Elective Privacy Notice

This Privacy Notice ("Notice") explains how Gnosis Labs Inc. (dba Elective) and its affiliates Elective Group USA Inc. (collectively, "Elective") collect, use, and disclose your information when you request and obtain our financial products, interact with Elective as a representative of another business, use our website and mobile applications, or otherwise interact with us (our "Services"). We also explain your data privacy rights and how you can exercise them.

1. How Elective collects your information. 

1.1. Information you give Elective.

If you open an account or use the Elective Services, either directly or through a merchant partner or a third-party platform, we may collect the following types of information:

  • Identity and Profile Information. This includes your full name, date of birth, Social Security number, email address, mailing address, phone number, password, and account preferences (if you create an account with us).
  • Financial Information. This includes bank account online login information, bank account numbers, bank account details including transaction history, routing numbers, and/or debit card numbers and credit card numbers that you link to your Elective account or give us when you use the Services. Before permitting you to use the Services, we may require you to provide certain information, including but not limited to your date of birth and Social Security number. We may use this information or other information you provide to verify your identity.
  • Customer Service Interaction Information. We collect information you provide when you engage with Elective's customer service personnel and mechanisms, including through recorded phone calls, chat conversations, surveys, and email correspondence.
  • Marketing and Communications Information. This includes your preferences in receiving marketing communications from us and our third parties (marketing and servicing vendors and merchant partners) and information collected about you through cookies and other tracking technologies described below.
  • Geolocation Information. We may collect or infer information about your general or precise location (including the precise location of your device) when you access or use the Services, or turn on Bluetooth, Wi-Fi, or other geolocation functionality on your device.
  • Usage Details and Device Information. We may collect certain information automatically when you use the Services, including your details about your browser, operating system, or device (such as your MAC address, cookie identifiers, Internet protocol (IP) address, mobile advertising, and other unique identifiers, device ID, Internet service provider, mobile carrier, Internet service provider, location information (including inferred location based off of your IP address), actions that you take while using the Services, information about how you interact with the Services, including the frequency and duration of your activities, information about the links you click, and other information about how you use the Services.

    Much of this information is collected through cookies, web beacons, and other tracking technologies, which may be operated by our partners who assist us in collecting information about usage of the Services, serving ads, or providing other services to you, such as:

    (i) Site operations: Enabling features that are necessary for providing you the Services on our site, such as identifying you as being signed in, tracking content views, remembering your preferences, and the number of times you have been shown an advertisement.

    (ii) Analytics: Allowing us to understand how our Services are being used, track site performance, and make improvements.

    (iii) Personalized advertising: Delivering tailored advertising based on your preferences or interests across services and devices, and measuring the effectiveness of advertisements.
  • Information about Businesses, Non-natural Person Entities (e.g. Sole Proprietorships) and Business Representatives. In addition to the other types of information listed in this section, we may also collect the registered business name, industry field, business address, business email, business telephone number, tax identification number, and ownership percentages.

You can learn more about ad-serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from other companies that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. Note that if you delete your cookies, you may also delete your opt-out preferences.

1.2. Information obtained from third parties.
We may obtain information about you from other sources, including sources that we rely on to enrich our Services, such as service providers, merchant partners, online advertising companies, and social media platforms.

  • Vendors/service providers. This includes vendors we rely on to provide our Services, like IT and security service providers.
  • Third party sources that we rely on to enrich our Services. This includes credit reporting agencies, identity verification, fraud prevention, and similar services.
  • Merchant partners. We may obtain information about you, such as your billing and shipping address, from third parties like our merchant partners you interact with, identity verification services, or public sources, or that we receive from companies that partner with us to provide products and services.
  • Online advertising companies and other advertising and research partners. This includes third parties who may disclose information about your interests, demographic information, and information about the marketing and advertisements you have seen or clicked on.
  • Social media platforms and other publicly available data sources managed by third parties. Elective may have access to your information from your accounts managed by third parties. The information we have access to varies by third party site and is controlled by your privacy settings on that site and your authorization.

2. How Elective uses your information.

2.1 Provide our Services. We use your information to provide our products and Services. For example, we use data to process transactions, resolve disputes, authenticate and verify identities, collect payments, prevent fraud and other illegal activities, customize the Services, and verify the accuracy of data. We may also use data to facilitate your relationship with our merchant partners who you choose to interact with.

2.2 Improve our Services and grow our business. We use your information to understand our customer base, conduct research and analysis, develop new or improved products and Services, in the utilization of artificial intelligence and/or machine learning tools, and build relationships with merchant partners. If you are an employee, representative, or agent of a merchant, vendor, or other business entity, Elective may use the information collected from you in connection with the business relationship between the entity and Elective, or to market a prospective relationship to the entity you represent.

2.3 Respond to your requests. We use your information to provide customer service and support, respond to your questions, comments, and other requests.

2.4 Communications and marketing. We may use information to provide service update notices and to notify you about products, services, and promotions that may be of interest to you, based on your communication preferences. We may combine your information with information we collect from other companies and use it to improve and personalize your experience, including advertising. We may also use your information to facilitate and offer contests and sweepstakes.

We may offer location-based services. In some cases, Elective may directly offer you the opportunity to participate in a targeted advertising experience. We request your permission before collecting and using the location data associated with your identifying information for non-essential activities.

You can change or disable your location data permissions in your device's system preferences or in-app settings. You can also uninstall apps that use location services. We recommend you familiarize yourself with the location capabilities and settings of your device and look into the privacy policies and terms where third-party location-based services are provided.

2.5 Offer, maintain, and improve our website and other online Services. We may process your information to monitor the performance of our Services, improve the user experience, and to ensure the security of our Services.

2.6 Comply with legal and regulatory obligations. We may process your information to comply with our regulatory requirements or in connection with inquiries from regulators, law enforcement agencies, or parties involved in litigation, in each case anywhere in the world, as necessary for Elective to bring claims and exercise defenses, including to enforce the terms of loan agreements and Terms of Service.

3. How Elective discloses your information.

3.1 Affiliates and subsidiaries. We disclose your information with our affiliates and subsidiaries, including information regarding your experience using our Services.

3.2 With Service Providers and Contractors. We engage service providers and contractors to perform functions on our behalf, such as processing transactions, marketing, billing and collection, auditing and accounting, professional services, measurement and analytics services, security and fraud prevention, maintenance and hosting of our Services, and IT.

3.3 With third parties to offer our Services. We disclose your information with certain third parties as necessary to offer and improve our Services, including vendors who assist with identity verification, servicers of loans and lines of credits, partner and underwriting financial institutions, credit bureaus, and other financial institutions.

3.4 With our merchant partners. We disclose your information with merchants you interact with while using our Services to effectuate your transactions, for internal analysis, and improvement of the Services, and to maintain and grow our partnerships with such merchants. When you accept this Notice and use our Services, you consent to us sharing your information with merchants you interact with for those merchants to market to you. We do this to help merchants personalize services and offers, so you can have a better experience.

You can opt-out of information sharing with merchants for marketing by emailing compliance@elective.com. If you opt out, we will continue to share your information as necessary to complete transactions you initiate, but will not share information for marketing purposes.

3.5 With our Advertising Partners. We partner with third parties who assist us in serving advertising regarding the Services. These third parties may use tracking technologies to collect or receive information through the Services and elsewhere on the internet and use that information to provide measurement services and targeted ads. Third parties may allow other companies to access information about you so that they may market other products you may be interested in.

3.6 When required by law. We disclose information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law, and without your consent when it is necessary to protect our customers, employees, or property, in emergency situations, to enforce our rights under our terms of service and policies, or to combat fraud or criminal activity.

3.7 As part of a corporate transaction. Elective may disclose your information in connection with corporate transactions, in the event that Elective enters into, or intends to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Notice.

4. What are your options?

4.1 Notifications. If you no longer wish to receive notifications about our Services, you may change your notification preferences by emailing help@elective.com. Elective reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Elective Service. You are still responsible for any amounts due to Elective even if we close or limit access to your account.

4.2. SMS Messaging. You can opt out of receiving SMS messages by emailing help@elective.com. Again, Elective reserves the right to close or limit access to your account should you opt out of the crucial notices that are required to perform the Elective Service. You are still responsible for any amounts due to Elective even if we close or limit access to your account.

4.3 Access your information. You can review and edit your Personal Information at any time by contacting us at help@elective.com. You can also request to close your account if you do not have an active loan by contacting us at help@elective.com. If you close your Elective account, we will mark your account in our database as "Closed," but will keep your account information in our database to comply with our legal obligations. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or in accordance with this Privacy Notice.

Some states extend specific privacy rights to their residents. Section 7 discusses these rights in more detail below.

5. How we protect your information.

Elective maintains physical, electronic, and procedural security measures to guard against unauthorized access to systems and uses safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and we authorize access to Personal Information only for those employees or agents who require it to fulfill the responsibilities of their jobs.

6. Retention of your information.

Elective will retain your Personal Information for as long as is necessary to complete the purposes for which it was collected, or as may be required by law. California law requires us to provide information regarding the criteria we use to determine the length of time for which we retain Personal Information.

We utilize the following criteria to determine the length of time for which we retain information:

  • The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;
  • Whether we are required to retain the information type in order to comply with legal obligations or contractual commitments, to defend against potential legal claims, or as otherwise necessary to investigate theft or other activities potentially in violation of Elective's policies and procedures applicable to you or against the law, to ensure a secure online environment, or to protect health and safety;
  • The privacy impact of ongoing retention on the consumer; and
  • The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

Individual pieces of personal information such as those listed above may exist in different systems that are used for different business or legal purposes. A different maximum retention period may apply to each use case of the information. Certain individual pieces of information may also be stored in combination with other individual pieces of information, and the maximum retention period may be determined by the purpose for which that information set is used.

7. Your state privacy rights.

7.1 California Residents

Persons with disabilities may obtain this notice in an alternative format upon request by contacting us at compliance@elective.com or by calling Customer Care at +1 (833) 355-2849.

California Shine the Light: Residents of the State of California have the right to request information from Elective regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies' direct marketing purposes. If you are a California resident and would like to make such a request, please email compliance@elective.com.

California Consumer Privacy Act: The California Consumer Privacy Act ("CCPA") (as amended by the California Privacy Rights Act) provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of "Personal Information," as well as the right to know/access, delete, and limit sharing of Personal Information. The CCPA defines "Personal Information" to mean "information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household." Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below:

  • Right to notice at collection regarding the categories of Personal Information collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

Category of Personal Information
Required Information
Personal Identifiers

We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to provide the Services, respond to your requests, and send information and advertisements to you.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

We collect payment information when you provide it to us, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to streamline and facilitate payments and transactions.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

We may collect your Social Security number or Driver's License number. We use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

We collect your IP address and device ID.

Source: Collected automatically when you use our Services.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, other third parties listed under Section 3

Retention Considerations: See Section 6

Protected classification information

We may collect your age.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we collect this information to comply with laws that restrict collection and disclosure of personal information belonging to minors.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

Commercial information

When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.

Source: Collected from third parties as described in Section 1 of our Notice.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements, and offers.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Biometric Information

We collect information about your physiological, biological, and behavioral characteristics.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to verify your identity.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Internet or other similar network activity

We collect information about your browsing history, search history, interaction with websites, and applications or advertisements automatically when you utilize our Services.

Source: Collected automatically when you use our Services.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Geolocation Data

As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device's IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates).

Source: Collected from you when you use our Services.

Purpose of collection and use: Used for purposes listed under Section 2. If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Sensory Data (audio, electronic, visual, or similar information)

If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect your photographic or video image, or similar information.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

Professional or employment-related information

We collect information about your current employer and your employment history.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to conduct background and other screening activities, and to promote our services to others.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

Inferences drawn from other personal information

We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.

Source: Collected directly from you and automatically through your use of our Services.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Services, applications, and tools, and to provide you with targeted information, advertisements, and offers.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, and Other third parties listed under Section 3

Retention Considerations: See Section 6

Category of Personal Information

Required Information

Personal Identifiers
We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to provide the Services, respond to your requests, and send information and advertisements to you.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

We collect payment information when you provide it to us, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to streamline and facilitate payments and transactions.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

We may collect your Social Security number or Driver's License number. We use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

We collect your IP address and device ID.

Source: Collected automatically when you use our Services.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, other third parties listed under Section 3

Retention Considerations: See Section 6

Protected classification information
We may collect your age.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we collect this information to comply with laws that restrict collection and disclosure of personal information belonging to minors.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

Commercial information
When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.

Source: Collected from third parties as described in Section 1 of our Notice.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements, and offers.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Biometric information
We collect information about your physiological, biological, and behavioral characteristics.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to verify your identity.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Internet or other similar network activity
We collect information about your browsing history, search history, interaction with websites, and applications or advertisements automatically when you utilize our Services.

Source: Collected automatically when you use our Services.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Geolocation data
As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device's IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates).

Source: Collected from you when you use our Services.

Purpose of collection and use: Used for purposes listed under Section 2. If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, Other third parties listed under Section 3.

Retention Considerations: See Section 6

Sensory data (audio, electronic, visual, or similar information)
If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect your photographic or video image, or similar information.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

Professional or employment-related information
We collect information about your current employer and your employment history.

Source: Collected directly from you.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to conduct background and other screening activities, and to promote our services to others.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers

Retention Considerations: See Section 6

Inferences drawn from other personal information
We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.

Source: Collected directly from you and automatically through your use of our Services.

Purpose of collection and use: Used for purposes listed under Section 2 above, including we use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Services, applications, and tools, and to provide you with targeted information, advertisements, and offers.

Categories of Parties to Whom PI is "Sold": Not sold

Categories of Parties to Whom PI is "Disclosed": Service providers, Merchant partners, and Other third parties listed under Section 3

Retention Considerations: See Section 6


Last 12 months

Over the last 12 months:

  • Elective collected and disclosed the Personal Information as described in the chart above
  • Elective did not sell your Personal Information

Right to know about personal information collected, disclosed, shared or sold

You have the right to request that we disclose to you the Personal Information we collect, use, disclose, share, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information, we may ask you to take additional steps to verify your request or identity, as described below.

Right to know/access information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request.

Right to know/access information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to information regarding participation in data sharing for financial incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

Right to opt-out of the sale of Personal Information to third parties

Though Elective does not sell Personal Information to third parties, California law requires that we maintain a separate webpage that allows you to opt out of the sale of your Personal Information in the future, which can be accessed by visiting our "Your California privacy choices" webpage, emailing us at compliance@elective.com or by calling us at +1 (833) 355-2849.

Please note that your right to opt-out does not apply to our disclosing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.

We may also disclose information to other entities when required by law or to protect Elective or other persons, as described in our Privacy Notice.

Right to Opt-Out of Sharing Personal Information for Cross-Contextual Behavioral Advertising

You have the right to opt out of sharing your Personal Information with third parties that generate a profile about you for marketing purposes. This information may include Personal Information related to your use of our Services (such as cookie and user identifiers, IP address, and browsing behavior). California law requires that we maintain a separate webpage that allows you to opt-out of sharing this Personal Information for this purpose in the future, which can be accessed by visiting our "Your California privacy choices" webpage, emailing us at compliance@elective.com or by calling us at +1 (833) 355-2849.

Right to Restrict Use of Sensitive Personal Information

You have the right to request that we restrict our use of certain pieces of Personal Information that are considered sensitive under California law—such as information about your race, ethnicity, religion, and philosophical beliefs, financial information to the extent such would enable access to your account, biometric information, and health information. California law requires that we maintain a separate webpage that allows you to restrict the use of Sensitive Personal Information in the future, which can be accessed by visiting our "Your California privacy choices" webpage, emailing us at compliance@elective.com or by calling us at +1 (833) 355-2849.

Right to Correct/Rectify Inaccurate Information

You have the right to correct inaccurate Personal Information that we hold about you under certain circumstances. We may need to verify the validity and scope of the request as well as the scope and purpose of maintaining it. If you are an Elective account holder, you may modify certain Personal Information by visiting our "Your California privacy choices" webpage, emailing us at compliance@elective.com or by calling us at +1 (833) 355-2849.

Right to Non-Discrimination

You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and we will provide more information when we ask you to participate.

How to submit a request

You may submit a request to exercise your rights through the following means:

  • By visiting Your California privacy choices, where you can request specific pieces of information we have collected.
  • By calling us at +1 (833) 355-2849.

Verification procedures

In order to process your request to know about or delete Personal Information we collect, disclose, or sell, we must verify your request. We do this by:

  • Providing personal identifiers we can match against information we may have collected from you previously, and
  • Asking you to confirm your request using the email address or telephone account stated in the request.

If you have authorized someone else to make requests on your behalf, we will require that you provide notarized statements confirming the identity and authority of that person. Such notarized statements can be obtained by emailing compliance@elective.com.

Authorized agent

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.

7.2 Nevada residents. Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. Elective does not sell the Personal Information of its customers. However, if you are a Nevada resident and would like to make such a request, please email compliance@elective.com.

7.3 Virginia residents. Under the Virginia Consumer Data Protection Act, Virginia residents have the right to:

  • Confirm whether Elective processes your Personal Information, and if we do, you have the right to access it in portable format
  • Delete your Personal Information
  • Correct your Personal Information
  • Opt-out of the sale of your Personal Information and the use of it for targeted advertising

This Notice details what Personal Information Elective collects, discloses, and uses as part of our Services. If you are a Virginia resident and would like to make a request, please email compliance@elective.com.

7.4 Biometric data of Illinois and Texas residents. We may collect biometric data, such as a photograph of yourself, to verify your identity. This data will not be stored longer than three years, unless otherwise required by law.

7.5 Connecticut Residents. Under the Connecticut Personal Data Privacy and Online Monitoring Act, Connecticut residents have certain personal data rights, subject to various data and entity exclusions and exceptions. These rights include:

  • To access your Personal Information
  • To correct your Personal Information
  • To delete your Personal Information
  • To transfer your Personal Information
  • To opt out of the sale of your Personal Information, targeted advertising and automated decision making for legal or similar purposes
  • The right to not have your sensitive Personal Information processed, without first providing consent

If you are a Connecticut resident and would like to contact us to discuss your rights, please email compliance@elective.com.

7.6 Colorado Residents. Under the Colorado Privacy Act, Colorado residents have certain personal data rights, subject to various data and entity exclusions and exceptions. These rights include:

  • To access your Personal Information
  • To correct your Personal Information
  • To delete your Personal Information
  • To transfer your Personal Information
  • To opt out of the sale of your Personal Information, targeted advertising and automated decision making for legal or similar purposes
  • The right to not have your sensitive Personal Information processed, without first providing consent

If you are a Colorado resident and would like to contact us to discuss your rights, please email compliance@elective.com.

7.7 Utah Residents. Under the Utah Consumer Privacy Act, Utah residents have certain personal data rights, subject to various data and entity exclusions and exceptions. These rights include:

  • To access your Personal Information
  • To correct your Personal Information
  • To delete your Personal Information
  • To transfer your Personal Information
  • To opt out of the sale of your Personal Information, targeted advertising and automated decision making for legal or similar purposes
  • The right to not have your sensitive Personal Information processed, without notice or an opportunity to opt out

If you are a Utah resident and would like to contact us to discuss your rights, please email compliance@elective.com.

8. Contact Elective.

If you have questions or concerns regarding this Privacy Notice, you should contact us at help@elective.com.

Elective Privacy Notice

Facts
What does Elective do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social security number and payment history
- Transaction history and account transactions
- Credit scores and checking account information
When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Elective chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information
What information does Elective share?
Can you limit this sharing?
For our everyday business purposes--
such as to process your transactions, maintain your account(s), offer or service loans or lines of credit, offer other financial services, respond to court orders and legal investigations, or report to credit bureaus
Yes
No
For our marketing purposes--
to offer our products and services to you
Yes
No
For joint marketing with other financial companies
Yes
No
For our affiliates' everyday business purposes--
information about your transactions and experiences
Yes
No
For our affiliates' everyday business purposes--
information about your creditworthiness
Yes
Yes
For our affiliates to market to you
Yes
Yes
For nonaffiliates to market to you
Yes
Yes

To Limit Our Sharing

You may limit our sharing by emailing us at help@elective.com. You may also call +1 (833) 355-2849.

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice, or earlier if you consent or as permitted by law. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

Questions?

Email help@elective.com or call +1 (833) 355-2849.

Who we are

Who is providing this notice?

Elective

What we do

How does Elective protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Elective collect my personal information?

We collect your personal information, for example, when you
- Apply for a loan or open an account
- Provide account information or pay your bills
- Use your credit or debit card
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only
- sharing for affiliates' everyday business purposes--information about your creditworthiness
- 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.

Definitions

Affiliates

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

Our affiliates include Elective Group USA Inc.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Nonaffiliates we can share with include our merchant partners, third-party platforms, and marketing service providers.

Joint marketing

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

Our joint marketing partners include merchant partners.

Other important information

Special Notice for State Residents

For California Residents. We will not share personal information with affiliates or nonaffiliates except as permitted by California law, such as to process your transaction or with your consent.

For Vermont Residents. We will not share personal information with affiliates or nonaffiliates except as permitted by Vermont law, such as to process your transaction or with your consent.

Facts

What does Elective do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social security number and payment history
- Transaction history and account transactions
- Credit scores and checking account information
When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Elective chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

What information does Elective share?

Can you limit this sharing?

For our everyday business purposes--
such as to process your transactions, maintain your account(s), offer or service loans or lines of credit, offer other financial services, respond to court orders and legal investigations, or report to credit bureaus
Yes
No
For our marketing purposes--
to offer our products and services to you
Yes
No
For joint marketing with other financial companies
Yes
No
For our affiliates' everyday business purposes--
information about your transactions and experiences
Yes
No
For our affiliates' everyday business purposes--
information about your creditworthiness
Yes
Yes
For our affiliates to market to you
Yes
Yes
For nonaffiliates to market to you
Yes
Yes
To Limit Our Sharing

You may limit our sharing by emailing us at help@elective.com.

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice, or earlier if you consent or as permitted by law. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

Questions

Email help@elective.com or call +1 (833) 355-2849.

Who we are
Who is providing this notice?

Elective

What we do
How does Elective protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Elective collect my personal information?

We collect your personal information, for example, when you
- Apply for a loan or open an account
- Provide account information or pay your bills
- Use your credit or debit card
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only
- sharing for affiliates' everyday business purposes--information about your creditworthiness
- 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.

Definitions
Affiliates

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

Our affiliates include Elective Group USA Inc.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Nonaffiliates we can share with include our merchant partners, third-party platforms, and marketing service providers.

Joint marketing

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

Our joint marketing partners include merchant partners.

Other important information
Special Notice for State Residents

For California Residents. We will not share personal information with affiliates or nonaffiliates except as permitted by California law, such as to process your transaction or with your consent.

For Vermont Residents. We will not share personal information with affiliates or nonaffiliates except as permitted by Vermont law, such as to process your transaction or with your consent.