Last updated: February 3, 2020
Dividend Solar Finance LLC and its affiliates (collectively, "Dividend Solar," "we," "us" or "our") value your privacy. The following policies apply to the collection of data by Dividend Solar. If you have questions or concerns regarding our policies, please contact us at firstname.lastname@example.org.
This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy, which describes how your Personal Information (defined below) is protected both electronically and physically. Click here for a copy of our official notice regarding our privacy practices.
"Personal Information" is information:
- that identifies or can be used to identify your household;
- that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your household;
- that can be used to authenticate you or provide access to an account;
- that relates to you and that might be sensitive (such as personal medical or health information, account number, account value).
In general, and as described in detail below, we collect several types of information from you:
- Personal Information required to verify your identity
- Personal and financial information necessary to assess your eligibility to borrow money
- Optional Personal Information you may wish to share in the furtherance of your goals in using the Dividend Solar website, www.dividendfinance.com, and any and all subdomains thereof, including those requiring login (the "Site")
- Information about your visits to and use of this Site or the websites of third-party services to help us maintain the appropriate features, functionality and user experience.
Dividend Solar expresses its absolute commitment to integrity, our corporate values and ethical standards and the associated business conduct we expect from all our employees. The Dividend Solar Code of Ethics and other policy documents include very specific guidelines concerning the safeguarding of confidential information, which includes customer information. In general, these guidelines limit employee access to confidential information and limit the use and disclosure of such information to specifically authorized processes and transactions. If it is determined that an employee has violated the Code of Ethics, corrective action may be taken, including immediate dismissal.
Verification of Practices
Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information. These reviews may be conducted by our own internal staff, external accounting and auditing firms and government regulators. Included in these self-assessments and examinations are reviews of the controls and safeguards related to consumer privacy.
Information We Collect From You and About You
We collect Personal Information and financial information from you while you use the Site, and most of this collection occurs during the registration and application process. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the Site, whenever you choose to provide it.
Certain Personal Information must be supplied during the user and borrower registration processes, as indicated below, in order to (a) enable registered users to login to the Site (b) determine borrowers' eligibility for loans through our proprietary credit scoring process, (c) verify borrowers' identities, (d) establish borrowers' ability to request loans by verifying that they are at least 18 years of age, (e) guard against potential fraud, and (f) allow our solar installers to contact users and install solar systems at borrowers' residences. This basic Personal Information includes:
- Your name (user / borrower registration)
- Your email address (user / borrower registration)
- Your home address and telephone number (borrower registration)
- Your Social Security number (borrower registration)
When you register as a borrower, we will use this information to pull a credit report from credit bureaus to determine your creditworthiness. We will also use your required and optional information to facilitate activities and transactions that need to occur during the lending process, such as:
- Informing your solar installer that your loan request has been approved at a specific interest rate, is under review or was denied
- Assigning you a loan risk score based on your credit history and financial circumstances
- Enabling our financial services partners to implement automatic payments
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
- Implementing collection activities, if needed
- Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
Finally, we (and/or our service providers) collect information about your computer and your visits to the Site, such as your IP address, geographical location, browser type, referral source, length of visit and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize the Site based on the needs of our users. We will retain your information for as long as your account is active or as needed to provide you services, subject to our standard retention practices. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Communications from Our Site
When you register on our Site, you will receive emails that confirm specific actions you request as well as follow-up communications concerning the status of your application, loan, and solar installation, if applicable. You may receive notifications confirming your registration, of the outcome of any request to pre-qualify for credit, updating you on your solar system installation, of delinquent payment amounts, as well as reminders to complete your credit application and of upcoming payments due. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your Personal Information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.
Links to Third-Party Websites
Dividend Solar is not responsible for the information practices employed by websites controlled, owned and operated by third parties ("Third-Party Sites") linked to or from our Site. In most cases, links to Third-Party Sites are provided solely as an access point to obtain information on products and topics that may be useful to the users of the Dividend Solar Site. Third-Party Sites may have different privacy policies and/or security standards governing their sites. Further, Dividend Solar has no control over the content of Third-Party Sites. Please consult the privacy policies on these sites before you provide them with any of your Personal Information.
How and When Your Information Is Shared With Other Parties
Information is shared with other parties in the following ways:
- Information is shared directly between users and other or potential users. Information shared directly by users might contain Personal Information
- Dividend Solar may, with your consent, share required and optional information about you
- Dividend Solar may share your contact information with third parties that may be able to offer financing to you in the event we are unable to offer a loan to you
- Dividend Solar may share your contact information with service providers to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services; our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit
Dividend Solar is not responsible for any Personal Information that borrowers may choose to reveal about themselves in their screen names, public profiles or other forms of electronic communication not expressly between the borrower and Dividend Solar.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on the Site.
Dividend Solar works with a number of trusted partners that perform vital functions as part of our operations, including credit bureaus, collection agencies, electronic payment service providers and customer support call centers. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
How Your Credit History and Dividend Solar Loan Data Are Shared
If you successfully receive a loan through Dividend Solar, certain Personal Information will be made anonymous and displayed to our investors. This information includes details about your loan request, geographic location, credit score, solar system specifications and installation partner. We will also display status information about your loan to our investors. Your payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to our investors.
Dividend Solar will send you email notifications from time to time, and these are required elements of your transactions on the Site, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally, you may not opt out of these service-related emails.
Where You Can Find and/or Correct Your Information
You can access your Personal Information that we collect online and maintain by visiting your profile in your borrower portal or the Account section of the Site. This section of the Site is password-protected to better safeguard your information. As a registered user, you can update your password, email address, phone number and bank account information at any time on the Site, and if you need to change any other information in your profile you can contact us at firstname.lastname@example.org. To protect your privacy and security, please contact us at email@example.com to make changes to your sensitive account information.
Web-related Information Collection
We (or our service providers, such as Google Analytics) may also collect web surfing data related to your use of the Site. This may include, for example, information regarding which of our web pages you access, the frequency of such access and your product and service preferences. This data collection may be accomplished by using cookies, web beacons, page tags or similar tools that are set when you visit the Site. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Site. Web surfing data and similar information may be used for administrative purposes, to assess the usage, value and performance of our online products and services, and to improve your experience with the Site. As with cookies, the web surfing information collected is aggregated, anonymous "click stream" and transactional data, and is not associated with any users as individuals.
Compliance with State and Federal Laws
Dividend Solar Security Policy
We limit access to the Personal Information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
You can take several precautions to protect the security of your computer and Personal Information. For instance, you can use a well-chosen password, and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Site, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information known as "phishing," whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money.
Dividend Solar will never ask you for your login information in the context of any email. In general, you can protect yourself against phishing by never providing personal or login information via an email. Instead, go to the Site directly. It is advised that you check the URL of a web site to be sure that it begins with the correct domain. In the case of Dividend Solar, you should always ensure the URL begins with http://www.dividendfinance.com.
Supplemental provision applicable to California residents:
California residents have certain rights with respect to Personal Information under the California Consumer Privacy Act ("CCPA"). For purposes of this subsection, the terms "consumer," "categories of Personal Information," "business purpose," "third party," and "sell" have the meanings ascribed to them respectively in the CCPA. Terms defined under the CCPA may differ in meaning from the common usage of the same terms used elsewhere in this Notice.
(1) You have the right to request, up to two times every 12 months, that Dividend disclose to you the following: (i) the categories of Personal Information that Dividend has collected about you; (ii) the categories of sources from which Dividend has collected Personal Information about you; (iii) the business or commercial purpose for collecting or selling your Personal Information; (iv) the categories of Personal Information that Dividend has sold about you in the last 12 months and the categories of Third Parties to whom the Personal Information was sold, by category or categories of Personal Information for each Third Party to whom the Personal Information was sold; (v) the categories of Personal Information that Dividend has disclosed about you for our business purposes in the last 12 months and the categories of third parties to whom the Personal Information was disclosed, by category or categories of Personal Information for each third party to whom the Personal Information was disclosed; and (vi) the specific pieces of Personal Information that Dividend has collected about you. Please note that Personal Information we have collected in connection with your personal account with us is not subject to the requirements of CCPA because it is already protected under existing federal and California state privacy laws, including the Graham Leach Bliley Act.
(2) You have the right to request a portable copy of your Personal Information.
In response to verified requests pursuant to #1 or #2 above, we will disclose and deliver the required information to you free of charge within 45 days of receiving a verifiable consumer request. We may extend this time period to provide once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.
(3) You have the right to request that Dividend delete Personal Information collected from you, subject to certain exceptions allowed under applicable law.
(4) You have the right to opt out of the sale of your Personal Information to third parties by contacting us at firstname.lastname@example.org. CCPA defines sale very broadly, covering both monetary and other consideration. Dividend does not sell Personal Information for money. However, we share some types of Personal Information. See our Privacy Notice for additional information.
(5) Dividend will not discriminate against you because you elect to exercise these rights, including by:
a. Denying goods or services to you.
b. Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
c. Providing a different level or quality of goods or services to you.
d. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Submission of Requests; Authorized Representatives
You may exercise these rights by managing your information at email@example.com. If you wish to submit a request to have your Personal Information deleted or wish to opt-out of the selling of your Personal Information, call us at (844) 805-7100 option 3.
We will take reasonable steps to verify your identity prior to responding to your requests under CCPA. Upon receiving a request pursuant to #1 or #2 above, we will confirm receipt within 10 days and provide you with information about how we will verify and process the request. In order to verify your request, we will require you to provide certain information and we will compare information provided by you against information that Dividend deems reliable in its records. Verification may require you to execute a declaration under penalty of perjury that you are the consumer who Personal Information is being requested. In the event that Dividend is unable to confirm your identity, we will deny your request to protect the Personal Information of the borrower.
We May Make Changes to This Policy
We will continue to improve and evolve the Site to improve the user experience and to comply with prevailing regulations. As such, this policy may be updated from time to time as such needs dictate, and we will always communicate these changes to you by posting them on the Site and/or by notifying you via email in the event of any substantive or material changes.
You may contact us at:
Dividend Solar, Inc.
Attn: Compliance Department
433 California St, Suite 300
San Francisco, CA 94104
Via email at: firstname.lastname@example.org