Privacy Policy

Last Update: 09/02/2016

Starting Point Financial, LLC and the Starting Point Financial Network recognizes your expectations of privacy and security and we greatly respect your privacy concerns. This Privacy Policy describes how we gather information, what we do with the information we collect and what steps we take to safeguard your privacy and protect your personal information.

To ensure that this Privacy Policy is up-to-date and responsive to changes in our website(s), our business activities, relevant laws and regulations and developments in the applicable technology, we reserve the right to change and/or amend this Privacy Policy from time to time. Your use of our website(s) constitutes your consent to the current version of our Privacy Policy.

We may make changes to this Privacy Policy at any time and will inform you of changes, as required by law. To receive the most up to date Privacy Policy, you can visit our web site at: https://startingpointfinancial.com/privacy/.

If you have questions or concerns regarding this statement or your rights under our Privacy Policy, you should first contact Customer Care at support@startingpointfinancial.com.

We have organized this Privacy Policy as a series of answers to questions that we have found to be of most interest to consumers. If you do not see the answer to any question you may have about what information we collect, how we collect information and what we do with the information we collect, please contact us at the following e-mail address: support@startingpointfinancial.com.

What Does This Privacy Policy Cover?
This Privacy Policy covers what we do with any personal information you may submit or authorize us to obtain, as well as any other information that we may gather when you access any of our websites. This Privacy Policy also covers any of your personal and other information that any of our business partners may share with us.

Starting Point Financial, LLC owns and operates several websites, as well as a number of websites and/or domains that point to one or another of our websites. We may, from time to time, add additional websites and/or domains to our portfolio. Whether or not any particular site is specifically identified in this Privacy Policy, this Privacy Policy applies to any website owned and/or operated by Starting Point Financial, LLC.

Please note that our policies and procedures apply only to websites owned and/or operated by us and not to websites maintained by other companies or to any website to which we may link or to unrelated businesses with which we may share information.

What is “Personal Information”?
Personal information is any information that you provide to us or authorize us to obtain that identifies you, personally, or that can be logically associated with you. Examples of personal information would be your name, your address, your e-mail address and your Social Security Number. Demographic information such as gender, age, zip code, etc., is generally not considered personal information.

Why Do You Need To Collect My Personal Information?
We collect and use personal information to respond more completely to your requests for products and services we offer and those that are offered by our Network of business partners, as well to service your relationship with us and any account you may have with us. We also collect personal and other information to make you aware of products and/or services that are likely to be of interest to you.

What Personal and Other Information Do You Collect and/or Maintain?
We collect and maintain the information you provide to us, such as:

Any information you provide to us on applications or forms when you request a product or service, such as your income and accounts with others. This information may include your name, your address, your telephone number and, in some cases, your Social Security number. Depending upon the product or service you request, you may also be asked to provide additional information, such as the amount of your current unsecured debt and the identity of your creditors, information about your mortgage and other financial and personal information.
Information we receive about your transactions with us, such as your account balance, payment history and credit card usage.
Information, such as your e-mail address, that you provide to us when you register to receive communications from us or when you communicate with us through our customer service facility, or otherwise correspond with us.

We also collect other, non-personal information, which is broadly defined as any information that is not and cannot be directly associated with you. An example of this type of non-personal information would be your zip code.

How Do You Use The Personal and Other Information You Collect?
We use the personal information you supply to us, for a number of purposes, such as to provide to you the service(s) or product(s) that you request, to service your account, and to keep you informed about services that may be of interest to you.

We may also use your personal and other information to enhance your experience on our website(s) by displaying content based on your preferences and/or to send information to you about additional products or services in which you may be interested. We may “depersonalize” your personal information to enable us to use that information, aggregated with the information of others, for research, analysis and modeling purposes.

We occasionally receive medical or health information from a customer if, for example, a customer lists a medical debt. We do not share medical or health information, including information received from third parties, among our companies, except to maintain accounts, process transactions or service customer requests to the extent permitted by law.

With Whom Do You Share My Information?
If you submit a request for a product or service, we will share the personal and other information you supply with those products and service providers that have agreed to participate in our network. Generally, these product and service providers are prohibited from using the information we provide to them for any other purpose, including using your information for other, unrelated marketing purposes.

By submitting your request you are consenting to being contacted by us or by our business partners, through any means, based on the information you provide to us, even if you have opted into the National Do Not Call List administered by the Federal Trade Commission, any state Do Not Call List or the Do Not Call List of any specific institution. If, after you are contacted by that product or service provider, you do not wish to be contacted by that person again you must make a specific request to the product or service provider.

As permitted by law, we may also share your personal and other information with a third party that provides a service or supplies a specific functionality to us, such as a call center operator. These service providers will be provided only with the information necessary for them to perform their functions and are not allowed to share any of the provided information with others for any purpose whatsoever.

Additionally, we may share your personal and other information within our family of companies for a number of purposes, for example, to process your requests and to keep you informed of services that may be of interest to you. Any person with whom we share your personal information is also required to comply with federal and state privacy regulations and will have its own privacy policies that should be made available to you at the time you are first contacted.

Are There Any Other Circumstances Where You Disclose My Information?
We may be required to share your information with law enforcement or government agencies in response to subpoenas, court orders or other forms of legal process. We may elect to share information when, in our reasonable judgment, such sharing is necessary or appropriate for the investigation or prevention of illegal activities, including actual or suspected fraud, real or potential threats to the physical safety of any person or otherwise as required by law.

In addition, if we are merged with, or acquired by, another company the successor company will have access to all of the information collected and maintained by us. In such a circumstance, the successor company would continue to be bound by the terms and conditions of this Privacy Policy.

How Do You Collect Information Online?
We collect certain types of non-personal information and technical data from each visitor to our website(s). For example, when you click on a banner advertisement or text link that is associated with one of our websites, the banner or text placement, along with the time of your visit, your Internet Protocol address and other path-related information, is sent to us. Similarly, the page requests you make when you visit our website(s) are stored and used by us. We use this information, none of which is or can be personally associated with you, for statistical and analytic purposes, to help us understand which page views are most appealing to our customers and to help us improve the likelihood that we will be able to offer you only products or services in which you have a genuine interest.

What Are Cookies?
“Cookies” are small files that are placed automatically on your computer system when you visit a website. Cookies enable a website to recognize you as a return visitor and, by keeping track of your website activity, help us identify which pages to serve to you while reducing the time it takes for those pages to load. Cookies enable us to personalize and enrich your experience and are not tied in any way to your personal information. If you do not wish to accept cookies or if you wish to remove cookies that remain in your browser following the close of your browser session, you may adjust the settings on your web browser to prevent cookies from being placed on your hard drive. Please review your web browser “Help” file to learn the proper way to modify your cookie settings.

What Are Web Beacons?
“Web beacons” are, like cookies, small files that enable an ad server to recognize a visitor’s cookie when the visitor returns to a particular site. Web beacons may also be used in e-mail advertising to help track which e-mail messages have been opened. Web beacons are used to track the movement of visitors to our sites and, like cookies, are not tied to any personal information.

How Do You Safeguard The Information You Collect?
The security of your personal information is a very high priority for us and we take a number of steps to safeguard it. Some of the measures we take are:

Limiting access to personal information to those employees who are critical to the delivery of products and services to you.
Implementing appropriate physical, electronic and procedural safeguards to guard against unauthorized access or use.
Requiring appropriate consents and protections from our business partners before we share any personally identifiable information.

Starting Point Financial, LLC uses commercially reasonable physical and technical security measures to protect all personal information in our possession. Sensitive information such as Social Security numbers are encrypted using secure sockets layer encryption from the time of your submission and while it is stored by us. We cannot, however, guarantee or warrant the absolute security of any system or that any information we hold will not be accessed, disclosed, altered or destroyed.

How Long Do You Retain My Personal Information?
We normally retain your personal information for a reasonable time after our customer relationship with you ends, and in any event, generally not less than one (1) year from the date we first collect it. For legal reasons, we may sometimes be required to retain personal information for a longer period. Under certain circumstances, Federal and/or state law may require us to retain your personal information for different periods of time.

We may disclose personal information about former customers to affiliated and other persons in the same way and of the same types as we disclose for customers.

Non-personal information may be retained indefinitely.

Can I Correct or Remove My Personal Information?
If you believe there are factual errors in any of the information you have submitted to us, please contact us and advise us of the error. To protect your privacy and security we may require that you verify your identity before we make any requested changes to personal information.

What Choices Do I Have?
You can always elect not to provide personal information to us, although if you do not complete and submit the information we ask for we may not be able to provide you with the most complete responses or you may not be able to access all the available features.

Choices You May Make for Your Privacy
You may choose to limit the way we share information about you. You may also choose to limit the solicitations we send you. These choices are referred to as “opt-outs.”

I. Sharing of Information Outside of the Starting Point Financial, LLC Network of Companies

If you do not want us to disclose nonpublic personal information about you outside the Starting Point Financial, LLC Network of companies, you may choose to opt out of those disclosures. In other words, you may tell us not to share this information and we will not, except in those cases where we may be required or permitted by law. For example, required disclosures may be made to law enforcement and regulators, while permitted disclosures may be made to vendors assisting us in opening, maintaining or servicing your account. (CA and VT Residents: To the extent state law applies, we will not disclose information about you outside of the Starting Point Financial, LLC Network of companies, except as required or permitted by law.)

II. Use and Sharing of Information among Companies in the Starting Point Financial, LLC Network of companies

Affiliate Marketing-Companies and Affiliated Service Providers in the Starting Point Financial, LLC Network of companies may market their products and services to you based on information received from other companies in the Starting Point Financial, LLC Network of companies. This may include any information collected about you including your income, your account history, and your credit score. If you would like to limit the offers you may receive based on this shared information, you may choose to opt out. If you opt out, we will not market products or services to you based on information received from other companies in the Starting Point Financial, LLC Network, except as expressly permitted by law. This limitation will not apply in certain circumstances, such as if you ask to receive information from the Starting Point Financial, LLC Network.

III. How to Opt-Out

Your opt-out choices will continue to apply until you tell us to change them, except with respect to limits on solicitations which we will honor for the time periods required by law. If you have previously opted out based on the Starting Point Financial, LLC notice and would like to keep the same preferences you do not need to opt out again.

Joint/Multiple Accounts: Your opt-out choices will apply to all of your consumer accounts within the Starting Point Financial, LLC Network of companies, including joint accounts. For a joint account, an opt-out choice made by one joint account holder will only apply to that account holder.

Applicants: Unless otherwise notified, applicants who do not become our customers may not make certain privacy elections.
To exercise one or more of your opt-out choices described: Call us toll free: (855) 866-3436.

If you wish to stop receiving e-mails from us or from a third party e-mail service, we recommend you follow the opt-out instructions included in the e-mail.

Do You Use My Personal Information to Contact Me Without Permission?
This Privacy Policy constitutes the Starting Point Financial, LLC Network Do Not Call Policy under the Telephone Consumer Protection Act for all consumers and is pursuant to state law. When you talk with us by telephone your conversation may be monitored or recorded by us. We maintain an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days and will be effective for at least five years from the date of the request. No telemarketing calls will be made to residential or cellular phone numbers that appear on the Do Not Call list.

Starting Point Financial, LLC has a strict “anti-spam” policy for itself and its business partners and vendors. You will not receive Starting Point Financial, LLC e-mails unless you submit your e-mail address to us or register on one of our websites to receive communications, such as our newsletter.

You may tell us not to solicit you at your postal mailing address, telephone number or e-mail address. If you elect not to receive marketing offers by postal mail, telephone and/or e-mail, please note that we may continue to contact you as necessary to service your account and for other non-marketing purposes. We may also continue to provide marketing information in your regular account mailings and statements, including online and electronic communications.

To receive our newsletter via e-mail you must sign up on one of our websites. If you decide at a later time that you no longer wish to receive our newsletter, you may unsubscribe using the “unsubscribe” link on each newsletter that you receive. If you have any problems unsubscribing, please contact us.

Social Security Numbers
Often we do not collect your Social Security number but if we do our Privacy Policy (1) protects the confidentiality of Social Security numbers, (2) prohibits unlawful disclosure of Social Security numbers, and (3) limits access to Social Security numbers.

A Special Note about Children’s Privacy
We do not knowingly collect, use or share personal information about visitors under 18 years of age. If you are under 18 years of age, you can use the products and/or services offered on our website(s) only in conjunction with your parents or guardians.

Special Notification for California Residents
California residents who provide us with their personal information may request certain information regarding disclosures made to third parties for direct marketing purposes, including the names and address of those to whom such disclosures have been made. Such requests must be submitted to us at the following mailing address: Starting Point Financial, LLC – 10242 NW 47th Street, Suite 26, Sunrise, FL 33351. This request may be made no more than once per calendar year.