Privacy Statement

Effective Date: May 30, 2023

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We are GreenPath, Inc. d/b/a GreenPath Financial Wellness. We are a not-for-profit financial and credit counseling agency. We empower people when it comes to managing their finances. We provide housing and credit counseling, debt management programs and bankruptcy counseling, and other financial education.

This Privacy Policy explains how we collect, use, share and protect your information. It governs our website and other digital platforms and other forms of our online activity that reference this Privacy Policy. Federal law gives consumers the right to limit some but not all sharing of this information. Please read this notice carefully to understand what we do. This Privacy Policy is part of our Terms of Use. If you do not agree to the practices in this Privacy Policy and our Terms of Use, do not use our products or services.

“Personal Information” uniquely identifies you or can identify you by combining it with other data. It includes your financial and account information, as well as email addresses, phone numbers and other information associated with you. The legal name and definition of personal information differs from jurisdiction to jurisdiction.

Personal Information collected by financial institutions is also called “nonpublic personal information.” This includes information provided by a consumer to a financial institution resulting from any transaction with the consumer, any service performed for the consumer, or otherwise obtained by the financial institution.

What information do we collect?

The types of Personal Information we collect and share depend on the products or services you have with us. This information may include:

• Name, postal address, telephone and email address
• Social security number
• Employment Information, income and assets income
• Credit history and credit scores
• Creditor names and addresses
• Creditor account numbers, balances, interest rates and payment history
• Banking information for use in processing payments
• Information about your transactions and educational programming with us
• Information we receive from your creditors
• Demographic information

When providing housing counseling, credit counseling or debt management services through face-to-face conversations, telephone calls, and e-mail communications, we may request additional information. We may also collect your Personal Information from credit bureaus, our affiliates, or other companies.

When you engage in transactions through our website, we collect information about those transactions, including the amount and timing of payment and the nature of the goods and services involved.

When you visit our website, we collect other data that may not be Personal Information, such as your IP address, your activity on the site, the websites you visited before and after our website, and the type of device you used to access our site.

We do not provide services to or intentionally collect information from individuals under the age of 18.

How do we use your information?

We use your Personal Information to provide you with our products and services, complete transactions, communicate with you, process data for internal administration, ensure data security, and prevent fraud.

We also use your information to better understand your needs and improve our products and services. Our employees and agents may view or access your Personal Information if necessary for the performance of their duties or obligations, consistent with our purposes and subject to this Privacy Policy.

If you conduct transactions through us, we use your payment information only for payment processing and do not retain it for other purposes. We retain it only as long as necessary to complete the transactions or as otherwise legally or contractually required.

We may also use your information to tell you about our other products and services. If you do not wish to receive communications about our other products and services, you can opt-out by following the instructions in that communication. You may continue to receive product or service-related emails unless you cancel the products or services altogether.

We use information collected from visitors of our website and digital platforms to analyze their online behavior and administer our site more effectively. Like many other websites, our site uses “cookies” to track activity within our site and record the IP address of site visitors. A cookie is a small text file stored on your computer, so we recognize you when you return to our site. A cookie or other analytics tools such as Google Analytics may also track information regarding your activities and device, such as the site you just visited, which of our pages you visit, the type of device accessing our site and the locale of the computer for that IP address. These tools provide us with aggregated data about our website and digital platform visitors. You may be able to limit such tools through your browser settings, or for Google Analytics, by downloading Google Analytics Opt-Out Browser Add-on. Such changes may affect your ability to use some or all of our website or digital platforms.

Our website may contain web beacons (also known as “clear gifs”) or similar technologies that gather non-personally identifiable information about your use of the product or website. Such technology may also be contained in e-mail messages or newsletters from us that allow us to determine whether messages have been accessed. The purpose of our use of this technology is so that we may analyze the effectiveness of our marketing efforts and the quality of the website and product.

Apart from these ad-specific choices, there are “do not track” or similar browser choices available to online users, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our website and product will not operate any differently when a “do not track” signal is received.

How do we protect your information?

We seek to use reasonable organizational, technical and administrative measures to protect your Personal Information. Unfortunately, no system can be guaranteed to be secure at all times.

With whom do we share your information?

We do not share your Personal Information with third parties for marketing purposes. In the ordinary course of our business we may share your Personal Information:

• With our employees who need your Personal Information to provide you with services, assistance or communications in the course of their duties, and who are obligated to prevent against its unauthorized disclosure.
• With our third-party vendors and service providers (such as cloud hosting, data management and payment processing) where such sharing is necessary for us to optimize, secure, or deliver the Services to you.
• With your financial service providers and creditors such as banks, saving and loans, credit unions, mortgage bankers, finance companies, and credit card issuers for housing and credit counseling, debt management services, and bankruptcy counseling, as authorized by you. If you have authorized our sharing of this information, you may stop sharing it by calling us at (888) 496-2971.
• With your financial institution or financial service provider who helps make our LearningLab+ educational resources available to you. We share your LearningLab+ usage such as course completion and survey responses with the financial institution or financial service provider that referred you to LearningLab+. If you have authorized our sharing of this information, you may stop sharing it through your Profile Settings or by calling us at (888) 496-2971.
• With our program partners and funders, such as your financial services company or our regulating agencies, with whom we may also share individual information for program audit, evaluation and reporting.
• We may also share aggregated non-Personal Information with our program partners and funders, government agencies, and in some cases your employer for program evaluation and reporting.
• With our affiliates (meaning entities controlled by, controlling or under common control with us). GreenPath, Inc. is affiliated with Homeownership Preservation Foundation, Innovative Financial Solutions, LLC, Consumer Credit Counseling Service of Delaware Valley d/b/a Clarifi, Rural Dynamics, Inc., Consumer Credit Counseling Service of Puerto Rico, Inc., and GreenPath Innovation Design.
• When we have a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our Terms of Use; (3) respond to claims of a violation of the rights of third parties; or (4) protect the rights, property, or safety of others or the public.
• As part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

How do you correct and update your Personal Information?

You may contact GreenPath to review, update and correct your Personal Information by calling us at the number listed below or by sending an email to [compliance@www.greenpath.com].

Questions? Call (888) 496-2971 or go to www.greenpath.com

Last updated: May 30, 2023