Full Sail University
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
policy will address why and how we collect data, whom we share it with and how we safeguard
demonstrates the significance of the policy’s provisions in relation to the offered services.
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
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).
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
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
that we collect. For example:
We May Disclose Information that We Collect as Described Above to the
Financial service providers, such as securities broker-dealers or
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.
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
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.
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 firstname.lastname@example.org. You can also call us at 1-800-EZCARLOANS or write
to us at:
123 Main St.
Orlando Florida 32807.
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).
FTC. The Fair Credit Reporting Act (n.d.) Retrieved from
NIADA. Compliance with the Federal Trade Commission’s Safeguard Rule (n.d.) Retrieved
The Better Business Bureau. Frequently Asked Questions (n.d.) Retrieved from