Borrower Privacy Policy

Scratch Financial, Inc. Privacy Policy

Effective Date: Dec 20, 2024

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAYS SCRATCH FINANCIAL, INC. AND ANY OF OUR AFFILIATES ("Company", "we", "us", "our") COLLECT, PROTECT, USE AND STORE YOUR PERSONAL INFORMATION. YOU ACCEPT THIS PRIVACY POLICY BY USING 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. The revised version will be effective as of the “Effective Date” posted at the top of the policy. If we make material changes, we may notify you either by posting a notice of such changes, by directly sending you a notification, or as otherwise required by law. We encourage you to review this Privacy Policy frequently for any revisions or amendments.

1. How Scratch Financial collects your information

We collect information about you as follows:

1.1. Information you give Scratch Financial

If you open an account through the Services or otherwise use the Services, either directly or through a Merchant Partner or a third-party platform, we may collect the following types of information directly from you:

Name
User name
Phone number
Date of birth
Address
Email address
Social security number
Driver’s license and/or passport number or similar identification
Geolocation
Products or services you are interested in
Account numbers
Third-party application IDs
Professional or employment-related information
Any other information you may provide to us

We may also collect your 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 that you give us when you use the Services.

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 as required by law. We may collect your photographic or video image, or similar information, when you visit our offices. 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.

We may also collect information about you from any contact you have with us such as with our customer support team or in surveys, or through interactions with our affiliates.

1.2. Information Scratch Financial collects automatically

When you visit the Scratch Financial website or use the Services, we may automatically collect information sent to us by your computer, mobile phone or any other device. This information may include your IP address; online identifiers; 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, and cookies that may uniquely identify your browser or your account.

In some cases, we may collect click or touch stream data, movement, scroll, keystroke activity and third-party sites or services you were using before and after interacting with the Services.

We may also collect your general geographic location based on IP address when you use the Services

1.3. Cookies and other tracking technologies

When you use the Services, we collect and store the information described above using various tracking technologies, including cookies, clear gifs, web beacons, and tracking pixels. Our mobile applications may use software development kits (“SDKs”) to help us understand how you interact with the applications and collect certain information about the device and network you use to access the application. We may use tracking technologies in the emails we send you. 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, and remembering your preferences.

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. We also use Google Analytics for analytics purpose. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.

Personalized advertising: Delivering tailored advertising based on your preferences or interests across services and devices, tracking the number of times you have been shown an advertisement, and measuring the effectiveness of advertisements. If you are interested in more information about personalized advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

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. Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control browser choice referenced below.

1.4. Information obtained from third parties

We may also obtain information about you from third parties such as credit bureaus and identity verification services.

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.

How Scratch Financial protects your information

Scratch Financial utilizes a combination of physical, technical, and organizational security measures designed to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, the Internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by Scratch Financial in connection with the Services or any other service offered by Scratch Financial. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.

2. How Scratch Financial uses your information

We or our vendors use your information for various business and operational purposes depending on the types of information we have collected from and about you and the specific Service you use, including as follows:

Provide the Services or complete a transaction
Respond to your request for information and provide you with more effective and efficient customer service
Provide you with updates and information about products available through the Services
Contact you by email, postal mail, or phone regarding Scratch Financial and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
Customize advertising and content on the Services
Help us better understand your interests and needs, and improve the Services
Engage in analysis, research, and reports regarding use of the Services
Allow us and our advertising partners to personalize content and advertising that you may see on the Services and on third-party platforms
Provide, manage, and improve the Services and its performance, and test and create new products, features, and services
Secure our websites, products, software, or applications
Understand and resolve app crashes and other issues being reported
Comply with any applicable legal obligations and establish, exercise, or defend our legal rights
Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or the Services
Prevent fraud, unauthorized access/use of the Services, breaches of terms and policies, or other wrongful behavior
As required or permitted by law
As otherwise described to you at the point of collection

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the AI Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy

Aggregate/Anonymous Data. We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data with any third parties, including advertisers, promotional partners, and sponsors.

3. How Scratch Financial discloses your information.

3.1. For our everyday business purposes

We disclose 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..

3.2. 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, to combat fraud or criminal activity, when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Scratch Financial, our users and partners, or the public; and to enforce our agreements and policies.

3.3. With our merchant partners

We may share our final decision on your Scratch Pay loan approval with merchants you interact with using the Services. We will only share whether you were approved or declined and, if applicable, that you are eligible to use Scratch Pay to pay for additional services in the future. If you are approved, we may share the loan amount with the merchants you interact with using the Services.

3.4. In connection with a merger, sale, financing, or other business transaction

We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Scratch Financial, financing of Scratch Financial, public stock offerings, the sale of unrecoverable loans, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Scratch Financial as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

3.5. With your consent

We may also disclose your information to any third parties based on your permission to do so.

3.6. Mobile phone numbers

We will not sell or share your mobile phone number or consent with third parties for their promotional or marketing purposes

4. Data Retention

We will retain your information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Policy. We also store information when necessary to comply with contractual and legal obligations, when we have a legitimate interest to do so (such as improving and developing the Services, and enhancing the safety, security, and stability of the Services). We may also store your information in order to defend or ascertain our legal rights, respond to valid legal requests, in the context of a merger/acquisition or in order to implement our Terms or our other agreements with you.

In addition to the purposes, we may consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data, in determining how long to retain personal data.

5. What are your options?

5.1 Notifications

If you no longer wish to receive marketing notifications from us, 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. Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

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. 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 and edit your information

You can review and edit certain of 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.

6. What are your rights?

If you are a resident of certain jurisdictions, you may have various rights regarding your information. If these rights apply to you, they may permit you to request that we:

confirm whether or not we are processing your information and provide access to and/or a copy of certain information we hold about you;
correct information which is incorrect;
delete certain information which we are holding about you

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests, such as public information or information covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act or the Fair Credit Reporting Act.

To exercise any of these rights, please click here: https://scratchpay.com/legal/ccpa-dsar-form. You can also contact us at [email protected] or at (855) 727-2395. We may request that you provide us with information necessary to verify your identity before responding to your request as required or permitted by applicable law, such as personal identifiers we can match against information we may have collected from you previously. We may also ask you to confirm your request using the email address or telephone account stated in the request.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. This can be emailed to [email protected]. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request. To do so, contact us at [email protected] and describe in detail why you believe the denial was in error. Your description must include your full name and the email address to obtain the Services from us, along with a copy of the denial notice you received from us.

Opting Out of Sales of Personal Information or Targeted Advertising. You may also have the right to opt out of the “sales” of personal information and targeted advertising, as those terms are defined under applicable law. For more information on “sales” and targeted advertising, please see the “Sharing” and “Selling” Information” section below. To opt out of such sales and targeted advertising, please contact us at [email protected] or at (855) 727-2395.

7. State Privacy Laws

Some state laws, such as the California Consumer Privacy Act, provide certain rights to their residents concerning non-financial related personal information, including the rights to access and delete such information, unless an exception applies. These state laws do not apply to information subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and the Fair Credit Reporting Act (“FCRA”), except in some states in the event of a data breach. They also do not apply to information that cannot be associated or reasonably linked with a particular consumer or household. As a financial services platform, all of the information Scratch Financial collects and shares is subject to GLBA and FCRA or cannot be associated or reasonably linked with a particular consumer or household. Scratch Financial is thereby exempt with respect to requirements related to accessing and deleting personal information as well as certain other rights under these laws.

8. Contact Scratch Financial

If you have questions or concerns regarding this Privacy Policy, you should contact us at [email protected].