Last Modified: June 27, 2023
- What Personally Identifiable Information is collected from you through our Site or in the course of rendering our Services, how it is used, and with whom it may be shared.
- What choices are available to you regarding the use of your data.
- The security procedures in place to protect the misuse of your information.
- How you can correct any inaccuracies in the information and request to be forgotten.
1. Information Collected in the Course of Rendering Services
We collect your personal information, for example
- When you apply for a loan
- Information we receive from you on other forms (such as your name, address, social security number, assets and income);
- Information about your transactions with us or others (such as your account balance, payment history, parties to transactions, and credit usage); and
- Information we receive from a consumer reporting agency (such as your creditworthiness and credit history).
We may disclose information about you and transactions: (a) where it is necessary or helpful to effect, process or confirm your transactions; (b) to verify the existence, history and condition of your account for credit reporting agencies; (c) to comply with legal process, such as subpoenas and court orders; (d) to law enforcement authorities if we believe a crime has been committed; (e) if you give us your consent; and (f) as otherwise permitted by law.
2. How We Protect Information Collected in the Course of Rendering Services
Founders First restricts access to your personal and account information to those employees who need to know that information in order to provide products or services to you.
- Security Measures: To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards.
- Employee Training: Founders First requires and trains its employees to comply with its privacy standards and policies, which are designed to protect customer information.
- Impact Reports: We publish reports that include aggregate de-identified personal information or offer for purchase de-identified data regarding businesses that receive our services. You have the right to opt out of the sale of your personal information in published Impact Reports by contacting us at email@example.com.
3. Information We Collect from Site Visitors
Like most websites, we may also use automatic data collection technology when you visit the Site, such as Google Analytics Tracking, to record information that identifies your computer, to track your use of our Site, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site (the “Usage Information”).
We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Site, but may not be able to use or maximize the functionality of some areas of the Site.
- How We Use Information Collected from Site Visitors
FFCP’s mission is to solve racial and social economic equity gaps that prevent businesses led by diverse founders from growing profits, premium wage jobs and wealth creation in their communities. We accomplish this by helping businesses get financing. We use personal information we collect about prospective member companies applying for financing. This allows us to understand the business as a whole so that we can make the best investment decision for ourselves and for the company seeking financing. This internal use includes sharing information among our employees, contractors, attorneys, capital providers (investors & lenders), and our Investment Committee.
In addition, we may use the personal information we collect for the following purposes:
- Support and Services: to provide our Services, operate our Sites and online services, and interact with you about your application, account or funding; to communicate with you about your access to and use of our Site and Services; to respond to your inquiries; to provide troubleshooting, process and collect your payments; provide technical support; and for other customer service and support purposes.
- Improving our Business: to better understand how users access and use our Services and Site, to evaluate and improve our Sites, Services and business operations, and to develop new features, offerings and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to monitor consumer interest in our products and Services; to troubleshoot problems that may arise on the website; to improve the accuracy of our customer database; to increase our understanding of our customer database; to increase our understanding of our customers; and for other research and analytical purposes.
- Personalization: including tailoring content we send or display on our websites and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. To assist in these purposes, as well as the other purposes identified in this Policy, at certain times, we create a profile relating to you in order to show you the content that we think you might be interested in and to display the content according to your preferences.
- Advertising, Marketing and Promotional Purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services, products, or other information we think may interest you; to identify potential new customers; and to administer promotions, sweepstakes, contests or other special promotions.
- Securing and Protecting our Business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
- Defending our Legal Rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
- Auditing, Reporting, Corporate Governance, and Internal Operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
- Complying with Legal Obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.
- How We Share Information Collected from Site Visitors
Although we may need to provide your information to trusted third parties to the extent necessary to optimize our Site and the user experience, we will not sell or trade this information to outside parties. Specifically, we may share or disclose your Personally Identifiable Information in the following ways:
- Service Providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, customer service and/or support providers.
- Subsidiaries and Affiliates: We may share your personal information with our affiliated companies (i.e., our parent company and other companies under common ownership, control or management with us); they may use such personal information for the purposes set out in this Policy.
- External Partners: We may also join together with other businesses to bring selected opportunities to customers or potential customers. For example, we may share client information with external partners who can provide additional financing options. You may opt out of such sharing as explained in the Choices and Rights section below.
- Legal Compliance: We may share personal information where necessary to comply with a law, legal obligation or legal process, such as in response to a valid court order, subpoena, or government investigation. In addition, we may share certain personal information in order to protect the rights, property and safety of our company and/or others, in support of our compliance with tax or corporate governance legislation, to assist law enforcement, for debt collection purposes, for loss and fraud prevention, or to regulatory or other governmental authorities with jurisdiction over us or our affiliates. Finally, we may share your information to comply with our obligation to comply with fair lending laws and other regulations related to the services that we provide.
- Business Transfers: We may disclose and/or transfer personal information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
- Protect our Rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect the rights, property or safety of FFCP or our affiliates, clients, customers and/or others.
- Aggregated and De-identified Data: We may share aggregate or de-identified information with third parties for research, analytics and/or other purposes.
- How We Protect Information from Site Visitors
We take commercially reasonable steps to protect your Personally Identifiable Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
To help prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect, including, but not limited to, the following:
- Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit as safe as possible.
- We implement a variety of security measures when a user makes a contribution , submits, or accesses their information to maintain the safety of your Personally Identifiable Information.
- In addition, information you supply is encrypted via Secure Socket Layer (SSL) technology.
While we use systems to protect sensitive information transmitted online, we also protect your information offline. Only authorized agents of FFCP who need the information to perform a specific job (i.e. to operate, develop, improve or support our Site and/or programs) are granted access to Personally Identifiable Information and are required to keep the information confidential.
- Links to Third Party Sites
- California Users
Our Site is not intended for children under thirteen (13) years of age. No one under the age of 13 may provide any personal information to, or on, the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site, or on or through any of its features/functionality, or engages in services provided through the Site, use any of the interactive or public comment features that may be available on this Site, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.
If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
California Consumer Privacy Act (“CCPA”). Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. In general, we may (i) collect and (ii) disclose for a business purpose, the following categories of personal information (as defined by the CCPA) about California residents: (a) identifiers: such as a real name, alias, address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers; paper and electronic customer records containing personal information, including without limitation, name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information; characteristics of protected classifications under applicable state or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information; commercial information, including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies; internet or other electronic network activity Information: including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement; geolocation data; employment history: professional or employment-related information; education information that is not publicly available personal information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99); profiles and inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
We collect these categories of personal information from the sources described in the Information We Collect section above, and for the purposes described in the Disclosure of Personal Information section above.
The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration. We may “sell” (as defined by the CCPA) the above categories of personal information to third parties, such as our business partners so they may contact you with information, products and services for your business. We also may make certain categories of personal information available through third party cookies and tags to collect browsing history and other information on our Sites to improve and measure our ad campaigns, including (a) identifiers such as a real name, alias, address, unique personal identifier, online identifier, IP address; and (b) internet or other electronic network activity Information: including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
California Residents’ Rights. Subject to certain exceptions, California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below. FFCP will respond to requests from California residents to the extent required by the CCPA.
- Do-not-sell: California residents have the right to opt-out of our sale of their personal information. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.
- Notice before collection: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
- Request to delete: California residents have the right to request, at no charge, deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
- Request to know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties/with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose; and
- categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
California residents may make a Request to Know up to twice every 12 months, at no charge. We will respond to verifiable requests received from California residents as required by law.
California residents may submit requests under the CCPA:
- Via email at email@example.com
- By phone at (858) 264-4102
We will respond to verifiable requests received from California residents as required by law. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA.
- Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. There are five (5) core principles of Fair Information Practice: (i) consumers should be provided notice of whom the information is going to and what it will be used for; (ii) choices should be offered and consent required; (iii) consumers should be able to access and alter data; (iv) data should be accurate and secure; and (v) mechanisms in place for enforcement and redress are necessary. In order to be compliant with Fair Information Practices we will take the following responsive action, should a data breach occur:
- We will notify you via email within seven (7) business days.
- We will notify users via in-site notification within seven (7) business days.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
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