Last Updated: February 18, 2019
Innovation Finance USA, LLC ("Company," "Innovation Finance," "we," or "us"), provides commercial equipment leasing and financing services to commercial borrowers for Equipment and software located in the United States of America. We respect your privacy. We are committed to protecting it through our compliance with this policy.
This policy describes:
- the types of information we may collect or that you may provide when you download, register with, access, or use the Company’s QuickFi® mobile application (the “App”); and
- our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy DOES NOT apply to information:
- that we collect offline or on other Company apps or through other websites, including third-party websites you may access through the App; and
- that you provide or is collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the App or Websites (see Third-Party Information Collection).
These other Company websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
The App is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If you believe we might have any information from or about a child under 18, please contact us. If we learn we have collected or received personal information concerning a child under 18 without verification of parental or guardian consent, we will take appropriate measures to investigate and address the issue promptly.
Information We Collect and How We Collect It
We collect information from and about users of our App:
- directly from you when you provide it to us;
- automatically when you use the App; and
- from affiliates, for example, our technical business partners, in connection with the functioning of the App.
Other than the specific list of technical affiliates and bank affiliates listed herein, we do not collect information from, or share your information with, any third-parties.
Information You Provide to Us
When you download, register with, or use this App, we may ask you provide information:
- by which you or your company/employer may be personally identified, such as image of your drivers' license, your name, company's/employer's name, postal address, email address, telephone number, social security number, company tax identification number, drivers' license number, biometric identifiers (see Biometric Information Privacy including a fingerprint, voiceprint or face geometry), any other information the App or Websites collect that is defined as personal or personally identifiable information under applicable law or any other identifier by which you may be contacted online or offline (”personal information”);
- through the camera(s) on your mobile device, by which the Camera access occurs temporarily and specifically after (i) the user triggers functionality that utilizes the camera and (ii) camera access is allowed by the user for the purpose of drivers’ license scanning (user authentication) or the scanning of invoices to be financed or leased (the core function of the App), after completion of which tasks, the camera access is again automatically disabled; or
- about you but individually does not identify you, such as your company's/employer's business or your personal or business income or assets, which credit information is used to evaluate the creditworthiness of the borrower to facilitate commercial equipment loans and equipment leases.
The information we collect includes:
- information that you provide by taking a picture, uploading files, emailing invoices or filling in forms through the App. This includes information provided at the time of registering to use the App, as well as information collected later when submitting materials in connection with continued use of the App, and when requesting additional future services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with the App;
- records and copies of your correspondence (including email addresses and phone numbers), if you contact us;
- details of transactions you carry out through the App and of the fulfillment of your financing. Depending on the amount of publicly available information concerning your company, you may be required to provide additional financial information before or during your application for commercial equipment financing or leasing through the App;
- your responses to surveys that we might ask you to complete for research and service improvement purposes;
- your search queries in the App or on our Websites;
- the names and email addresses of other Company employees entered by the App user in connection with the User’s establishment of his or her authority to bind the Company pursuant to legal financing obligations initiated through his or her use of the App; and
- ANY OTHER TYPES OF INFORMATION THE APP OR WEBSITE USER PROVIDES.
You may also provide information for publication or display (”Posted”) on public or user-restricted areas accessed through the App or the Websites (collectively, “User Contributions”). Your User Contributions (for example, to post user questions, reviews or testimonials for our community) are Posted and transmitted to others at your own risk. We cannot control the actions of third parties with whom you may choose to share your User Contributions, and some sites where such feedback is obtained may be public or controlled by third-parties not affiliated with the Company. Therefore, we cannot and do not represent that User Contributions will be private or will be protected from view by unauthorized persons.
Automatic Information Collection and Tracking
When you download, access, and use the App, it may use technology to automatically collect:
- Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the mobile telephone number.
- Stored Information and Files. The App also may access files stored on your device, such as equipment invoice PDF files to be financed. This only occurs if the user initiates such file access by browsing to such a file and initiating an upload through direct user action in the App.
- Location Information. This App collects real-time information about the location of your device, when a user is being authenticated or when a financing transaction is being processed. For security reasons, the App requires the user to turn on location services to authenticate a user or to process financing or leasing transactions. If the user does not activate location services when prompted in the App, these activities will not function.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
- Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App relating to user authentication, the processing of commercial financing transactions, or other features that rely on cookies to provide a level of user security deemed necessary by the Company.
- Web Beacons. The App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics such as, recording the popularity of certain app content and verifying system and server integrity.
Third-Party Information Collection
In addition to the Company, the only other parties that may access data are technology affiliates of the Company. These firms provide technology components that are integrated into the Company’s App or websites to provide certain capabilities, such as biometric authentication, or optical character recognition of user imported equipment invoices, or blockchain services (for example). When you use the App or its content, these technology affiliates of the Company may use automatic information collection technologies to collect information about you or your device. Technology affiliates of the Company (hereafter, “Technology Affiliates”) include:
- Daon Inc.,
- Jumio Corporation,
- New Relic, and
- other affiliated technical partners that work with the Company from time to time.
Bank affiliates of the Company (hereafter, “Bank Affiliates”) include:
- Wells Fargo,
- Signature Bank,
- MB Bank,
- Sterling Bank,
- Wintrust and
- other affiliated banks that partner with the Company from time to time.
The Technology Affiliates may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites.
While Technology Affiliates and Bank Affiliates of the Company have agreed to comply with the Company’s privacy policies, we do not control these parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Notwithstanding the foregoing, no third parties (in addition to the Technology Affiliates and Bank Affiliates of the Company, referenced above) are given access to any customer information obtained through the websites or the App. The Company does not sell to, or otherwise share customer data with, any third parties except those Technology Partners referenced above, who’s technology enables the overall functioning of the Company’s App and websites.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
- provide you with the App and its contents, and any other information, products or services that you request from us;
- fulfill any other purpose for which you provide it, including but not limited to, evaluating your company’s credit and the credit of any personal guarantor of your company’s credit, for the purpose of obtaining a business loan or equipment lease;
- give you notices about your account, financing applications or contract transactions, including when documents are available for your review;
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- notify you when App updates are available, and of changes to any products or services we offer or provide though it; and
- such other uses and methods as we might employ from time to time in the future.
The usage information we collect helps us to improve our App and to deliver a better and more secure and personalized experience by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our App according to your individual interests;
- speed up your searches;
- provide you with support when you may need assistance with a transaction; and
- recognize you when you use the App to better serve you.
We use location information we collect to help maintain the security of your account and your information by accurately verifying your identity at the time of user authentication and at the time you process loan or lease applications through the system. We may also use your information to contact you about services that may be of interest to you.
Disclosure of Your Information
We may disclose information about our users to Technical Affiliates and Bank Affiliates without restriction.
In addition, we may disclose personal information that we collect or that you provide:
- to subsidiaries and divisions of the Company;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Innovation Finance’s assets, whether as a going concern or as part of an acquisition, a bankruptcy, liquidation, or similar proceeding, in which personal information held by Innovation Finance about our App users is among the assets transferred;
- to fulfill the purpose for which you provide it;
- to a buyer or servicer of your loan or financial obligation originated by us;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to enforce our rights arising from any contracts entered into between you and us, including the App's Terms and Conditions and for billing and collection;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Innovation Finance, our customers or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
- with your consent; and
- for any other purpose disclosed by us.
Your Choices About Our Collection, Use and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
- Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may be inaccessible or may not function properly.
- Promotion by the Company. If you do not want us to use your email address or other contact information to promote our products or services, you should not download, install or use the QuickFi® App, and you should not visit the Company’s websites.
Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to deliver advertisements from the Company, you should not download, install or use the QuickFi® App, and you should not visit the Company’s websites.
- Disclosure of Your Information for Third-Party Advertising and Marketing. Notwithstanding Technical Affiliates and Bank Affiliates described above, we do not sell or otherwise share your information with third party companies for their promotional use.
We do not sell or otherwise share your information with third party companies and we do not control any third parties’ collection or use of your information to serve interest-based advertising. Third parties may provide you with ways to choose not to have your information collected or used. You may opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website http://optout.networkadvertising.org/?c=1.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Accessing and Correcting Company and Personal Information
You can review and change your company and personal information by logging into the App and visiting your Account Settings.
You may send us an email at email@example.com to request to access, correct, or delete any personal or business information that you have provided to the Company. We will not delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete your account, if we believe the change would violate any law or legal requirement, or if the request may cause the information to be incorrect, or in the event that the information needs to be retained in connection with unpaid commercial loan or lease obligations.
If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users. Proper access and use of information provided on the App, including User Contributions, is governed by our Terms and Conditions.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org, or contact us by any of the ways described in the Contact Us section below. We take pride in the relationship of trust we build with our users and we are dedicated to treating your personal information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), members of Innovation Finance do not share customers’ personal or company financial information with non-affiliated third-parties (companies we own or control) or outside companies we do business with, unless the firm is a Technical Affiliate or a Bank Affiliate of the Company. Please review your account profile settings to ensure it matches your wishes, and if not, make changes accordingly or contact us.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
- Encryption & Transmission. Any personally identifiable information will be encrypted using Secure Socket Layer (SSL) technology. The purpose of this encryption protocol is to keep confidential the information passed back and forth between a web server and a mobile device or computer.
- Storage & Protection. We use computer anti-virus software and information you provide to us is either stored on our secure servers behind firewalls to prevent viruses and unauthorized access from individuals and computer networks, or it is stored on a private blockchain with a hash on the Ethereum network.
- Blockchain Security & Accessibility. Each user has data contained in a unique encrypted data block in a private blockchain with a hash on the Ethereum network. Immutable, time-stamped, and geo-tagged records may be kept on user identity, completed contracts and related transactions. Neither you nor Innovation Finance may make changes or modifications to data stored in the blockchain. You or anyone with access to your private key, however, can access data stored in the blockchain, with the corresponding ability to confirm the unaltered state of such data.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with others. When a password is reset, you will be asked to authorize yourself again by using your driver's license, to confirm your continued control of your account following the password reset.
Unfortunately, the transmission of information via the internet, mobile platforms or blockchains is never completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App or any other electronic means. Any transmission of personal information is always at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Biometric Information Privacy
Biometric data is Biometric Identifiers or other information that is related to a person’s human characteristics, which can be used to identify that person ("Biometric Data"). "Biometric Identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.
- How Do We Collect and use your Biometric Data? When you establish a QuickFi® account, you will be asked to provide certain Biometric Identifiers through your smartphone. Innovation Finance will then encrypt your Biometric Data and store it on our data servers, which information we may use to identify you when you use the App. Your Biometric Data is accessed when you log into the App and it may be required at other times that enhance the security of your Company’s account.
- Is Your Biometric Data Secure? Innovation Finance takes your Biometric Data security seriously. We implement industry-standard data security methods to ensure that your Biometric Data is secure.
- Do We Share or Sell Your Biometric Data? We do not sell your Biometric Data to any third parties. We may work with Technical Affiliates and Bank Affiliates to provide you with services through the App. We only share your Biometric Data with a Technical Affiliate if a Technical Affiliate is involved in the biometric authentication process. We only share your Biometric Data with a Bank Affiliate if the Bank Affiliate is involved in the credit underwriting, loan, lease or funding process, and has a need to have it, and only for so long as those needs continue. Innovation Finance has agreements with Technical Affiliates that will receive your Biometric Data that requires them to keep your Biometric Data secret and secure. Bank Affiliates do not typically receive any biometric data from the Company, except in the case of fraud or suspected criminal activity.
- How Long Do We Keep Your Biometric Data? Your account is considered “active” as long as you have registered or made at least one transaction using QuickFi® within the last year. We may delete biometric data after an account become inactive. We may keep your Biometric Data indefinitely, subject to the terms and conditions outlined herein.
- What Happens to Your Biometric Data After You Close Your Account? After you close your account (or your account automatically closes, if inactive for a period of time, determined by the Company), Innovation Finance will typically keep your Biometric Data on file for one year, after which the Company may permanently destroy your Biometric Data, unless there are in-process loan or lease transactions which have not been fully repaid, or other reasons why the Company may elect to keep the Biometric Data beyond one year.
Innovation Finance USA, LLC
Attn: Privacy Department
30 Liftbridge Lane E., Suite 200,