Note: Please note that if we are unable to verify your identity, we may not be able to fulfill your request. A copy of our CCPA Privacy Policy can be found below outlining all rights of the consumer (California resident) under the California Consumer Privacy Act.
California law requires we disclose certain information with respect to our privacy practices. This Privacy Notice is specific to California residents who are users and visitors of our Services (defined below). It explains how Franklin Loan Center and its affiliates with websites that link here (collectively "Franklin," "we," "us," or "our"), collect, share, use, and protect personal information and data we receive through our business activities, website, mobile applications, and other online services and communication channels, including via email, telephone, or our branches (collectively, the "Services"). "You" and "your" refer to any California user or visitor who accesses or uses the Services.
This California Consumer Privacy Act Policy supplements our Online Privacy Policy. Please keep in mind that if you have a financial product or service with us, we will also use and share any information that we collect from or about you consistent with our Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information. The Consumer Privacy Notice shall supersede this California Consumer Privacy Act Policy and our Online Privacy Policy in the event of any conflict.
We may collect the categories of personal information described below and where we believe it is reasonably required for ordinary business purposes. Personal information generally means information that reasonably identifies you or your device, and other information we associate with it.
Note that if you provide us with information regarding one or more other individual(s), you represent that you have their consent to give us their information and to permit us to use their information in accordance with this policy.
1.1 Customer Lending Activities. This section describes the information we collect when you apply for or use, our financial products and services.
1.1.1 Personal information you voluntarily provide: This includes a username and password, contact information (such as name, email address, mailing address, telephone number), and financial account information. We may also collect payment card information, social security numbers, and driver’s license numbers (or comparable), identification that you provide for ordinary business purposes such as user authentication. We also receive information you may provide through the Services (e.g., feedback, inquiries, etc.) and communications between you and us, such as emails, call recordings, or messages regarding the Services.
1.1.2 Transactional information associated with lending and other financial services we provide to you: This includes information relating to account management and other financing and lending activities.
1.1.3 Information received from third parties: We may receive personal information about you from additional online and offline sources and third parties (e.g., credit reporting agencies) to supplement the information we receive from you.
1.1.4 Mobile Activity: When you use our mobile application or otherwise use a mobile device to connect to our Services, we may collect a unique device identifier or other device information to provide the Services and/or functionality. Certain Services may require your mobile phone number, which we may associate with your account and device. We may also collect, use, and store information about your general location. Your personal information and mobile device information (e.g., location and device identifier) may be used for security and user authentication purposes.
All of the above information is collectively referred to as "Customer Lending Activities."
1.2 Job Applicants. This section describes the information we collect when you apply for a job opening with Franklin.
1.2.1 Information you give us. We may collect certain information from and about you in order to evaluate and process that application. This information may include contact information (such as name, telephone number, physical address, email, and other contact details); previous work experience, education, skills, and other qualifications; professional and other work-related licenses, permits, and certifications; work authorization status; information relating to references; information from social media sites if you choose to link your application to a social media; and any other information you elect to provide to us. We may also ask you to provide certain information that we use to further our goal of maintaining a diverse workforce, or to comply with laws, such as information about your race, ethnicity, gender, veteran status, or whether you have a disability. As described in the application process, you are not required to provide this information.
1.2.2 Information received from third parties. We may obtain information about you from platforms used to collect application information, recruiters, references, and former employers. We may use background check services to collect additional information, subject to consent which we will request while evaluating your application. If you submit an application through a third-party job posting service, please note that we do not control the privacy practices of these services. Please review their privacy policies carefully prior to providing application information.
1.3 Business Contacts. This section describes our practices when you interact with Franklin as an employee, representative, or agent of a merchant, vendor, or other business entity. Our disclosure covers information that may be collected about you and not about the business on whose behalf you interact with us.
1.3.1 Information you give us. You may provide us with your full name, email address, office location, phone number, and other contact information.
1.3.2 Information received from third parties. We may obtain your business contact information from the business you represent.
1.4 Online User Activity. We also collect certain information from Customers, Job Applicants, and Business Contacts referred to as "Online User Activity." We use third-party analytics tools to help us measure traffic, usage, and other trends by your use of our Services. We may also use third-party cookies, web beacons, or other similar technologies to collect and store other information about your visit to, or use of, our Services. These tools may capture:
1.4.1 Usage Details about your interaction with our Services (such as the date, time, and length of visits, specific pages or content accessed during the visits, search terms, frequency of visits, and referring website addresses).
1.4.2 Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device's telephone number).
1.4.3 Location information where you choose to provide our website or mobile app with access to information about your device's location.
1.4.4 Site usage and session information. We collect information about your interaction with the Services, including the resources that you access, pages viewed, how much time you spent on a page, and how you reached our website. We also log the details of your visits to our website and information generated in the course of using our website, such as mouse movements, clicks, page visits, text entered, how long you spent on a page, and other details of your actions on our website.
If you do not want information collected through the use of cookies, most browsers allow you to reject cookies, although it can impact your ability to use the functionality or features provided by the Services. You may also turn off the tracking cookies used on our website at the link titled "Consent Preferences" in the footer of any page on this website.
We collect information that identifies, relates to, and describes references, may be associated with, or could be linked, directly or indirectly, with a particular consumer or device, known as "personal information." The information outlined below describes what we have and have not collected from consumers within the last twelve (12) months.
Most of the information we collect about current or prospective customers is in the context of our relationship as your financial institution. As such, this information generally is not subject to state consumer privacy laws and is covered by our [Link to Privacy Policy on Website]. However, in certain circumstances, we may collect information that is outside the context of our financial relationship, in which case it is discussed below.
Note that if you provide us with information regarding one or more other individual(s), you represent that you have their consent to give us their information and to permit us to use their information in accordance with this California Consumer Privacy Act Policy.
How to read this chart:
The categories we use to describe the information are those enumerated in the California Consumer Privacy Act (CCPA); categories listed in the CCPA and not covered here are either not collected or financial information not within the scope of the CCPA. Certain personal information may fall into multiple categories.
We are required to list entities to whom we (1) "sell" personal information; or (2) "share" personal information for cross-context behavioral advertising. Under the CCPA, a business "sells" personal information when it discloses it to a third party for monetary or other benefit. A company may be considered a third party either because the purpose for its sharing of personal information is not for an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for other purposes. A disclosure is not considered a sale if it is authorized by you or otherwise does not meet this definition.
We are required to list entities to whom we disclose information to conduct activities on our behalf. These entities are restricted from using personal information for any purpose that is not related to our engagement.
Note, that we are not required to list disclosures that are infrequent or that are not considered "sales" or "sharing" under the law. Please see Section 4 for more information about how we share your information.
We use personal information and other information for essential and other purposes, as described below.
3.1 We may use the information we collect as we believe to be necessary or appropriate for certain essential purposes, including:
3.1.1 To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our company policies;
3.1.2 To detect, prevent, or investigate fraud, suspicious or other illegal activities;
3.1.3 To enforce our Terms of Use;
3.1.4 To protect our rights, privacy, safety or property, operations, security, and/or that of our affiliates, business partners, you or others; and
3.1.5 To allow us to pursue available remedies or limit the damages that we may sustain.
3.1.6 We may aggregate data we collect on an anonymous basis that does not identify you for any purpose otherwise allowed by applicable law, such as for research, analysis, modeling, marketing, and advertising, as well as improvement of our Services.
3.2 Customer Lending Activity. In addition to the purposes described in Section 3.1, we may also use Customer Lending Activity as follows:
3.2.1 Process account applications and transactions, and facilitate other customer account activities;
3.2.2 Verify your identity or authenticate your device (such as when you access account information or conduct transactions), and to enhance our online security measures and prevent fraud;
3.2.3 Help you efficiently access and manage your information and preferences;
3.2.4 Provide you with customer support, and quality assurance of the same;
3.2.5 Operate and improve our business and operations, including internal administration, auditing and troubleshooting for our Services;
3.2.6 Provide personalized content and information, which could include customized services for you, or offers of various products or services that you may be interested in;
3.2.7 Monitor metrics such as total number of visitors, traffic, and demographic patterns; and
3.2.8 Provide, improve, test, and monitor the effectiveness of the Services, diagnose and fix technology issues, and develop and test new products and features.
3.3 Business Contacts. In addition to the purposes described in Section 3.1, we may use Business Contact Information
3.4 Job Applicants. In addition to the purposes described in Section 3.1, we may use Job Applicant Information as follows:
3.4.1 To solicit applicants for job openings and to process job applications submitted to us.
3.5 Online User Activity. We use information that we collect via cookies to further the business purposes described in Sections 3.2 - 3.4, above. In particular, information collected via cookies is used to understand our customer base, advertise our Services to you and other prospective consumers, monitor the performance of our Services, improve the user experience, and to ensure the security of our Services.
See below in Section 6.2 for your choices regarding cookies.
We may disclose your personal information to a third party for a business purpose. In connection with the provision of our financial products and services, we disclose information of Franklin applicants and customers as described in our Consumer Privacy Notice. When we otherwise 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.
We otherwise do not disclose personal information to third parties without your consent, except in the following circumstances:
4.1 Our legal affiliates;
4.2 Our service providers that we believe need the information to perform a technology, business, professional, or insurance function for us (e.g., IT services, maintenance and hosting of our website, payment processors), but we only provide information so these individuals or entities can perform their required functions on our behalf;
4.3 Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Franklin’s businesses;
4.4 To comply with legal requirements, including, but not limited to, regulatory, court, and law enforcement demands (e.g., subpoenas, court orders, etc.);
4.5 To address fraud, security, or technical issues; and
4.6 To respond to an emergency or otherwise to protect the rights, property or security of Franklin, our customers or third parties.
4.7 Customer Lending Activity may also be shared with:
4.7.1 Our service providers assist in marketing our Services to current or prospective customers.
4.7.2 Where appropriate, we will limit sharing of Customer Lending Activity in accordance with the choices you have provided us in response to our Consumer Privacy Notice and applicable law.
4.8 Business Contact Information may also be shared with:
4.8.1 Our third-party service providers that we believe need the information to perform a technology, business, professional, or insurance function for us, but we only provide information so these individuals or entities can perform their required functions on our behalf;
4.9 Job Applicant Information may also be shared with:
4.9.1 Our service providers that we believe need the information to perform recruiting and related business functions for us, but we only provide information so these individuals or entities can perform their required functions on our behalf;
4.9.2 Advertising partners as described immediately below.
4.10 Online User Activity may also be shared with the partners referenced on this page. You may be able to opt out tracking by cookies or control how information collected by cookies is used via a number of means, as described in Section 6.2 below.
We do not provide a financial incentive or a price or service difference to customers in exchange for the retention or sale of their personal information. We may send hard copy or electronic promotions or offers to customers or other individuals who subscribe to marketing communications, and unless a customer has opted out of such communications, the customer will continue to receive such notices irrespective of whether any information privacy request described here has been submitted. We do not offer financial incentives to deter customers from making such requests.
6.1?Customer Lending Activities:
6.1.1 Information we collect from or about individuals in connection with any Customer Lending Activities is treated in accordance with applicable federal and state privacy laws including the Gramm-Leach-Bliley Act (GLBA) and Fair Credit Reporting Act (FCRA). We therefore use and share any information that we collect from or about consumers of our financial products or services consistent with the disclosures in our Consumer Privacy Notice, posted [ Link Privacy Notice page].
6.1.2 Accessing and Correcting Customer Lending Activities: Keeping your customer account information up-to-date is very important. You may review or update certain account information and transactions by logging in to the Services or by contacting us. You can also adjust certain profile and privacy settings as follows:
6.1.2.1 Account profile: Customers may view or update their profile and privacy settings by submitting a request.
6.1.2.2 Emails: In all promotional emails, you will be given the opportunity to opt out of receiving such messages in the future by clicking on the link at the bottom of the email that says "unsubscribe." It may take up to ten (10) business days for us to process your opt-out request. Please note that even after opting out of promotional emails, we may still send you customer service announcements, administrative notices, and Service-related communications (e.g., account notices, transaction confirmations, and security notices).
6.1.2.3 Text messages: In the event you are enrolled in any service that provides text messages to you, you can opt out of receiving text messages from that service by replying "STOP" to any text message received. You will continue to receive text messages from product lines or services from which you have not opted out.
6.1.2.4 Mobile devices: As with cookies, mobile devices may allow a user to block certain information requests (e.g., location information), but doing so may diminish your experience with our Services. Mobile device or mobile operating system providers typically provide instructions on how to adjust such privacy features.
6.2 Job Applicant Information:
Same as 6.1 above.
6.3 Business Contact Information:
Same as 6.1 above.
Online User Activity information collected by third parties about your visit to, or use of, our Services may be used by those parties for their own purposes, some of whom may be able to associate such information with you based on other information they have collected independently (not from us). When you opt-out as provided below, we will endeavor to block such information collection activities by third parties.
7.1 Rejecting Cookies.?Most internet browsers allow you to block cookies. If you block cookies, your browsing experience may be affected, and you may not be able to use all of the features of our Services. You can delete cookies that are already stored on your computer or device by following the instructions associated with your browser and operating system.
7.2 Opting Out of Tracking Cookies.
7.2.1 We provide all customers and other website visitors with the option of turning off the tracking cookies used on our website by visiting the homepage and clicking on the "Cookie Choices" link. (The California Consumer Privacy Act refers to this as a "Do Not Sell" request.)
7.3 Global Privacy Control. Our website recognizes Global Privacy Control signals, and where required by law treats such signals as an opt-out of tracking cookies.
8. CCPA Rights
If you are a California resident, you have the right to:
8.1 Right to Know. You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it.
8.2 Right to Correct. You also have the right to correct inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
8.3 Right to Delete. Additionally, you have the right to request in certain circumstances that we delete personal information that we have collected directly from you.
8.4 Right to Opt-out of Sale or Sharing of Personal Information. You may opt out of our sale or sharing of personal information to third parties. Please note that your right to opt-out does not apply to our sharing 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.
8.5 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, and financial information to the extent such would enable access to your account, biometric information, and health information.
Please note that if you are a customer or prospective customer, we only collect sensitive personal information in the context of our provision of financial services. Such sensitive personal information is not subject to CCPAs access or deletion provisions.
You may submit a request to exercise your rights by calling us at (760) 779.8100 or ccparequest@franklinlc.com. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
To protect your personal information, we are required to verify your identity before we can act on your request. Thus, we ask you to provide personal identifiers we can match against information we may have collected from you previously, and to confirm your request using the email address or telephone number stated in the request.
10. Response Timing and Format
We will make a good-faith effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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—for example, if your information is not protected by the CCPA because it is financial information. If we do, we will explain that to you in our response.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
11. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
12. Contact Us
Please contact us about this California Consumer Privacy Act Policy or our Services at (760) 779.8100 or ccparequest@franklinlc.com.
13. Effective Date
This California Consumer Privacy Act Policy was last revised and is effective as of 08.2023.
We will make a good-faith effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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—for example, if your information is not protected by the CCPA because it is financial information. If we do, we will explain that to you in our response.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights.
Please contact us about this California Consumer Privacy Act Policy or our Services at (760) 779.8100 or ccparequest@franklinlc.com.
This California Consumer Privacy Act Policy was last revised and is effective as of 08.2023.