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Progressive Leasing

Privacy Policy

Last Updated: February 9, 2024

Your privacy is important to us at Progressive Finance Holdings, LLC, Prog Leasing, LLC, Approve.Me LLC, and their affiliates (collectively “Prog Leasing,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights.  This online privacy statement (the “Statement” or “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our websites (collectively, the “Site”), our application, when you view or interact with Prog Leasing social media accounts or any social media accounts or content affiliated with us, and when you interact with us as a customer or otherwise (collectively, the “Services”).

For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations.  It does not include data excluded or exempted from those laws and regulations.  Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Prog Leasing generally or in any specific context.

This Policy expressly incorporates any privacy notices we may issue to supplement this Policy.  Depending on your residency, a supplemental privacy notice may apply to you.  For example, if you are a California resident, please view our California Privacy Policy.  If you are an employee or job applicant, please see our Employee Privacy Policy.

1.  You Consent to This Statement

You should read this Statement carefully, so that you understand our privacy practices.  By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement.  If you do not agree to this Statement, you may not use the Services.

This Statement applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data.  This Statement supplements these other notices and is not intended to override them.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

2. What Types of Information Do We Collect? 

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties.  The categories of personal information that we collect and the purposes for which we collect that information are described below.

Categories of Personal Information We Collect

The following list describes the categories of personal information we collect.

  • Analytics Information. We collect certain analytics information automatically as you navigate our Services.  This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails.  For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below.  We collect this information for the purposes of account management, advertising and marketing, analytics and research, customer service, providing lease and purchase services, and website security and maintenance.
  • Biometric Information includes imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, or voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted. We collect this information from our third party service providers when you provide it directly to such providers when you sign up or apply for Prog Leasing’s products or services or create an account.  We collect this information for the purposes of complying with our legal and regulatory compliance obligations, policies, and procedures.
  • Contact Information includes name, email address, and phone number. We collect this information when you provide it directly to us such as signing up for newsletters, requesting information about Prog Leasing services, creating an account, or filling out a form. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
  • Leasing and Purchase Information includes information you provide when you apply to lease products. This information includes name, email address, social security number, bank account details, banking history, credit bureau reporting information, income, a credit or debit card, and date of birth.  You may also need to create an account with a user name and password.  We collect this information for the purposes of account management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
  • Payment Information includes name, address, phone number, bank account details, and debit or credit card information. We, or our service providers, collect this information for the purposes of account management, customer service, providing leasing and purchase services, and website security and maintenance.
  • Social Media Information includes information that you post by sharing on a blog or another social media platform. We collect this information when you provide it directly to us.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.  We collect this information for the purposes of advertising and marketing, and analytics and research.
  • User-Generated Content. If you post, upload, comment, or otherwise submit content on the Services, we may collect certain information about you such as your name and email address and products you may have purchased.  Be aware that as a default, any information you post on the Services, including without limitation reviews, comments, and text, may be available to and searchable by all users of the Services.  We collect this information for the purposes of advertising and marketing, and analytics and research.

Purposes for Collection of Personal Information

The following chart identifies the purposes for which we may collect your personal information, as well as information regarding our use and disclosure of that personal information.  Please note that we may not collect each category of information about each user of our Services.

For the chart above, the following definitions apply:

  • Analytics Providers means a provider of analytical tools which may include cookies, tracking pixels, tags, or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails. Please refer to the “Analytics, Performance, and Research” row of the cookies chart below for more information about Analytics Providers we use.
  • Retail Providers means third party merchants who supply the underlying product or service that is the subject of the current, potential, upcoming, or former lease and/or Services you obtain from us.
  • Service Providers means third party vendors who process personal information on our behalf in connection with the Services and with whom we have entered into a written contract.
  • Third Party Advertisers means third parties whose services or tools, such as cookies or pixels, we use to deliver relevant ads, track ad campaign performance, or track email marketing.

Other Ways We May Collect, Use, or Share the Information 

We may also reserve the right to collect, use, or share personal information for the following purposes:

  • For Legal Purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful or unlawful user activity on this site.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.Business Transactions or Mergers.  We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.  Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence.  If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
  • Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
  • Improving Our Services. We use your information to improve our Services, which may include processing the information as part of machine learning and artificial intelligence developments.
  • Information From Our Partners. We may collect information from our business partners, as well as our affiliates, subsidiaries, joint ventures, or other companies under common control.  We may combine that information with other information we collect about you, but we will always use the information as described in this Policy.  We may also share information with our affiliates, subsidiaries, joint ventures or other companies under common control.

3.  How Do We Use “Cookies” and Other Tracking Technologies? 

We may send one or more cookies to your computer or other device.  We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services.  This information allows us to understand how you use the Services.

What Are Cookies?

Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website.  When you access our Services, we use cookies and other tracking technologies to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Services according to your individual needs;
  • Contact you to provide you with information or services that you request from us;
  • Advertise new content, events, and services that relate to your interests;
  • Provide you with more personalized content that is most relevant to your interest areas; and
  • Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties.  You can manage your cookies preference as described in the “Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers.  Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.

We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Services until the end of that particular browsing session.  These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser.  These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie.  Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies.  If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.

You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.

Does the Site Respond to “Do Not Track” Signals?

We recognize the Global Privacy Control.  Your browser must be able to support the Global Privacy Control (“GPC”) for us to recognize your opt-out preference signal. 

4.  Colorado, Connecticut, Virginia, and Utah Users’ Rights

Colorado, Connecticut, Utah, and Virginia residents have certain rights with respect to their data.  These rights are established through the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).  The chart below explains these rights and lists the states whose residents may exercise those rights.  To exercise any of the following rights listed in the chart below, please email us using the information set forth in the “Contact Us” section below.

Sensitive Information

Sensitive Data as defined in the CTDPA, UCPA and VCDPA includes precise geolocation and biometric information.  For the purposes of serving you relevant advertisements based on your location, we collect geolocation information to perform geofencing.  We will not collect geolocation information from Connecticut and Virginia residents without first obtaining consent, and we will not collect biometric information from any consumers without first obtaining consent.  Utah residents have the right to opt out of our collection of geolocation information.

Exercising Your Rights

If you are a Colorado, Connecticut, Virginia, or Utah resident and wish to exercise one of the above rights and it applies to you, please visit our Data Subject Request or Your Privacy Choices pages.

If necessary, we may request additional information reasonably necessary to authenticate you and your request.

In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights.

We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay.  If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.

We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside.  We may charge a fee in:

  • Colorado, Connecticut, and Utah, if you make more than one request in a twelve-month period; and
  • Connecticut and Virginia, if the request is manifestly unfounded or excessive, or repetitive in nature.

Appealing a Rights Request Decision

If you are a resident of Colorado, Connecticut, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision.  To do this, you may call 877-898-1970 between 9 a.m. and 5 p.m. Mountain Time, Monday through Friday or email us at privacy@progleasing.com.  In the email appeal, please specify the right(s) you requested to exercise and the date you made such a request.

We will inform you in writing within 45 days of any action taken or not taken in response to the appeal.  We will also provide a written explanation of the reasons for our decisions regarding your request(s).

5. Nevada Users’ Rights

Under Nevada law, certain Nevada consumers may opt out of the sale of certain personally identifiable information for monetary consideration to a person for that person to license or sell such information to additional persons.  We do not sell personally identifiable information under Nevada law.

If you are a Nevada resident who has purchased or leased goods or services from us, you may (A) submit a request to opt out of any potential future sales, and/or (B) request changes to your Covered Information by emailing us at privacy@progleasing.com.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.

6. Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared. We may communicate with you via email, telephone, postal mail, and/or your mobile device about our products and services. If at any time you would like to unsubscribe from receiving future marketing emails, you can email us at privacy@progleasing.com or follow the instructions at the bottom of each applicable email, and we will promptly remove you from those marketing correspondences that you choose to no longer receive.  Please note, however, that we may still need to contact you regarding other matters.

7.  How Long Is Your Personal Information Kept

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided.  We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.

If you use our mobile application, you can delete your app, but that will not delete your account or your profile.  You may submit a request to delete your mobile app profile information by emailing privacy@progleasing.com or calling 877-898-1970 between 9 a.m. and 5 p.m. Mountain Time, Monday through Friday.  Prog may not delete your underlying account information for legal and business purposes.

8.  Our Commitment to Data Security

The security of your personal information is important to us.  We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.  If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

However, we cannot and do not guarantee complete security, as it does not exist on the Internet.

9.  Where Your Personal Information Is Held

We process personal information on our servers in the United States of America, and may do so in other countries.  If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

10.  Third Party Links

Prog Leasing’s Services may contain links to third-party websites.  When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within.  It is important to note that this Statement only applies to Prog Leasing’s Services.  We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites.  We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

11.  Children’s Privacy

Protecting the privacy of the very young is especially important.  Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13.  In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information.  If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact Us” section below.

12.  Policy Changes

This Statement may change from time to time.  If we need to change this Statement at some point in the future, we will post any changes on this page.  If we make a significant or material change to this Statement we will notify you via email.  You should check these terms when you use the Site.  Your continued use of the Site constitutes acceptance of the most current version of this Statement.

13.  Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@progleasing.com, via phone at 877-898-1970, or by mail at the following address, 256 W Data Drive, Draper, UT 84020, ATTN: Privacy Office

23-707301

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