LEGAL

Privacy Policy

info@levelcredit.com

LevelCredit Privacy Policy

Effective Date: December 31, 2019

Lasted Updated: December 31, 2019

LevelCredit, a division of RentTrack Inc., ("LevelCredit") is committed to protecting your privacy. This Privacy Policy covers how LevelCredit and its affiliated companies (collectively, "LevelCredit", "RentTrack," "we," "us" or "our") collect, use, and share information in connection with your access and use of our Services. It does not cover the privacy practices of third parties that we do not own or control. When you leave our Services or interact with a third-party feature, you should also read the applicable third party's privacy policies and terms of service to make sure you understand how they might collect and share information about you. Additional policies and a description of the services are provided in the LevelCredit Terms of Service which also define the usage and restrictions of our Services.

User Consent

By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Data in accordance with this Privacy Policy.

Types and Use of Information We Collect

Information You Provide to Us

You may provide information to us in various ways, such as through forms, features or other means offered through our Services. A couple of examples include information you provide to us when registering as a member, and feedback forms where you send us comments, questions, or other feedback. The types of information you provide us fits into two general categories:

    Personal Information: LevelCredit collects the following Personal Information from you when you sign up and use our Services: Contact Information - name, email address, mailing address, phone number, etc.; Identity Verification Information - Social Security Number, date of birth, cellular phone number, person associated with the identified bank account, etc; Payment Information - credit card or bank account numbers, billing addresses, bank account transactions, etc.

    Non-Personal Information: This is information about you or your household that doesn't identify you personally, including but not limited to: gender, salary, demographic data, marital status, loan and credit card monthly payment, total amount and interest rates, home value, etc.

Information We Automatically Collect

In addition to information you provide to us, we automatically collect certain information about how you access and interact with our Services ("Usage Information"). This Usage Information is a key part of how we improve your LevelCredit experience and provide you with more personalized insights and recommendations. We and our partners may use various technologies to collect and store Usage Information in connection with our Services. These may include things like cookies, browser web storage (e.g., HTML5), web beacons and similar technologies. There are three types of Usage Information we may collect:

    Device Information. This is information about how you access our Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device. We may also integrate with built-in device features.

    Log Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with our Services, such as which features you visit or click on. This Log Information may also include things like your IP address, browser or device configuration, date and time of access and cookie information.

    Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent.

Information Third Parties Provide About You

Some of our features rely on information about you that we collect from third parties, such as the credit reports and credit scores we request on your behalf from Experian, TransUnion and Equifax. We may also work with different third party partners to supplement the Usage Information and other information we collect directly from you. For example, our partners may provide us with information such as employment or income data, vehicle or driver information, or information about special offers available based on your credit profile so that we can give you more personalized recommendations. We might also collect information from other users like you through things like a member referral program.

Use of Your Data

We use the information we collect from you and third parties to operate our Services, communicate with you, conduct research and development to improve or enhance our Services and our users' experience, and promote our Services. These are a few examples:

To create your account and provide the Services to you. We use the information we collect to create and secure your account, create and maintain your account, and to provide the Services to you.

To provide features to you, such as your credit score and profile. We use the information we collect to provide you with credit profile analysis and simulation for, credit score display and monitoring, rent payment reporting to credit bureaus for and full credit report purchase. The information we collect also goes into developing and bringing you various other features and personalized offer recommendations.

To improve our recommendations and insights. The information we collect also helps us tailor our content and improve the way we match you to recommended offers or insights.

To communicate with you, either directly or through our partners. We use information we collect to provide you with member support or to send you things like service-related announcements, recommendations, offers from our partners and other updates or promotions. Most of the time we'll communicate with you by email, but we may also send you push notifications, browser notifications, or physical mail.

To conduct research and to improve and promote our services. We use the information we collect to conduct research and to improve or enhance and promote our Services.

For legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to:

Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law;

Enforce our Terms of Service, including investigating any potential violations;

Protect the safety, integrity, rights or security of our members, our Services or equipment, or any third party; or

Detect, prevent or otherwise address fraud, security or technical issues related to our Services or our partners.

Disclosure of Your Personal Data

We do not share your credit reports or scores with unaffiliated third parties (except agents acting on our behalf, as explained below).

We do not sell your Personal Information to or share your Personal Information with unaffiliated third parties for their own advertising or marketing purposes.

We may share information about you, including Personal Information, with third parties in a variety of ways, such as:

Agents acting on our behalf. We may share information about you with service providers or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Policy and our Terms of Service. This includes things like designing or operating features, helping us research and test feature improvements, identifying offers or personalized recommendations, performing analytics and marketing our Services. These third parties are acting on our behalf so while they may have access to your information, including things like your credit reports and scores, they're required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them.

When we collaborate with third parties to provide and improve our Services. We may sometimes share information about you with third parties we collaborate with in connection with providing or improving our Services. We may also share information like the feedback you submit to us if it relates to both our Services and a partner's products. When we share information with third party collaborators, they are also obligated to not share your credit reports or scores with unaffiliated third parties or sell your Personal Information to unaffiliated third parties for their own advertising or marketing purposes. Our third party collaborators may use the information in connection with their own activities to the extent allowed under their own privacy practices (e.g., respond to your feedback, conduct additional research, or improve a feature of theirs).

Our partners when you ask for their services. We may also give you opportunities to interact with third party partners through our Services, such as when we provide you with the opportunity to review and send your personal information to a partner in order to pre-populate your application on the partner's site or we send you to the partner's site for you to provide the information directly to them. In some cases, if you click through to go to a partner's site, you will automatically be sending your personal information to that partner. When this happens, you will still have to submit your application on the partner's site. Any information you provide to the partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.

When you publicly post the information. As part of our Services, we may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include Personal Information and portions of your account designated as public profile information, like your name or user name. Anything you share in a public forum is public.

As Part of a Corporate Change. We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets. If such a business transfer results in a material change in the treatment of your Personal Information, you will be notified by e-mail (using the primary email address on your account) or by a prominent notice on our site.

For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes.

With Your Consent. There may also be other limited contexts in which we share specific types of personal information with your express consent.

We may also share with third parties de-identified or aggregated data we collect, such as de-identified or aggregated credit reports or scores, de-identified demographic information, or information about the computer or device from which you access the Service. We share such information for a variety of purposes, including to analyze Service usage, develop shared services, and improve our own products and features.

Third Parties

Links to Third Party Websites

The Services may link to websites operated by third parties that we do not control. Our provision of such links is for your convenience and does not signify our endorsement of such other website or location or its products, services, or contents. When you click on such a link, you will leave our site and go to another site. During this process, any Personal Data submitted by you to any of those sites is governed by their privacy statements. We encourage you to carefully read the privacy statement of any websites you visit. Please be aware that the terms of this Privacy Policy do not apply to these outside websites, or to any collection of data after you click on links to such outside websites.

Security of Your Personal Data

LevelCredit is committed to protecting the security of your Personal Data. We use a variety of industry-standard physical, electronic, and procedural safeguards to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. We also encourage you to change your password frequently. We specifically do not store your bank account login credentials, and you will need to reconnect through Plaid from time to time in order to maintain your connection.

From the time you login to our Site, communications between your computer and our Site are encrypted using secure socket layer (SSL) technology. We also use SSL to communicate with our Third Party Service Providers. While LevelCredit uses these and other reasonable efforts to protect your Personal Data, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, LevelCredit cannot guarantee absolute security of your Personal Data.

Communications Preferences

You can manage your communications preferences by visiting your account profile. We also include "unsubscribe" instructions in marketing emails. You may also have the ability to adjust app- or browser-specific communications settings (e.g., for things like push or browser notifications) within the settings screen of your mobile app or browser.

Our Interest-Based Advertisement Practices

Advertising Service Providers

Some of our third-party service providers or partners are advertising networks, marketing partners, publishers and other entities who perform analytics and advertise our products and services on websites not affiliated with us ("Advertising Service Providers"). In connection with these advertising services, we or our Advertising Service Providers may use cookies, web beacons, and similar technologies to collect behavioral information about how you use our site or other websites in order to perform tracking and marketing analytics or serve advertisements that are more likely to be of interest to you ("Interest-Based Advertisements"). Our Advertising Service Providers may permit you to opt out of all or some Interest-Based Advertisements on designated websites.

Contact Information

LevelCredit welcomes your comments or questions regarding this Privacy Policy. Please email us at info@LevelCredit.com or contact us at the following address: RentTrack Inc. Attn: LevelCredit Customer Service 4601 Excelsior Blvd #503, St. Louis Park, MN 55416.

Correcting and Updating Your Personal Information

To review and update your personal information to ensure it is accurate, contact us by email.

Changes to This Privacy Policy

This privacy policy may be modified from time to time to comply with applicable laws or to conform to our current business practices. If we substantially modify this privacy policy, we will notify you by sending you an email and/or by prominently posting notice of the changes on our Site. We encourage you to revisit the Privacy Statement that is posted on our web site from time to time to check for updates. This Privacy Policy was last revised on March 18, 2019.

California Privacy Disclosures

This Privacy Notice for California Residents below supplements the information contained in LevelCredit's Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (" personal information"). In particular, LevelCredit's website or platform has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

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.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A 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.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA's scope, like:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

LevelCredit obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.

  • Indirectly from you. For example, from observing your actions on our Website.

  • Customer Relationship Management platforms.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information.

  • To create, maintain, customize, and secure your account with us.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of LevelCredit's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by LevelCredit about our Website users is among the assets transferred.

LevelCredit will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

LevelCredit may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.

  • Data aggregators.

  • Customer Relationship Management platforms.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

  • Customer Relationship Management platforms.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information/has sold the following categories of personal information:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

  • Customer Relationship Management platforms.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that LevelCredit disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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.

  • Our business or commercial purpose for collecting or selling that personal information.

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

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchased; and

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that LevelCredit delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at (866) 841 - 9090

  • Email: help@levelcredit.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically a CSV file.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by:

Email: help@levelcredit.com

Telephone: (866) 841 - 9090

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:

Email: help@levelcredit.com

Telephone: (866) 841 - 9090

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

LOYALTY PROGRAMS: However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to help@levelcredit.com or call us at: (866) 841 - 9090

Changes to Our Privacy Notice

LevelCredit reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes .

Contact Information

If you have any questions or comments about this notice, the ways in which LevelCredit collects and uses your information described below your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (866) 841 - 9090

Website: www.levelcredit.com

Email: help@levelcredit.com

Postal Address:

LevelCredit
Attn Data Access CCPA Request
4601 Excelsior Blvd #503
St. Louis Park, MN 55416