Privacy and Security Policy

Orange Commercial Credit, Inc. (“OCC” or “Us” or “We”) is serious about protecting the privacy of personal information. We have put strict policies into place to ensure that the privacy of personal information is protected while still enabling use of the website (the “Site”) by OCC clients, customers, debtors, brokers and other users, including their employees and agents (collectively, “User” or “you”) or any mobile application or other products or services provided by OCC for a User (collectively with the Site, the “Services”). An electronic file or files (“Account(s)”) may be set up by OCC for use by Users for storage of data related to the Services and interaction with OCC in order to facilitate the Services, including deposit of funding requests. We use information collected through the use of the Services or on the Site solely for the purposes set out in this policy. The terms of this policy are also incorporated into the OCC Terms of Use.

What information do we collect?

We collect personal information from certain individuals upon submission of an online form and/or completion of application for our Services. “Personal information” generally means information that may be used, alone or in combination with other information, to personally identify a business or individual.

This information includes, but is not limited to, first and last name, e-mail address, mailing address, phone number, social security number and bank account information. Personal information does not include publicly available information or information that has been de-identified, aggregated, or in a form that is not capable of being associated with or linked to an individual.

We also collect information regarding our transactions and experiences, including payment history. We may also collect information from third-parties’ websites or applications as specified in this policy below. We may also collect information through the use of cookies, as outlined below.

If you provide, or make available, any personal information about any business personnel, administrators, employees, owners, and other authorized persons you must first obtain their consent to disclose such information to us. You must inform all such other persons how we process personal information and all other terms of this Privacy and Security Policy.

What do we do with the information we collect?

Any of the information we collect from you, if any, or other Users may be used in one of the following manners:

  • To compile, save, use and analyze information in both a personally identifiable form and an aggregated, non-personally identifiable form;
  • To operate, maintain, improve and provide our Services, conduct our business and process transactions;
  • To verify identity;
  • To register individuals as a user and identify those individuals when signing into an Account;
  • To conduct background checks and determine eligibility for our products;
  • If approved for funding an Account, or other product, to process, service and collect on a financing transaction, and otherwise service an Account, or other product;
  • To personalize an individual’s experience and improve customer service (personal information helps us to better respond to individual needs, service requests, to send marketing communications and send Account update notifications);
  • To develop and improve our website (we continually strive to improve our website offerings based on the information and feedback that we receive);
  • To detect and guard against potential fraud, identity theft, security incidents, or other illegal activity.

Security or how do we protect information?

We take security and privacy very seriously and have developed a comprehensive set of practices, technologies and policies to help ensure data is secure. Accordingly, we adhere to industry-standard security practices including use of advanced security technology and implement a variety of security measures to maintain the safety of personal information.

More specifically:

  • All of our communications and processing occur through technology which ensures such information is encrypted and secure. Such information is stored in our secure database in an encrypted format, which is only accessible to OCC employees and representatives with special access rights. These individuals are required to keep the information confidential.
  • We have established a dedicated security team.
  • To help prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
  • We also use the services of leading companies to process all financial transactions.

While we strive to protect personal information and use commercially acceptable means to protect personal information, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, OCC cannot ensure or warrant the absolute security of any data or content transmitted to us.

In the event of a suspected breach of the security of personally identifiable information, we will, to the extent required by law, notify the affected individual so that they can take appropriate protective steps and we will inform that individual of the steps that OCC is taking with respect to any such suspected breach.

Do we use cookies?

As is true of most platforms, we may use tracking technology (i.e., cookies) which help us make our website and services more user-friendly, efficient, and secure. We may use such technology for advertising purposes. Cookies will not harm computer or mobile devices and do not contain viruses.

If Users prefer not to accept cookies, User’s can opt out as follows:

  • By browser. Most browsers allow the user to (1) require that the browser notifies the user and lets the user choose whether to accept or reject a cookie, (2) disable existing cookies, and/or (3) set the browser to automatically reject cookies. If the user wishes to reject cookies across all browsers used, the user will need to do this on each browser on each device used.

Blocking cookies may negatively impact the experience on our website. Additionally, Users may still receive ads, though they should not be based on the user’s interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs.

Email and Text Message Communications

In order to provide the highest quality user experience, we may communicate with you from time to time using SMS text messaging.

Consent to Electronic Communications

By providing your personal contact information and opting in to receive electronic communications, you consent to:

  1. Receiving occasional marketing, informational and promotional emails, SMS messages, and other forms of electronic communication from OCC. For example, the type of SMS text messages you may receive would be sending of our application and updates on your application status.
  2. The use of your data as outlined in this Privacy Policy.

Update and Opt-Out Mechanism

You may opt out of receiving electronic communications from us at any time. To opt out:

  1. Email Communications: Click the "unsubscribe" link at the bottom of any marketing, informational and promotional email you receive from OCC.
  2. SMS Communications: Reply "STOP" to any SMS message you receive from OCC.
  3. Contact Us Directly: You can also update your personal information or opt out by contacting us in any of the following ways:

Do we disclose any information to outside parties?

We may provide information to our trusted business partners who assist us in operating the Site, conducting our business (including partners referring you or your organization to us), or servicing an Account, so long as those parties agree to keep this information confidential. We also may disclose information to third parties to whom we may refer you or your organization or the application for factoring or other services, consistent with our notice to you or your organization and/or consent from you or your organization. In addition, we may disclose our transactions and experiences with guarantors and clients to credit bureaus.

We do not sell personal information, or otherwise provide personal information to third parties without prior consent to do so, other than service providers receiving information to perform services for us on our behalf. Below are the following categories of third parties with whom we may share information about guarantors and clients:

  • Affiliates;
  • Our service providers, which may include advertising and marketing companies, social media companies, technology companies, fraud prevention agencies, and credit bureaus;
  • Entities with which we have a business relationship, which may include collection agencies;
  • Any other third party with prior consent to do so.

In addition, we may also disclose information:

  • As required by law, such as to comply with a subpoena, judicial or administrative order or warrant, and/or any similar legal process;
  • When we believe in good faith that disclosure is necessary to (i) protect our rights or the rights of third parties (ii) to protect our property and safety or the property and safety of others, or (iii) investigate fraud or respond to a request from a governmental entity;
  • If OCC is involved in a merger, acquisition, transfer, auction (including in a bankruptcy proceeding) or sale of all or substantially all of its assets or equity, or of assets related to the divestiture of a particular division or product, in connection with such a transaction;
  • In connection with the sale of delinquent debt for collections purposes; or
  • With third parties in de-identified or aggregated form for marketing, advertising, research, or other business purposes.

Using Third Party Services and Data Retention

You or your organization allow us to receive information when our Services are used to log in to a third-party website or application (e.g. Facebook, Twitter or LinkedIn) (the “Third Party Platform”). Please note that we retain the information we receive from personal profiles on the Third Party Platform while logged-in to the Services and even after log-out from the Services if such retention is reasonably necessary to enforce this policy and our Terms of Use, in our sole discretion.

Use by Minors

We do not knowingly collect personal information from anyone under the age of 18. If we learn of such information, we will delete it as quickly as possible. If you or your organization believe we may have such information, please contact us.

Links to Other Sites

The Site may offer links to sites of other companies and associations. We are not responsible for the privacy practices or consent of such third-party sites. These external sites are not subject to this Privacy and Security Policy and we have no control over their content. Please carefully review the policies of these sites before providing any personal information.

Governing Law

This policy is governed by the laws of the State of Washington without regard to conflict of laws hereof.

By using the Site, you consent to the OCC’s Terms of Use.

Changes to our Privacy and Security Policy

We may make changes to this Privacy and Security Policy, and we encourage you and your organization to regularly check this page to review any changes we may make. You and your organization understand that you and your organization will be deemed to have accepted an update if you continue to use the Site and Services after any update takes effect. If any material changes are made to this Privacy and Security Policy, advance notice may be posted on the Site.

Effective Date

This version of our Privacy and Security Policy is effective as of June 8, 2024.