Privacy Policy

This Privacy Policy (“Policy”) describes how Impact Capital Funds, Inc. (“Impact Capital Funds”, “we”, “us”, or “our”) collects, uses, and shares the information you provide when you request to be pre-qualified for a refinance of a qualified education loan; apply to refinance a qualified education loan; request to invest in one of our impact investment funds; access, use, or visit our website; receive our emails; and interact with our ads on other company’s websites (collectively, the “Services”). Information subject to this Policy is referred to as Non-Public Personal Information (“NPI”). This Policy applies to all products and services we offer you and only covers the information we collect, use, and share, including information that we may collect through offline channels, such as phone calls and mail. This Policy does not cover any websites, products, or services provided or operated by third-parties, including any third-party websites, applications or services, that may be accessed through the Services. We suggest that you read this Policy carefully.

As used in this Policy, “you” or “your” refers to you, the individual who visits our websites or uses the Services. By using the Services, you accept and agree to this Policy. If you do not agree to this Policy, do not use or continue to use the Services.

How We Collect Information

We collect information from or about you in various ways, including but without limitation:

- - Directly from you
    - We collect information directly from you such as when you request or apply for one or more of our products or services, use the Services, communicate with us, respond to surveys, or provide us with feedback (including if you report a problem with the Services).
  - Automatically when you use the Services
    - We may collect Device Information, Location Information, Online or Mobile Activity Information (as those terms are defined below) and other information about you when you visit, use or interact with the Services.
  - From vendors or other third parties
    - We may receive information about you from vendors or other third party service providers who work on our behalf in connection with providing the Services.

Additional Information

We may collect information about you from publicly and commercially available sources, as permitted by law. For example, we may receive information about you from a social media site if you connect to us through that site, or if you apply to refinance a qualified education loan, we may receive information about you from a credit reporting agency, based on your consent to conduct a soft credit inquiry. We may combine additional information we receive with personal and other information we have collected about you under this Policy.

Information We Collect

We may collect certain information from or about you, including but without limitation, as described below:

- - When you apply for, request or use our Services, we may collect:
    - Personal Identifiers (for example, your name, email address, phone number, username, or other additional information we or our third-party service providers may ask you to provide or you choose to provide).
    - Professional Information (for example, your title, the name of your employer or other additional information, we or our third-party service providers may ask you to provide or you choose to provide).
    - Financial Information (for example, financial account name and number, balance, transaction history or other additional information we or our third-party service providers may ask you to provide or you choose to provide).
  - When you browse, use, or interact with our Services, we may also collect:
    - Location information (for example, your time zone setting and device location).
    - Device Information (for example, your device type or model, web browser type and version and operating system type and version).
    - Online or Mobile Activity Information (for example, your Internet Protocol (“IP”) address, the domain name of your Internet service provider, your browser data, search history and information about how and when you use or interact with the Services).
    - Marketing Information (for example, your marketing preferences and inferences based on your interactions with us or our third-party service providers).
    - Communications Information (for example, your communications preferences and details or the content of your communications with us or our third-party service providers. Calls from you to us or our third-party service providers and calls we or our third-party services providers make to you may be monitored or recorded for quality assurance, customer service, training or risk management. We may also retain email or other electronic messages or communications you send in any interactions with our customer service agents and our third-party service providers).
    - Survey and Research Information (for example, your responses to questionnaires, surveys, requests for feedback and research activities).
    - Inferences we derive from the information we collect

How We Use the Information We Collect

We may use the information we collect from or about you for various purposes, including, without limitation, the purposes described below:

- - Provide Services:
    - To operate, provide, and maintain the Services (for example, to allow you to request or apply for a refinance of a qualified education loan, invest in one of our impact investment funds, verify your identity, provide customer service, communicate with you, and provide you with tools and features related to the Services);
  - Improve Existing Services:
    - To improve, enhance, modify, add to, and further develop the Services;
  - Advertising and Marketing:
    - To send you offers for special products and services, personalize or customaize your experience with the Services, display online advertising targeting our offers or promotions, conduct market research, and evaluate or improve the effectiveness of our marketing efforts;
  - Conduct Analytics and Research:
    - To examine which parts of our websites you visit or which aspects of the Services you find most useful, evaluate user interface and experiences, test features or functionality, perform debugging and error repair, and analyze your use of the Services;
  - Detect and Prevent Fraud:
    - To determine fraud risk and identify fraudulent transactions;
  - Protect Against Security Risks:
    - To protect against security risks, including by monitoring network activity logs, detecting security incidents, and conducting data security investigations;
  - For Legal Purposes:
    - To carry out legal purposes, including to comply with applicable laws; to respond to civil, criminal, or regulatory lawsuits, subpoenas, or investigations; to exercise our rights or defend legal claims; and to resolve complaints and disputes; and
  - With Your Consent:
    - For other notified purposes with your consent at your direction.

How We Share Information We Collect

Our Privacy Notice gives you certain choices about how we can use and share your personal information. We may share information we collect from or about you for various purposes, including but without limitation:

- - Affiliates, Subsidiaries, or Parents.
    - We may share your information with our affiliates, subsidiaries, or parents when permitted under relevant laws and regulations.
  - Business Partners.
    - We may share your information with companies we work with to offer or enhance the Services. For example, we may share your information with companies to bring you co-branded services, products or programs, or with joint marketing partners, including banks and other financial companies.

- - Service Providers.
    - We may use third-party services providers to provide the Services on our behalf and help us run our business. We may share your information with these third party-service providers or they may collect information on our behalf, for various business purposes. For example, we may use third-party service providers for hosting and securing our information systems or providing website analytics.
  - Credit Bureaus and Other Consumer Reporting Agencies.
    - We may share your information with consumer reporting agencies such as Experian, Equifax, TransUnion, or LexisNexis Risk Solutions to report on or learn about your financial circumstances and for other lawful purposes.

- - Third Parties You Authorize or Direct Us to Share Your Information With.
    - We may share your information with your consent or at your direction.
  - Government Entities and Other Third Parties with Whom We Share Your Information for Legal or Necessary Purposes.
    - We may share your information with government agencies or similar entities for legal and necessary purposes, such as:
      - To respond to requests from regulators or to respond to a warrant, subpoena, government audit or investigation, law enforcement request, legal order, or other legal process;
      - To facilitate a merger, acquisition, sale, bankruptcy, or other change in ownership or control of some or all of our assets or business; and
      - For other legal purposes, such as to enforce our Terms of Service, exercise or defend legal claims, or if we determine disclosure is necessary or appropriate to protect the rights, safety, or property of Impact Capital Funds, you or third-parties related to the Services.

- - Aggregated and De-Identified Information
    - We may share the information described in this Policy in a way that does not allow us to reasonably identify you, with third-parties for analytics or other business purposes. Any information we aggregate or de-identify is no longer subject to this Policy.

How We Use Online Tracking Tools or Technologies

Services

We and our third party service providers (like Google Analytics) may use various online tools and technologies to track non-personal, aggregated information about individuals who click on our emails or visitors who stop by our website. We or our third-party service providers may use online tracking tools or technologies to collect information about your use of the Services including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information, that include but are not limited to:

- - Cookies
    - A web or HTML cookie is a piece of data sent from a website that is stored on your computer by your web browser. Cookies help us to know how you’re interacting with our site. Without cookies, you’d have to fill out your name and password on every new page you viewed. You may set your browser to notify you when a cookie is sent or refuse cookies altogether, but certain features of the Services might not work without cookies. You can control whether to accept cookies or not by adjusting your browser settings to notify you whenever you receive a cookie. You can then choose whether or not to accept it. You can also set your browser to not accept any cookies automatically. To learn more about Google Analytics’ opt-out feature, please visit https://tools.google.com/dlpage/gaoptout/. Please note that Google, not Impact Capital Funds, maintains this page, and we have no control over it.

- - Pixel Tags
    - Pixel tags are images or small strings of code that may be placed in a website, advertisement, email, or other marketing message. They allow companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our third-party service providers may use pixel tags to determine whether you interacted with a specific feature of the Services, viewed a particular advertisement, or opened a specific email. We or our third-party service providers may also use pixel tags to help us recognize users, assess traffic or use patterns, and measure engagement with the Services, advertisements, emails, or other marketing campaigns.

Purposes

We and third-party service providers use the information collected from online tracking tools or technologies for various purposes including analyzing and tracking data, determining the popularity of certain content, delivering advertising and content targeted to your interests (“interest-based advertising”), and better understanding your online activity. We may allow advertisements to be placed on our site by third-party organizations. These organizations may collect web-reporting data on their placed advertisements. We do not directly transmit information to advertising partners, but when you leave our site to go to one of theirs, some partners may capture information such as your incoming IP addresses or referral URL (that is, the address of our webpage). Our website may provide links to the sites of third parties that maintain their own privacy policies. You should review the privacy policy and terms of use of any sites you access.

More Information

If you would like more information about the use of third-party cookies and pixel tags, or the process of opting out, please visit http://www.google.com/privacy.html.

If you prefer not to receive targeted advertising, you can opt out of some network advertising programs by visiting the NAI Opt-Out Page (http://www.networkadvertising.org/choices). Please note that even if you choose to remove your information you will still see online advertisements, but they may be less relevant.

How We Keep Your Information Secure

We use reasonable physical, electronic and procedural safeguards that comply with applicable laws and regulations to protect and limit access to your information. We restrict access to your information to those employees or third parties that need to know your information to provide services to you. From time to time, we enter into agreements with third parties to provide services to us, or to make services and products available to you. If these third parties receive your personal information, we require them to safeguard your information and only use your information for those purposes that we specify.

While we strive to protect your information, no method of data transmission over the internet, mobile networks, wireless transmission or electronic storage of information is 100% secure and we cannot guarantee the security of your information. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us. We are not responsible for circumvention of any privacy settings or security measures contained in the Services.

Opting Out

The information we collect about you helps us provide you with products, services, and experiences that are tailored to your needs.

- - E-mail
    - When you provide us with your email address, we may use it to send you responses or materials you have requested, updates, newsletters, or product offers. If you don’t want to receive marketing materials by email, indicate your preference on the ‘opt-out’ link provided in our email messages or through your Impact Capital Funds account. Opting out in this manner will not affect our ability to send you service or transaction related emails, such as information and summaries about accounts, services, or products you have with us.

Social Media

Personal information that you choose to share on any social media platforms (e.g., LinkedIn, Facebook, Instagram, and Twitter) related to or managed by Impact Capital Funds are subject to the privacy policies and terms of use of those platforms. Please refer to those policies before posting any content to those pages. Please note that you should never provide NPI to Impact Capital Funds through social media.

Children's Online Privacy Protection

Our website and services are intended for adults over the age of 18. We do not knowingly collect any personal information, including NPI, from individuals under 13 years of age. If we become aware that a child under 13 is attempting to submit personal information, we will remove the information from our records and provide notification to the applicant of the violation of our Terms of Service.

Notice of Changes

We reserve the right to update this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed. The effective date, as shown below, indicates the most recent modification or revision.

Questions

If you have any questions about this Privacy Policy, please contact us at (844) 672-2802.

Effective Date

This Privacy Policy was last modified February 15, 2023.