Privacy Policy

Reviewed Date: February 9, 2023

This Privacy Policy (the “Policy”) describes the information InCharge Debt Solutions (“InCharge,” “we,” or “us”) collects from or about you, including through this website (“Site”) or any InCharge-owned website—InCharge.org, HomeTrek.org, and PersonalFinanceEducation.com (collectively, our “Sites”)—via the telephone, and in person, in connection with the debt relief products and services InCharge provides (“Services”). It also describes how we may use, share, and handle the information we collect.

Terms and Conditions and Your Consent

Before using this Site or our Services, you should review this Policy, the Terms and Conditions, and the Privacy Notice on this Site. By using this Site or our Services, you are consenting to the collection, processing, use, and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you are not authorized to, and you may not, access or use this Site or our Services. This Policy is incorporated into our Terms and Conditions that govern your use of this Site and our Services. You may access these Terms and Conditions by using the link provided at the bottom of each page of this Site.

InCharge reserves the right to revise this Policy at any time, in our discretion, and for any or no reason. Such revisions shall be effective immediately upon posting such changes to this Site. By continuing to access and use this Site or our Services, you acknowledge and agree that you shall be bound by any such revisions. Accordingly, you should periodically review this Policy. For your convenience, whenever this Policy is changed, we will update the “Effective Date” at the top of this page. We encourage you to check the Effective Date to see if this Policy has been revised since your last visit.

What Information We Collect

Information You Manually Provide. When you create an account, interact with us through the Site, telephone, or in person, use our Services, or otherwise use or visit the Site, we may collect personal information, that is, information that identifies you personally, alone or in combination with other information available to us. For example, we may collect your name, contact information, date of birth, Social Security number, financial and credit history, and credit card or other debt information. In certain instances, you may provide personal information to us directly or have the choice to provide such information. For example, you may submit personal information to us through a form on this Site and consent to receive communication from us or our business affiliates and non-affiliates based on the information in the form. Consent to receive communications is required to submit a form. Not all data fields in a form are required, but fields necessary for us or our business affiliates and non-affiliates to provide certain services or assistance are mandatory. We may also automatically collect information as you use our Site through the use of cookies or other technology.

Information from Your Mobile or Tablet Device. If you access our Site through your mobile or tablet device, we may automatically collect certain information from or about your mobile or tablet device. The types of information we may collect include the type of device you use, your device’s unique ID, the IP address of your device, your device’s operating system, the type of mobile or tablet Internet browsers you use, and information about the way you use our mobile or tablet application.

More About IP Addresses. Your IP address is the identifier assigned to your particular computer when you access the Internet. Depending on how you connect to the Internet, your IP address may always be the same, or it may change each time you access the Internet. IP addresses do not include your name, email address or other personal information, but in some cases, they can be used to identify you. If we suspect inappropriate or criminal activity or a threat to our Site or their users, we may also share our server logs—which contain users’ IP addresses—with the appropriate investigative authorities, who could use that information to trace and identify individuals.

Cookies and Other Technologies:  A “cookie” is a small file placed on your device when you visit a site, such as ours. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so that when you end your session and return to the same web site at a later date, the cookie information is still available. Our Site’s webpages and our e-mails may contain small electronic files known as “web beacons” (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to gather usage statistics. We use cookies and other technologies to collect information to improve and support functions on this Site so we can serve you better. For example, we may use these technologies to:

• collect information about how visitors access and use this Site, such as which pages they visit and for how long, and what functions or links they use most often; and

• support the features and functionality of this Site and make it more personal, for example, by repopulating information you have already provided so you do not need to enter that information again.

As with your browser, we do not collect directly personally identifiable information using cookies and other technologies, but we or business affiliates and non-affiliates may link it to personal information that you provide or that we have. Most browsers are initially set to accept cookies.  However, you may, at any time, control the use of cookies by selecting your browser settings on your device. You may also be able to receive an alert when a cookie is placed on your device. If you choose to reject cookies when you access or use this Site, it may impact your ability to use all of the features and functions on this Site.

Information About Third-Party Cookies and Internet-Based Advertising

In addition to the cookies we deliver to your computer or mobile or tablet device through our Site, certain third parties may deliver cookies to you for a variety of reasons. For example, we use Google Analytics, a web analytics tool that helps us understand how visitors engage with our Site. To learn more about Google Analytics, click here.

Other third parties may deliver cookies to your computer or mobile or tablet device for the purpose of tracking your online behaviors across non-affiliated websites and delivering targeted advertisements either on our Site or on other websites.

You have choices about the collection of information by third parties on our Site. For example, if you don’t want information about your visit to our Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Please note that the Add-on does not prevent information from being sent to InCharge.

Please be aware that if you do not configure your browser or actively opt out, you will accept cookies provided by this Site.

How We Use Your Information

Generally, we use the personal information we collect through this Site:

• to improve our products and services;
• to improve, administer, customize, and maintain the Site;
• to manage transactions;
• to build relationships with you and other users;
• to provide you with information about our Services;
• to connect you with relevant third-party business affiliates and non-affiliates;
• to fulfill other purposes for which you provide the information;
• to provide you with notices about your account;
• to carry out our obligations and enforce our rights;
• to allow you to participate in interactive features of the Site;
• to conduct market research and analysis; and for any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Please see below for information about the choices you have about the ways we use your personal information.

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers.

We do not control these third 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.

Click-Through Agreements. When you sign up to use special features of this Site, you may be asked to agree to special terms governing your use of the special feature. In some cases, you may be asked to expressly consent to special terms, for example, by checking a box or clicking on a button marked “I agree.”  This type of agreement is known as a “click-through” agreement. If any terms of the click-through agreement differ from the terms of this Policy, the terms of the click-through agreement will supplement or amend this Policy and be binding upon you, but only with respect to the matters specified in the “click-through” agreement.

Your Choices

In General. We respect your right to make choices about the ways we collect, use and disclose your personal information. In most cases, we will ask you to indicate your choices at the time we collect your personal information.

Information Access. Upon your request, we will remove your personal information from our records related to the Site. Removing your personal information from our records related to this Site may prevent you from accessing and using the Site. If you wish to update or correct personal information you have already provided to us, or if you wish to remove your personal information from our records, please send your request to us via email to the address provided below.

Opting Out of Email Marketing. You may choose to opt out of receiving marketing emails from us at any time by sending your request to us via email to the address provided below, or by using the means provided in our marketing emails such as clicking “unsubscribe”.

Disclosure for Direct Marketing/Advertising Purposes. As set forth in this Policy, we may share your personal information with service providers or non-affiliated third parties so that they may offer, market, and advertise products and services directly to you. For more information about our disclosure practices, including to non-affiliated third parties, please see our Privacy Notice.

Do Not Track Mechanisms. Because of the changing state of technology and indecision within the industry regarding the meaning of Do Not Track (“DNT”) signals, we currently do not make any guarantee that we will honor DNT signals.

Safeguarding Your Information

We maintain reasonable administrative, physical and technical measures to protect the confidentiality and security of your personal information. Unfortunately, no website is completely secure. Therefore, we cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others.

How We Share Your Information

Third–Party Service Providers. We share personal information collected through our Site with third-party service providers who act for or on our behalf. For example, we may use third-party vendors to design, operate, and/or host our Site, and to help us with our promotional efforts. These third parties may need information about you to perform their functions.

Business Negotiations. We may contemplate, for strategic or other reasons, selling, buying, merging, or otherwise reorganizing one or more of our businesses. In negotiating with a third party about entering into such an arrangement, we may need to disclose your personal information. In such cases, we will take reasonable measures to protect the personal information we disclose, for example, by requiring a prospective purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the personal information.

Business Transfers. We may transfer the personal information you submit on or through our Site to any organization that acquires or merges with us.

Compliance with Laws and Protection of Our Rights and the Rights of Others. We may disclose your personal information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your personal information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our Terms and Conditions or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

With Third-Party Social Media Platforms. We may provide functionality on our Site that allows you to automatically post information to a third-party social media platform (such as Facebook, Twitter, or Pinterest). If you choose to take advantage of this functionality, people with access to your profile on the third-party platform will be able to see your post. Thus, you should have no expectation of privacy in those actions. Further, if you choose to link your profile on our Site with an account on a third-party social media platform, we may share the information in your profile with that third-party platform. We may also use third-party social media platforms to offer you interest-based ads. To offer such ads, we may convert your email address into a unique value which can be matched by our affiliates and non-affiliates with a user on their platform. Although we do not provide any personal information to these platform vendors, they may gain insights about individuals who respond to the ads we serve.

In Aggregate or De-Identified Form. We use information collected through our Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share with third parties information about how particular individuals use our Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not directly personally identifying, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. We may provide basic demographic information (gender and age) in conjunction with providing Individualized Data. Third parties typically use this information for analytical purposes and to market their own products and services.

As Described in a Privacy Notice. We reserve the right to disclose your personal information as described in any privacy notice posted on a page of this Site where you provide that information. By providing your personal information on that page you will be consenting to the disclosure of your personal information as described in that privacy notice.

As Described in a Click–Through Agreement. We reserve the right to disclose your personal information as described in any click–through agreement to which you have agreed.

As a Financial Organization. All financial organizations need to share client personal information to provide the programs and services requested by the client. Please see our Privacy Notice for more information about how we share and use your personal information as a financial organization.

We may offer you the opportunity to opt out of some of our sharing, as required by applicable law, by contacting us as provided in this Policy. You may also be able to exercise “opt out” choices by contacting the third party directly.

Creditor Sharing. We may also share your information with creditors to assist in creating additional debt reduction programs. Please refer to your card member agreement with the creditor for more information about how the information may be used and for any actions that may be taken by the creditor.

We may retain your personal information as needed to maintain this Site and provide you with any Services; to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Policy; and to prevent fraud and abuse. If requested by law enforcement, we may also retain your personal information for a period of time.

We reserve the right to disclose your information as described in our Privacy Notice, or as described in any other agreement with us.

Children’s Online Privacy

This Site is not intended for children or minors under the age of eighteen (18) years without the permission of a parent or guardian. If you are a parent or guardian and believe your child has submitted personal information through this Site without your consent, please contact us using the information provided below.

Links to Other Sites

Our Site may contain links to other web sites controlled or offered by third parties. InCharge does not control, operate, and is not responsible for the content, accuracy or opinions expressed on such third-party sites, and we do not investigate, monitor or check such sites for accuracy or completeness. InCharge hereby disclaims any and all liability for the privacy practices and any information, materials, products, or services posted or offered at any of the third-party sites. InCharge does not endorse or recommend any products or services offered or information contained at such sites, nor are we liable for any failure of products and services offered or advertised at those sites. Any information you provide to third parties on or through their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal information. This Policy does not govern your use of those sites and we encourage you to review the privacy policies specifically belonging to such sites.

Your California Privacy Rights

California residents who have an established business relationship with us may request and obtain information, free of charge and on an annual basis, about the personal information that we shared with other businesses for their own direct marketing use within the prior calendar year. If applicable, this information will include a list of the categories of personal information shared with third parties and the names and addresses of all third parties with which we shared this information in the immediately preceding calendar year. To obtain this information, please contact us at the number or address below and let us know you have a “California Shine the Light Privacy Request.” We will then respond to you with the requested information.

If you are a California resident and under the age of eighteen (18), you may request that we remove content or information that you have posted to our Site by contacting us using the contact information below.

Jurisdiction

This Site and our Services are operated in the State of Florida, United States of America. If you access this Site or our Services from outside of the United States, you are responsible for compliance with any applicable laws. The data protection laws of the country in which you reside may be more restrictive than the data protection laws of the United States. Your personal information may be subject to disclosure under the laws of the United States or other countries to which it is transferred, and it may be accessible to law enforcement and national security authorities of those jurisdictions. By using this Site or our Services, you consent to our collection, processing, use and transfer of your personal information in or to the United States or any other country, subject to this Policy.

Contact Us

If you have any questions regarding this Policy or would like to exercise your choices as described herein, please contact us at (888) 734-6229 or [email protected].