Legal & Privacy
Mariner Finance Website Privacy Statement
Last Updated: November 2022
Table of Contents:
- Collection, Use, and Disclosure of Personal Information
- Collection, Use, and Disclosure of Other Information
- Security
- Changes to Your Information
- Changes to Privacy Statement
- Mariner Finance Contact Information
- Additional Privacy Information for California Residents
- California Privacy Rights Notice for California Job Applicants, Former and Current Employees
JUMP TO ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
1. COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
2. COLLECTION, USE AND DISCLOSURE OF TRACKING INFORMATION
3. SECURITY
4. CHANGES TO YOUR INFORMATION
California residents: Please refer to section 7 below for additional information.
5. CHANGES TO PRIVACY STATEMENT
6. MARINER FINANCE CONTACT INFORMATION
7. ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
- Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act, and implementing regulations, or the California Financial Information Privacy Act; and
- An activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency by a furnisher of information who provides information for use in a consumer report and by a user of a consumer report.
- Sensitive Personal information – Sensitive personal information is collected from consumers and loan applicants. Examples: Information that reveals social security number, driver’s license, state identification card, passport number, account log-in, financial account, debit card, geolocation and biometric information (e.g., for log-in purposes)
- Identifiers – Examples: Your 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 other similar identifiers. Note: Some personal information included in this category may overlap with other categories.
- Category C. Protected classification characteristics under State or federal law. – Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, veteran or military status).
- Customer Records with Personal Information – Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note: Some personal information included in this category may overlap with other categories.
- Protected classification characteristics under State or federal law – Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity), veteran or military status.
- Commercial information – Examples: Information including, but not limited to, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity – Examples: Information including, but not limited to, browsing history, search history, information regarding a consumer’s interaction with a website, loan application, and/or advertisement.
- Professional or employment-related information – Examples: Current or past job history and/or performance evaluations.
- Inferences drawn from other personal information – Examples: Information that can be used to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We have collected the above categories of personal information from the following sources:
- Directly from our customers and/or their agents.
- Indirectly from our customers or their agents. For example, through information we collect in the course of providing services to our customers.
- Directly and indirectly from activity on the Site, as described in Section 2 herein. For example, from submissions through our online loan application, Customer Account Center, website usage details collected automatically, and/or Mariner app usage.
- From third parties that interact with us in connection with the services we perform. Examples include, but are not limited to, personal information from credit reporting agencies, lead generator partners, as applicable, and cookie information service providers.
We currently collect and have collected the above Personal Information for the following business or commercial purposes:
- For auditing purposes related to our customer relationships, including, but not limited to, verifying the quality of ad impressions and auditing our compliance with applicable law;
- For detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- For debugging activities to identify and repair errors that impair Site functionality;
- For short-term use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer;
- For performing services for Mariner or on behalf of a service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of Mariner or a service provider;
- For internal research for technological development;
- For use in activities to verify or maintain the quality or safety of Mariner’s services, and to improve, upgrade, or enhance such services; and
- For commercial purposes, such as inducing another person to buy, services or enabling or effecting, directly or indirectly, a commercial transaction.
We currently collect and have collected the above Sensitive Personal Information for the following business or commercial purposes:
- For auditing purposes related to our customer relationships, including, but not limited to, verifying the quality of ad impressions and auditing our compliance with applicable law;
- For detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- For debugging activities to identify and repair errors that impair Site functionality;
- For short-term use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer;
- For performing services for Mariner or on behalf of a service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of Mariner or a service provider;
- For internal research for technological development;
- For use in activities to verify or maintain the quality or safety of Mariner’s services, and to improve, upgrade, or enhance such services; and
- For commercial purposes, such as inducing another person to buy services or enabling or effecting, directly or indirectly, a commercial transaction.
Disclosure, Sale, and Sharing of Personal Information
In the 12 months preceding the Last Updated Date of this Privacy Statement, we disclosed for a business purpose the categories of personal information identified above to the following categories of third parties:
- Our lead generator partners;
- Our service providers, including, but not limited to, credit reporting agencies, mail service providers, and complaint management service providers; and
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services offered and/or provided to you, including but not limited to insurance companies, and ancillary product administrators.
Mariner does not offer any financial incentives for the collection, sale, sharing, or deletion of personal information.
In the preceding twelve (12) months, we have not sold or shared personal information or sensitive personal information.
We do not knowingly sell the personal information of minors under 16 years of age.
Length of Time Personal Information is Retained
We will not retain your personal information or sensitive personal information for longer than is reasonably necessary for the disclosed collection or use purpose. Our retention of personal information also is subject to state and federal legal requirements.
Right to Access to Specific Information
California residents have the right to request that we disclose certain information about our collection and use of personal information. Once we receive and verify 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 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.
Right to Correct Inaccurate Personal Information
You have the right to request that we correct any inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. Upon receiving a verifiable request to correct inaccurate personal information, we shall use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
Right to Delete Personal Information
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete your personal information from our records, unless an exception applies. We will also ensure that all deletion requests are passed along to applicable third parties, contractors, and services providers, unless an exception applies.
Please note, however, that we may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer and/or employee expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right, at any time, to direct us to limit the use and disclosure of sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA. Upon receiving a verifiable request to limit the use and disclosure of sensitive personal information, we shall use commercially reasonable efforts as directed by you.
Right to Opt-Out of Sales and Sharing
You have the right, at any time, to direct us not to sell or share your personal information to a third party. This right may be referred to as the right to opt-out. Mariner does not currently sell personal information. However, you may exercise your right to opt out of sales in the event that Mariner subsequently decides to sell personal information that is subject to the CCPA. If Mariner elects in the future to sell personal information and if we at any time receive direction from you not to sell your personal information, we will not sell your personal information that is subject to the CCPA, if any, unless you subsequently provide express authorization for such sales.
Exercising Your Rights:
To exercise your access, correction, deletion, and limitation of use and disclosure rights described above, please submit a verifiable request to us by either:
- Calling us at 877-310-2373, select option 3. Available Monday through Friday, 8:30 am EST to 5:00 pm EST, excluding observed holidays.
- Filling out an online request at any time by clicking HERE.
To exercise your right to opt- out of the sale or sharing of your personal information to a third party or to limit the use of your sensitive personal information, please call us at 877-310-2373, select option 3 or click the following link: Do Not Sell or Share my Personal Information and/or Limit the Use of My Sensitive Personal Information. .
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. Please attach a written authorization signed by the California resident authorizing you to make the request on their behalf.
We will respond to a verifiable request for access or data portability up to two times within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable request within forty-five (45) calendar days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account, unless you elect otherwise. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data access requests, we will select a format technically feasible to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is manifestly unfounded or excessive, for example, because of a repetitive nature. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Accessibility
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described above. Please also see our Website Accessibility Statement available here.
8. CALIFORNIA PRIVACY RIGHTS NOTICE FOR CALIFORNIA JOB APPLICANTS, FORMER AND CURRENT EMPLOYEES
Under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), Mariner Finance, LLC (“Mariner Finance”) is required to inform job applicants and former and current employees who reside in California about the categories of personal information Mariner Finance collects, the purposes for which that information will be used, and whether that information is disclosed, sold or shared. This notice contains disclosures required by the CCPA and applies only to personal information that is subject to the CCPA.
For more information on Mariner Finance’s privacy policies as it concerns its customers, loan applicants, and website visitors, please visit: https://wps-qa.marinerfinance.io/resources/legal/privacy-statement/
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on https://wps-qa.marinerfinance.io/why-mariner-finance/careers/. Please review this Privacy Policy periodically.
This privacy policy covers the following topics:
1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
Mariner Finance collects the following categories of personal information about our job applicants and employees who are California residents:
Sensitive Personal Information: Information that reveals social security number, driver’s license, state identification card, passport number, account log-in, financial account, debit card, racial or ethnic origin, contents of consumer email and text messages, unless the business is the intended recipient of the communication; and biometric information.
Personal and online identifiers: Your first and last name, alias, postal address, email address, unique personal identifier, online identifiers, social security number, driver’s license, passport number, and/or other similar identifiers.
Categories of personal information as defined in Section 1798.80(e) of the California Civil Code: Name, signature, physical characteristics or description, education, employment, employment history, social security number, passport number, driver’s license or state identification number, telephone number, address, insurance policy number, credit/debit card number, bank account number, medical information and health insurance information.
Characteristics of protected classifications under California or federal law: Age, color, race, citizenship, national origin, marital status, disability, medical condition, request for family care leave, request for an employee’s own serious health condition, request for pregnancy disability leave, veteran or military status, and gender.
Biometric information: Physiological, behavioral, and biological characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as, fingerprints, or other physical patterns and video security surveillance.
Internet or other similar network activity: Browsing history, search history, and information on your interaction with our website, application, or advertisement.
Professional or employment related information: Current or past job history and/or performance evaluations.
Education information
- Inferences drawn from other personal information that can be used to create a profile reflecting a person’s preferences, characteristics, psychological trends, behavior, attitudes, intelligence, abilities, predispositions, and aptitudes.
2. CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED
We collect the above categories of personal information directly from individuals, through recruiting entities, and from other entities such as companies that perform background checks for us.
3. BUSINESS PURPOSES FOR COLLECTING PERSONAL INFORMATION
- Mariner Finance uses the personal information collected regarding our job applicants and employees for our business purposes. These business purposes include, without limitation:
To comply with state and federal law(s) requiring businesses to collect, monitor, maintain or transfer certain records regarding applicants or applications for employment or contract work, including demographic characteristics and to respond to law enforcement requests as required by applicable law;
- To have you fill out applications and forms associated with your prospective employment;
- To assess ability, fitness or eligibility of applicant to fulfill or perform prospective job duties and work in relevant corporate location and environment;
- To perform audits related to Mariner Finance’s interactions with job applicants;
- To detect and protect against security incidents, fraud, and illegal activity;
- To debug to identify and repair errors that impair existing intended functionality;
- To schedule travel, and pay for or reimburse job applicants for covered business expenses related to the job application or interview or similar expenses;
- To maintain and protect the rights, security and safety of job applicants, our personnel, clients and others, as well as our facilities, premises and other property;
- To perform services on behalf of Mariner or one of its service providers by providing job applicants with information, products or services related to the job opportunity or that they request from us and with notices or announcements concerning our business operations, opportunities, or policies that may be relevant and/or of interest to them;
- To fulfill or meet the reason for which the information was provided to us by the job applicant;
- To perform internal research for technological improvement and to use in activities to verify or maintain the quality or safety of Mariner Finance’s services, and to improve, upgrade, or enhance such services;
- To process payroll;
- To perform a background check;
- To verify your ability to work in this country;
- To identify you as a veteran;
- To have you acknowledge your agreement to certain company policies;
- To enroll you in any applicable wellness program;
- To administer and maintain benefits, including group health insurance;
- To the extent applicable, administer and maintain your retirement account;
- For emergency contact purposes;
- To track time and attendance at work;
- To manage workers’ compensation claims;
- To manage your job-related performance;
- To grant and monitor your access to secure company facilities;
- To engage in corporate transactions requiring review of employee records and information such as for evaluating potential mergers and acquisitions;
- To review web traffic and events, monitor for virus attacks and web content, and determine bandwidth consumption;
- To maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance; and
- To perform call monitoring and surveillance (e.g., CCTV).
4. TRANSFERS OF PERSONAL INFORMATION
We do not transfer your personal information to third parties as that term is defined in the CCPA. However, we do transfer your personal information to service providers and contractors who perform services on our behalf. For example, we transfer personal information to payroll service providers to pay you. We have disclosed the categories of personal information identified in Paragraph 1 for the business purposes identified in Paragraph 3.
We do not knowingly collect or sell the personal information of minors under 16 years of age.
5. HOW WE PROTECT YOUR PERSONAL INFORMATION
Mariner Finance protects personal information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the personal information held. Mariner Finance takes commercially reasonable measures to safeguard personal information but cannot guarantee its absolute security.
6. YOUR RIGHTS
Right to Access to Specific Information
California residents have the right to request that we disclose certain information about our collection and use of your personal information. Once we receive and confirm your verifiable consumer 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 purpose for collecting or selling that personal information.
- The categories of third parties to whom we disclosed, sold or shared that personal information (if applicable).
- The specific pieces of personal information we collected about you.
- The categories of personal information that we disclosed, sold or shared about you (if applicable).
Right to Correct Personal Information
You have the right to request that we correct any inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. Upon receiving a verifiable request to correct inaccurate personal information, we shall use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
Right to Deletion
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We will also ensure that all deletion requests are passed along to applicable third parties, contractors, and services providers, unless an exception applies.
Please note, however, that we may deny your deletion or correction request if retaining the information is necessary for us or our service providers to:
- maintain the personal information pursuant to federal, state, or local law or regulation;
- complete the transaction for which the personal information was collected;
- any requests to delete any information created by Mariner concerning an applicant or employee; and
- any requests to correct internal Mariner employment reviews, processes, or similar information.
Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right, at any time, to direct us to limit the use and disclosure of sensitive personal information. Upon receiving a verifiable request to limit the use and disclosure of sensitive personal information, we shall use commercially reasonable efforts as directed by you.
Right to Opt-Out of Sales and Sharing
You have the right, at any time, to direct us not to sell or share your personal information to a third party. Mariner does not currently sell or share personal information covered by this privacy policy. However, you may exercise your right to opt out of sales in the event that Mariner subsequently decides to sell personal information that is subject to the CCPA. If Mariner elects in the future to sell personal information and if we at any time receive direction from you not to sell your personal information, we will not sell your personal information that is subject to the CCPA, as amended, if any, unless you subsequently provide express authorization for such sales.
Exercising Your Rights
To exercise your access and, correction, deletion, and limitation of use and disclosure rights described above, please submit a verifiable request to us by either:
- Calling us at 877-310-2373, select option 3. Available Monday through Friday, 8:30 am EST to 5:00 pm EST, excluding observed holidays.
- Filling out an online request at any time by clicking HERE.
To exercise your right to opt-out of the sale or sharing of your personal information to a third party, please call us at 877-310-2373, select option 3 or click the following link: Do Not Sell or Share my Personal Information and/or Limit the Use of My Sensitive Personal Information.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. Please attach a written authorization signed by the California resident authorizing you to make the request on their behalf.
You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable request within forty-five (45) calendar days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data access requests, we will select a format technically feasible to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is manifestly unfounded or excessive, for example, because of a repetitive nature. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Length of Time Personal Information is Retained
We will not retain your personal information or sensitive personal information for longer than is reasonably necessary for the disclosed collection or use purpose. Our retention of personal information also is subject to state and federal legal requirements.
7. ACCESSIBILITY
We are committed to ensuring this notice is accessible to individuals with disabilities. If you wish to access this notice in an alternative format, please contact us at careers@marinerfinance.com.
8. HOW TO CONTACT US
If you have any questions or comments regarding this privacy policy, please contact us at 877-310-2373, select option 3.
