Scope
This policy explains what FrontPay Cash, LLC collects when you use frontpaycashapp.com or apply for a product, how we use it, who we share it with, and the choices you have. It applies to applicants, borrowers and site visitors.
Because we are a financial institution under the Gramm-Leach-Bliley Act, we also provide a separate Privacy Notice for consumers describing our information-sharing practices and your right to limit certain sharing. That notice is provided at application and annually thereafter.
What we collect
Information you give us
- Name, date of birth, address, email address and mobile number
- Social Security number or ITIN, for identity verification and credit reporting
- Income details and the amount and term you request
Information from your bank connection
- Account and routing details for the account you link
- Transaction history, typically 60 to 90 days, including deposits, balances and overdraft events
We never receive your banking username or password. The connection is made through an encrypted third-party provider and gives us read-only access. We cannot move money from the account except for payments you have separately authorised.
Information from third parties
- Identity verification results from public and consumer-reporting sources
- Credit reports from consumer reporting agencies, where the product involves a credit check
Information collected automatically
- Device type, browser, operating system, IP address and approximate location
- Pages viewed, referring URL and interaction data, through cookies and similar technologies
How we use it
- To verify your identity, as federal law requires of every lender
- To assess income, affordability and, where applicable, creditworthiness
- To service your account, take scheduled payments and communicate with you
- To detect and prevent fraud and to secure our systems
- To meet legal, regulatory and record-keeping obligations
- To improve the site and, where permitted, to market our own products to you
Who we share it with
- Service providers that operate on our behalf — bank-linking, identity verification, payment processing, hosting, customer support — under contracts limiting their use of the data.
- Consumer reporting agencies, for identity verification and, on Installment Loans and Credit Lines, to report payment history.
- Lending partners, where a product is originated by a partner in your state.
- Regulators, courts and law enforcement, where required by law or valid legal process.
- A successor entity, in a merger, acquisition or sale of assets.
We do not sell your personal information, and we do not share the data obtained from your bank connection with third parties for their own marketing.
Cookies and tracking
We use cookies that are strictly necessary for the site to function, plus analytics cookies to understand how the site is used and, where you consent, advertising cookies. You can control cookies through your browser settings; disabling necessary cookies will stop parts of the application working.
We honour the Global Privacy Control signal where your browser sends one.
How long we keep it
Account and transaction records are kept for the period required by federal and state lending, tax and anti-money-laundering rules — generally seven years after an account closes. Application data from applications that are declined or abandoned is kept for 25 months as required by the Equal Credit Opportunity Act, then deleted or de-identified.
Security
Data is encrypted in transit using TLS and at rest. Access is limited to staff who need it, systems are monitored, and we maintain an information security programme as required of financial institutions. No system is perfectly secure, and we cannot guarantee absolute security.
Your rights
Depending on where you live you may have the right to:
- know what personal information we hold and request a copy;
- correct inaccurate information;
- request deletion, subject to the record-keeping obligations above;
- opt out of sale or sharing for targeted advertising, and of certain profiling;
- limit sharing of certain financial information under the GLBA notice;
- not be discriminated against for exercising a privacy right.
To exercise any of these, email [email protected]. We will verify your identity before acting and respond within the period your state's law allows.
Some information cannot be deleted while it is needed to service an open account or to meet a legal obligation. We will tell you if that applies.
Credit reporting disputes
If you believe something we reported to a credit bureau is inaccurate, contact us and we will investigate. You also have rights under the Fair Credit Reporting Act to dispute directly with the bureau.
Children
The service is not directed to anyone under 18 and we do not knowingly collect information from children. If we learn we have, we will delete it.
Changes
We may update this policy. The date at the top shows when it last changed. Material changes will be notified to account holders by email before they take effect.
Contact
FrontPay Cash, LLC, Midvale, UT 84047, United States. Email [email protected]. Complaints may also be raised with the CFPB or your state regulator.