We collect Personal Information that you provide to us on the Online Services via coaching sessions, forms, applications, surveys, user account creation, and other fillable fields. This “Personal Information” may include your name, address, date of birth, Social Security number, citizenship, military status, age, national origin, email address, telephone numbers, loan number, account number, driver’s license number, passport number, username (if different than your email), password, education or academic information, housing information, audio information, professional (or employment) information, salary, income, financial information, and other identifying information. Personal Information does not include de-identified or aggregated information, which is information in which identifiable information is removed and that cannot reasonably be used to identify an individual.
If you choose to use the Online Services, we may also collect information from third parties, such as credit reports and employment information.
We also collect information about your use of the Online Services, such as your information relating to any loan application, transaction history, account balance, Ascent Connect experience, and other account information, subscription status, and payment information.
We may also collect information through offline channels, which includes audio recordings through customer service calls and physical correspondence.
In addition to the Personal Information that we collect from you as described above, we may automatically collect certain information, including Personal Information, from your use of the Online Services. This information may include:
The information described above may be collected through cookies (defined below), pixel tags (defined below), clear gifs, or other technologies.
Ascent uses your Personal Information for the following purposes:
We do not sell your Personal Information or the Personal Information of minors. We do not trade, or otherwise transfer your Personal Information to third parties without your consent, except as described in this paragraph. We may, without your consent, disclose your Personal Information:
We may also request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
We employ reasonable security measures, designed to maintain the confidentiality, integrity, and security of your Personal Information to protect against the loss, misuse, or alteration of information that we have collected about you. For example, Ascent employs policies and procedures designed to protect Personal Information in accordance with applicable law, including but not limited to the Gramm-Leach-Bliley Act. Unfortunately, no security technology is completely secure, and you should remember that email and the Internet generally may not be a secure means of communication and/or transmitting Personal Information. Personal Information that you share via email is done so at your own risk.
Some web browsers may transmit “do-not-track” or similar signals to the websites with which a user communicates. There currently is no industry standard for how websites must respond when they receive such a signal. The Online Services do not respond to do-not-track signals sent by web browsers.
Some of the content, advertisements, and functionality on the Online Services may be provided by third parties. We also use third-party service providers, including Sentry.io, to provide us with analytics, error detection, and application functionality services, so we can improve our Online Services. Although Sentry.io does not use cookie technology, collect Personal Information, or otherwise track users, data is collected during instances of application crashes, errors, software bugs or other adverse events. Sentry.io data is paired with randomly generated unique identifiers (UUIDs) to enable us to diagnose adverse events, like application crashes. Other third parties may collect information about your use of the Online Services through technologies such as cookies and web beacons, and this information may be collected over time and combined with information collected across different websites. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. For example, some of these third parties may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”), which provide websites where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit https://www.networkadvertising.org/managing/opt_out.asp or https://www.aboutads.info. For more information about mobile device opt outs, please visit https://thenai.org/opt-out/mobile-opt-out/.
One of the third-party services that we use is Google Analytics, which is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the Online Services and may share this data with other Google services. We have also enabled Google Analytics Advertising features, including Remarketing, so Google may use the data collected to contextualize and personalize the ads of its own advertising networks. The Online Services and third parties, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to the Online Services and report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Online Services. You can learn more about Google’s privacy practices by visiting their website at https://www.google.com/policies/privacy/partners/.
When you link a bank account in connection with an ISA, you authorize Skills Fund and Plaid to continue to collect data from the financial institution you specify for as long as your ISA remains outstanding. The frequency at which Skills Fund and Plaid will collect data during this period will vary. You can revoke this authorization by writing Skills Fund at [email protected].
The Online Services also use “cookies” (small data files stored on your device) and other tracking technologies to collect information about your use of the Online Services. The information that is captured about your use of the Online Services may be used in a variety of ways, such as to monitor and maintain information about your visits to the Online Services, to help us identify and address problems, to improve the Online Services, to analyze web traffic trends, and to help protect the security and integrity of the Online Services.
You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use the Online Services, but your experience may be degraded.
Web Beacons are commonly used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked. We may use Web Beacons via the Online Services in connection with our identity verification process for loan applications. This may include utilizing online activity, device, and location data collected to verify information submitted to us.
We may also use pixel tags (also known as “clear gifs,” “Web beacons,” or “1-by-1 gifs”) via the Online Services. These may be used in connection with certain pages of the Online Services or with email messages to measure the effectiveness of our communications and our marketing campaigns, to compile statistics about usage and response rates, to market to you, and to assist us in resolving issues that may arise on the Online Services.
We do not knowingly collect Personal Information from individuals under 13 years of age without parental consent. If we become aware that a child under 13 is attempting to submit Personal Information, we will inform the child that he or she is ineligible to do so. We will then remove this information from our records. If you believe that we have inadvertently collected Personal Information from a child, please notify us immediately. Our Online Services are not intended for children under 13 years of age.
If you are a California resident, California law may provide you with additional rights regarding your Personal Information, including under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”).
We take reasonable steps to ensure that the Personal Information we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Information whenever necessary. We also take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of, data.
We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements, including taking into account the freedoms of speech and expression.
Ascent collects the following categories of Personal Information about you:
Ascent will use the categories of Personal Information about you described above for the following business or commercial purposes:
Under the CCPA/CPRA, you have the right to request Ascent disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Under the CCPA/CPRA, you have the right to request the deletion of Personal Information. However, this right does not apply where we need to retain the Personal Information for any of the following purposes:
California consumers have the right to opt-out of the sale and sharing of Personal Information by a business that sells or shares Personal Information. Ascent does not sell any Personal Information of California consumers. Ascent does share some personal information with bank partners and trusted third parties in order to process transactions, applications, provide identity verification, monitor fraud, and operate and support the Online Services.
California consumers may request the correction of any of their sensitive Personal Information for specific secondary purposes.
California consumers may request to limit the use and disclosure of their sensitive Personal Information for specific secondary purposes.
We will not discriminate against you for exercising any of your rights under the CCPA or CPRA. Discrimination under the CCPA/CPRA includes but is not limited to:
If you are a California resident and would like to exercise your access or / and deletion rights under the CCPA or CPRA, please submit a verifiable consumer request to us by either calling the Toll Free Number at +1 855-218-6733 or email us at [email protected]. If you are making a request under CCPA or CPRA, only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will attempt to match the Personal Information submitted with your request against our records to verify your identity.
You may designate an authorized agent to make a CCPA/CPRA request on your behalf by writing to us at the contact information provided above. In addition to the requirement stated above that the agent must be registered with the California Secretary of State, we also require documentation confirming that the individual is authorized to submit the request on your behalf. This may include a signed letter from you or notarization of your request.
Last Updated: December 22nd, 2022