Privacy Notice

Service Privacy Policy

Effective Date: November 1, 2022

Introduction

In today’s marketplace, privacy is a constant concern and at Flagship Credit Acceptance LLC (“Flagship,” “we,” “our” or “us”), we take this concern very seriously. We want you to understand what our policies are regarding every Flagship product and service that we offer—which includes how we handle the nonpublic personal information that we receive about you. We respect the privacy of visitors to our website and users of our services (“you”, or “your”), including users accessing the Flagship Auto Refinance experience seeking to refinance an auto loan.

Flagship collects, uses, and shares certain nonpublic personal information about you that is described below (“Private Information”). This Privacy Policy will help you understand what Private Information Flagship collects when you visit www.flagshipautorefi.com our website (“Site”) or use Flagship’s mobile or other online services (collectively with the Site, the “Service”), with whom we share it, and how we protect it. This Privacy Policy also explains how we protect the security and confidentiality of your Private Information. It also describes your choices regarding use, access and correction of your Private Information. This Privacy Policy applies only to Private Information collected online and does not apply to information we collect by other means (including offline) or from sources other than through the Service. This Privacy Policy is governed by our Terms of Use.

By accessing or using the Service, you consent to the data practices described in this Privacy Policy.

Additional Information

For California Consumers, refer to https://www.flagshipcredit.com/california-privacy-notice/ to access Flagship’s California Privacy Notice.

For Flagship’s financial privacy policy, refer to https://www.flagshipcredit.com/privacy-policy/ to access Flagship’s financial privacy policy.

Information We Collect

Throughout our business relationship with you, you provide us with, and we collect, Private Information about you. Private Information is any information that may be used to identify an individual, including, but not limited to, a first and last name, home or other physical address, an email address, phone number or other contact information. The following is a list of the Private Information we collect and maintain about you, and the sources of such information:

• Information provided by users of the Service when they complete an online form or enter information regarding themselves and/or their vehicle(s), i.e., your name, address, Social Security Number and income, etc.
• Information about your transactions with us, our service providers and others – i.e., your account balance, payment history and information that we obtain to verify employment history, if insurance coverage is in force; and
• Information we receive from credit reporting agencies (also referred to as consumer reporting agencies or credit bureaus) – i.e., your credit history, information about your creditworthiness, etc.
• Information we collect by using technology when visitors use our Site:
  • Google Analytics collects the following information through the default implementation:
    • Number of users
    • Session statistics
    • Approximate geolocation
    • Browser and device information
  • We also use cookie and local storage to store an authentication token for the user. On the server side, Flagship saves the current and previous IP addresses that the user signed in from and a device fingerprint for fraud tracking purposes.

Private Information

Flagship collects Private Information that you choose to make available to us on the Service, and may include, without limitation, the city where you live, your zip code, your first and last name, your billing address, vehicle registration/titling information, your cell phone number, your email address, information regarding your vehicle and its history, banking or payment information for purchasing a vehicle, making payments on your account, or for other services we offer. By providing us with your mobile phone number(s), you verify that it is your mobile phone number(s) and you are providing express consent to receive autodialed calls and prerecorded/artificial voice messages, including text messages, by Flagship or its authorized agents at that number. You certify that that the telephone numbers you have provided are your telephone numbers. You represent that you are permitted to receive calls at each of the telephone numbers you have provided. You agree to notify Flagship whenever you stop using a telephone number you have previously provided. You understand that your cellular or mobile telephone provider may charge you depending on the type of plan you have.

If you choose to post content to any of the interactive areas of our Service, such as discussion forums, comments fields and social media areas, the information you post can be seen, collected and used by anyone who has access to those areas. Flagship is not responsible for any third-party use of such information.

We may survey our users to measure their satisfaction with our Service and to help us learn more about our audience and how they interact with our Service. Third-party research firms may conduct these surveys on our behalf. We will not share, without your consent, any Private Information you submit in response to a survey with any company other than the research firm conducting the survey. We will, however, take the information you provide and aggregate it on a non-identifying basis with data collected from other survey participants. We may use and disclose that pool of aggregated information, without identifying you personally.

Flagship also automatically receives and records information on our server logs from your browser when you use our service, including your Internet Protocol (“IP”) address, cookie information, and the page you request, to analyze trends in the aggregate and administer the site.

We may also receive Private Information about you from third parties, including, for example, information about your transactions, purchase history, credit history or relationships with various product and service providers, and your use of certain applications. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.

Cookies Information

When you visit the Service, we may (or we may authorize a trusted third-party partner to) send one or more cookies, a small text file containing a string of alphanumeric characters, to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service) and allow us or our business partners to track your usage of the Service over time.

A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Log File Information

Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include information such as your web request, IP address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Clear Gifs/Web Beacons Information

When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Devices Identifiers

When you access the Service by or through a mobile device (including but not limited to smartphones, iPads or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a Unique Device Identifier (“UDID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. The device identifier information that we collect does not itself collect or transmit any Private Information to us, however, a device identifier may be used in conjunction with other information in a manner that may constitute Private Information. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

Location Data

When you utilize the Service by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers. We collect your location-based information for the purpose of customizing your experiences with our Service, as well as for usage by us or our third-party fraud prevention service for fraud prevention purposes. Location data may convey to us information about how you browse and use the Service. The location data that we collect does not itself contain or transmit any Private Information to us, however, location data may be used in conjunction with other information in a manner that may constitute Private Information. You may opt-out of location-based services at any time by editing the setting at the device level.

To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit the Network Advertising Initiative’s online resources, at https://www.networkadvertising.org.

How is Your Information Used?

Private Information collected by us is used to provide you with the Service. We collect your email address if you create an account through email, through an app, or online. We collect your first and last name and your phone number to provide you quality customer service. We may use your Private Information to provide you with product information, support the services offered on the Service and to notify you of technical updates, changes in policy or other customer services. We may contract with one or more third party agents to provide the Service. These third parties may include credit card processing companies, finance companies, credit reporting companies, vehicle registration companies, automobile valuation agencies, insurance companies, website designers, website hosting companies and others who assist in providing the information, systems or materials available through the Service. Selected parts of your Private Information may be shared with these third party agents in order to provide you with the Service. We also use your Private Information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

We will retain your Private Information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at Hello@flagshipcredit.com. We will retain and use your Private Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How is Your Information Shared or Disclosed?

We only share your Private Information as expressly allowed or required by law. We may disclose some or all of your Private Information described above, as follows:

Service Providers. We may share some or all of the Private Information described above with companies that perform services for us or act on our behalf, such as a marketing company that sends you information about our products. The information we may share includes your name, address and account number, and can consist of other Private Information. We may share such information about you as a consumer, customer, or former customer.

Other Third Parties. We may share some or all of the Private Information described above with other non-affiliated third parties as permitted by law.

You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile number, name, address, email, network  status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.

Online Advertising

We partner with a third party to deliver online advertisements (“ads”) that may be of interest to you. We may allow third-party ad servers or ad networks to place advertisements on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service. These ad-servers and ad-networks automatically receive your IP address when this happens. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, which are described above) to compile information about your browser’s or device’s visits and usage patterns on the Service (without using any other Private Information), and to measure the effectiveness of their ads and to personalize the advertising content. We do not sell, rent, or share your Private Information with these third-party ad servers or ad networks for such parties’ own marketing purposes, unless you choose in advance to have your information shared for this purpose. However, please note that if an advertiser asks us to show an ad to a certain audience and you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. In addition, third-party advertisers may use Non-Private Information (e.g., information that does not include your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements on this and other websites about third-party goods and services that may be of interest to you. This Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information. Please note you will continue to receive generic ads.

Your Choices About Your Information

We will use your email address to send you notifications while using our Service. You may opt out of these notifications at any time by sending an email to Hello@flagshipcredit.com. Even if you opt out, we will send you strictly Service-related announcements on rare occasions when we deem it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we may send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your Flagship account.

You can manage your account and make modifications to any preferences applicable to providing the Service by updating your user information on the applicable Service. You can also access, modify, amend or delete any account information you provide to the Service. Upon request, we will provide you with information about whether we hold any of your personal information. We will respond to your request within a reasonable timeframe.

Opting Out of Collection of Private Information

You may, of course, decline to submit any Private Information through the Service, in which case we may not be able to provide certain services to you.

Do Not Track Signals

We do not respond to Do Not Track signals or other mechanisms that provide you the ability to exercise choice regarding the collection of Private Information about your online activities over time and across third-party Web sites or online services. As described in the following paragraph, you may disable cookies on your browser to prevent us or its business partners from tracking your browser’s activities in relation to the Service, and for use in targeted online advertising.

Opting Out of Collection of Non-Private Information

The only way to completely “opt out” of the collection of any information through cookies or other technology is to actively manage the settings on your browser. Please refer to your browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit the Network Advertising Initiative’s online resources, at https://www.networkadvertising.org.)

Note that disabling cookies on your browser prevents us or our business partners from tracking your browser’s activities in relation to the Service, and for use in targeted online advertising. However, doing so may disable many of the features available through the Service.

Opting Out of Online Advertising

As noted above, we may share Non-Private Information with third-party business partners to deliver online advertisements to your browser or mobile device through the Service, and/or to third- party websites and services. If you would like more details about this practice and your choices about how to opt out of the collection and use of your information by these companies for online advertising purposes, visit http://www.google.com/privacy_ads.html for Google.

The Security of Your Information Safeguarding Measures

We take commercially reasonable steps to ensure information we collect through the Service is stored in a secure manner. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of all information collected. We protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you input.

International Transfers

All information collected on the Service, including Private Information, may be stored and processed in the United States or any other country in which we or our affiliates, subsidiaries or agents maintain facilities, and by using this Service you consent to any such transfer of information outside of your country and the use and disclosure of information about you, including Private Information, as described in this Privacy Policy.

Children

This Site is not intended for or directed to persons under the age of 18 or without legal capacity to enter into binding contracts. Any person who provides their information to us through the Account login page for new customers or any other part of the Service represents to us that he/she is 18 years of age or older with legal capacity to enter into binding contracts.

Changes in This Privacy Policy

We may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. If we decide to change our Privacy Policy, we will update the “effective” date at the top of this page. Your continued use of this website following the effective date of any such amendment shall be deemed to constitute your agreement to the terms of this Privacy Policy as amended. By visiting   www.flagshipautorefi.com, you agree that your visit, and any dispute over privacy, is governed by this Privacy Policy and our Terms of Use. If we make any material changes we will notify you by mail, email (sent to the e-mail address specified in your account), or by means of a notice on this website prior to the change becoming effective.

Disclaimer

We take our commitment to protection of your privacy, as set out in this Policy, seriously. Nevertheless, NOTHING IN THIS PRIVACY AND SECURITY POLICY IS INTENDED TO CREATE OR PROVIDE ANY RIGHT OF ACTION FOR VIOLATION.

California Privacy Rights Notice

California residents: You can review the California Privacy Notice at this link: https://www.flagshipcredit.com/california-privacy-notice/

Contact Us

If you believe that Flagship has not adhered to this Privacy Policy or should you have any questions about the details of any of Flagship’s policies, please contact us at 1-800-707-0114 between 9 am and 5 pm EST Monday-Friday, or go to www.flagshipcredit.com, and we will use commercially reasonable efforts to remedy the problem.