PRIVACY POLICY

Effective/Updated as of March 26th, 2018

Jewish Free Loan Association and its affiliates and related entities (collectively, “we” or “JFLA”) are committed to protecting the privacy of certain data that is collected from you and that you submit when you access this web site or web sites under our operation and control (collectively, the “Site”). We recognize the sensitive nature of much of the information with which we are entrusted on a daily basis, and we are committed to high standards of privacy. The nature of our business requires that we gather and maintain information that is of a personal nature, whether it is financial or other information that you wish to keep protected. This Privacy Policy (“Policy”) is intended to familiarize you with our policies for the gathering, use, maintenance, and protection of private information on the Site. The examples given are intended to be for illustrative purposes only, and therefore, should not be considered a complete representation of our practices.

More specifically, this Policy summarizes how JFLA handles the personal and other information users of the Site provide while accessing and using the Site. Users of the Site include members of the general public.

BY ACCESSING AND/OR USING THIS SITE, YOU ARE INDICATING YOUR AGREEMENT TO THIS POLICY. Please review this Policy carefully. JFLA reserves the right to change its Policy at any time, in which event the Site will contain a notice of the change. Changes will be effective immediately upon posting to the Site. However, to the extent we receive your authorization or as permitted or required by applicable law, we will handle your personal information in accordance with the terms of the Policy in effect at the time of the collection. If you have any questions or concerns about the Policy, please call us at (323) 761-8830, send an e-mail to info@jfla.org, or contact us as provided below.

Information Collected. As you are probably aware, in the course of our relationship with you, we may collect information from a variety of sources to operate the Site, carry out our business, comply with law, and other purposes described herein.

We may compile statistical information concerning the usage of the Site. This information allows JFLA to monitor its utilization and continuously improve its quality. Examples of this information would include, but not be limited to, the number of visitors to the Site, or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site, etc. In order to compile this information, JFLA may collect and store your IP address, your operating system version, your browser version, the pages you visit within the Site, the length of time you spend on pages within the Site, the site from which you linked to ours, search terms you used in search engines which resulted in you linking to the Site, etc. While all of this information can be associated with the IP address your computer had while you visited the Site, other than information which we gather when you submit a form through the Site, it will not be associated with you as an individual, or associated with any other information you may submit through the Site, or that JFLA may store about you for any other purposes.

Most of our information comes directly from you. We also collect personal information such as: your name, participation in programs we offer or sponsor, etc. If you choose to complete the pre-loan application process through the site, this personal information can also include: income sources, income amounts, veteran status, expense data, as well as information related to the loans, products, or services you are interested in obtaining from us.

We may also collect information about you from third parties such as through your social media services consistent with your settings on such services, and from other third-party sources that are lawfully entitled to share your data with us. We use and share this information (and may add it to the other information we have on file for you) for the purposes described in this Policy.

Note that if you choose not to provide your personal information, we may be unable to provide the loans, products, services, information, or assistance you are seeking.

Cookies and Analytics. JFLA may use web site internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by- 1 GIFs) and “cookies.” We may deploy these tags/cookies though a third party partner who may be located and store the information in a foreign country. This technology, including cookies, may be sent to your computer or other device, in the process of compiling the statistical information mentioned above and to tailor certain pages of the Site for your browsing convenience. A cookie is a small data file that contains information such as the URL you came from, your computer’s IP address and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our Site that were viewed, and any search terms that you entered on our Site. This information generally is used for internal purposes. For example, we use cookies to improve the quality of our service when you visit our Site. We also use cookies to remind us of who you are, tailor our products, services and advertising to suit the personal interests of you and others, estimate our audience size, assist our vendors to track visits to our Site, and/or analyze your visiting patterns. We do not link your URL or IP address to any personal information unless you have logged into our Site with an established account login and password. A session cookie expires immediately when you end your session (i.e., close your browser). A persistent cookie stores information on the hard drive so when you end your session and return to the same web site at a later date the cookie information is still available. You may prevent or stop the installation and storage of cookies by your browser settings by downloading and installing the free Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout?hl=en (link is external). If you do that, our Site may not function correctly. Refer to the Help feature of your browser for information on disabling cookies.

If you would like more information about web tags and cookies associated with on-line advertising please
visit the Network Advertising Initiative website http://www.networkadvertising.org (link is external) or
http://www.allaboutcookies.org/.

We may use analytics services, such as provided by Google Analytics, to help generate statistics about our Site’s traffic, use, etc. for reports on our Site activity. The analytics services may transfer this information to third parties in case of a statutory obligation or if a third party processes data on behalf of that service. These analytics services will generate detailed statistics about a website’s traffic and traffic sources and measure interactions between you and the Site. Other than information which we gather when you submit a form through the Site, the information generated about your use of our Site, including your IP address, will be anonymized by use of the appropriate settings (“_anonymizelp()” function or equivalent). For more information on how IP anonymization works please see, for example, https://support.google.com/analytics/answer/2763052 (link is external).

IMPORTANT: By using the Site, you consent to the processing of any personal data for the analytics
purposes and functions described above.

Information of Children. The Site is not directed to children as the products and services on this Site are intended for persons 18 years of age and older. JFLA does not knowingly collect, use or disclose any personal information from children. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site.

Use of Information. In general, we will use the information we collect about you only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, as necessary to provide you with the services offered by us, and as otherwise provided in this Policy. For example, we may use your personal information to:

  • Provide you with the loans, products, services, information, or assistance you have sought or requested. This might include: establishing an on-line profile; contacting you; verifying your identity; checking your qualifications; to follow up with transactions initiated on the Site, including those initiation by your completion of the pre-loan application; or make improvements in the design and administration of the Site.
  • Market our loans, products, or services that we think may be of interest to you. For example, we may use your personal information to send you information and promotions using any communications preferences you have expressed. We use your information to send you marketing messages and to conduct surveys. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, and other means. With your consent, we also use user-generated content (such as photos) from social media services to deliver display advertising on our Site.
  • Ensure your information is accurate and to personalize our loans, products, and services. For example, we may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Policy

Disclosure of Information. In general, we will not disclose your personal information except with your consent and as described in this Policy unless otherwise permitted or required by law. We may disclose your personal information for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated entities, as we deem necessary to carry out those purposes. This includes the provision of financial and other related services and performing other functions of our business. For example, and without limitation, JFLA may need to use or disclose this information with its third party vendors to manage the Site; process requests for loans, products and services; provide you with loans, products, services, or offers; coordinate your participation in our programs; engage in marketing activities, such as sharing personal information with our partners to deliver advertisements to our shared customers; enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies; and protecting JFLA’s interests and legal rights, such as through responding to subpoenas and defending litigation. We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of personal information.

If you decide to provide personal information to us, in no case will JFLA sell or license personal information to third parties, except as required or permitted by law. For example, we may sell, assign or share personal information in connection with certain business transactions, such as the acquisition of all or substantially all of JFLA’s assets. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient agrees to provide privacy protections substantially similar to those established by this Policy.

Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.

Safeguarding of Information. No system for safeguarding personal or other information is 100% secure. However, we take a number of steps to safeguard the security of personal information obtained through the Site. For example, we use Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our Site. We have installed a firewall and other security technologies to help prevent unauthorized access to our systems. The data centers we are in are maintained in a secure environment with appropriate security measures. When you donate to JFL via the Site, your donation information is encrypted and transmitted by way of a secure connection. Our employees are trained to understand the importance of confidentiality and are required to adhere to our privacy policies and procedures. Employees who violate these policies and procedures are subject to disciplinary action. We employ numerous practices to protect against the disclosure of information for purposes unrelated to the performance of our business functions or to individuals other than those who must use it in the course of their work activities. These practices include the use of password protection of computer files, e-mail and voice-mail, video surveillance, and other physical, electronic, and procedural safeguards.

Links to Third Party Sites. The Site may contain links to other web sites ("Linked Sites"). The Linked Sites are not under the control of JFLA and JFLA is not responsible for the contents of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site. JFLA is not responsible for webcasting or any other form of transmission received from any Linked Site. JFLA is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by JFLA of the site or any association with its operators.

Retention. We retain your personal information only for the period of time needed to fulfill the purposes stated in this Policy.

For information you provide when completing the pre-loan application through this Site, JFLA may retain your information as long as necessary and appropriate to comply with applicable legal standards. Once the information is submitted, you cannot later delete this information. This information may be transferred into credit and application processing system and used to manage your loan, may become part of your file and may be used for other loan or credit related purposes. Your information will be destroyed in accordance with JFLA’s record retention policy.

Applicable law. This Policy is governed by the internal substantive laws of California, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within California. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

UNDER NO CIRCUMSTANCES SHALL JFLA HAVE ANY LIABILITY WHATSOEVER FOR ANY ERRORS OR OMISSIONS IN INFORMATION ON THE SITE, OR FOR ANY DAMAGES, LOSSES, OR EXPENSES THAT MAY OCCUR WHILE ACCESSING THE SITE, OR ANY LINKED SITE, OR THE INABILITY TO ACCESS THESE SITES; OR ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE; OR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT OR SPECIAL DAMAGES ARISING OUT OF THE BREACH OF THIS PRIVACY POLICY, HOWEVER OCCASIONED.

Contact Us. If you have any questions regarding this Policy or our policies in the event of a compromise
of your information, you may contact us at:

Jewish Free Loan Association
6505 Wilshire Blvd., Suite 715
Los Angeles, CA 90048
(323) 761-8830
info@jfla.org

If you have any technical questions regarding our website, please contact webmaster@jfla.org.

Updates and Changes. We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.

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