Privacy Policy
Updated 01/12/2007
We take your right to privacy seriously and take all reasonable precautions to preserve
the privacy and security of your personally identifiable information. This Privacy
Policy deals with personally identifiable information (referred to as "Data" below)
that may be collected by us on our site. This Policy does not apply to other entities
that we do not own or control or persons that are not our employees, agents or within
our control. Please take time to read our Terms of Use.
1. Collection of Data Our process requires a significant amount
of information collection in order that we may appropriately serve you. Required
fields are indicated and collect such personal information as name, address, email
address, phone number, and financial information in our registration pages, blogs,
refer-a-friend, etc. Some information in the forms is optional to complete. Please
take note that your name, e-mail address, or other submissions that you make on
this site will contain your real name or other personally identifiable and sensitive
information.
As is true of most Web sites, we gather certain information automatically and store
it in log files. This information includes internet protocol (IP) addresses, browser
type, internet service provider (ISP), referring/exit pages, operating system, date/time
stamp, and click-stream data.
We use this information, which does not identify individual users, to analyze trends,
to administer the site, to track user's movements around the site and to gather
demographic information about our userbase as a whole.
We do not link this automatically-collected data to personally identifiable information.
While IP addresses are ultimately tied to personally identifiable information, we
use this information for the monitoring of geo-targeted advertising campaigns only.
We use the third-party tracking service Google Analytics that uses cookies and log
files to track non-personally identifiable information about visitors to our site
in the aggregate. This information includes web-traffic statistics, including, but
not limited to, comprehensive site usage and volume data, in order to enhance the
user experience of our visitors.
2. Use of Data We share information with third parties only to
the extent permitted by applicable law. This includes information that we share
because you have consented to us sharing the information for the purpose of obtaining
a loan. We also will keep information that you provide us for future products and
services that we may market to you, unless you tell us otherwise.
3. Legal Disclaimer We reserve the right to disclose your personally
identifiable information as required by law and when we believe that disclosure
is necessary to protect our rights and/or to comply with a judicial proceeding,
court order, or legal process served on our Web site.
Think Financial abides by federal law and the guidelines established by the Federal
Trade Commission regarding youth privacy. Therefore, we will not knowingly collect
any personal information from or allow the registration of young people under the
age of 13. If we become aware that we have inadvertently collected personal information
from a person under the age of 13, we will promptly take all reasonable steps to
delete the data from our system.
Think Financial will not share your personal information with nonaffiliated, third
parties except as required or permitted by federal law or regulation. For example,
we may share your personal information with schools, lenders, agencies of the United
States government and their agents, credit-reporting agencies, and with third-party
servicing organizations. These third parties are required to use your personal information
for its intended purpose only.
Think Financial will always protect the personal information you share with us.
We maintain physical, electronic and procedural safeguards that comply with federal
regulations to guard your nonpublic personal information. All personal information
you provide online is encrypted using SSL, or 128-bit encryption technology; the
internet standard for secure communication online.
We reserve the right to disclose your personally identifiable information as required
by law and when we believe that disclosure is necessary to protect our rights and/or
comply with a judicial proceeding, court border, or legal process served on our
Web site.
4. Editing or Deleting Your Account Information You may request
deletion of your e-mail address by contacting our webmaster at webmaster@thinkfinancial.com.
Other data that you may have provided to us may continue to remain within our files
at our discretion even though your e-mail is deleted, for product development and
marketing purposes. Please see our Terms of Use for more information.
5. Changes to this Privacy Policy We may make changes to this Policy
from time to time. We will notify you of material changes to this Policy either
by posting a prominent announcement on our site and/or by sending a message to the
e-mail address you have provided to us. We suggest that you visit this privacy policy
frequently so that you are aware of what information we collect, how we use it,
and under what circumstances, if any, we disclose it.
6. Contact InformationIf you have any questions about this Policy
or our web site, please feel free to contact our webmaster at: webmaster@thinkfinancial.com
7. Links to Other Sites This Web site contains links to other sites
that are not owned or controlled by Think Financial. Please be aware that we, Think
Financial, are not responsible for the privacy practices of such other sites.
8. Registration If you provided your email address with the application,
your initial loan decision will be emailed to you within minutes (unless the address
for any Applicant or Co-signer is a California address, in which case California
law requires manual processing of your application, and your loan decision may be
delayed).
Once you have been conditionally pre-approved, we will send you a Credit Agreement
with a detailed list of instructions, either via the mail or online depending upon
the option that you chose. Carefully complete, sign and return the form with the
requested documentation.
If you have any further questions regarding the processing of your loan, feel free
to call our Customer Service Department at the number above, or email us at: info@thinkfinancial.com,
or simply visit us online to view your current loan status. Our Customer Service
professionals will be happy to assist you.
9. Blog If you use our Blog, you should be aware that any personally
identifiable information you submit there can be read, collected, or used by other
users of these forums, and could be used to send you unsolicited messages. We are
not responsible for the personally identifiable information you choose to submit
in this Blog. Think Financial reserves the right to terminate the account of any
visitor that uses these services in a manner inconsistent with our
Terms of Use.
10. CookiesA cookie is a small text file that is stored on a user's
computer for record-keeping purposes. We use cookies on this site to monitor visitor
navigation behavior, and to monitor the efficacy of our advertising campaigns. We
do not link the information we store in cookies to any personally identifiable information
you submit while on our site.
We use both session ID cookies and persistent cookies. We use session cookies to
make it easier for you to navigate our site. A session ID cookie expires when you
close your browser. A persistent cookie remains on your hard drive for an extended
period of time. You can remove persistent cookies by following directions provided
in your Internet browser's "help" file. Here is an explanation on how cookies work.
We use temporary cookies on our site to track the efficacy of our advertising campaigns,
and to monitor visitors' navigation paths within our site. We use persistent cookies
to enable us to track and target the interests of our users to enhance the experience
on our site. Information collected in this manner is in no way connected to non-public,
personally identifiable information. If you reject cookies, you may still use our
site, but your ability to use some areas of our site, such as our loan application
page, may be limited. Some of our business partners use cookies on our site. We
have no access to or control over these cookies.
This privacy statement covers the use of cookies by Think Financial only and does
not cover the use of cookies by any third parties.
11. Log Files As is true of most Web sites, we gather certain information
automatically and store it in log files. This information includes internet protocol
(IP) addresses, browser type, internet service provider (ISP), referring/exit pages,
operating system, date/time stamp, and click-stream data.
We use this information, which does not identify individual users, to analyze trends,
to administer the site, to track users' movements around the site and to gather
demographic information about our user base as a whole.
We do not link this automatically-collected data to personally identifiable information.
While IP addresses are ultimately tied to personally identifiable information, we
use this information for the monitoring of geo-targeted advertising campaigns only.
We use the third-party tracking service Google Analytics that uses cookies and log
files to track non-personally identifiable information about visitors to our site
in the aggregate. This information includes web-traffic statistics, including, but
not limited to, comprehensive site usage and volume data, in order to enhance the
user experience of our visitors.
12. Security The security of your personal information is important
to us. When you enter sensitive information (such as credit card number and/or social
security number) on our registration or order forms, we encrypt that information
using secure socket layer technology (SSL). To learn more about SSL, you can read
about it here.
We follow generally accepted industry standards to protect the personal information
submitted to us, both during transmission and once we receive it. This includes
the use of firewalls, and on-site access-controlled server facilities. No method
of transmission over the Internet, or method of electronic storage, is 100% secure,
however. Therefore, while we strive to use commercially acceptable means to protect
your personal information, we cannot guarantee its absolute security.
If you have any questions about security on our Web site, you can send email us
at webmaster@thinkfinancial.com.
13. Application Forms We use framing and masking techniques when
you are on our application pages. We utilize these techniques to provide a seamless
experience while on our site. Our privacy policy governs the collection and use
of this personally identifiable information.
If you apply for a student loan while on our site; we require that you provide certain
personally identifiable information, including your name, address, phone number,
Social Security number, and employer information. This information is necessary
to process your application and to contact you. The applicant will receive a confirmation
email upon successful completion of our loan application.
14. Social Security Numbers We require your social security number
to provide loan products. When you enter your social security number on our application
form, we encrypt it using secure socket layer technology (SSL). See "Security" above.
We do not collect any nonpublic personal information about you unless you expressly
authorize us to collect such information, such as when you submit a loan application
to us. This information may include your name, address, telephone number, Social
Security Number, and certain personal financial information such as student loan
account balances, payment history, account usage and similar information relating
to your transactions with Think Financial, and is used only to facilitate the performance
of our services.
15. Refer-a-Friend If you choose to use our referral service to
tell a friend about our site, we will ask you for your friend's name and email address.
A one-time email will automatically be sent to your friend, inviting him or her
to visit the site. Think Financial does not store this information except for purposes
of sending this one-time email.
16. Information Sharing and Disclosure Aggregate Information (non-personally
identifiable): We do not share aggregated demographic information about our user
base with our partners or any other companies.
Personally identifiable information: In order to facilitate the processing of certain
financial lending services for you, we pass the personal information you submitted
to a third party - Charter One Bank. These third parties perform a credit check
to determine if you qualify for one of the Think student loan products, and they
use your name and social security number to request a credit report.
Choice/Opt-out You will receive emails from this Web site as noted
in this privacy statement (confirmation emails, loan application status emails,
responses to your emails, and critical service updates.) You may not opt-out of
receiving these communications as they are required to provide our primary services.
If you have any questions or problems related to these communications, please email
us at info@thinkfinancial.com.
18. Supplementation of Information In order to facilitate certain
financial lending services for you, our partners may supplement the information
you submit with information from credit reporting agencies. This supplemental information
is used to determine if you qualify for our student loan products. If you have any
questions or comments in connection with this privacy policy, please contact us
at:
Attn: Customer Privacy
Think Financial Headquarters
26 Mississippi Street, 4th Floor
Buffalo, NY 14203
19. Think Financial is a licensee of the TRUSTe Privacy Program.
TRUSTe is an independent, non-profit organization whose mission is to build user's
trust and confidence in the Internet by promoting the use of fair information practices.
This privacy statement covers the Web site located at www.thinkfinancial.com. Because
this Web site wants to demonstrate its commitment to your privacy, it has agreed
to disclose its information practices and have its privacy practices reviewed for
compliance by TRUSTe.
If you have questions or concerns regarding this statement, you should first contact
Brett Schusterbauer at bschusterbauer@thinkfinancial.com. If you do not receive
acknowledgement of your inquiry or your inquiry has not been satisfactorily address,
you should contact TRUSTe.
TRUSTe will then serve as a liaison with us to resolve your concerns.
We encourage you to be aware when you leave our site and to read the privacy statements
of each and every Web site that collects personally identifiable information.
This privacy statement applies only to information collected by this Web site.