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Effective Date: April 1, 2021
Last Revised: September 19, 2024
This ( “Online Privacy Policy”) describes how Chowder, Inc., its affiliates and subsidiaries (collectively “Chowder”, “we”, “our”, or “us”), collects, uses and shares your information at our Website, www.chowderfinancial.com (our “Website”). We take the privacy of our customers and visitors to our Website very seriously.
This Online Privacy Policy applies to information collected through our Website (defined in Section 2 below) but does not apply to information, including Personal Information, collected from third-party sources(such as consumer reporting agencies) or that you reveal or post in any public forum on our Website, Website that link to or from our Website, or any other Website.
Chowder owns the information we collect on the Website. This Website is intended for visitors located in the United States. This Website is governed solely by the federal and state laws in the United States. Information submitted to the Website is housed on servers located in the United States. You agree not to attempt to log on to the Website from any country under sanctions by the Office of Foreign Asset Control (“OFAC”). Which countries are under sanctions may be found on the United States Department of the Treasury website. Any attempt to log on to the Website from such a country may result in your access being restricted or terminated. Your use of the Website may be monitored, tracked, and recorded.
By using the Website, you agree to the terms of this Online Privacy Policy. If you do not agree to the terms of this Online Privacy Policy, do not use the Website. Furthermore, by using the Website, you agree to the application of United States law and consent to the use and disclosure of your information consistent with this Online Privacy Policy.
Chowder collects Personal Information and Non-Personally Identifiable Information (“NPI”).
Personal Information is any information that directly identifies an individual, such as an individual’s name, street or postal address, e-mail address, geolocation, financial and banking information (including bank account information and payment card data), social security number, government issued identification number, telephone number, or date of birth. Personal Information may also include details about devices used to access our Website such as IP address, browser information, device information, and operating system information. We may also collect information about the use of Website, social media presence, and internet-enabled services and platforms by automated means, such as cookies, web beacons, HTML5 localStorage, and other technologies.
Non-Personally Identifiable Information or NPI is any information about an individual or about categories of individuals that does not identify you individually. This may include your gender, income and benefits information, residence-related information such as lease and ownership information, payment history with us, and other information.
We may collect Personal Information from you in a variety of ways, such as when you seek to lease our products and when you apply for a lease or a lease amount at www.chowderfinancial.com. We may also collect Personal Information from or about you when you visit a website owned or operated by Chowder or on our behalf when you enroll in automatic payments, visit social media Website, or when you enter a promotion we offer. On occasion, we use third parties to provide us with Personal Information about you. For example, if we know your name and postal address, we may use a third-party to provide us with your email address. In addition to what is described below, we use this information for market analysis, marketing and other business purposes, including enforcement of contractual obligations. We may also collect Personal Information about you from consumer and/or credit reporting agencies or individuals we believe may be associated with you, among others. In addition to what is described below, we collect NPI through many sources, including from information that you and third parties provide to us.
Online Activities. When you visit our Website, we may collect information about your visit and store that information, which are records of the activities on our Website. Our servers automatically capture and save the information electronically. The information we collect helps us administer the Website, analyze usage, protect the Website and their content from inappropriate use, and improve the visitor’s experience. The information maybe used for marketing purposes and may uniquely distinguish your browser or computer from others’ devices. Examples of information that we may collect or that third parties may collect while you navigate our website include, but are not limited to:
Cookies. A cookie is a small data string that a web server stores on your computer or mobile device. (A web server is the computer that hosts a website and responds to requests received from your computer.) We may use cookies to store and help track information about you in order to offer and provide a good customer experience using on our Website. Among other things, cookies enable a website to maintain continuity when a visitor’s web browser requests a series of webpages. For example, without cookies, a website owner may not be able to recognize that a visitor just completed the first step during an online ordering process so that the second step can be presented.
Cookies also enable advertising, allowing web servers involved in advertising operations to recognize your browser as you navigate to other Website. Google’s Adwords technology may recognize a cookie that our Website have sent to your browser during a past visit and use the cookie information to show you ads for our products or similar products.
Most browsers are initially set up to accept browser cookies; however, you can manage browser cookies by using features and functions available on most Internet browsers. For example, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. You should understand that some features of many Website may not function properly if you block or don’t accept cookies.
Some website content is served by third parties. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Website and other online services.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Other Data Collection Technologies. Web beacons, pixel tags, .gif files, and the like, allow for the collection of information about your interactions on our Website. These technologies may be used to place advertisements, understand website traffic patterns and the number of visitors to our Website, and to measure the effectiveness of advertisements or our Website.
Social Networks and Widgets. Our Website also include social network or other third-party plug-ins and widgets that may provide information to their associated social networks or third-parties about our Website you visit, even if you do not click on or otherwise interact with the plug-in or widget and regardless of whether you have an account or other relationship with these social networks and third parties. Information is transmitted from your browser and may include an identifier assigned by the social network or third-party, information about your browser type, operating system, device type, IP address and the URL of the web page where the plug-in or widget appears. If you use social network tools or visit social networking Website, you should read their privacy policies, to learn what information they collect, use, and share.
Links to Other Websites. Chowder may establish on our Website links and pointers to Website that are operated and maintained by third parties (each, a “Third Party Site”). These links are provided solely as pointers to information on topics that may be useful to you. However, the establishment of any link to a Third-Party Site is not a recommendation or endorsement by Chowder of any products, services, information, goods, ideas or opinions that may be found on any Third-Party Site.
Chowder makes no warranties, either express or implied, concerning the content of any Third-Party Site, including the accuracy, completeness, reliability or suitability thereof for any particular purpose. Chowder does not warrant that any Third-Party Site is free from any claims of copyright, trademark or other infringement. Chowder does not warrant that any Third-Party Site is free from any viruses or other contamination.
You understand that Third-Party Sites may have a privacy policy that is different from that of Chowder and that Third-Party Sites may provide less security than this Site. The choice to access a Third-Party Site, or to purchase or otherwise use any of the products or services advertised or provided on a Third-Party Site is yours, in your sole discretion.
We use the Personal Information and NPI we collect from you for many purposes, including, but not limited to:
In addition to other sharing described in this section, we may disclose Personal Information and NPI: (a) in order to comply with laws or legal process, including subpoenas or agency orders and investigations which we determine are required under appropriate circumstances; (b) as we reasonably determine necessary or appropriate to protect property, our rights or the rights of others; and (c) to enforce our contracts, policies and customer agreements. We may also de-identify Personal Information that we receive from you or from third-parties so that it cannot be used to identify a specific individual and we may transfer or provide a copy of information covered by this Online Privacy Policy, including Personal Information, in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) of all or part of Chowder’s business or as part of a change in control.
Sharing With Corporate Entities and Third Parties. We may share Personal Information and NPI with our affiliates, subsidiaries, and service providers who provide services to us on or on our behalf and agree to only use as much information for the purpose for which it was provided and in accordance with this Online Privacy Policy. We may also provide Personal Information and NPI to credit bureaus, third parties collecting amounts owed to us, and third parties to whom we assign your account for collection purposes.
We may share the Personal Information with select third-party vendors, business partners, and other companies so that they can send you promotional materials about goods and services (including special offers and promotions) offered by them. After the information is provided to such third parties, the subsequent use or disclosure of such information is subject to those third-parties’ privacy policies and practices.
We may use services hosted by third parties to assist in providing our services and to help us understand our customers’ use of our products. A third-party service may collect information sent by your browser as part of a web page request, including, for example, your IP address, the third-party’s cookies, or any of the other categories of information itemized under Online Activities, above.
Chowder may use “interest-based” ads also known as “online behavioral advertising” or “OBA”. Online behavioral advertising is advertising that is directed to you based, at least in part, on your internet browsing behavior across the web. Although we do not share Personal Information with third parties that conduct advertising operations on our behalf, these third parties and their affiliates do collect certain information as a result of their “tags” being on our website. The information they collect includes the name (URL)of the web pages you view while on our site, your IP address, time of visit, information about your browser software, information about your device, and randomly assigned identifiers stored and/or transmitted using cookies or similar technologies, which they use to target and serve advertising.
We maintain administrative, technical, and physical safeguards intended to protect against the loss, misuse, alteration, and unauthorized access or disclosure of Personal Information and NPI, but we make no assurances about the safety and security of Personal Information or NPI.
We will keep Personal Information about you for as long as it is necessary to fulfill the purposes for which we process it, or if we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data. This may mean that we will retain some information about you for longer than other information. The criteria we use to determine data retention periods for personal data includes the following:
Personal Information is deleted and erased from Chowder’s servers and backups per business processes, as required by law, and upon consumer request.
This Online Privacy Policy maybe updated periodically to reflect relevant changes in our information practices. We will post a notice on our Website to inform you of significant changes to this Policy. We will also provide additional information regarding changes to this Online Privacy Policy as may be required by law. Your continued use of our Website following our posting of any such changes will mean that you accept such changes.
You may request that we correct, update or amend your Personal information we collect and maintain. To update us regarding changes in your Personal Information, please contact us as described below.
You may elect to opt-out of receipt of email and text communications from us by following the instructions provided in such communications or by contacting us as provided below. Even after opting out, you may still receive service oriented, non-promotional communications from us and promotional communications from other third parties as a result of their own interactions or transactions with you. Please allow time for us to process your request or contact us should you have any concerns about your opt-out request.
You can make decisions about your privacy and the ads you receive. As explained in Section4 above, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. Please note that if you decide to block cookies, some parts of our website may not function correctly.
You may also follow the steps provided by initiatives that educate users on how to set tracking preferences for most online advertising tools. These resources include the Network Advertising Initiative (https://thenai.org/about-online-advertising/) and the Digital Advertising Alliance (https://digitaladvertisingalliance.org/ ). The Digital Advertising Alliance also offers an application called AppChoices (https://youradchoices.com/appchoices ) that helps users to control interest-based advertising on mobile apps.
Residents of Colorado have certain additional rights with respect to their Personal Information, as described in our Supplemental Privacy Notice, which is listed below as Exhibit A.
Our Website are not directed to children under the age of 18, and we do not knowingly collect Personal Information from children under the age of 18 on these Website. In addition, Chowder does not sell any Personal Information of minors under 18 years of age.
Without prejudice to any other administrative or judicial remedy you might have, you may have the right under data protection legislation to lodge a complaint with the relevant federal and/or state data protection supervisory authority if you believe that we have infringed on applicable data protection legislation when processing Personal Information about you.
For further information or if you have any questions or queries about this Online Privacy Policy, please email us at info@chowderfinancial.com or call us toll free at 833-550-0505 Monday through Friday from 9am until 8pm Eastern or Saturday from 10am through 6pm Eastern.
Last Revised: September 19, 2024
This Supplemental Online Privacy Notice (“Supplemental Notice”) describes how Chowder, Inc., its affiliates and subsidiaries (collectively “Chowder”, “we”, “our”, or “us”), collects, uses and shares your information at our website, www.chowderfinancial.com(our “Website”).
This Supplemental Notice is parallel in scope to our Online Privacy Policy, but applies only to information collected about Colorado consumers. The Colorado Privacy Act of 2021 (the “CPA”).
Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.
This Supplemental Notice covers Personal Information, that is, information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:
Colorado residents have the right to request:
If you wish to exercise, or have any questions about, the above rights, please contact us by email at info@chowderfinancial.com or by using the information below.
Chowder, Inc.
8920 Eves Rd. #769479
Roswell, GA 30076
833-550-0505
In order to respond to your request, we will need to collect additional personal information from you in order to verify your identity and residency. The personal information that we use to verify your identity and residency will not be used for any other purpose. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. 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. You may also make a verifiable consumer request on behalf of your minor child, but please note that we do not have actual knowledge that we collect, disclose, or sell information regarding any minor under the age of 16. Your request must include sufficient detail to allow us to properly understand, evaluate, and respond to it. Making a verifiable consumer request does not require you to create an account with us.
Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We will try to comply with your request as soon as reasonably practicable. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of the reasons we are unable to honor your request.
We will not discriminate against you for exercising these rights.
We may use information we collect to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We obtain the categories of Personal Information listed below from the following categories of sources:
We collect the following categories of Personal Information from you and use those categories for the following purposes. The following table also lists, for each category, the retention period, whether or not we sell the category of Personal Information to third parties or share it for cross-context targeted advertising, and whether we disclose it for business purposes (like with our service providers).
Such as 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 similar identifiers.
Yes
To tailor our services to your particular needs.
To verify your identity.
To process transactions you initiate with us.
Maintain your account(s).
Respond to court orders and legal investigators.
Reporting to credit bureaus.
Seven years
YES, information may be shared with our affiliates, nonaffiliates, subsidiaries, and service providers.
YES, with our affiliates, nonaffiliates, subsidiaries, and service providers.
A name, signature, physical characteristics or description, address, telephone number, social security number, credit card number, debit card number, or any other financial or medical information.
Note to California Residents: These categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)
Yes
To tailor our services to your particular needs.
To verify your identity.
To process transactions you initiate with us.
Maintain your account(s).
Respond to court orders and legal investigators.
Report to credit bureaus.
Seven years
YES, information may be shared with our affiliates, nonaffiliates, subsidiaries, and service providers
YES, with our affiliates, nonaffiliates, subsidiaries, and service providers.
Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information).
No
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Yes
To verify homeownership
To process transactions you initiate with us. Maintain your account(s).
Three years
YES, information may be shared with our affiliates, nonaffiliates, subsidiaries, and service providers.
YES, with our affiliates, nonaffiliates, subsidiaries, and service providers.
Including 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
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Including browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Yes
For analytics purposes to helps us administer the Website, analyze usage, protect the Website and their content from inappropriate use, and improve the visitor’s experience.
One year
YES, information may be shared with our affiliates, nonaffiliates, subsidiaries, and service providers.
YES, with our affiliates, nonaffiliates, subsidiaries, and service providers.
Yes
For validation of homeownership and address.
Use, and improve the visitor’s experience.
One year
YES, information may be shared with our affiliates, nonaffiliates, subsidiaries, and service providers.
YES, with our affiliates, nonaffiliates, subsidiaries, and service providers.
Audio, electronic, visual, thermal, olfactory, or similar information.
Yes
Calls are recorded for quality assurance, training purposes, ACH authorizations, and complaint management.
Three years
NO
Not applicable
Information about your current employer, position, and other aspects of your professional history.
Yes
To validate source of income.
One year
YES, information may be shared with our affiliates, nonaffiliates, subsidiaries, and service providers.
YES, with our affiliates, nonaffiliates, subsidiaries, and service providers.
Information about the institutions you have attended or the level of education you have attained.
No
Not applicable
Not applicable
Not applicable
Not applicable
To create a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
No
Not applicable
Not applicable
Not applicable
Not applicable
If you live in Colorado, you have some additional rights:
If you wish to exercise, or have any questions about, the above rights, please contact us by email at info@chowderfinancial.com or by using the information below.
Chowder, Inc.
8920Eves Rd. #769479.
Roswell,GA 300076
833-550-0505
Feel free to reach out to us for more information or assistance.
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