Privacy Policy

Introduction

Jewish Free Loan Association (“JFLA”, or “We”) respects your privacy and is committed to protecting it through our compliance with this policy (the “Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you (i) use services or features, or otherwise engage with, the JFLA website located at www.jfla.org (the “Website”), (ii) download, install, access, or use the JFLA mobile application (the “App”), (the “Website” and “App” together, the “Platform”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect about you:

  • Through the Platform;
  • Through email, text, and other electronic communications between you and the Platform, including via third party electronic messaging platforms;
  • For the purpose of registering with or creating an account on the Platform; and
  • When you interact with the Platform through third-party websites and services.

It does not apply to information collected by:

  • Any other means, including through any other application or website operated by JFLA or any third party; or
  • Any third party, including through any application or content that may link to or be accessible from or through the Platform.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, please do not access or use the Platform. By accessing or using the Platform, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Access to and use of the Platform is governed by our Terms of Service, which are available at Terms of Service. The Terms of Service are hereby incorporated by reference into this Privacy Policy. Please review the terms of this Privacy Policy and our Terms of Service carefully.

In the event of any inconsistency between the statements made in this Privacy Policy and our Terms of Service as it relates to the subject matter of the Terms of Service, the terms of the Terms of Service take precedence over this Privacy Policy. All terms defined in this Privacy Policy and Terms of Service shall have the meaning ascribed to them in the respective document and, if such term is not defined in the relevant document, it shall be ascribed the meaning given to it in this Privacy Policy or the Terms of Service, as applicable.

Information We Collect About You and How We Collect It

We may collect certain types of information from and about users of the Platform, including information:

  • By which you may be personally identified (“personal information”), including your name, location, employer, residential and workplace address, email address, and telephone or cell phone number;
  • Sensitive personal information (“SPI”), such as your Social Security Number, marital status, driver’s license, demographic information, and a description of your finances and salary, including paystubs and tax returns;
  • Regarding your income and property, including paystubs, tax returns, utility bills, mortgage or rental agreements, and payment history;
  • Provided to us by your employer, personal references, or guarantors;
  • That is about you but individually does not identify you; and
  • About your internet connection, the equipment you use to access the Platform, and usage details.

We collect this information:

  • From you when you provide it to us or a third party working on our behalf through the Platform or through other means, including in person or via telephone;
  • From the guarantors or personal references you provide to us; and
  • Automatically as you navigate through the Platform.

Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

Information You Provide to Us

The information we collect on or through the Platform or as otherwise described in this Privacy Policy may include:

  • Information that you provide by filling in forms on the Platform. This includes information provided at the time of registering to use the Platform, when submitting loan applications, making donations, or participating in surveys. We may also ask you for information when you report a problem with the Platform;
  • Information that you provide to us or a third party working on our behalf outside the Platform, including in person or via telephone;
  • Records and copies of your correspondence (including email addresses), if you contact us;
  • Information about your spouse, civil partner, and other individuals you include in your loan application as personal references or guarantors (“Third Party Personal Information”);
  • Testimonials you provide to us about your experience using the Platform or otherwise interacting with us (the “Testimonials”); and
  • Your responses to surveys that we might ask you to complete for research purposes.

You agree that you will obtain consent from the relevant third party prior to providing to us or inputting to the Platform any Third Party Personal Information.

Information We Collect Through Automatic Data Collection Technologies

We may use certain technologies for automatic data collection in connection with the Platform, including:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Platform.

Web Beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit JFLA, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Consent to Obtain Information from Third Parties

You hereby authorize us to contact third parties to verify any information you provide us, including personal references, guarantors, your employer, credit reporting agencies and credit bureaus, and other third parties. We will treat information provided to us by such third parties only in accordance with the terms of this Privacy Policy, or as otherwise permitted under applicable law.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present the Platform and its contents to you and to enable your use of the Platform;
  • To provide you with information that you request from us;
  • To make decisions on your loan application;
  • To process credit and background checks with the relevant third parties;
  • To administer, service, or collect any loan;
  • To fulfill any other purpose for which you provide the information;
  • To contact you (including via email and phone) with general information about our initiatives, marketing campaigns, surveys or other promotional activities;
  • To notify you about changes to the Platform;
  • To comply with applicable law or court orders and to exercise or defend our legal rights or the rights of others;
  • In any other way we may describe when you provide the information; and
  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We will not sell your personal information or SPI to third parties. We may disclose personal information or SPI that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates;
  • With credit reporting agencies, credit bureaus, social service agency, and other financial regulatory bodies;
  • With third party marketing consultants we have retained in order for such third party marketing consultants to contact you regarding your participation in anonymized studies. You are under no obligation to participate in such marketing studies, and your personal information will not be used for purposes of cross-context behavioral advertising;
  • To any employers or other supervisory entities with which you are affiliated that require, permit, oversee, or supervise your use of the Platform;
  • To governmental and nonprofit entities with which we coordinate in connection with deployment of the Platform;
  • To contractors, service providers, and other third parties we use to support us and the Platform and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of JFLA’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by JFLA about the Platform users is among the assets transferred;
  • To fulfill the purpose for which you provide the information;
  • For any other purpose disclosed by us when you provide the information;
  • With your consent;
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce or apply our Terms of Service, available at Terms of Service; or
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of JFLA, our partners, affiliates, personnel, or others.

Aggregated or pseudonymized data that does not directly identify you may be shared with third parties for educational, informational, or promotional purposes.

Retention of Your Information

We will only keep your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, according to this Privacy Policy and our internal policies. Such policies take into account relevant legal and regulatory retention requirements (e.g., tax, audit, or legal compliance requirements) and operational considerations. Certain information, like personal information of JFLA loan applicants, may be kept indefinitely for data integrity and fraud prevention purposes. We reserve the right to retain indefinitely data that does not directly identify you, for example, aggregated or anonymized data.

Accessing and Correcting Your Information

You can review and change certain of your personal information by logging into the Platform and visiting your account profile page. There may be some information that you provide to us or input to the Platform that you may change only by contacting us at info@jfla.org.

You may also send us an email at info@jfla.org to request access to, correction or deletion of any personal information that you have provided to us. We may not be able to accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement, breach an existing contract, cause the information to be incorrect, or if retention of such information is necessary for record keeping, operating the Platform, or the performance and delivery of JFLA’s services.

We will not discriminate against you in any way as a result of the exercise of your rights under this Privacy Policy.

Data Security

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password, as applicable, with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

Changes to Our Privacy Policy

If we make material changes to this Privacy Policy or how we treat our users’ personal information, we will notify you through a notice sent via the Platform. The date this Privacy Policy was last revised is identified at the top of this Privacy Policy.

Language

This Privacy Policy is drafted in both the English and Spanish languages. The Spanish-language version is a courtesy translation provided for reference purposes only, and has no legal or binding effect. Only the terms and conditions of this Privacy Policy drafted in the English language govern such Privacy Policy.

Contact Information

To make any privacy requests or to ask any questions about this Privacy Policy or our privacy practices, please contact us at: info@jfla.org.

JFLA Assistant