EZCarLoans: Privacy Policy 1


                         EZCarLoans.com: Privacy Policy

                                Roger Michaels

                               Full Sail University
                                                                   EZCarLoans: Privacy Policy 2


The purpose of our web sites is to collect auto-loan credit applications from credit challenged

individuals, and resell them to local dealerships as prequalified leads. The sites offer special

financing, and require interested visitors to submit personal, sensitive information for loan pre-

approval. These applicants want reassurance that their data is transmitted and kept safely and

securely. For this reason, and to help ensure compliance with federal law, it is important to have

a well-written privacy policy in place. In addition to identifying who we are and what we do, the

policy will address why and how we collect data, whom we share it with and how we safeguard

the data we collect. And a privacy policy would not be complete without easy opt-out

instructions. This report identifies and evaluates key elements of an efficient privacy policy, and

demonstrates the significance of the policy’s provisions in relation to the offered services.
                                                                  EZCarLoans: Privacy Policy 3


All privacy policies should begin with a paragraph that identifies the company requesting and

handling their personal information, and should aim to reassure applicants that their privacy is

taken seriously. The following paragraph is an example:

EZCarLoans.com is an ABC Company web site property. ABC is an online lending marketplace

that connects car buyers seeking financing with dealers and lenders who can help them. ABC

values our customers’ trust and confidence and is dedicated to protecting the privacy of your

personal information.

Information Collection

The next section answers the ‘what and how’ questions, and should address what type of

information we collect and the method of collection. This is also in compliance with the Fair

Credit Reporting Act (FCRA), a Federal law that promotes the accuracy and privacy of

information in the files of the Nations credit reporting companies (www.ftc.gov). Here is an


        In order to match you with appropriate lenders and/or affiliates, you will provide

        certain personal information such as name, address, e-mail address, social

        security number and income. This and other information such as your credit

        history and credit score will be obtained by ABC and provided to certain

        participating lenders and affiliates for a loan decision. We Collect Information

        about You from the Following Types of Sources:

           Applications, questionnaires and other forms you submit (information such as

            your name, address, social security number, assets and income).
                                                                  EZCarLoans: Privacy Policy 4

          Credit bureaus (to determine your eligibility for credit or other financial


          Public sources, including census data and real estate records.

          Web-based tools when you visit our Web sites, including "cookies."

          Telephone calls, which we may monitor or record when we communicate with


Information Sharing

Applicants want to know who will be eyeballing their personal information. Our business

depends on collecting applications and sharing them with our business partners. The next

paragraph in our privacy policy should outline exactly to whom we may disclose information

that we collect. For example:

       We May Disclose Information that We Collect as Described Above to the

       Following Entities:

              Financial service providers, such as securities broker-dealers or

               insurance companies.

              Non-financial companies, such as retailers, data processors, and


              Carefully selected business partners (e.g., so they can alert you to their

               products and services).

              Companies that perform marketing services on our behalf or to other

               financial institutions with which we have joint marketing agreements

              Other third parties, including non-profit organizations, as required or

               permitted by law, or when you permit us to share information about you.
                                                                  EZCarLoans: Privacy Policy 5

Information Security

Perhaps the most important element of any privacy policy is the reassurance that the sensitive

information provided by applicants is kept secure and confidential. This section describes when

and how we safely collect and store personal data, who has immediate access to this data, and for

how long this data is stored. Furthermore, The FTC’s Safeguards Rule specifically requires every

dealer, regardless of the size of his dealership, to develop, implement and maintain a

comprehensive written information security plan that describes the dealership’s program to

protect customer information (www.niada.com). The following paragraph is an example that

explains how the company will attempt to adhere to these rules:

       We safeguard your personal data (e.g., credit card and finance application

       information) during electronic transmission from you to us using known

       encryption, security standards and procedures. We restrict access to non-public

       personal information about you only to those individuals who need to know that

       information in order to provide products or services to you. We maintain

       physical, electronic and other procedural safeguards to comply with applicable

       privacy laws to guard your nonpublic personal information. We also assess new

       technology for protecting sensitive customer information on an ongoing basis.

       However, if your information is forwarded to a dealership or other third party

       provider, your information will be transmitted according to the security and

       privacy policies of that dealership or third party provider whose privacy practices

       may differ from ours. Your information as shared with outside providers will

       become subject to those different privacy policies. Due to federal and state

       regulations, we are required to keep a copy of your information for a period of 3
                                                                 EZCarLoans: Privacy Policy 6

       years. Over this period, we will maintain all such data in a confidential and

       secure area that third parties will not be allowed to access.

Opt-Out Instructions

Another important element of any privacy policy is a section that clearly explains how users can

opt-out from future correspondence. This portion is usually found at the end of the privacy policy

notice and contains contact information, including e-mail, phone and mailing address. The

following paragraph is a good example:

       We provide you the opportunity to ‘opt-out’ of having your personally identifiable

       information used for certain purposes, when we ask for this information. For

       example, if you complete our loan application but do not wish to receive any

       additional marketing material from us or our partners, you can indicate your

       preference to opt-in or opt-out on our application form. You may opt-out of any

       special promotions or offers at anytime by sending an email requesting to opt-out

       to admin@ezcarloans.com. You can also call us at 1-800-EZCARLOANS or write

       to us at:

               ABC Company
               123 Main St.
               Orlando Florida 32807.
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A well-written and prominently-displayed privacy policy with the proper elements will help

reassure our site users that the information they choose to share with us is collected, stored and

distributed in a safe and secure manner. The policy will also clearly provide options that users

can exercise to control that information. Privacy policies become important both to online

entities as well as individual users. Easy to find and understand disclosures of information

practices will help build consumer trust and relationships; while at the same time create means

by which online users can evaluate sites, exercise choice, and control the collection and

subsequent use of personal information (www.bbbonline.og).
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FTC. The Fair Credit Reporting Act (n.d.) Retrieved from

NIADA. Compliance with the Federal Trade Commission’s Safeguard Rule (n.d.) Retrieved
     from http://www.niada.com/PDFs/Publications/Safeguards%20Rule.pdf

The Better Business Bureau. Frequently Asked Questions (n.d.) Retrieved from

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