Privacy Policy
ETI Privacy Policy
Your Privacy Is Important to Us
At ETI, keeping your personal information in strict confidence is important to our program. If you have any questions or concerns regarding our policies and practices regarding your personal information, please see the “How to Contact Us” section below.
You Should be Aware of Your Privacy Rights:
We encourage you to read this privacy policy so that you can understand how we collect, use, disclose and protect your personal information. To help you understand our privacy policy, here are some important terms you should know:
“personal information” or “information” means information about an identifiable individual such as contact information, account numbers, or details such as age, marital status, and financial information. This information can be in any form including paper, electronic or voice recording.
“ETI”, “we”, “our” or “us” means ETI.
“permitted or required by law” or “legal and regulatory obligations” means actions that we are permitted or required to do under any laws or regulations, or any rules, codes, guidelines, expectations or requests of any applicable regulator or self-regulatory organization.
About This Privacy Policy
This privacy policy applies to the collection, use and/or disclosure of any personal information collected by ETI in the course of our interactions with you. By providing us with your personal information, you are consenting to our practices as described in this privacy policy.
This privacy policy or our other privacy related documents will be updated from time to time. You are responsible for reviewing this privacy policy periodically to stay current on any changes to this privacy policy. This policy may be found on the ETI website or obtained by contacting our Privacy Officer (see “How to Contact Us”, below).
The effective date of this privacy policy is: September 30, 2020.
The Personal Information We Collect
The type of personal information we collect includes:
- Contact – information that allows us to communicate with or contact you (e.g., address, telephone number, e-mail or other electronic address and fax number).
- Financial – information that allows us to determine third-party eligibility or appropriateness (e.g., employment and financial history with others, income, net worth, and credit reports).
- Transactional – information about how you do business with us (e.g., payment history).
- Relationship – information that helps us to understand more about you including how you like to do business (e.g., language and communication preferences, location and demographics).
- Another Individual – information we request, or that you provide, about an individual other than yourself (e.g., spousal information and employer information). If you provide us with information about another individual, you must have the authority to provide this information and to allow us to collect, use and/or disclose such information in accordance with this privacy policy.
How We Collect Your Personal Information
We collect information from a variety of sources, but most of your personal information comes from you (e.g., loan applications, communications with us and user-generated content on our social media websites). We also collect personal information from other sources such as credit bureaus and references you have provided.
We may monitor or record communications between you and our representatives (e.g., telephone calls, virtual meetings) in order to enhance and maintain our service quality, to protect you and ETI, to confirm our discussions with you and/or for training purposes.
How We Use and Disclose Your Personal Information
We use and disclose your personal information for the following purposes:
Eligibility
- Establishing your identity and determining your eligibility for financial assistance or other program (e.g., checking your credit reports).
Communicating with You
- Sending communications by various methods including mail, email, telephone, fax, or other telecommunication channels (e.g., to contact you regarding payment issues)
Providing You with Value
- Reviewing and analyzing your application(s), transactions and other information to understand you and your business
- Supporting you in promoting your business
- Managing and improving your overall experience with ETI including monitoring, reviewing and/or improving our services and processes
Managing our Business
- Performing our everyday business and operations including record keeping or internal reporting
- Understanding and better managing our activities including conducting market research or analyzing data we hold about you
- To meet tax or legal and regulatory obligations
Service Providers
- Employing third party service providers to assist with the administration and operation of our business. This could include disclosing your personal information with:
- Financial Institutions – Once your third-party funding has been approved, we may be asked to disclose your information to the applicable institution to facilitate the disbursement of your funds (i.e., rent history)
To Protect You
- Where you might be a victim of fraud, financial abuse or other illegal activity or where we have reasonable grounds to believe your interests can best be served by taking action, we may disclose your personal information with the appropriate legal or governmental authorities, your next of kin or any other appropriate person (e.g., notification of our concerns regarding potential financial abuse may be provided to a public guardian or trustee’s office). In these circumstances, we will only disclose information as we believe is reasonably necessary to protect your interests.
To Protect Us
- We disclose information to protect our rights or interests. For example, where we are involved in judicial, administrative or regulatory proceedings or other similar processes, including enforcing our rights under the loan agreement (e.g., to collect on a debt), we may disclose your personal information. In addition, we may disclose your personal information in order to comply with any legal and regulatory obligations including any subpoena, warrant or any judicial, administrative orders or demands.
Protecting Your Personal Information
At ETI, we take the protection of your personal information seriously. We make every reasonable effort to prevent unauthorized use, sharing, loss or theft of your information.
Employees who have access to your information are made aware of the importance of keeping it confidential. Depending on the nature of the information, it may be stored in ETI’s office and computer systems or in the record storage facilities of one of ETI’s service providers.
Where we use service providers who might have access to your information, we select them carefully and require them to have privacy and security standards that are comparable to ours.
We use contracts and other measures with our service providers to maintain the confidentiality and security of your information and to prevent it from being used for any other purpose.
ETI, service providers and other parties to whom we disclose information in accordance with this privacy policy, may perform activities outside of Pennsylvania. As a result, your information may be used, stored and/or accessed in other states. However, all such information will be protected in accordance with this privacy policy. Please note that when your personal information is located outside Pennsylvania, it will be subject to the laws of the state in which it is situated.
Retaining Your Personal Information
The length of time we keep your personal information will vary depending on your individual circumstances. We keep your information for as long as we reasonably need it to manage your loan portfolio or for legal and reasonable business purposes. For these reasons, we may keep your information beyond the end of your relationship with us. When your information is no longer required, we securely destroy it rendering it unable to identify you.
Keeping Your Information Updated
We take care to keep the information in our records as accurate, complete and up to date as necessary for the purposes for which it is used. However, we also rely on you to tell us when your information changes. You may update your personal information using our contact information in the “How to Contact Us” section below.
Accessing Your Information and Addressing Privacy Concerns
You have the right to access personal information we hold about you and to have any concerns you may have over our policies and practices addressed. In addition, you have the right to obtain information regarding our policies and practices with respect to our use of service providers outside Pennsylvania. To access your information, discuss your concerns or learn more about our policies and practices please see our contact information in the “How to Contact Us” section below.
How to Contact Us
Any comments or questions regarding your personal information or our policies and practices with respect to your personal information may be directed to: roach009@gannon.edu.