Last Revised: June 30, 2016
This policy (“Policy”) describes how Progressive Finance Holdings, LLC, Prog Leasing, LLC, Approve.Me LLC, and their affiliates, subsidiaries, and divisions (collectively “Prog Leasing”), collect, use and share user information.
This Policy applies to the Prog Leasing websites that post this policy (including, without limitation, progleasing.com and approve.me)(each a “Site”) and to information collected through Prog Leasing’s kiosks and mobile applications, regardless of whether accessed via computer, mobile device, or otherwise (collectively with all Sites, the “Progressive Platforms”). The Progressive Platforms are owned or controlled by Prog Leasing.
Prog Leasing takes the privacy of its customers and users of the Progressive Platforms very seriously. Prog Leasing understands that users may have questions about how Prog Leasing collects, uses, and shares user information. This Policy describes the type of information Prog Leasing collects, how Prog Leasing uses, shares, and protects that information, user choices regarding that information, and how the user can contact Prog Leasing with any questions.
WHAT INFORMATION IS COLLECTED, HOW IS IT COLLECTED AND HOW IS THAT INFORMATION USED?
• Prog Leasing collects Personal Information and Non-Personally Identifiable Information (“NPI”), as defined below.
• Prog Leasing collects Personal Information and NPI about users of the Progressive Platforms, in primarily these ways: directly from users of the Progressive Platform; from or about users leasing products from stores where Prog Leasing does business; from Prog Leasing’s web servers and application logs, cookies, web beacons, and similar technologies; and from third-parties.
• Prog Leasing uses user Personal Information and NPI primarily to review a user’s lease application and provide the user with the ability to lease products, to ensure quality of service, to contact users, to provide users with offers or information about products and services, and to provide users with a personalized user-experience.
• As part of Prog Leasing’s information collection process, Prog Leasing may detect additional bank accounts under the user’s ownership. Prog Leasing will consider these additional accounts to be part of the application process. By applying, the user authorizes Prog Leasing to search for and evaluate bank accounts that the user owns for this purpose.
• Prog Leasing does not share with others any Personal Information, unless otherwise indicated, or when Prog Leasing believes in good faith that the law requires it.
HOW IS MY INFORMATION SHARED?
• Prog Leasing may share user Personal Information and NPI with our affiliated companies for servicing, financial reporting, improvement, marketing, analytical, and other purposes.
• Prog Leasing also shares user Personal Information and NPI with our service providers and other third-parties as described below.
• Prog Leasing may also share some user Personal Information and NPI with the stores where the user does business or with those companies that have offered products to the user in return for payment from Prog Leasing (“Retailer”).
• Prog Leasing may also share a user’s Personal Information and NPI to meet Prog Leasing’s obligations to technology and content providers, or as required by law. More Details
WHAT CHOICES DO I HAVE?
• If a user does not want to receive information about Prog Leasing’s products or services, the user may update his/her account preferences (where available), and/or utilize the “unsubscribe” or “opt-out” mechanism within the communications that the user receives from Prog Leasing.
• If a user has any additional questions or concerns related to this Policy, the user may: email Prog Leasing at email@example.com; call Prog Leasing at 877-898-1970 between 9 a.m. and 5 p.m. Mountain Time, Monday through Friday; or write to Prog Leasing at Prog Leasing, LLC, 256 West Data Drive, Draper, UT 84020.
HOW IS MY INFORMATION PROTECTED?
• Prog Leasing has implemented certain appropriate security measures to help protect Personal Information from accidental loss and from unauthorized access, use, or disclosure.
• Despite these measures, Prog Leasing cannot guarantee that unauthorized persons will always be unable to defeat Prog Leasing’s security measures.
WHAT INFORMATION DOES PROG LEASING COLLECT?
Prog Leasing collects two main categories of information from or about its users: Personal Information and NPI.
Prog Leasing defines Personal Information as information that directly identifies an individual, such as name, residential street address or postal address, email address, social security number, date of birth, driver’s license number, government issued identification number, phone number, credit card number, bank account or other financial institution account number, and the user name and password used when a user uses the Progressive Platforms to make payments.
NPI is information about a user or about categories or groups of users that does not identify the user individually, such as a user’s IP address, randomly assigned values in “cookies,” mobile device identifiers, geo-location, and other technical information. Prog Leasing also collects other information that may not identify a user individually, such as vehicle information, occupation and other employment information, source of income, personal references, and residence-related information such as lease and ownership information, and other information.
HOW DOES PROG LEASING COLLECT USER INFORMATION?
Prog Leasing may collect Personal Information from users in a variety of ways. For example, Prog Leasing collects information:
i) that users provide directly to Prog Leasing when users seek to lease or buy products from a store where Prog Leasing does business;
ii) from those companies that have offered a product to users in return for payment from Prog Leasing (“Merchant”);
iii) when users enter into a contractual arrangement with Prog Leasing or its affiliates, whether online or at physical store locations; or
iv) when users visit or use the Progressive Platforms or when users otherwise contact Prog Leasing.
When a user submits a lease application to Prog Leasing, Prog Leasing may use third-parties to acquire additional Personal Information about the user. For example, if Prog Leasing knows the user’s name and postal address, Prog Leasing may use a third-party to acquire the user’s email address. In addition to what is described below, Prog Leasing uses this information for market analysis, marketing, improving the Progressive Platforms, and other business purposes, including enforcement of contractual obligations. Prog Leasing may also acquire Personal Information about a user from other sources, including but not limited to, consumer and/or credit reporting agencies, other companies used for identity verification and fraud detection, a user’s personal references, and from Prog Leasing’s affiliates.
When a user uses the Progressive Platforms, Prog Leasing may collect information about that user’s visit and store that information, which includes records of the user’s activities on the Progressive Platforms. Prog Leasing’s servers automatically capture and save the information electronically. Examples of the information that Prog Leasing may collect about a user or that third-parties (including third-parties involved in advertising or anti-fraud operations) may collect about a user during usage of the Progressive Platforms include, but are not limited to:
• Internet protocol or “I.P.” address
• Internet Service Provider
• The city, state, and country from which the Progressive Platforms are accessed
• The type and version of browser, operating system, computer, or mobile device used
• Screen resolution
• A list of browser plug-ins
• Installed fonts
• Other technical characteristics of the browser, computer, or device
• Unique device identifiers as well as identifiers set by software, us, the browser, or the mobile platform
• The links clicked within the Progressive Platforms and the pages visited;
• The date and time of the visit
• The referral web page to the Progressive Platforms; and
• Certain searches/queries conducted via the Progressive Platforms.
The information that Prog Leasing collects helps Prog Leasing administer the Progressive Platforms, analyze usage and performance of the Progressive Platforms, protect the Progressive Platforms and their content from inappropriate use, and improve the visitor’s experience. The information may also be used for marketing purposes and may uniquely distinguish a user’s browser or computer from others devices.
Cookies also enable advertising. Navigating the Progressive Platforms may result in the placement of various advertising-related cookies by third-parties on the user’s computer or device. These cookies allow web servers involved in advertising operations to recognize the user’s browser as the user navigates to other websites, and are necessary for the online delivery or placement of certain ads. Some third-parties involved in ad operations may maintain their own proprietary consumer databases that allow them to personally identify or track website user’s.
Cookies generally hold various types of information, including randomly assigned unique identifiers, which allow websites, including those included in the Progressive Platforms, to customize the user’s experiences and gather information about the user’s navigation of the websites. Prog Leasing may use different kinds of cookies, including HTTP cookies (also known as browser cookies) and Local Shared Objects such as Flash cookies that are built for use with the Adobe® Flash®Player. Prog Leasing may also use similar technologies, such as HTML5 local storage.
The user should understand that some features of many websites, including the Progressive Platforms, may not function properly if the user blocks or does not accept cookies.
OTHER DATA COLLECTION TECHNOLOGIES
Prog Leasing may use web beacons, pixel tags, .gif files, and the like, that allow for the collection of information about a user’s interactions on the Progressive Platforms. These technologies may be used, for example, to place advertisements, to understand internet traffic patterns and the number of users of the Progressive Platforms, and to measure the effectiveness of advertisements or the Progressive Platforms. Web beacons, and the like, also enable third-parties involved in advertising operations to recognize the user’s browser as the user navigates to other websites, and are necessary for the online delivery or placement of certain types of ads.
SOCIAL NETWORKS AND WIDGETS
The Progressive Platforms may also include social network or other third-party plug-ins and widgets that may provide information to their associated social networks or third-parties about the Progressive Platforms that the user visits, even if the user does not click on or otherwise interact with the plug-in or widget and regardless of whether the user has an account or other relationship with these social networks and third-parties. Information is transmitted from the user’s browser and may include an identifier assigned by the social network or third-party, information about the user’s browser type, operating system, device type, IP address and the URL of the web page where the plug-in or widget appears. If the user uses social network tools or visit social networking websites, the user should read their privacy policies to learn what information they collect, use, and share.
LINKS TO OTHER WEBSITES
The Progressive Platforms may contain content, services, advertising and other materials that link to websites operated by third-parties. Prog Leasing has no control over those other websites, and this Policy does not apply to them. The user should refer to the privacy policies of those websites.
HOW DOES PROG LEASING USE AND SHARE USER INFORMATION?
Prog Leasing uses the Personal Information and NPI that Prog Leasing collects from the user for many purposes. For example, Prog Leasing uses Personal Information and NPI to:
• process, review, determine eligibility, and approve or deny user applications for leasing products
• contact the user about his/her lease application
• process, manage, complete and account for transactions, including verifying the user’s identity and location, fulfilling product and service arrangements, and collecting amounts payable associated with such arrangements
• refer the user to lenders
• provide products and services that the user requests
• enforce contractual obligations
• help prevent fraud, unauthorized or criminal activity, claims and other liabilities
• operate, evaluate and improve Prog Leasing’s business, including developing new products and services, managing Prog Leasing’s communications, performing research and administering the Progressive Platforms and other programs, and for auditing purposes
• market to the user Prog Leasing’s products and services and the products and services of Prog Leasing’s franchisees and other third-parties;
• communicate with the user about Prog Leasing’s products and services, including to respond to the user’s comments and inquiries, to use “click-to-chat” or equivalent functionality for customer service purposes, and to identify the user’s preferences so that Prog Leasing can notify the user of new or additional products, services, promotions or events that may be of interest to the user
• communicate with the user about and administer the user’s participation in promotions that Prog Leasing offers or is involved in, such as sweepstakes, contests, special events and other programs
• enable the user to participate in surveys and other research efforts
• perform data analysis, including market and consumer research, financial analysis, and to measure the effectiveness of Prog Leasing’s advertising efforts online and otherwise; and
• comply with applicable legal and regulatory requirements, industry standards or guidelines, and Prog Leasing ‘s policies
• comply with applicable legal and regulatory requirements, industry standards or guidelines, and Progressive’s policies
In addition to other sharing described in this section, Prog Leasing may disclose Personal Information and NPI: (i) in order to comply with laws or legal process, including subpoenas or agency orders and investigations which Prog Leasing determines are required under appropriate circumstances; (ii) as Prog Leasing reasonably determines necessary or appropriate to protect property, Prog Leasing’s rights or the rights of others; and (iii) to enforce Prog Leasing’s contracts, policies and customer agreements.
Prog Leasing may also de-identify Personal Information (by removing certain data elements such as name, phone number, date of birth) that Prog Leasing receives from the user or from third-parties so that it cannot be used to identify a specific individual.
Prog Leasing may transfer information covered by this Policy, including Personal Information, in connection with a merger or sale or acquisition (including transfers made as part of insolvency or bankruptcy proceedings) of all or part of Prog Leasing ‘s business or as part of a corporate reorganization, stock sale, or other change in control.
SHARING WITH CORPORATE ENTITIES, FRANCHISEES, AND THIRD PARTIES
Prog Leasing also shares Personal Information and NPI with our affiliates, Merchants, and service providers who provide services to Prog Leasing or on Prog Leasing’s behalf and agree to only use such information for the purpose for which it was provided and in accordance with this Policy. Prog Leasing may also provide Personal Information and NPI to consumer and/or credit reporting agencies, companies used for identity verification and fraud detection and to third-parties collecting amounts owed to Prog Leasing, including third-parties to whom Prog Leasing assigns a user’s account for collection purposes.
If a user submits an application through certain Progressive Platforms, the user’s information may be shared with third parties who may be interested in providing the user with services. These third parties are unaffiliated with Prog Leasing so the user should be sure to review the privacy policies of those parties.
Prog Leasing may also share the user’s Personal Information with select third-party vendors, business partners, and other companies so that they can send the user promotional materials about goods and services (including special offers and promotions) offered by them. After the information is provided to such third-parties, the subsequent use or disclosure of such information is subject to those third-parties’ privacy policies and practices.
Prog Leasing may also use services hosted by third-parties to assist in providing our services and to help Prog Leasing understand users’ use of our products. A third-party service may collect information sent by a user’s browser as part of a web page request, including, for example, the user’s IP address, the third-party’s cookies, or any of the other categories of information itemized under Online Activities, above.
Prog Leasing may use “interest-based” ads also known as “online behavioral advertising” or “OBA.” Online behavioral advertising is advertising that is directed to the user based, at least in part, on the user’s Internet browsing behavior across the web. Although Prog Leasing does not share Personal Information with the third-parties that conduct advertising operations on Prog Leasing’s behalf, these third-parties and their affiliates do collect certain information as a result of their “tags” being present on certain Progressive Platforms. The information they collect includes the name (URL) of the web pages that the user views while using the Progressive Platform, the user’s IP address, time of visit, information about the user’s browser software, information about the user’s device, and randomly-assigned identifiers stored in cookies, which they use to target and serve advertising. Prog Leasing uses third-parties that participate in the Digital Advertising Alliance (DAA), which prescribes certain norms of conduct and provides an opt-out for behaviorally targeted ads, as discussed in “User Options Regarding Personal Information,” below.
HOW DOES PROG LEASING PROTECT USER INFORMATION?
Prog Leasing maintains administrative, technical and physical safeguards intended to protect against the loss, misuse, unauthorized access, or disclosure of Personal Information and NPI. Although Prog Leasing takes such precautions seriously, it is impossible for Prog Leasing or others to guarantee the safety and security of Personal Information and NPI.
WILL THIS POLICY CHANGE?
This Policy may be updated periodically to reflect relevant changes in Prog Leasing’s information practices. We will post a notice on our website to inform users of significant changes to this Policy. Prog Leasing will also provide additional information regarding changes to this Policy as may be required by law.
USER OPTIONS REGARDING PERSONAL INFORMATION
A user may request that Prog Leasing correct, update, or amend the Personal Information that Prog Leasing holds about that user. To update Prog Leasing regarding changes in a user’s Personal Information, the user must contact Prog Leasing as described below.
A user may elect to opt-out of receipt of email and text communications from Prog Leasing by following the instructions provided in such communications or by contacting Prog Leasing as provided below. Even after opting out, the user may still receive service oriented, non-promotional communications from Prog Leasing and promotional communications from other third-parties as a result of their own interactions or transactions with the user. Please allow time for Prog Leasing to process requests. The user should contact Prog Leasing should there be any concerns about the user’s opt-out request.
“Do-Not-Track.” Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by third-parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including Progressive’s, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal. The user can, however, make decisions about your privacy and the ads the user receive. As explained in the section above, “Sharing With Corporate Entities, Franchisees and Third-Parties,” Prog Leasing uses online behavioral advertising. The user can control whether companies serve the user behaviorally-based advertising by visiting the DAA web page and using the DAA’s opt-out: http://www.aboutads.info/choices/. The DAA opt-out requires that cookies not be blocked in the browser.
As an alternative to the DAA opt-out, a user can also elect to block advertising cookies from first-parties (such as Prog Leasing) and from third-parties involved in advertising by using the cookie blocking options built into a user’s browser software. For example, in Internet Explorer 9, a user can block both first and third-party advertising cookies by changing the settings in Tools/Internet Options/Privacy/Settings-Advanced/Override Automatic Cookie Handling. As another example, if a user is using Firefox 25, a user can “uncheck” Accept All Cookies under Firefox Preferences/Privacy-Use Custom Settings For History/Accept Cookies from Sites.
Please note, however, that if a user does decide to block certain cookies, some parts of the Progressive Platforms may not function correctly.
HOW CAN USERS CONTACT PROG LEASING?
If a user wishes to contact Prog Leasing regarding the user’s information or this Policy, the user may:
• email Prog Leasing at firstname.lastname@example.org
• call Prog Leasing at 877-898-1970 between 9 a.m. and 5 p.m. Mountain Time, Monday through Friday
• write to Prog Leasing at Prog Leasing, LLC, 256 West Data Drive, Draper, UT 84020
CALIFORNIA PRIVACY RIGHTS
If a user is a California resident, the user may ask Prog Leasing to refrain from sharing Personal Information with third parties for their own direct marketing purposes. The user must indicate the user’s preference by contacting Prog Leasing as described above. Please also note it may take Prog Leasing thirty (30) days to fully process a request.
The Progressive Platforms are not directed to children under the age of 18, and Prog Leasing does not knowingly collect Personal Information from children under the age of 18 through the Progressive Platforms.