications). This information may include all personal information provided during the third-party application process. The information these other third-party partners provide us with will be governed by this policy.

If we combine or associate information from other sources with personal information we collect through the service, we will treat the combined information as personal information in following this policy.

How We Use the Information We Collect 

We use the information we collect on the service in a variety of ways, including the following:

  • To operate, maintain, enhance, and provide all service features, to provide services and information requested, respond to comments and questions, or otherwise provide support to users.
  • Analyze credit history, enable financial service partners to implement automatic payments and fund transfers, engage in collection activities as needed, and contact users regarding transactions and their accounts.
  • Extending pre-approved credit offers to applicants.
  • Understand and analyze usage trends and preferences of our users to improve services offered, and to develop new products, services, features, and functionality.
  • To contact users for administrative purposes, such as customer service or sending communications, including updates on promotions and events relating to products and services offered by  AOFCD and by third parties who work with  AOFCD. See the section below entitled “Choices” for information on opting out of receiving promotional communications.
  • Personalizing our services, such as remembering information to ensure users will not have to re-enter it during subsequent visits to the service.
  • Providing customized advertisements, content, and information.
  • Monitoring and analyzing the effectiveness of services and third-party marketing activities. This could include using customer data for testing purposes.  AOFCD will make every effort to redact certain pieces of Personally Identifiable Information (“PII”) when third parties conduct testing with and for AOFCD.
  • Monitoring aggregate site usage metrics, such as total number of visitors and pages viewed; and
  • Tracking entries, submissions, and status in any promotions or other activities on the services.

When We Disclose Information:

AOFCD will share personal information with third parties only in the ways we described in this policy. We may disclose information to third parties if we have been given consent to do so, as well as in the following circumstances:

  • AOFCD works with numerous third parties who perform vital functions for internal operations, including credit bureaus, collection agencies, electronic payment service providers, customer support call centers, and other third-party service providers. We share information with these parties only to the extent necessary to process customer transactions or to perform other specific services, like collections or identity verification.
  • We work with third-party service providers who provide us with website, application development, hosting, maintenance, and other services. Third parties may have access to process user information to provide those services for us. We limit the information provided to these service providers to that which is necessary for them to perform their functions. We require providers to agree to maintain the confidentiality of such information.
  • If you reached AOFCD through a third-party partner, we might send information back to the third-party partner, including applications AOFCD approved or denied, and the performance of the associated loans.
  • To make information, whether automatically collected, aggregated, personal or otherwise non-personal information, available to third parties, including (a) compliance with reporting obligations; (ii) for business, analytic or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the service.
  • We may disclose information if required by law or in good faith. These disclosures may be in response to comply with state and federal laws, in response to a court order, judicial or government subpoena or warrant, to comply with bankruptcy proceedings, or otherwise cooperate with law enforcement or other governmental agencies.
  • We also reserve the right to disclose user information we believe, in good faith, is appropriate or necessary to (I) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of AOF and AOFCS and any facilities or equipment used to make AOFCD’s products, services and website available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
  • We may disclose and otherwise transfer information about our users, including personal information to the entities within any merger, acquisition, debt financing, sale of assets, insolvency, bankruptcy, or receivership in which information is transferred to third parties as one of our business assets, and similar transactions.

Choices:

Users may decline to share certain personal information with AOFCD, in which case we may not be able to provide some of the features and functionality of services. If users wish to access or amend any personal information managed byAOFCD, they may contact  AOFCD at Compliance@aofund.org. Users’ abilities to amend information will depend on account types and status. All changes made will be reflected in active user databases within a reasonable period. We may retain all information submitted for backup, archiving, prevention of fraud and abuse, analytics, the satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

  • If users receive commercial emails from AOFCD, they may unsubscribe at any time by following the instructions contained within the email. Users may also opt-out of receiving commercial emails and any other promotional communications from  AOFCD, by sending an opt-out request by email at Compliance@aofund.org or by writing to us at the address given at the end of this policy. Within user account functionality on the service, AOFCD allow users to view and modify settings relating to the promotional communications received.
  • Please be aware that, when opting out of receiving commercial emails, or otherwise modifying the nature or frequency of promotional communications users receive from AOFCD, changes may take up to ten business days for the request to process. There might be promotional communications regarding the service being used if a user opts-out from receiving commercial messages during this processing time.
  • AOFCD do not specifically respond to Do Not Track (DNT) signals. Some third-party websites keep track of browsing activities, including other websites visited on the Internet, enabling these third-party sites to tailor what is presented to users. Web browsers might allow a setup of a DNT signal to ensure they know to not track the user.
  • Users can request AOFCD to delete personal information collected and inform their service providers (if any) to do the same, subject to certain exceptions (an example being, if AOFCD is legally required to keep the information, for situations such as legal holds).

Third-Party Services

The Service may contain features or links to websites and services that third parties provide. Any information provided on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy, and security, even if accessed through the Service.  AOFCD is not responsible for the content, privacy and security, or practices and policies of third-party site links or access, which are provided through the  AOFCD sites.  AOFCD encourages everyone to learn about third-party privacy and security policies before providing information on their portals.

Children’s Online Privacy

The service and products available through the  AOFCD website and other products or services are not intended for children under the age of thirteen (13); however, AOFCD strives to ensure we are Children’s Online Privacy Protection Act (COPPA) compliant. We request that people under the age of eighteen (18) not use the service without supervision from a responsible adult. If  AOFCD knowingly receives personally identifiable information from children who would be covered by COPPA, the data will immediately be deleted from the company network.

Data Security

We use certain physical, administrative, and technical safeguards to improve the integrity and security of personal data that we collect and maintain. However, we cannot ensure or warrant the security of any information stored or transmitted to AOFCD through the offered services, as this will be done so at the user’s own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of our physical, technical, or managerial safeguards.

If we learn of a security systems breach, we might attempt to notify users electronically, to ensure actions and appropriate protective steps can be taken.  AOFCD could post a notice through the service if a security breach occurs.

Privacy Settings

Although we may allow users to adjust privacy settings limiting access to personal information, note there are no security measures which are perfect or impenetrable.  AOFCD is not responsible for circumvention of any privacy settings or security measures on the service, nor can we control actions if users choose to share confidential information. Even after information posted on the service is removed, caching, and archiving services on the user side may have saved information, and unknown users or third parties might have copied or stored information available on the service.

International Visitors

AOFCD services are hosted in the United States (U.S.) and intended for legal residents only located within the United States. If users choose to access the services from the European Union (EU) or other regions of the world with laws governing data collection and use differing or more stringent from the U.S. law, please be aware that this results in understand, data transferring personal information outside of the U.S. for storage and processing.

 

Transfers to Other Countries

We may transfer information to other countries, for example, for customer service or to process transactions. We will protect information as described in this policy if information is transferred to other countries. By using the service, users consent to information being transferred to other countries, including countries that have different data protection rules than the U.S. AOFCD does not represent that the service is appropriate or available in any jurisdiction.

Changes to this Policy

AOFCD may update this policy to reflect changes to our information collection or retention practices. We will revise the “Effective Date” above and post the new, updated policy. AOFCD encourages users to periodically review this page for the latest information on our privacy practices.

California Privacy Rights

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information (as defined by the statute) to any third parties for their direct marketing purposes. We will not sell or transfer customer personal information to third parties for direct marketing purposes without consent. California customers who wish to request further information about our compliance with this statute or who have questions more generally about this policy and our privacy commitments to our customers and Service users should not hesitate to contact us at Compliance@AOFund.org or via mail at Accion Opportunity Fund, 111 W. ST. John Street, Suite 800, San Jose, CA 95113.