NCRT Financial Services, DBA ViviaFi (“ViviaFi”) PRIVACY POLICY-SUMMARY

Last Updated 2024-12-10

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

Social Security number and employment information
Income and checking account information
Credit history and payment history
Web page http headers (home server domain names, IP address, type of client computer, and type of Web browser)
Information provided by you through on-line forms, application forms, registration forms, surveys, and/or other entries, including but not limited to, your name, address, driver’s license number or other government issued photo ID, social security number, e-mail addresses, assets and income
The e-mail addresses of visitors that communicate with us via e-mail
Information we receive from third parties, such as consumer reporting agencies and other lenders, regarding creditworthiness and credit history
Any other information you provide to us while on our Website (as defined below)

How?

All ﬁnancial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons ﬁnancial companies can share their customers’ personal information, the reasons ViviaFi chooses to share, and whether you can limit this sharing.

Reasons we can share your personal information	Does ViviaFi share?	Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes— to offer our products and services to you	Yes	No
For joint marketing with other ﬁnancial companies	Yes	No
For our afﬁliates’ everyday business purposes— information about your transactions and experiences	Yes	No
For our afﬁliates’ everyday business purposes— information about your creditworthiness	Yes	Yes
For our afﬁliates to market to you	Yes	Yes
For nonafﬁliates to market to you	Yes	Yes

To limit our sharing:

Call 1-866-268-2773 —our menu will prompt you through your choice(s) or
Visit us online: https://www.viviafi.com/contact-us

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions?

Call 1-866-268-2773 or go to https://www.viviafi.com (the “Website”)

Who we are:

Who is providing this notice? NCRT Financial Services, LLC, operating under the ViviaFi brand.

What we do:

How does ViviaFi protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured ﬁles and buildings. We also maintain physical, electronic and procedural safeguards (i.e., computer virus protection software, firewalls, 128-bit SSL). How does ViviaFi collect my personal information? We collect your personal information, for example, when you:

Apply for credit or give us your income information
Provide account info or provide employment information
Give us your contact information

We also collect your personal information from others, such as credit bureaus, affiliates, and other companies. Why can’t I limit all sharing? Federal law gives you the right to limit only:

Sharing for afﬁliates’ everyday business purposes—information about your creditworthiness
Afﬁliates from using your information to market to you
Sharing for nonafﬁliates to market to you

State laws and individual companies may give you additional rights to limit sharing. What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account.

Definitions

Afﬁliates Companies related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.

Our affiliates include companies operating under ViviaFi.

Nonafﬁliates Companies not related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.

Nonaffiliates we share with can include direct marketing companies for application resell, direct mail and other purposes.

A formal agreement between nonafﬁliated ﬁnancial companies that together market ﬁnancial products or services to you.

Our joint marketing partners include financial institutions, such as credit card companies, marketers, and other lending companies.

Other important information

Please visit https://www.viviafi.com/privacy-policy to view our privacy policy and https://www.viviafi.com/terms-of-use to view our terms of use for additional information. We automatically collect certain information when you use our Site. This information may include: “clickstream” data, including information regarding which of our web pages you access, the frequency of such access, and your product and service preferences, device information, including hardware model, operating system, browser, or IP address, and mobile device information, including telephone number, the unique device identifier assigned to that device, mobile carrier, or other device attributes.

Privacy Policy

ViviaFi (“Us” “We” and “Our(s)”), is a small personal loan lender. You, the Visitor of this Website, is referred to as “You” “Your(s)” or “Visitor”. ViviaFi recommends and encourages you to always opt out of agreeing to share your nonpublic, or private information with non-affiliated third parties. The purpose of this Privacy Policy (“Policy”) is to describe the types of information we may collect from you or that you may provide when you visit this Website https://www.viviafi.com, and explain your rights and responsibilities relating to the use, collection, and distribution of your personal data and information. This Policy replaces any privacy policy previously delivered to you or appearing on https://www.viviafi.com and any transaction agreement or any other document previously delivered to you. If there are conflicts between this Policy and any other policy delivered to you, the terms of this Policy shall control. This Policy explains our practices concerning privacy and how they may pertain to You as a user of our Website and Services. All information transmitted, printed, or otherwise submitted to Us via this Website shall be deemed to be the property of ViviaFi and our affiliates. We shall be free to use such information for any lawful purpose as detailed herein. We reserve the right to release such information to law enforcement or other governmental officials as We, in Our sole and absolute discretion, deem necessary to comply with the law. Your use of this Website and/or Your use of Our services constitute Your agreement with this Policy. This notice applies to all information We collect:

Through our Website (including mobile versions).
In email and other electronic messages between You and this Website.
Through mobile and desktop applications You download from this Website, which provide dedicated non-browser-based interaction between You and this Website.
When You interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Or when You interact in similar methods with Our Website, products or services.

All information transmitted, printed or otherwise submitted to Us remains Your property; however, We will be free to use that information for any lawful purpose as detailed in this Policy.

DISCLOSURE OF DATA TO THIRD PARTIES

If You choose to provide Personal Information, it will be used for the following purposes:

Considering Your application for a loan or collecting any loan which is in default; and
For marketing products and services which We determine, in Our sole discretion, may be of interest to You.
To be used by Our subsidiaries and affiliates.
To be used or sold to contractors, service providers, and other third parties We use to support Our business.
To be used by 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 ViviaFi’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ViviaFi about Our Website users is among the assets transferred.
To be used by third parties to market their products or services to You if You have consented to/not opted out of these disclosures.
To fulfill the purpose(s) for which You provide the Personal Information.
For any other purpose disclosed by Us when You provide the Personal Information.
To be used for any other purposes with Your consent.

We may also disclose Your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply Our terms of use, please navigate to the footer of our home page.

We may sell, rent, lease or otherwise provide the Personal Information that You supply to Us to or with any third party and We may work with other businesses to bring selected retail opportunities to Our users. These businesses and third parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. We may also employ other companies and individuals to perform certain functions on Our behalf. Examples include sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on Our behalf shall have access to Our users’ Personal Information as needed to perform their functions for Us but We do not permit them to use Your Personal Information for other purposes. All the above categories exclude text messaging originator opt-in data and consent, including information collected for two-factor authentication purposes; this information will not be shared with any third parties.

ACKNOWLEDGEMENT AND AGREEMENT

ViviaFi’s Website is not intended for use by consumers under the age of 18. By visiting this Website and participating in any of the Websites infomediary services, You consent and agree to accept the terms of this Policy. If You do not agree to the terms of this Policy, or if You are not 18 years of age or older, please do not use this Website or participate in our services. This Policy may be updated from time to time to ensure our Visitors are provided with the most accurate information. We will revise this Policy to reflect any material changes in our practices. You are encouraged to thoroughly read and review this Policy each time You use Website or participate in any of our infomediary services.

COOKIES

A “cookie” is a small text file with small bits of data that a web server sends to Your browser. It stores information about Your account, Your preferences, and Your use of the Website. Some cookies are stored for longer periods and some are temporary. When You use this Website, We may collect information using technology such as cookies, pixel tags and web beacons, and other similar technologies. These technologies are used by Us to coordinate and record interactivity and fill Your requests for services and information. This information is stored in web server logs and in web cookies kept on Your computer, which help Us recognize You when You revisit the Website to provide a customized experience and helps Us detect certain types of fraud. Pixel tags and web beacons are used to help Us improve Our communication with You and improve Our Website. They are tiny graphic images placed in e-mails or on websites that track what actions have taken place on Our Website. They help Us measure responses and actions on Our Website to improve the user experience. Some kinds of information that may be collected are; browser type, operating system type, some system settings, domain, the language used on Your system, as well as the time zone and country of Your device. We may also collect the Internet Protocol addresses of the devices You use to access Our Website. Internet Protocol address is a way to identify and communicate with the devices that are used to access the Website. In most cases the information gathered is used in non-identifiable ways. This information is typically used to enhance the users experience and learn about website traffic.

WHAT IS ‘PERSONAL INFORMATION’?

In this Policy, “Personal Information” refers to information that is gathered in connection with an application, pre-approval, loan or other product or service through, by and/or for ViviaFi.

WHAT INFORMATION WE COLLECT

We collect personally identifiable information, including non-public Personal Information, as well as other types of personally identifiable information from You and from other sources as described herein. Our primary goal in collecting Your Personal Information is to provide You with efficient, accurate, and customized financial products and services. The Personal Information we collect on or through Our Website may include:

Information that You provide by filling in forms on Our Website. This includes information provided at the time of registering to use Our Website, subscribing to Our service, posting material, or requesting further 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 Our Website.
Records and copies of Your correspondence (including email addresses), if You contact Us.
Your responses to surveys that We might ask You to complete for research purposes.
Details of transactions You carry out through Our Website and of the fulfillment of Your orders or requests for services.
Your search queries on the Website.

We may also collect the following personally identifiable information:

Your name, postal address, e-mail address, telephone number (”PII”);
that may be about You but individually does not identify You;
Your internet connection, the equipment You use to access Our Website, and usage details;
Web page http headers (home server domain names, IP address, type of client computer, and type of Web browser);
Information, user specific or aggregate, on what pages Our Visitors access; and
e-mail addresses of Visitors that communicate with Us via e-mail forms; such as the form found in the “Contact Us” section of Our Website.

As You navigate through and interact with Our Website, We may use automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

Details of Your visits to Our Website, including traffic data, location data, logs, and other communication data and the resources that You access and use on the Website.
Information about Your computer and internet connection, including Your IP address, operating system, and browser type.

SHARING YOUR INFORMATION

We may share Personal Information with Our service providers, such as lenders, data processors and companies that help Us market products and services to You. When permitted or required by law, We may share Personal Information with other third parties for purposes including responses to legal process. We reserve the right to transfer any Personal Information We have about You in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of Our business.

HOW WE USE THAT INFORMATION

We use information that We collect about You or that You provide to Us, including any Personal Information:

To present Our Website and its contents to You.
To provide You with information, products, or services that You request from Us.
To fulfill any other purpose for which You provide it.
To provide You with notices about Your account/subscription, including expiration and renewal notices.
To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us, including for billing and collection.
To notify You about changes to Our Website or any products or services We offer or provide though it if We provide such notices.
To allow You to participate in interactive features on Our Website.
To estimate Our audience size and usage patterns.
To store information about Your preferences, allowing Us to customize Our Website according to Your individual interests.
To speed up Your searches.
To recognize You when You return to Our Website.
In any other way We may describe when You provide the information.
For any other purpose, with Your consent.

We may also use Your personal, demographic and profile data to improve Our Website, for statistical analysis, for marketing and promotional purposes, and for editorial or feedback purposes for Our advertisers. Information collected by Us may be added to Our databases and used for future e-mails or postal mailings regarding site updates, new products and services, upcoming events, and/or status of orders placed online. Even though We do not disclose Your Personal Information for these purposes without Your consent, if You click on or otherwise interact with an advertisement, the advertiser may assume that You meet its target criteria.

COLLECTION AND USE OF BANK ACCOUNT INFORMATION FOR PURPOSES OF COLLECTING LOAN PAYMENTS

If We extend credit to You, We will consider the bank account information provided by You as eligible for Us to process payments against. In addition, as part of Our information collection process, We may detect additional accounts owned by You. We will consider these additional accounts to be part of the application process and eligible for payment retrieval.

DISCLOSURE OF DATA TO THIRD PARTIES

If You choose to provide Personal Information, it will be used for the following purposes:

Considering Your application for a loan or collecting any loan which is in default; and
For marketing products and services which We determine, in Our sole discretion, may be of interest to You.
To Our subsidiaries and affiliates.
To contractors, service providers, and other third parties We use to support Our business.
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 ViviaFi’s assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ViviaFi about Our Website users is among the assets transferred.
To third parties to market their products or services to You if You have consented to/not opted out of these disclosures.
To fulfill the purpose for which You provide it.
For any other purpose disclosed by Us when You provide the information.
With Your consent.

We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply Our terms of use please navigate to the footer of Our home page.

We may sell, rent, lease or otherwise provide the Personal Information that You supply to Us to or with any third party and We may work with other businesses to bring selected retail opportunities to Our users. These businesses and third parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. We may also employ other companies and individuals to perform certain functions on Our behalf. Examples include: sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on Our behalf shall have access to Our users’ Personal Information, as needed to perform their functions for Us, but We do not permit them to use Your Personal Information for other purposes.

HOW WE SAFEGUARD YOUR INFORMATION

Although no data transmission over the Internet can be guaranteed to be 100 percent secure, We network all information collected in a technically and physically secure environment. While We strive to protect Your Personal Information, You transmit any information at Your own risk. We cannot warrant or ensure the security of any information that You transmit. Upon receipt of Your transmission, We make reasonable efforts to ensure its security on Our systems. We strictly limit access to this information only to employees who need the Personal Information to perform a specific job. Your information is not accessible to the public. In the event that We learn of an information security breach with respect to Your Personal Information and in compliance with applicable state and federal laws, We will notify You via email along with any applicable regulatory agencies. However, notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

THIRD PARTY WEBSITES

Our Website may provide and/or refer You to links to other Internet websites and/or resources including, but not limited to, websites operated by Third Party Providers. Because We have no control over such third party websites and/or resources, You hereby acknowledge and agree that We are not responsible for the availability of such third party websites and/or resources. Furthermore, We do not endorse, and are not responsible or liable for, any terms and conditions, privacy policies, content, advertising, services, products and/or other materials at or available from such third party websites or resources, or for any damages and/or losses arising therefrom. We strongly encourage consumers to read the privacy policies of every website they visit when leaving ViviaFi’s Website, including the privacy practices and terms and conditions of any website. This Policy is applicable solely to ViviaFi and this Website. Third party websites will have different and independent privacy practices and We have no responsibility or liability for the content and activities of these linked sites.

OUR RIGHT TO CONTACT YOU

We reserve the right to contact You regarding Your account status and changes to subscriber agreements, the Policy, or any other policies or agreements relevant to You and/or Your loan.

YOUR OPT-OUT RIGHTS

Our company affiliates may contact You to promote and offer products and services that may be of interest to You. Consumers who requested to be contacted through any Opt-in process of ViviaFi may be contacted via e-mail or telephone. If You do not wish to receive these emails, telephone solicitations, or other forms of contact from Our company or affiliates, You may unsubscribe or opt-out at any time, no questions asked, by messaging Us through Our Contact Us page, emailing Us, writing Us, or responding to any communication sent with the words “Unsubscribe” or “Opt-Out” in the subject line to opt-out from receiving future communications. All the contact information can be found at the bottom of this Policy. Subscriber text messaging originator opt-in data and consent details will not be shared with any third parties not required for Our everyday business purposes except when explicitly authorized by the subscriber.

OUR RIGHT TO CHANGE THIS POLICY

We reserve the right to change this Policy at any time by notifying You of the existence and location of the new or revised privacy policy or by posting the changes online on Our Website. Your continued use of Our Website or acceptance of Our emails following the posting of changes to this Policy will mean that You accept all such changes and that You agree to continue receiving marketing from Us and other third-party companies. We reserve the right to contact You regarding Your account status and changes to subscriber agreements, Policy or any other policies or agreements relevant to You.

WE DO NOT INTEND TO COLLECT DATA FROM MINORS

We do not knowingly collect any Personal Information from Visitors or users of Our Website who are under the age of 13. If You are under 13, please do not give Us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce Our Policy by instructing their children to never provide Personal Information through the Internet without parental permission. If You have reason to believe that a child under the age of 13 has provided Personal Information to Us, please contact Us, and We will endeavor to delete that information from Our databases.

SOCIAL MEDIA

If You interact with Us on social media, please ensure You review the privacy options and settings on those platforms.

STATE SPECIFIC PRIVACY RIGHTS

We do not “sell” Your Personal Information, but You can opt-out of sharing Your Personal Information with third parties for cross-context behavioral advertising. You cannot opt-out of Our first party Strictly Necessary Cookies, as they ensure the proper functioning of Our Website (such as remembering Your settings, logging You into Your account, redirecting You when You log out, etc.).

CONTACT US:

If you have any questions regarding this Policy, or would like more information on Our privacy practices, please contact Us at: Website: https://www.viviafi.com/ Email: customerservice@viviafi.com Toll Free at: 1-866-268-2773 Please contact Company directly via certified mail at: NCRT Financial Services, LLC DBA Vivia Finance 40 East Main St., Suite 147 Newark, DE, 19711