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CCPA Privacy Notice / Notice At Collection (effective June 2023)

Maintaining the privacy and security of your personal information is AFCO Credit Corporation’s and AFCO Acceptance Corporation’s (collectively referred to as “AFCO”) highest priority. In doing so, we want to provide transparency regarding how and why your data is collected, how it is used, with whom it may be shared, and how long it is kept. This notice, as well as AFCO’s Consumer Privacy Notice on the AFCO Privacy Notice and Statement of Online Privacy Practices [AFCO Statement of Online Privacy Practices] informs consumers how we will interact with your personal information. 

The purpose of this Notice at Collection and CCPA Privacy Notice (“Notice”) is to provide you with timely notice, at or before the point of collection, of the details about our practices concerning the privacy of your personal information. This Notice is directed to consumers who reside in the state of California (“consumers” or “you”) and relates to personal information covered by the California Consumer Privacy Act (CCPA).  Specifically, this Notice provides comprehensive information about our online and offline practices, along with details concerning how you may exercise your California privacy rights and make requests to access, correct or delete the information that AFCO holds about you. We will not collect additional categories of personal information without providing you a new Notice at Collection disclosing these categories.

Please note that AFCO adheres to an exemption within the CCPA for data collected pursuant to the Gramm-Leach-Bliley Act (GLBA). This Notice and the rights described do not apply to information we collect when you apply for or obtain our financial products and services for personal, family, or household purposes, which is subject to our AFCO Privacy Notice.

Personal Information Collected and Purpose for Collection

The following charts provide specifics about AFCO’s practices related to the collection, use and selling or sharing of personal information:

General Personal Information

Categories of Personal Information Collected & Disclosed

Purpose for Collection

Purpose for Disclosure

A. Identifiers: For example, real name or alias, address, online identifier, IP address, email address, account name, SSN, driver’s license number, passport number, or other similar identifiers.

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

B. Personal Information Categories from Cal. Civ. Code § 1798.80I: For example, name, signature, SSN, physical characteristics or description, address, phone number, passport number, driver’s license or state ID card number, policy or account numbers, education, employment, employment history, credit or debit card numbers, or any other financial, medical or health insurance information.

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

-Share personal information with service providers that provide various services to us

C. Characteristics of CA or Federal Protected Classifications: For example, race, religion, national origin), age (40 and over), gender, sexual orientation, medical condition, ancestry, pregnancy (includes childbirth, breastfeeding and/or related medical conditions), familial status, disability, veteran status, or genetic information.

N/A

N/A

D. Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

N/A

N/A

E. Biometric Information: For example, physiological, biological or behavioral characteristics, including DNA, that can be used to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

N/A

N/A

F. Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement

N/A

N/A

G. Geolocation Data: For example, information that can be used to determine a device’s physical location

N/A

N/A

H. Sensory Data or Recordings: For example, audio, electronic, visual, thermal, olfactory, or similar information that can be linked or associated with a particular consumer or household

N/A

N/A

I. Professional or Employment-Related Information: For example, compensation, evaluations, performance reviews, personnel files and current and past job history.

N/A

N/A

J. Education Information (defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an education institution or party acting on its behalf, for example, non-public information that can be used to distinguish or trace an individual’s identity in relation to an educational institution either directly or indirectly through linkages with other information.

N/A

N/A

K. Profile Data: For example, inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

N/A

N/A

Sensitive Personal Information

Categories of Sensitive Personal Information

Purpose for Collection

Purpose for Disclosure

SSN, Driver’s License, State ID Card, Passport Number

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

-N/A

Account Login, financial account, debit or credit card number when provided with any security or access code, password or credentials allowing access to an account

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

-Deliver, manage, and support products and services, manage relationships, and maintain accounts

-Manage fraud and financial crimes

-Meet legal, regulatory, or compliance requirements

-Share personal information with service providers that provide various services to us

Precise geolocation

N/A

N/A

Racial or ethnic origin, religious or philosophical beliefs, or union membership

N/A

N/A

Contents of a consumer’s mail, email and text messages (unless AFCO is the intended recipient)

N/A

N/A

Genetic Data

N/A

N/A

Biometric information for the purpose of unique identification

N/A

N/A

Health information

N/A

N/A

Information concerning sex life or sexual orientation

N/A

N/A

What we Sell to Third Parties or Share with Third Parties for Cross-Context Behavioral Advertising and What we Share with Third Parties for Business Purposes

We have not sold or shared with third parties for cross-context behavioral advertising personal information to third parties in the preceding 12 months as disclosed in the table below. We do share personal information for business purposes with the third parties described below.

General Personal Information

Categories sold to or shared with third parties over the last 12 months

Categories of Third Parties to whom the information was shared for business purposes

A. Identifiers

- Affiliates and other entities in the AFCO family

- Service Providers that provide various services to us

B. Personal Information Categories from Cal. Civ. Code § 1798.80(e)

- Affiliates and other entities in the AFCO family

- Service Providers that provide various services to us

C. Characteristics of CA or Federal Protected Classifications

N/A

D. Commercial Information

N/A

E. Biometric Information

N/A

F. Internet or Other Similar Network Activity

N/A

G. Geolocation Data

N/A

H. Sensory Data or Recordings

N/A

I. Professional or Employment-Related Information

N/A

J. Education Information

N/A

K. Profile Data

N/A

Sensitive Personal Information

Categories sold to or shared with third parties over the last 12 months

Categories of third parties to whom the information was shared for business purposes

Social Security Number, Driver’s License, State Identification Card, or Passport Number

N/A

Account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account

- Affiliates and other entities in the AFCO family

- Service Providers that provide various services to us

Precise geolocation

N/A

Racial or ethnic origin, religious or philosophical beliefs, or union membership

N/A

Contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication)

N/A

Genetic data

N/A

Biometric information for the purpose of unique identification

N/A

Health information

N/A

Information concerning sex life or sexual orientation

N/A

 

Notice of Right to Limit Use of Sensitive Personal Information

AFCO only collects/processes sensitive personal information for permissible purposes that do not infer characteristics about a consumer, therefore there is not an opt-out for the use of sensitive personal information.

Retention of Personal Information

AFCO has established product and business-level criteria for retention and disposal according to business requirements, laws, regulations, and applicable industry standards.

Sources of Personal Information

AFCO collects information from various sources, including:

  • Directly from you or your guardians/representatives
  • Service providers that support our business operations (e.g., data analytics providers)
  • Our affiliates or subsidiaries
  • Independent insurance agents
  • Public records or publicly available data

Consumer Rights Under the CCPA

Right to Know / See Data Request

You have the right to request that AFCO disclose categories or specific pieces of information we have collected about you over the last 12 months, the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, sold, or shared with third parties for cross context behavioral advertising, and the categories of third parties with whom we share personal information.

Right to Correct

You have the right to request correction of inaccurate information maintained by AFCO.  In many instances, such updates are best made by logging into your online account or employee portals, emailing AFCO-Compliance@afco.com, or calling 800-288-2313, and some corrections may require specific documentation to be provided as required by law. If you provide us documentation, it will only be used or maintained for the purpose of correcting the information and complying with our recordkeeping requirements under the CCPA. AFCO also provides links and the privacy request line as described below.

Right to Delete

You have the right to request deletion of personal information that AFCO has collected, subject to certain exceptions. For example, we may deny your request if retaining the information is necessary for us to complete a transaction you requested or comply with our legal obligations. 

Submitting a Verified Consumer Request

Consumers are welcome to submit right to know, correction, or deletion requests by visiting our Consumer Rights Request Portal, hosted by One Trust:

  • To submit a request for yourself, click here.
  • To submit a request on behalf of another individual, click here.

Individuals are also welcome to submit requests by emailing AFCO-Compliance@afco.com or calling 800-288-2313.

All requests must be verified prior to receiving a response, using AFCO authentication protocols. Requesters will be asked to supply certain basic Personal Information to enable us to verify the request against our records, such as name, Social Security number, and address. Information submitted for verification purposes will only be used to verify the requestor’s identity and/or authority to make a request on another’s behalf.

Requests made on another person’s behalf can only be accepted upon receipt of documentation that the requestor is an authorized agent, parent, or legal guardian of the consumer whose information is being requested. This will require the submission of a valid Power of Attorney, Birth Certificate, approved AFCO authorization form, Guardianship Order, or other court order granting authority to receive information, as appropriate.

Upon submission of a request, consumers will receive an initial confirmation of receipt within 10 days. We will respond to your request within 45 days (unless an extension of up to 45 additional days is requested, upon which the consumer will receive notice and an explanation for the extension).

Non-Discrimination

The submission of any CCPA request will have no impact on the service and/or pricing you receive from AFCO. It will not result in any denial of goods or services, or different prices, rates or quality of goods or services, nor will it result in retaliation against an employee, applicant, or independent contractor.

Consumers Under 16 Years of Age

AFCO’s products and services are not intended for consumers under the age of 16, and we do not knowingly collect information from children under the age of 16 without consent. Truist does not knowingly sell the personal information of minors under the age of 16 or share such information for cross-contextual advertising.

Updates

This Notice may be revised from time to time, so please review this page periodically. Any changes will become effective when we post the revised notice on the site (please note the effective date listed at the top of this page).

Contact Us

If you have any questions or comments on this notice or our privacy practices generally, please contact us at AFCO-Compliance@afco.com or calling 800-288-2313. You can also visit AFCO Privacy for additional information.