California Privacy Policy

Last updated: February 22, 2023

Privacy Policy for California Residents

This Privacy Policy for California Residents (“California Privacy Policy”) explains how Reliable Credit Association, Inc. (referred to herein as “Reliable Credit”, “we”, or “us”), collects, uses, and discloses personal information about California residents (referred to herein as “consumer”, “you” or “your”) that is subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

The rights set forth under the CCPA do not apply to, among other information and activities excluded by the CCPA:

  • Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”), and implementing regulations, or the California Financial Information Privacy Act; and
  • Activities 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 furnisher of information who provides information for use in a consumer report; and

    • by a user of a consumer report.

Therefore, thisCalifornia Privacy Policy does not apply to, for example, information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes and is regulated by GLBA (“Customers”). For more information about how we collect, disclose, and secure information about our Customers, please see our Privacy Notice.

Categories of Personal Information Collected

We collect minimal personal information about you that is not personal information subject to the GLBA. We currently collect and, in the 12 months prior to the last updated date of this California Privacy Policy, have collected or may have collected the following categories of personal information about California residents that is not subject to the GLBA:

  • Sensitive personal information – Personal information about non-Customers that reveals:
    • a social security, driver’s license, state identification card, or passport number.
    • account log-in, bank account number, or debit card number, along with any required security or access code, password or credentials allowing access to an account.
  • Identifiers – Non-Customers:  first, middle, and last name; postal address; unique personal identifier; online identifier; email address; mobile phone number; residence phone number; work phone number; account name; date of birth; 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.
  • Protected classification characteristics under California law or federal law – Non-Customers: Age (40 years or older), marital status, citizenship, gender, veteran or military status.
  • Customer records with personal information – Any information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer who is a non-Customer, including, but not limited to, name, signature, address, telephone number, driver’s license or state identification card number, insurance policy number, bank account number, debit card number, or any other financial information. Note: Some personal information included in this category may overlap with other categories.
  • Commercial information – 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 electronic network activity – Information about non-Customer’s interaction with a website or online loan application which is limited to name, email address, and phone number.
  • Geolocation data – We collect geolocation data on Customers and non-Customers in a way that does not identify the individuals or allow us to locate the individual.
  • Professional or employment-related information – Current or past job history.

We have collected the above categories of personal information from the following sources:

  • Directly from consumers and/or their agents.
  • Indirectly from our Customers and/or their agents. For example, through information we collect in the course of providing services to our Customers.
  • Directly and indirectly from activity on our Site, as described in Cookie Policy herein. For example, from submissions through, eServices, Customer Satisfaction Surveys, website usage details collected automatically, and/or Reliable Credit app usage.
  • From third parties that interact with us in connection with the services we perform. Examples include, skip tracing services, repossession agents, and collection agencies.

We currently collect and may have collected the above personal information and sensitive personal information for the following business or commercial purposes:

  • Performing services for Reliable Credit or on behalf of a service provider, including providing financing; establishing, maintaining, or servicing accounts; providing customer service; processing transactions and payments; and verifying Customer information.
  • Helping to ensure security and integrity of the personal information.
  • Internal research for technological development.
  • For use in activities to verify or maintain the quality or safety of Reliable Credit’s services, and to improve, upgrade, or enhance such services.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
  • Debugging activities to identify and repair errors that impair Site and Reliable Credit computer system functionality.

In the 12 months preceding the last updated date of this California Privacy Policy, we have not disclosed the categories of personal information identified above with a third party.

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.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The verifiable consumer 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 and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Right to Access Specific Information

You have the right to request that we disclose certain information about our collection and use of personal information. Upon receiving and processing a verifiable 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 purposes for collecting that personal information.
  • The categories of third parties with whom we disclose personal information.

You also have the right to request the specific pieces of personal information we have 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 and processing 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 may request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Upon receiving and processing a 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 service providers, unless an exception applies.

Please note that we, or a service provider or contractor acting pursuant to its contract with us, may deny your deletion request if retaining the information is reasonably necessary for us or our service providers or contractors maintain the personal information 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.).
  • 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

The CCPA provides for the right to limit the use and disclosure of sensitive personal information to those purposes specifically permitted by the CCPA. However, we do not use or disclose sensitive personal information for purposes other than those specifically permitted in the CCPA.

Right to Opt-Out of Sales and Sharing

The CCPA gives you the right, at any time, to direct us not to sell or share your personal information to a third party. In the preceding twelve (12) months, however, Reliable Credit has not “sold” or “shared” (as those terms are defined in the CCPA) personal information.

How to Exercise Your Rights.

To exercise your access, correction, deletion, and limitation of use and disclosure rights described above, please submit a verifiable request to us:

  • online here
  • by calling us at 1-888-462-3003, Monday through Friday, 8:30 am PST to 5:00 pm, PST, excluding observed holidays
  • or mailing us at:

Reliable Credit Association, Inc.
Attn: General Counsel
PO Box 22829
Milwaukie, OR 97269

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.

The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you (or in the case of an authorized representative, the consumer) 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 and/or authority to make the request and confirm the personal information relates to you. In the case of an authorized representative, we may need to contact the consumer to directly verify their identity and your authority. 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.

Responding to Your Request

We will respond to a verifiable request for access or data portability once within a 12-month period.

If you have an account with us, we will deliver our written response to the physical or email address on that account, at your option, 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, to the physical or email address you provide in your request. We also may contact you for additional information to verify your identity and the validity of your request.

We attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format 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 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Accessibility

We are committed to ensuring this California Privacy Policy is accessible to individuals with disabilities. If you wish to access this California Privacy Policy in an alternative format, please contact us as described below. Please also see our ADA Policy available here.

Contact Information

If you have any questions about this California Privacy Policy you may call us during normal business hours at 1-888-462-3003 or write us at:

Reliable Credit Association, Inc.
Attn: General Counsel
PO Box 22829
Milwaukie, OR 97269