Privacy Policy
ARRA FINANCE, LLC ONLINE PRIVACY POLICY AND CONSUMER PRIVACY NOTICE
This notice is effective as of October 1, 2024.
1. INTRODUCTION
This Online Privacy Policy (“Privacy Policy”) explains the policy of Arra Finance, LLC (collectively referred to as "Arra Finance", "we", or "us") concerning how we collect, use, share, and protect information that relates to you (“personal information” or “personal data”). This Privacy Policy applies to personal information that is collected and processed by us in the course of your online and offline interactions with us (i.e., using this website and/or our services).
We respect privacy and are committed to protecting your personal information. This Privacy Policy also describes your privacy rights and how the law protects consumers.
It is important that you read this Privacy Policy carefully. By using our website and services, you accept the terms of this Privacy Policy, our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy.
Our website and services are not intended for use by minors (children under the age of 18) and we do not knowingly collect data relating to children.
2. SCOPE
If you are a California resident, this Privacy Policy is adopted to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“collectively, the “CCPA”). Also, please see section 11. ADDITIONAL DISCLOSURES AND RIGHTS FOR CALIFORNIA RESIDENTS.
If you are an individual who has obtained a financial product or service through us, this Privacy Policy also includes references and a link to our Privacy Notice which describes how we collect, use, and share non-public personal information about you in accordance with the federal Gramm-Leach-Bliley Act (“GLBA”), the federal Fair Credit Reporting Act (“FCRA”) and applicable state privacy laws. Information subject to our Privacy Notice is referred to as Non-Public Personal Information.
3. IMPORTANT INFORMATION & WHO WE ARE
Contact Details
Arra Finance, LLC
Attn: Data Privacy Compliance Team
P.O. Box 631250, Irving, Texas 75063
Email address: privacy@ArraFinance.com
Toll-free phone: +1 (833) 203-2002
Notification of Changes. This Privacy Policy may be updated from time to time and without prior notice to you to reflect changes in our personal information practices. We will provide the updated policy on this website, so you are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change. Please keep us informed if your personal data changes during your relationship with us. We realize that it is important that the personal data we hold about you is accurate and current.
Third-Party Links. Our website and services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they process personal data. We encourage you to read the privacy notice of every website you visit. Your use of third-party websites and links is at your own risk.
4. PERSONAL INFORMATION WE COLLECT
The types of personal information we obtain depend on how you interact with us and our products and services. Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, such as anonymous data. The following are the categories and specific types of personal data that you provide to us voluntarily, data we collect automatically, and information that may be provided from third-party sources.
In the preceding 12 months, we may have collected the following categories of personal information:
Identifiers, such as a real name or alias, phone number, postal address, signature, email address, unique identifiers, account name, Social Security number, driver’s license number, passport number, financial data (bank or debit card numbers) or other similar identifiers.
Personal Information Categories Listed in the Cal. Civ. Code § 1798.80(e), such as your name, signature, physical characteristics or description, social security number, address, telephone number, Passport number, Driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, and other financial information, medical information and health insurance information. Note: Some personal information included in this category may overlap with other categories.
Protected Classification Characteristics under federal or state laws such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, including insurance coverages.
Biometric Data, including photographs and physical characteristics
Sensory Information, such as audio, electronic, visual, or similar information.
Internet/Electronic Network Information, such as internet protocol addresses, login data, browser type and version, data on devices used to access a website, service, or application, browsing history, search histories, and how you use our website or service.
Professional or Employment-related Information, such as current or past job history or performance evaluations, resume information, education details, certifications and professional associations, historical compensation, pre-employment screening, and background check information, including criminal records information.
Vehicle Data, such as vehicle registration and license, vehicle identification number, vehicle pictures and related information.
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predisposition, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
We also collect, use, and share data that is derived from personal data but that does not identify a natural person. For example, we may aggregate website technical and usage data to calculate the percentage of users accessing a specific feature of our website or we may share data about vehicles as long as sharing such data does not identify a natural person. However, if we combine or connect data that identifies a natural person, we treat the combined data as personal data, which will be used in accordance with this Privacy Policy.
We may collect Sensitive Personal Information, such as precise geolocation, trade union membership, criminal conviction and offenses, race, or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, or political opinions, only where required to provide services or comply with a legal obligation. For example, sensitive personal information may be processed for recruitment or employee benefit services. More information will be provided in a separate Privacy Notice for this processing activity.
If You Fail to Provide Personal Data. Where we need to collect personal data by law or under the terms of a contract, we have with you and you do not provide that data, we may not be able to enter into or perform a contract with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
5. SOURCES OF PERSONAL INFORMATION
We obtain the categories of personal information listed in the section above from the following sources:
Direct Interaction with you or your authorized agent when you communicate with us directly or fill out a form on our website.
Vendors / Third Party Service Providers who provide services on our behalf, such as, but not limited to, credit reporting companies, software service providers, servicing vendors, etc.
Interaction with Devices and Cookies when you access our website.
Business Partners, such as automobile dealerships, submitting your credit application to us for underwriting and decision-making.
Family and Friends, such as when you provide us with their contact information on your credit application or contact information on your employment application.
Affiliated Entities related by common ownership or control.
Data Analytics Providers who use cookies to collect public information about your visits to our and other websites for performance, analytics and advertising.
Public Sources, such as public databases, government entities, or court records.
Recruiting and Employment Sources, such as recruiting agencies, your current or prior employer, or background check services.
6. HOW WE USE YOUR PERSONAL INFORMATION
Purposes For Which We Will Use Your Personal Data: We use personal information for a variety of business and commercial purposes, including:
To provide services to our customers such as approving your credit application, providing financing, maintaining, or servicing your account, verifying customer information, providing customer service, processing payments or other transactions, and similar services.
For our service providers or contractors to perform the services described above.
To provide access to and administer our website and other digital services, including services to troubleshoot, detect security incidents, protect against malicious activity, and make improvements.
To respond to or notify you when you reach out to us with a request, question, or comment.
For analytical and research purposes to better understand how you use our products and services and to make improvements.
To establish and manage relationships with our current or prospective business partners, vendors, and consultants.
For marketing and advertising purposes (excluding cross-context behavioral advertising, which we do not do) based on your consent.
For safety and legal purposes, such as to conduct and manage our business in a secure way and give you the best and most secure services and experience; address legal and regulatory compliance; and comply with legal obligations to respond to subpoenas, court orders, lawsuits, or government requests.
To evaluate your candidacy for employment or independent contractor and administer employment benefits.
To detect, prevent, and respond to actual or potential fraud or illegal activities.
For general business purposes to operate and improve our business and services, and for any other business purpose permitted by law.
For purposes that you have consented to, or purposes as described to you when collected.
We do not collect or process Sensitive Personal Information for purposes of inferring characteristics about you.
CHANGE OF PURPOSE. We will only use your personal data for the purposes for which we collect it unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may process your personal data without your knowledge or consent as permitted by law.
7. DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information for our business or commercial purposes to the following parties:
Service Providers. We may share your personal information with our third-party service providers who provide services to you on our behalf, or they provide services to us to allow us to provide our services to you.
Business Partners. We may share your personal information with business partners with whom we jointly offer our services, such as but not limited to automobile dealerships and lending partners.
Vendors. We may share your personal information with vendors to allow us to offer you our products and services or to assist with employment services.
Affiliates. We may share your personal information with our company affiliates for administrative purposes, IT management, human resources, or legal, in order for them to support and supplement the services we provide.
Professional Services Organizations. We may share your personal information with law firms and auditors.
Regulatory Agencies and Authorities. We may share your personal information with state or federal agencies as it relates to regulatory compliance.
Government Agencies. We may share your personal information with state agencies such as the Department of Motor Vehicles.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we engage in a merger, acquisition, financing due diligence, reorganization, purchase or sale of assets, or transition of service to another provider, your information may be transferred or sold as part of such a transaction, as permitted by law and/or contract.
8. SECURITY
We have put in place appropriate security measures (physical, electronic, and procedural) that comply with federal standards to safeguard your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. Please note that information you send to us electronically may not be secure when transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as our Social Security number) to us.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. RETENTION OF YOUR PERSONAL INFORMATION
We will only retain your personal data for as long as it is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
10. YOUR PRIVACY CHOICES
The privacy choices you may have about your personal information are determined by applicable law and are described below.
Phone Calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions per the call or by contacting us as set forth in section 3.
Email Communications. If you receive an unwanted email from us, you can unsubscribe. Note that you will still receive emails concerning services you have requested and communications regarding our Terms or updates to this Privacy Policy.
Marketing Communications. You can ask us to stop sending you marketing messages at any time. Opting out of marketing messages will not affect our processing of your personal information for non-marketing purposes, such as providing a product or service to you, servicing a contract, fulfilling a product or service experience, or other transactions.
Cookies. You can make choices about what cookies collect information on our websites. You may be able to set your browser to refuse all or some browser cookies. If you disable or refuse certain cookies, parts of the website may become inaccessible or not function properly.
You may opt not to disclose information to us. Some of your information, however, may be required in order to use our products or services. If you are a California resident, additional information regarding your privacy rights can be found below in section 11.
11. ADDITIONAL DISCLOSURES AND RIGHTS FOR CALIFORNIA RESIDENTS
As a California resident, you may have additional rights available to you when it comes to how we collect, use, and disclose your personal information under the CCPA. This will depend upon the relationship we have with you and our interactions.
If you are a California resident and have obtained a financial product or service with us for personal, family, or household purposes (e.g., you have an account with us for the purchase and financing of your vehicle), then this section does not apply. In this case, please refer to our US Consumer GLBA Privacy Notice referred to in section 2.
If you are a California resident and have not obtained a financial product or service from us, see below for a summary of additional disclosures and rights.
Also excluded from the disclosures and rights in this section are aggregated consumer information, deidentified personal information and publicly available information.
CCPA Disclosures
Our Actions Over the Past Twelve Months
The following table provides additional information on the personal information we may have collected in the last twelve months, including the categories of personal information, sources, purposes, and with whom the data may have been disclosed:
We do not collect or process Sensitive Personal Information for purposes of inferring characteristics about you.
CCPA Rights
Access to Specific Information Right. You have the right to know and request (not more than twice in a 12-month period) the personal information we have collected and used about you over the last 12 months. Once we receive and confirm your request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you.
Deletion Request Right. You have the right to request that we delete personal information we have collected about you, subject to certain exceptions and legal requirements that govern data, like other regulations or a potential legal hold. If not subject to an exception or legal requirement, we must also notify third parties of the deletion request so that they can also delete.
Correction Right. You have the right to correct any inaccuracies of your personal information we have collected about you where it is inaccurate or incomplete.
Data Portability Request Right. You have the right to request that we transfer a copy of the personal information we have collected about you in a structured, commonly used, and machine-readable format to another party.
Right to be Free from Discrimination for Exercising Your Rights (non-discrimination). You have a right not to receive discriminatory treatment for the exercise of your privacy rights.
We do not currently respond to “Do Not Track” signals.
Under certain circumstances, California residents may also have the right to use an authorized agent to make a request under CCPA on your behalf. You must provide us with written documentation that the agent is authorized to act on your behalf or has your lawful power of attorney. We may also contact you directly to verify your identity.
Notice Regarding Sale & Sharing of Personal Information for Targeted Advertising
In some states (including California), residents have the right to opt-out of having their personal information sold or shared for targeted advertising purposes. We do not sell or share personal information as defined under applicable data protection laws and have not done so within the last 12 months.
California Rights Requests
If you are a California resident and wish to exercise any of the rights set out above, please submit a verifiable consumer request to us by either method below:
Call us on 833-203-2002
Email us at privacy@arrafinance.com
When you make a Rights Request, we may need to request specific information from you to help us confirm your identity and ensure you have the right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If your request provides an email address, or our records contain your email address, we may ask you to verify your identity through such address. Where additional information is required, we try to only ask for information that can be corroborated through our records. We may also ask you for further information in relation to your request to speed up our response.
You can only make a verifiable consumer request for access or data portability twice within a 1-month period.
We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt.
We will keep a record of rights requests and responses for at least twenty-four months in a log that will not be used for any purpose other than for record-keeping and analytics.