Borrower Privacy Policy

Scratch Financial, Inc. Privacy Policy

Effective Date: March 9, 2022

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAYS SCRATCH FINANCIAL, INC. AND ANY OF OUR AFFILIATES ("Company", "we", "us", "our") OR OUR VENDORS COLLECT, PROTECT, USE AND STORE YOUR PERSONAL INFORMATION. YOU ACCEPT THIS PRIVACY POLICY BY USING OUR PRODUCTS AND SERVICES ON OUR WEBSITE, OUR MOBILE APP, SOCIAL MEDIA SITES OR PAGES OR THROUGH ANY OTHER MEANS (COLLECTIVELY THE "SERVICES"). We may amend this Privacy Policy at any time by posting a revised version on our website. We will attempt to give a reasonable notice period upon making any changes; however, unless otherwise stated, the revised version will be effective at the time we post it.

1. How Scratch Financial collects your information

1.1. Overview

Company will only gather personally identifiable information through lawful means. Company limits the collection of personal information to what is relevant and necessary to accomplish a lawful purpose. For example, we may need to know someone’s name, address, and/or telephone number, among other things, to properly contact people with whom we work with.

The purposes for which personally identifiable data is collected shall be specified prior to the time of collection. Any subsequent use of the information is limited to purposes not inconsistent with the purpose(s) given at the time of collection. Company shall maintain in its records only personal information that is relevant and necessary to accomplish a purpose of Company required or authorized by the California Constitution, statute, regulation, or mandated by the federal government.

Personal identifiable data will not be disclosed, made available, or otherwise used by Company for purposes other than those specified, except with the consent of the subject of the data, or as required by law or regulation.

Personally identifiable data collected shall be relevant to the purpose for which it is needed. Company shall maintain in its records only personal information that is relevant and necessary to accomplish a purpose of the agency required or authorized by the California Constitution, statute, regulation, or mandated by the federal government.

The Company’s efforts to require that any third-party with which the Company shares user data will provide the same or equal protection of user data as stated in the app’s privacy policy and the App store guidelines. You can revoke consent and/or request the deletion of the your data per Section 5 below.

1.2. Information you give Scratch Financial

If you open an account or use the Scratch Financial Services, either directly or through a merchant partner or a third-party platform, we may collect the following types of information:

Personal information - your name, user name, phone number, date of birth, address, online identifiers, email address, social security number, drivers license and/or passport number or similar identification, internet protocol address, geolocation, similar identifiers, products or services obtained or considered, account numbers, third-party application IDs, and other similar information - information regarding your interaction with our website including from Cookies, professional or employment-related information, and publicly available information.

Financial information - income, bank account online login information, bank account numbers, bank account details including transaction history, routing numbers and/or debit card numbers and credit card numbers that you link to your Scratch Financial account or you give us when you use the Services.

Before permitting you to use the Services, we may require you to provide certain information, including but not limited to your date of birth, social security number. We may use this information or other information you provide to verify your identity.

If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect your photographic or video image, or similar information. We use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.

We collect information about your current employer and your employment history. We use this information to conduct background and other screening activities, and to promote our services to others.

1.3. Information Scratch Financial learns from your use

When you visit the Scratch Financial website or use the Services, we may collect information sent to us by your computer, mobile phone or any other device. This information may include your IP address, device information including but not limited to identifier, name and type, operating system, location, mobile network information and standard web log information, such as your browser type, traffic to and from our site, the pages you accessed on our website, and any other available information. We may also collect information about your use and interaction with our website, application or the Services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account. We may also collect information about you from any contact you have with any of our services or employees, such as, with our customer support team, in surveys, or through interactions with our affiliates.

1.4. Cookies and other tracking technologies

We use various technologies to collect and store information when you use the Services, and this may include sending one or more cookies or device identifiers. We also use these tracking technologies when you interact with the services we offer to our partners, such as advertising services or Scratch Financial features that may appear on other sites and in any other manner that we deem necessary for our business purposes, such as:

Site operations: Enabling features that are necessary for providing you the Services on our site, such as identifying you as being signed in, tracking content views, remembering your preferences, and the number of times you have been shown an advertisement.

Analytics: Allowing us to understand how our Services are being used, track site performance, and make improvements. One such technology we use is the use of Hotjar cookies, which provides a session replay-like service.

Personalized advertising: Delivering tailored advertising based on your preferences or interests across services and devices, and measuring the effectiveness of advertisements. You can learn more about ad-serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from other companies that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. Note that if you delete your cookies, you may also delete your opt-out preferences.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://allaboutdnt.com.

1.5. Information obtained from third parties

We may also obtain information about you from third parties such as credit bureaus and identity verification services. If you apply for a loan or line of credit with Scratch Financial, we will obtain your permission to use consumer reports from consumer reporting agencies related to you at the time of your collection and periodically throughout the term of your loan or line of credit, as well as in connection with the use of any other services that we offer or that you may obtain from us (including financial management services, credit profile tools, and the Scratch Financial marketplace).

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third party with your Scratch Financial account and authorizing Scratch Financial to have access to this information, you agree that Scratch Financial may collect, store and use this information in accordance with this Privacy Policy.

2. How Scratch Financial protects your information

2.1. Safety policies

The general means by which personally identifiable data is protected against loss, unauthorized access, use, modification, or disclosure includes, but is not limited to, taking reasonable precautions to protect the personal identifiable information on individuals collected or maintained by Company against loss, unauthorized access, and illegal use or disclosure. Company staff is trained on procedures for the handling of information and access to such information is limited to those staff whose work requires it.

Scratch Financial stores and processes your information maintaining physical, electronic and procedural safeguards.

3. How Scratch Financial uses your information

3.1. To improve our service and meet regulatory/legal requirements

Scratch Financial uses information to perform and improve our services, contact you, conduct research, and provide anonymous reporting for clients. For example, we may use information to provide customer service and support, process transactions, resolve disputes, collect payments, prevent illegal activities, customize the Services, reduce risk to all parties involved in our transactions, and verify the accuracy of information. We use your data in a compliant manner to meet regulatory and legal requirements.

3.2. To serve relevant marketing to you

We may use data to deliver targeted marketing, service update notices,and promotional offers based on your communication preferences. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.

4. How Scratch Financial shares your information.

4.1. For our everyday business purposes

We share your personal information with employees, affiliates, vendors, partners, merchant partners, marketing providers, and third parties as required to offer the Scratch Financial Services. This includes, but is not limited to, sharing data in connection with a business transaction or with professional advisors, processing transactions, maintaining your account, offering or servicing loans or lines of credit, offering other financial services, responding to court orders and legal investigations, litigation purposes, complying with audits or other investigations, and reporting to credit bureaus. We also engage the following types of service providers to perform functions on our behalf: marketing providers, billing and collection providers, auditing and accounting firms, professional services consultants, providers of analytics services, security vendors, and IT vendors. Occasionally, these service providers may also collect data directly from you and their privacy policies may also apply. Scratch Financial will not share your financial information collected under Section 1.1 of this Privacy Policy with any third party unless required by law or valid court order.

4.2. When we deem appropriate or where required by law

We will share your information with any party when required by law or by a government request to do so or to combat fraud or criminal activity.

4.3. With our merchant partners to provide personalized offers

We may share your information with merchants you interact with using Scratch Financial for marketing, if you consent or as permitted by law. For accounts created on or after 11/30/17: By creating an Scratch Financial account, you consent to Scratch Financial sharing your information with merchants you use the Scratch Financial Services with, for those merchants to market to you. We do this to help merchants personalize services and offers, so you can have a better experience. You're able to revoke your consent at any time by following the steps below. If you choose to do so, we will stop sharing your information with merchants from that point onward, except as necessary to complete transactions you initiate. To revoke your consent to information sharing with merchants for marketing, you can log into your Scratch Financial account at www.scratchpay.com and edit your Personalized Services preferences.

5. What are your options?

5.1 Notifications

If you no longer wish to receive notifications about our Services, you may change your notification preferences by emailing [email protected]. Alternatively, you may be able to indicate your preference by logging into your account and adjusting your preferences or by following the directions provided with the communication. Scratch Financial reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Scratch Financial Service. You are still responsible for any amounts due to Scratch Financial even if we close or limit access to your account.

5.2 SMS messaging

You can opt out of receiving SMS messages by emailing [email protected]. Alternatively, you may be able to indicate your preference by logging into your account and adjusting your preferences or by following the directions provided with the communication. Again, Scratch Financial reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Scratch Financial Service. You are still responsible for any amounts due to Scratch Financial even if we close or limit access to your account.

5.3 Access your information

You can review and edit your personal information at any time by logging in to your account or by contacting us at [email protected]. You can also request to close your account if you do not have an active loan by contacting us at [email protected]. If you close your Scratch Financial account, we will mark your account in our database as "Closed," but will keep your account information in our database to comply with our legal obligations. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or in accordance with this Privacy Policy.

6. California consumers

6.1 Your California privacy rights

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at [email protected] or by calling Customer Care at (855) 727-2395.

California Shine the Light Residents of the State of California have the right to request information from Scratch Financial regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies' direct marketing purposes. If you are a California resident and you have any queries or requests related to your rights under CCPA, please direct these to [email protected].

California Consumer Privacy Act (CCPA) The California Consumer Privacy Act ("CCPA") provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of "Personal Information," as well as the right to know/access, delete, and limit sharing of Personal Information. The CCPA defines "Personal Information" to mean "information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household."

Exceptions to the CCPA - Gramm-Leach Bliley Act (GLBA) Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to notice at collection regarding the categories of personal information collected - SEE SECTION 1.2 FOR THE INFORMATION COLLECTED

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

Personal identifiers

We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Services, respond to your requests, and send information and advertisements to you.
We collect payment information when you provide it to us, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction. We use this information to streamline and facilitate payments and transactions.
We may collect your Social Security number or Driver's License number and or passport. We use this information to identify you, authenticate an collate information about you, prevent fraud, and conduct background checks or other screening activities.
We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
We collect your Device ID automatically when you use our Services. We use this information to monitor your use, and the effectiveness of, our Services, to identify you, and to provide you with targeted information and offers.

Protected classifications

We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors.

Commercial information

When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements, and offers.

Internet or other electronic network activity information

We collect information about your browsing history, search history, interaction with websites, and applications or advertisements automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.

Geolocation data

As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device's IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates). If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.

Audio, electronic, visual, or similar information

Professional or employment-related information

We collect information about your current employer and your employment history. We use this information to conduct background and other screening activities, and to promote our services to others.

Inferences drawn to create a profile about a consumer reflecting the consumer's preferences or characteristics

We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Services, applications, and tools, and to provide you with targeted information, advertisements, and offers.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.

Right to know about personal information collected, disclosed, or sold

You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity.

Verification procedures

In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by:

Providing personal identifiers we can match against information we may have collected from you previously, and
Asking you to confirm your request using the email address or telephone account stated in the request.

If you have authorized someone else to make requests on your behalf, we will require that you provide notarized statements confirming the identity and authority of that person. Such notarized statements can be obtained by emailing [email protected].

Right to know/access information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers' Personal Information, we are required to verify your identify before we can act on your request.

Right to request deletion of information

Under certain circumstances, you have the right to request that we delete any “personal information” that we have collected directly from you. We are required to verify your identity before we can act on your request. We may have a reason under law why we do not have to comply with your request or why we may comply with it in a more limited way that you anticipated. If so, we will explain that to you in our response.

Right to opt out of sale of personal information to third parties

Scratch Financial does not sell Personal Information to third parties. Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function. We are also exempt from many CCPA and other state privacy laws under the GLBA exemption. We may also disclose information to other entities when required by law or to protect Scratch Financial or other persons, as described in our Privacy Policy. If you are a California resident and have any queries or requests relating to your rights under CCPA, please direct these to [email protected]. Or by calling us at (855) 727-2395.

Authorized agent

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.

Right of Non-Discrimination

We will not discriminate against you for exercising any of your rights in this Privacy Policy and under applicable laws.

7. Nevada residents

7.1 Special information for Nevada residents

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. Scratch Financial does not sell the Personal Information of its customers. However, if you are a Nevada resident and would like to make such a request, please email [email protected].

8. Contact Scratch Financial

8.1 Questions or complaints

If you have questions or concerns regarding this Privacy Policy, you should contact us at [email protected]. We take our obligations to protect your privacy seriously. If you have any questions about this Notice, please contact our Privacy Contact. If you believe your privacy rights have been violated, you may submit a complaint to us via our Privacy Contact at the number at the top of this form or the Secretary of the U.S. Department of Health and Human Services. You will not be penalized for filing a complaint.