Privacy Policy

This Privacy Policy (hereinafter referred to 'Privacy Policy') applies to this www.sthreemarketing.com online interface (i.e., website or mobile application) owned and operated by S3 Marketing, LLC ('S3'), and any Company affiliate or subsidiary online interface (each, a 'Site', and, collectively, the 'Sites') (including, without limitation, both mobile and online versions of our site), and also applies to your use of all features, applications, content, downloads and other services that we make available through the site and/or that post a link to this Privacy Policy (collectively, referred to herein as the 'Site'), regardless of how you access or use the Site, whether via personal computers, mobile devices or otherwise. The term 'we' or 'us' or 'our' in this Privacy Policy refers to affiliates or subsidiaries of S3 that link to this Privacy Policy. This Privacy Policy describes how we may collect, use and share information from or about you, and explains how information may be collected and used for advertising purposes. This Privacy Policy is intended to help you understand our online information security practices.

Agreement to this Policy

By using this Site you consent to this Privacy Policy, including your consent to our use and disclosure of information about you in the manner described herein.

Our Commitment To Privacy

Your privacy is important to us. To better protect your privacy we explain our online information practices and the choices you can make about the way your information is collected and used. We make privacy information available on our homepage and on pages throughout our Site.

What Does This Privacy Policy Cover?

This Privacy Policy covers what we do with any personal information you may submit or authorize us to obtain, as well as any other information that we may gather during the course of business and/or when you access any of our Sites. This Privacy Policy also covers any of your personal and other information that any of our business partners may share with us as well as what we may share with third parties.

S3 owns and operates several Sites, as well as a number of Sites and/or domains that point to one or another of our Sites. We may, from time to time, add additional websites and/or domains to our portfolio. Whether or not any particular site is specifically identified in this Privacy Policy, this Privacy Policy applies to any Site owned and/or operated by S3. For more information about our family of companies you may contact us at the email or mailing address below.

Please note that our policies and procedures apply only to Sites owned and/or operated by us and not to websites maintained by other companies or to any website to which we may link or to unrelated businesses with which we may share information.

If by e-mail: [email protected]

If in writing:

S3 Marketing, LLC

222 S Riverside Plaza, Suite 1500

Chicago, IL 60606

The Information We Collect on our Site and Its Uses

This Privacy Policy applies to all information collected or submitted on any S3 Site or affiliated link. On some pages, you make requests and register to receive materials. The types of personal information collected at these pages are: your name, address, email address, state of residence, phone number, amount of unsecured debt, your IP address, your website interaction on the site and how you heard about us. We may use the information we collect about you in order to, but not limited to:

• learn more about your interest in the products or services we and/or our affiliates offer and provide you with information
• engage consumers who desire debt consolidation services
• provide customer service
• learn how to improve our products or services
• provide opportunities for our affiliates and other companies to inform you about the products or services they offer that may interest you
• share aggregated statistical data with our business partners or for public relations (For example, we may tell an advertiser that X number of individuals visited a certain area on our Site, or that Y number of men and Z number of women filled out our registration form, but we would not disclose anything that could be used to identify those individuals.)

Aside from the ways mentioned above, we may use your personally identifiable information in many other ways, including sending you promotional materials and sharing your information with third parties so that these third parties can send you promotional materials. (By “promotional materials,” we mean communications that directly promote the use of Sites, or the purchase of products or services.). However, you may "opt-out" of certain uses of your personal information.

DISCLOSURE OF INFORMATION TO THIRD PARTIES

We may disclose a consumer’s personally identifiable information in order to effect or carry out any transaction that you have requested of us or as necessary to complete our contractual obligations with you. As permitted by law, we reserve the right to sell, rent or transfer your personal information to third parties for any purpose. We may share your personally identifiable information with affiliated companies that are directly or indirectly controlled by, or under common control of S3. We may send personally identifiable information about you to nonaffiliated companies that are not directly or indirectly controlled by, or under common control of, S3. The personal information collected on this site and by third parties will be used to operate the site and to provide the services or products or carry out the transactions you have requested or authorized. We may change or broaden the use of your personal information at any time. We may use your personal information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, banner advertising, and other possible uses.

If you do not wish to have your personal information collected by any third party that is not our agent/service provider, please contact our customer service department to actively opt-out of having your personal information shared by sending us an email at [email protected].

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this Site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We use session ID cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. We can at your option set a persistent cookie to store your passwords, so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our site.

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited. Some of our business partners (e.g., advertisers) use cookies on our site. We have no access to or control over these cookies.

This privacy statement covers the use of our cookies only and does not cover the use of cookies by any advertisers.

Clear GIFS (web Beacons/Web Bugs)

We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Our Commitment To Children’s Privacy

The Site is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Site. We do not knowingly collect information from children under 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA). If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us at our email or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information.

Our Commitment To Data Security

To 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 online

Do You Use My Personal Information to Contact Me Without Permission?

This Privacy Policy constitutes the S3 Do Not Call Policy under the Telephone Consumer Protection Act for all consumers and is pursuant to state law. When you talk with us by telephone your conversation may be monitored or recorded by us. We maintain an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days and will be effective for at least five years from the date of the request. No telemarketing calls will be made to residential or cellular phone numbers that appear on the Do Not Call list.

S3 has a strict “anti-spam” policy for itself and its business partners and vendors. You will not receive S3 e-mails unless you submit your e-mail address to us or register on one of our Sites to receive communications.

You may tell us not to solicit you at your postal mailing address, telephone number or e-mail address. If you elect not to receive marketing offers by postal mail, telephone and/or e-mail, please note that we may continue to contact you as necessary to service your account and for other nonmarketing purposes. We may also continue to provide marketing information in your regular account mailings and statements, including online and electronic communications.

To receive our newsletter via e-mail you must sign up on one of our Sites. If you decide at a later time that you no longer wish to receive our newsletter, you may unsubscribe using the “unsubscribe” link on each newsletter that you receive. If you have any problems unsubscribing, please contact us immediately at [email protected].

Social Security Numbers

When we collect your Social Security number our Privacy Policy (1) protects the confidentiality of Social Security numbers, (2) prohibits unlawful disclosure of Social Security numbers, and (3) limits access to Social Security numbers.

Business Transitions

In the event our company goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You may, in our sole discretion, be notified via email and/or a prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.

California Do Not Track Disclosures

How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Sites or online services?

We currently do not respond to DNT signals in browsers because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different Sites when they visit www.sthreemarketing.com?

No

Notice to California Residents

In response to a California law, we will automatically treat individuals with California addresses or telephone numbers (when disclosed to us) as if you requested us to not share your information with nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us.

Notice to Vermont Residents

In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we not share your information with nonaffiliated third parties, and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

Notice to Nevada Residents

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing [email protected]. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: [email protected]

Notice to Users Outside of the United States

This Privacy Policy is intended to cover collection of information on our Sites from residents of the United States. If you are visiting our Sites from outside the United States, please be aware that your information is transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third-parties with whom we share it as described in this Notice.

Testimonials

If you submit a testimonial to us, we will ask for your permission to post your testimonial prior to any public use. We will post your name as given to us in your testimonial. We may post a photo of you or use a stock photo. Please be aware that any personally identifiable information you submit as a testimonial to be posted can be read, collected, or used by the general public, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to include in any testimonial you choose to submit. If at any time you decide to remove your testimonial, please contact us via e-mail or postal mail.

Your California Privacy Rights

This section applies to any California residents about whom we have collected personal information from any source, including through your use of our Website(s), by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person.

Certain of the personal information that we may process about you may be exempted from the California Consumer Privacy Act (“CCPA”) and certain other personal information may be subject to the CCPA.

For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. Personal information does not include publicly available information or information that has been de-identified. In our descriptions, we have included all data collected without regard to exempt data under other regulations such as the Gramm-Leach-Bliley Act (“GLBA”). However, by doing so, we do not intend to waive claims of preemption under the GLBA and other similar regulations.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information relating to consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records
• De-identified or aggregated consumer information
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (www.sthreemarketing.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, from affiliate marketers who place ads and forward activity to us or from credit reporting agencies (“CRA”).
• Information that is publicly available online or elsewhere and
• Employees and job applicants

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us assist you in debt consolidation activities.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, newsletters and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To assist you in identifying appropriate resources if we cannot serve you for any of a number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt
• To provide a third party with qualified leads for a program that they may administer
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• To conduct audit, compliance or other legal work associated with our business.
• To perform financial reporting and accounting and other general business administration
• To assess third party vendors and services providers
• As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information

Category E: Biometric data

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

Category K: Inferences drawn from other personal information

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

We may also disclose your personal information to a third party for a commercial purpose. When we disclose personal information for a commercial purpose, which may include providing your information to a provider which can assist you, we have a compensatory relationship which requires the recipient to abide by data privacy regulations and not use it for any purpose except as described.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a commercial purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information

We disclose your personal information for a commercial purpose to the following categories of third parties:

• Our affiliates
• Corporate credit facility lenders
• Service providers
• Vendors
• Other third parties including marketers

Your Privacy Rights

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information, to the extent your personal information is not already subject to federal law and the required privacy and security measures applied under federal law:

• Right to Know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
• Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information by us. You may access our Notice of Right to Opt-Out by clicking here
• Right to Data Portability.You have the right to request a portable version of your data.
• Right to Non-Discrimination.You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

You may also authorize someone to exercise the above rights on your behalf. In order to have a third party exercise rights on your behalf as an agent, the third party would need to fill out the same forms as the consumer and have a notarized letter authorizing them to act on your behalf. The agent would also need to be able to have sufficient data to verify the identity of the consumer in question.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws. In order to verify your identity for prospective consumers, you must provide first and last name, state of residence, phone, physical address and email. If you are a current customer, you must also provide the social security number or other identifying account number in addition to the items required for prospective consumers.

If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways:

• CCPA Request Form
• 800-583-5654
• [email protected]

Notice of Right to Opt-Out

You have the right to direct S3 not to sell your personal information and to refrain from doing so in the future. If you wish to opt-out of such sales, please do so in one of the following ways:

• CCPA Request Form
• 800-583-5654
• [email protected]

Please consult the other sections of our Privacy Policy for further information on our practices regarding your personal information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We will not jeopardize your privacy. The provisions contained in this Privacy Policy supersede all previous notices or policies regarding our privacy practices with respect to this site. Any and all changes will be made here, to this Privacy Policy.

We encourage you to check our site frequently to see the current Privacy Policy to be informed of how we are committed to protecting your information and providing you with improved content on our Site in order to enhance your online experience. Upon any material changes to the policy statement, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

How To Contact Us

Should you have other questions or concerns about the privacy policies, please send us an email at [email protected]

Effective 4/2020