Privacy

PRIVACY POLICY

Effective date April 2012

The privacy and security of your personal information is important to CFS. We provide this Privacy Policy to advise you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What personal information does CFS collect?

The types of personal information we collect and share depend on the product or service you have with us, but is clearly stated on our applications. This is information that you, your attorney, or third parties provide to us on applications and other forms, by phone, fax, the Internet, or other delivery services. This information can include: name, address, e-mail address, telephone number(s), your date of birth, social security number, employment and income information, specific medical information pertaining to your personal injury, specific case details and claims information, witness statements and police reports. We may also use your information in order to obtain additional information regarding you, such as credit or consumer reports.

How does CFS share personal information?

We share customers’ personal information in order to run our everyday business, such as to process or administer transactions, provide you with the services you are requesting from us, comply with legal requirements and as permitted by law. Some of this sharing is necessary to provide you with the services you are requesting from us. In the section below, we list the primary reasons we share customers’ personal information; the reasons CFS chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does CFS share?

Can you limit this sharing?

For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations

Yes

For our marketing purposes— to offer our products and services to you

No

For the purpose of trying to get you approved by our attorneys, escrow agents, underwriters, etc. 

Yes

For our affiliates’ everyday business purposes— information related to your transactions and experiences

No


For our affiliates’ everyday business purposes— information related to your transactions and experiences

No

For our affiliates to market to you

No

For nonaffiliates to market to you

No

In many circumstances, sharing information is necessary for us to provide you the services you are requesting. Federal law gives you the right to limit only

sharing for affiliates’ everyday business purposes

affiliates from using your information to market to you

sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

 

***TO BE CLEAR, we never share your information with anyone who is not part of the underwriting/review process.

California: In accordance with California law, XpressCapitalGroup.com will automatically opt out California residents from sharing with unaffiliated companies and will not share information we collect about California residents with unaffiliated companies except as permitted by law, such as with the consent of the customer or to service the customer’s accounts. We will limit sharing with affiliates to the extent required by applicable California law.

Vermont: In accordance with Vermont law, XpressCapitalGroup.com will automatically opt out Vermont residents from sharing with unaffiliated companies and will not share information we collect about Vermont residents with unaffiliated companies except as permitted by law, such as with the consent of the customer, to service the customer’s accounts or to other financial institutions with which we have joint marketing agreements. We will not share application information, consumer report information and information from outside sources about Vermont residents with affiliated companies except with the authorization or consent of the Vermont resident.

How Does CFS protect my personal information?

To protect your personal information from unauthorized access and use, we use reasonable security measures that comply with applicable laws. These measures include computer safeguards and secured files and buildings. Our agreements with service providers or other nonaffiliated companies require them to treat your personal information in a confidential and secure manner.

How does CFS collect my personal information?

We collect your personal information, for example, when you, your attorney, or third parties, such as credit bureaus, affiliates, or other companies provide it to us on applications and other forms, by phone, fax, the Internet, or other delivery services.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

Passive collection of information

While you are on our website, we may automatically track information related to your voluntary use of the website. Such voluntary provided information may include, among other things, URL tracking information, user’s browser, user’s IP address, files viewed by you and your path through the website, date, time and frequency of accessing website and length of time spent reviewing certain features. In addition we may (i) use pixels provided to us by a third party to track the pages viewed, the number of pages viewed, and the number of customer conversions obtained from third parties and marketing agencies, (ii) place a cookie, provided to us by a third party, on your computer that tracks if you click on an advertisement so that future advertisements can be targeted to you based on the advertisements clicked on by you and/or your other activities on the website.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Our affiliates include XpressCapitalGroup.com and Consumer Financial Services

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies

Nonaffiliates we share with can include companies such as money transfer companies, collection agencies, investment and insurance companies, mortgage and brokerage companies, retailers or marketing companies.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Our joint marketing partners include categories of companies such as banks or lending institutions and insurance companies.

Other Terms

We may access or disclose information about you in order to: (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of CFS, our service providers or our customers, including the enforcement of our agreements or policies governing your use of our services; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of CFS’ or our service providers’ employees, customers or the public. We may also disclose personal information as part of a proposed or actual corporate transaction such as a merger or sale of assets.

Through our website, you can link to other websites of third parties that provide useful information, or who have agreed to offer goods and services to our users. Any personal information you provide on the linked pages is provided directly to the applicable third-party and is subject to that third party’s privacy policy.

Revisions to this Privacy Policy

This Privacy Policy may be revised from time to time by XpressCapitalGroup.com. We will provide notice on our website that the Privacy Policy has changed, and will otherwise inform you of any changes to the extent required by law. Amendments to this policy will be effective when posted to our website at