Privacy Policy for Belmont Finance, LLC

Last Updated: November 2, 2022

1. Introduction

Belmont Finance LLC (together with its subsidiaries, divisions, and brands, collectively, "Belmont," "we," "us," or "our," as the context may require) is a sales finance company providing consumer financing for in-home and direct sales. This Privacy Policy (this "Policy") describes our privacy practices for the website where this Policy appears, along with the customer and dealer portals managed by Belmont as part of the website (collectively, the "Site"), including the types of information we may collect from you when you visit the Site and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of the users of the Site ("you" or "your," as the context may require) and we are committed to respecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using the Site, you agree to this Policy and our Terms of Service. If you do not agree with this Policy, please do not visit, access, use, or otherwise interact with the Site.

This Policy may change from time to time (see Section 10 (Changes to this Policy)). Your continued use of the Site after we revise this Policy means you consent to such revisions and agree to abide and be bound by the most recent version of the Policy, so please check this Policy periodically for updates.

Please keep in mind that any personal information that we collect and process in connection with a financial product or service offered to you will be subject to our Consumer Privacy Notice. The Consumer Privacy Notice addresses our privacy obligations to you under the Gramm-Leach-Bliley Act ("GLBA") and the Fair Credit Reporting Act ("FCRA"), and the Consumer Privacy Notice will supersede this Policy in the event of any conflict.

2. The Interactions this Policy Covers

Except as otherwise required by applicable law, this Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Site and in texts, emails, and other electronic communications sent through or in connection with the Site. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any application, website, or third party other than the Site, including through any application or content that may access, be linked to, or otherwise be accessible from the Site. If you visit an application, website, or third party that we mention or link to, be sure to review its privacy policy before providing any information, as that privacy policy will apply to your interactions with that application, website, or third party.

Except as otherwise provided in this Policy, "personal information" is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. "Personal information" does not include information which is generally not considered "personal information" under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, such as "protected health information" covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or information not otherwise considered "personal information" under applicable law. For the avoidance of doubt, "personal information" does include "personally identifiable financial information" as defined under the GLBA.

3. Information We Collect

We collect several types of information from and about you as a result of your use of the Site and as a result of your electronic communications with us. This information may include:

  • Personal information, including:
    • Identifiers, such as your name, social security number, username, postal address, billing address, email address, phone number, and other similar identifiers you might use.
    • Financial information, such as your salary and debt-to-income ratio, credit history, payment history, account balances, transaction history, overdraft history, and other information about your creditworthiness.
    • Demographic information, such as your age, gender, household income, education, and other similar categories.
    • Professional or employment information, such as your work history.
  • Confirm whether we process their personal information.
  • Access, correct, and delete certain personal information.
  • Request specific pieces of personal information we collected about you ("data portability").
  • Opt-out of personal data processing for targeted advertising and sales. However, we do not process personal data for targeted advertising or sales at this time.
  • Information that is about you or relates to you but is not personal information and which does not identify you, such as information which has been de-identified or aggregated in a manner where the information can no longer be used to identify you.
  • Technical information about your internet connection and the equipment you use to access the Site, your IP address and other unique device identifiers, your activity on the Site, and other usage details.
  • Any other information, including personal information, which you publicly disclose or share on the Site, or disclose to or share with us in any manner.
  • To provide you with the Site and any other information or services that you request from us.
  • To create, manage, maintain, and secure your account and provide you with notices about your account.
  • To process your requests and payments.
  • To notify you about changes to the Site or any services we offer though it.
  • To provide, support, personalize, and develop the Site.
  • To prevent transactional fraud and monitor for other types of fraud, abuse, and illegal activity.
  • To help maintain the safety, security, and integrity of the Site, as well as our products, services, databases, and other technology assets.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • For testing, research, analysis, and product development, including to understand our audience, develop and improve the Site, as well as our customer service, products, and services.
  • To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
  • To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale, or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.
  • To contact you about employment if you submitted your resume or other application, email, or other communication when you apply to work with us.
  • To fulfill any other purpose for which you provide it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

4. How We Collect Personal Information

We may collect personal information:

  • Directly from you when you provide it to us;
  • Automatically when you use or access the Site; and
  • From third parties, to the extent permitted by applicable law.

A. From You

The personal information we collect directly from you when you use or access the Site includes:

  • Any information you provide us when applying for a loan or opening an account.
  • Details of correspondence and transactions you carry out through the Site.
  • Information that you provide by filling in forms on the Site. This includes information provided at the time of requesting further information.
  • Records and copies of your correspondence, including email addresses, if you contact us.
  • Information you provide to us in a resume, application, email, or other communication in connection with an application for or other inquiry regarding employment with us.

B. Automatically

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain the information or associate it with personal information we collect in other ways or receive from third parties. This information helps us improve our Site and deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences.
  • Speed up your searches.
  • Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site, and overall functionality of the Site may be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
  • Web Beacons. Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may also use web beacons or pixel tags to compile anonymized tracking reports regarding website user demographics and website traffic patterns. We may then provide these reports to advertisers and others. For our own research purposes, we may link such reports with personal information voluntarily provided to us. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy.

C. From Third Parties

We also receive personal information from other sources, including credit bureaus, affiliates, and service providers. We generally require any service providers use your personal information only as we direct and in a manner consistent with this Policy.

We may offer the opportunity to engage with our Site and content on or through third-party social networking websites. When you engage with our content on or through third-party social networking websites, you may allow us access to certain information associated with your social media account, which may include personal data (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website. We do not build profiles based on this information. The sharing and processing of such information is exclusively controlled by the social media platform you are using. If you do not wish to share such information or exercise any data subject rights related to such information, please refer to the privacy notices or policies of the social media platform you are using.

 

5. How We Use Your Personal Information

We may use the personal information that we collect about you or that you provide to us:

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

 

6. Disclosure of Your Personal Information

We may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To the Nationwide Mortgage Licensing System & Registry.
  • To credit bureaus.
  • To service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, such as our software providers.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, and for billing and collection, including disclosure to a third-party debt collector.
  • To protect the rights, property, or safety of Belmont, our customers, or others, in circumstances when we believe disclosure is necessary or appropriate.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

 

7. Your Privacy Rights

We provide all users with rights to:

To exercise any of these rights, please contact us as provided below in Section 11 (How to Contact Us). We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law or as necessary to fulfill or enforce a loan or other contract to which you are bound.

To appeal a decision regarding a request, please contact us as provided below in Section 11 (How to Contact Us).

Additionally, we have identified or created the following mechanisms to provide you with further control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Site may then be inaccessible or not function properly.
  • Promotional Offers from Us. If you do not wish to have your contact information used by us to promote our own products or services, please contact us as provided in Section 11 (How to Contact Us). If you no longer wish to receive our email newsletters or promotions, you may unsubscribe using the link provided in every email or contact us as provided in Section 11 (How to Contact Us).
  • Accessing and Updating Your Information. To update your information (name, mailing address, telephone number and email address), you can review and change your personal information by logging into the Site and visiting your account profile page within the customer or dealer portal. You may also contact us as provided in Section 11 (How to Contact Us) to update your information.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website, https://thenai.org/opt-out. Similarly, you can opt out of receiving targeted ads from members of the Digital Advertising Alliance ("DAA") on the DAA's website, https://www.privacyrights.info.

If you are a resident of certain jurisdictions (e.g., California), applicable law may provide you with additional rights regarding certain categories of your personal information. Please see Section 12 (Jurisdiction-Specific Notices) for more information.


8. Security

We implement various physical, administrative, and technical safeguards in accordance with industry standards to protect the security of your personal information both online and offline, including firewalls, encryption, and multifactor authentication. However, the safety and security of your information also depends on you. Where you have a username and password for access to certain parts of the Site, you are responsible for keeping this username and password confidential. We ask you not to share your username or password with anyone. If you believe your username or password has been compromised, please contact us as provided below in Section 11 (How to Contact Us).

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

 

9. Children's Privacy

The Site is not directed to nor intended for use by anyone under 18 years old ("Prohibited Users"). We do not knowingly collect personal information from Prohibited Users. Prohibited Users are not authorized to use the Site. If you are a Prohibited User, please do not provide any personal information to, on, or through the Site. If we learn we have collected or received personal information from a Prohibited User, we will delete that information. If you believe we might have any information from or about a Prohibited User, please contact us by any of the methods listed in Section 11 (How to Contact Us).

10. Changes to this Policy

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to applicable legal requirements to notify you or obtain your consent. The date this Policy was last reviewed and/or revised is noted at the top of the page. You are responsible for periodically visiting the Site and this Policy to check for any changes. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

 

11. How to Contact Us

To ask questions or comment about this privacy policy and our privacy practices, contact us:

Via mail:

Belmont Finance LLC

300 Plover Road

Plover, WI 54467

Via email:

[email protected]

Via phone:

1-877-547-2926

 

12. Jurisdiction Specific Notices

A. California Privacy Notice

This Section 12.A applies exclusively to users of the Site who reside in the state of California. We provide our California Privacy Notice to supplement our main Privacy Policy and to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (the "CCPA"). The CCPA does not apply to certain information we collect, such as personal information collected, processed, sold, or disclosed pursuant to the GLBA. To the extent that we collect any personal information that is subject to the CCPA, our practices and your rights are described below. Notwithstanding anything to the contrary elsewhere in this Policy, terms defined in the CCPA have the meaning assigned to them under the CCPA when used in this California Privacy Notice.

If your account has a California mailing address, we will not share personal information we collect about you with any nonaffiliated third party unless you provide authorization (or "opt in"), except to the extent permitted under California law.

I. Personal Information We Collect

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from consumers:

Category

Examples

A. Identifiers

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 other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law

Age, race, citizenship, marital status, sex (including gender, gender identity, gender expression), and veteran or military status.

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

F. Internet or other similar network activity

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

I. Professional or employment-related information

Current or past job history.

II. Sources of Personal Information

We may collect your personal information from the categories of sources of personal information identified in Section 4 (How We Collect Personal Information).

III. Use of Personal Information

We may use, disclose, or otherwise process the personal information we collect for the purposes identified in Section 5 (How We Use Your Information) and Section 6 (Disclosure of Your Personal Information).

IV. Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of information to our third-party service providers: identifiers, California Customer Records personal information categories, protected classification characteristics under California or federal law, commercial information, internet, or other similar network activity, and professional or employment-related information.

We do not sell personal information.

V. Your Rights and Choices

The CCPA provides consumers with specific rights regarding their personal information. This Section 12.A.V describes your CCPA rights and explains how to exercise those rights.

a. Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (your "Right to Know"). Once we receive your request and confirm your identity (see Section 12.A.V.c), 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.
  • If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a "Data Portability Request"). 
b. Right to Delete

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 (your "Right to Delete"). Once we receive your request and confirm your identity (see Section 12.A.V.c (Exercising Your Rights to Know or Delete)), we will review your request to determine whether an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 et. 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 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 you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

c. Exercising Your Rights to Know or Delete

To exercise your Right to Know or your Right to Delete described above, please submit a request by either:

Only you or your authorized agent may make a verifiable consumer request related to your personal information. To designate an authorized agent, contact us through one of the methods listed above.

You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period. Your Request to Know, Data Access Request, or Data Portability Request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or are an authorized representative of such person, which may include information which we already maintain or, if we cannot verify your identity based on information already maintained by us, information that we or our representatives request from you.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
d. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within this timeframe, please contact us as provided in Section 11 (How to Contact Us).

We try to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. We cannot respond to your request or provide you with personal information unless we can verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your request within forty-five (45) days of its receipt, we may deny your request.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising your sale opt-out or opt-in rights, see Section 12.A.V.e (Personal Information Sales Opt-Out and Opt-In Rights) below.

e. Personal Information Sales Opt-out and Opt-in Rights

If you are 16 years old or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not collect personal information from anyone we actually know is less than 18 years old, and we do not sell personal information, and therefore we do not sell the personal information of consumers we actually know are less than 16 years old.

f. Non-Discrimination; Notice of Financial Incentives

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

We do not currently provide any financial incentives.

B. Nevada Privacy Notice

This Section 12.B applies exclusively to users of the Site who reside in the state of Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise this sale opt-out right may email us at [email protected]. Please include "Nevada" in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address. However, please note that we do not currently sell data triggering that statute's opt-out requirements.

C. Vermont Privacy Notice

This Section 12.C applies exclusively to users of the Site who reside in the state of Vermont. If your account has a Vermont mailing address, we will not share personal information we collect about you with any nonaffiliated third party unless you provide authorization (or "opt in"), except to the extent permitted under Vermont law.