January 23, 2017
Protecting the privacy of the nonpublic personal information ("Information") you share with us is one of our top priorities. We value your trust and want you to understand what information we collect, how we keep it safe, and how we use it.
In order to enable the customer to learn about our products and services, apply for their use, and enable us to decide the customer’s eligibility for them, we may collect the following types of Information about the customer from the following sources:
Information we receive from the customer or about the customer during the application process and on forms, such as the customer’s name, address, telephone number, email address, employment status, photo identification, and account credentials.
Information about the customer’s past and contemplated future transactions with us, such as equipment leased, services bundled with the leased equipment, payment history, and where and when the customer leases the equipment.
Information from third party providers of identification, payment history, authentication, and decisioning support services.
Information the customer provides to our customer support team and the results when he or she responds to a survey. Additionally, for quality and training purposes or for its own compliance purposes, SmartPay Leasing may monitor or record its telephone conversations with the customer or anyone acting on the customer’s behalf. By communicating with SmartPay Leasing, the customer acknowledges that such communications may be overheard, monitored, or recorded without further notice or warning.
Information we may collect about the customer and our interactions with him or her in order to help protect the customer from fraud and misuse of his or her personal information.
Communications from us
We will send the customer email and text messages (sometimes known as SMS) related to using the SmartPay Service.
Customers who commence a SmartPay lease agreement may receive email and/or text messages about their lease agreement, including, but not limited to, activating their SmartPay account, the status of their account, notices when a lease payment is due or scheduled or made, when certain legal notices are required by state law, when a return is made, when a lease payment is overdue, when a lease funding source needs to be changed, and when a chargeback on a lease payment occurs.
As part of our regular email and/or text correspondence about their existing SmartPay lease, Customers may also have the opportunity to opt-in to receive an email and/or text about the opportunity to upgrade to a new mobile device through SmartPay, the retailer, and their existing no-contract carrier. If the Customer does not affirmatively opt-in, SmartPay shall not send any further communications about upgrades.
For any messages, the customer can revoke consent at anytime by texting “STOP” from the customer’s mobile device to 97403, sending an email to firstname.lastname@example.org, or calling SmartPay at 1-844-663-1309 and letting us know which telephone number and/or email address we should cease contacting. The customer can also revoke consent for email messages by clicking “Unsubscribe” on any email.
Information We May Share and With Whom We May Share Information
SmartPay Leasing, LLC. may disclose all the Information described above among companies within its corporate family (subsidiaries, related, and affiliated companies), subcontractors, lenders and investors who provide us capital to purchase equipment that we lease through the SmartPay service, and data providers who assist us in our decision-making, authentication and underwriting process. In addition, SmartPay Leasing, LLC. may disclose Information under other circumstances such as the following:
Disclosures Permitted by Law. We reserve the right to disclose the customer’s Information as required by law and when we believe that such disclosure is necessary to protect our rights (including proving the existence and terms of a lease agreement and payments and the distribution of equipment thereunder) and/or comply with a judicial proceeding, court order, regulatory request, legal process, or payment network request or charge served on us.
Agents/Service Providers. We may disclose Information to companies that perform services for us, such as taking customer calls, processing the customer’s account, preparing the customer’s account statements, processing the customer’s payments, providing software or data to us, and helping us collect on monies owed to us. These companies are authorized to use the customer’s personal information only as necessary to provide these services to us. We may share Information to answer questions from law enforcement agencies or state and federal regulators, or to respond to a subpoena, or protect against fraud.
Accounts Receivable Purchasers and Consultants. In the event that the customer’s account with us is delinquent, we may sell the account and the right to collect on the account to a company that specializes in accounts receivable management. In the event of such a sale, we will need to disclose certain information about the customer account to its purchaser. We may also retain third party accounts receivable companies to assist us in collecting on delinquent accounts. We and third party accounts receivable companies may share certain of the customer’s information with third party information service providers in order to facilitate collections.
Consumer Reporting Agencies. We may report the status of the customer’s account with us to consumer reporting agencies.
Disclosures for Risk Management and Servicing. We may share all of the Information described above with companies that provide account management, risk management, and account servicing for us (including financial companies such as banks and insurers; non-financial companies, such as data providers; and others) or with other financial companies, such as insurers and banks with whom we have a joint marketing or similar agreement.
Merger or Acquisition. If SmartPay Leasing completes a merger, acquisition, or sale of all or a portion of its assets, the customer will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of his or her personal information, as well as any choices the customer may have regarding his or her personal information.
Retailers. SmartPay may share some of the information described above with the retailer where the transaction occurred, as well as its corporate family, for prudent business purposes, such as accounting purposes, risk management, and/or to comply with any state or federal regulations.
You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to use your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details, if available, solely to allow verification of your identity and to compare information you have provided to SmartPay with your wireless operator account profile information for the duration of the SmartPay relationship.
Information Regarding Former Customers
We will retain the customer’s information for as long as his or her account is active or as needed to provide him or her services. If the customer wishes to cancel his or her account or request that we no longer retain such Information, please contact us at email@example.com. We will make commercially reasonable efforts to honor the customer’s request, to the extent that it does not interfere with our use of his or her information to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Security Procedures
We limit use of Information about the customer to those employees, agents or contractors who we believe have a legitimate business purpose to access such Information. We maintain physical, electronic and procedural safeguards that comply with or exceed federal standards to keep information about him or her safe. We require companies working for us to protect Information and to agree to use it only to provide the services we ask them to perform for us.
The security of customer personal information is important to us. When the customer enters sensitive information (such as credit card number, social security number, and checking account information) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore we cannot guarantee its absolute security.
Updating or Correcting Personally Identifiable Information
If the customer’s personally identifiable information changes, or if the customer no longer desire our service, he or she may correct, update or request the deletion of it by updating his or her details on our member information page or by emailing our Customer Support at firstname.lastname@example.org. We will make commercially reasonable efforts to honor the customer’s request, to the extent that it does not interfere with our ability to comply with our legal obligations, resolve disputes, and enforce our agreements.
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