This Privacy Policy describes how Ascent Funding, LLC, Skills Fund, LLC, d/b/a Ascent Skills Funding, and their affiliates, subsidiaries and programs, and third parties acting on their behalf, (collectively referred to herein as “Ascent”) may collect, share, and use information that is captured while you use Ascent’s website(s), mobile application(s), and/or other online service(s) related to student success and learning about, applying for, or managing a loan, including entering into Ascent contests and sweepstakes (collectively, the “Online Services”). The use of “we,” “our,” and “us” herein refers to Ascent, and “you” and “your” refers to you as the consumer utilizing Ascent’s Online Services.
This Privacy Policy applies to your use of the Online Services. This Privacy Policy also applies to information that we may collect through offline channels, which include but are not limited to phone calls and physical correspondence.
International Users: This Privacy Policy is intended to cover only customers and other users of the Online Services in the United States. Any international users of the Online Services should be aware that by using the Online Services, your information will be transferred to, stored on, and/or processed on servers located in the United States. You also understand that the United States’ data protection laws may not offer the same protections or rights, including judicial redress, with regards to your personal information as the laws of the country in which you are located. By using the Online Services or providing us with your personal information, you consent to this transfer, storage, and processing of your personal information.
Your Consent to this Privacy Policy: By using our Online Services, you agree to the terms of this Privacy Policy as they may be amended from time to time. This Privacy Policy applies to all users of the Online Services. By providing information to us, you understand and consent to the collection, maintenance, processing, and transfer of such information in and to the United, in accordance with United States law. We reserve the right to modify or revise this Privacy Policy. We may notify users if we make material modifications to the Privacy Policy in accordance with applicable law; however, we reserve the right to make other modifications or revisions without prior notice to you. We recommend that users review the most up-to-date version of the Privacy Policy periodically, which will be available on the Ascent website. Your continued use of the Online Services indicates your agreement to be bound by subsequent modifications or revisions to the Privacy Policy.
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.
We also use third-party service provider Microsoft Clarity to capture the user interactions across our Online Services such as, how pages are rendering, and user interactions such as mouse movements, clicks, and scrolls. For more information, see Microsoft Privacy Statement. To control the use of your data for personalized advertising from Microsoft, visit the Microsoft opt-out page.
We also use Socure to help with identity verification and fraud prevention on loan applications. We share your personal information with Socure for said identity verification purposes. To the extent Socure generates or derives data from a photograph of your face, it is not done in order to identify you as a specific individual. Instead, such information is used by Socure in order to match document headshots with a selfie photograph. To the extent Socure derives biometric information from an image of your face, Socure will permanently destroy the images and any information derived therefrom within three years from the date the images were captured, unless otherwise specified in the Socure Products and Services Statement. For more information on Socure’s policies please visit their privacy policy here.
We also use StackAdapt to assist with targeted advertising. You can read more about StackAdapt’s privacy policies and opt-out preferences here. Please visit this page to opt-out of targeted advertising by StackAdapt.
Another third-party service 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/.
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/.
The Online Services also include third-party widgets, like TrustPilot and TrustPulse, links to third-party websites and services, and social media features such as Facebook “Like” or “Share” buttons. These features may collect your information, including IP address, device information, or identifiers, and may set cookies to enable the feature to function properly. Your interactions with social media features and third-party widgets appearing in the Online Services are not governed by this Privacy Policy, but by the privacy policies of the companies providing those features.
Some of the content, advertisements, and functionality of our Online Services may be provided by third-party subprocessors. When we share your information with third-party subprocessors, such as our vendors and service providers, we remain responsible for it. We work hard to maintain your trust and when bringing on new vendors and subprocessors, we make certain those third parties can be trusted with any Personal Information they may have access to.
Name of Subprocessor: AWS Amazon
Description of Processing: Data Hosting
Location of Processing: U.S.
Corporate Location: U.S.
Name of Subprocessor: Sentry.io
Description of Processing: Application monitoring provider
Location of Processing: U.S.
Corporate Location: U.S.
Name of Subprocessor: Microsoft Clarity
Description of Processing: Website analytics
Location of Processing: U.S.
Corporate Location: U.S.
Name of Subprocessor: Socure
Description of Processing: Identity Verification
Location of Processing: U.S.
Corporate Location: U.S.
Name of Subprocessor: Google Analytics
Description of Processing: Website analytics provider
Location of Processing: U.S.
Corporate Location: U.S.
Name of Subprocessor: Convert
Description of Processing: Website analytics provider
Location of Processing: U.S.
Corporate Location: U.S.
Skills Fund, LLC d/b/a Ascent Skills Funding (“Skills Fund”) may use Plaid Inc. (“Plaid”) to gather your account transaction data from financial institutions in regard to your Income Share Agreement (“ISA”). If you link a bank account in connection with an Income Share Agreement (“ISA”), Plaid will collect data directly from the financial institution you specify. You grant Plaid and us the right, power, and authority to access and transmit personal and financial information about you from the financial institution you specify. You agree to such personal and financial information being collected, transferred, stored, and processed in accordance with our Privacy Policy and Plaid’s Privacy Policy.
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 share this data with trusted third parties who assist us in operating the Online Services, processing transactions (such as your student loan or bootcamp loan application), conducting our business, or servicing you. These parties agree to keep Web Beacon information confidential, consistent with this Privacy Policy.
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.
The Online Services may contain links to other websites that we feel may be of interest to you. We are providing these links to you as a convenience, but these external websites may have different privacy policies than the Online Services. Please review the privacy policy of any third-party website or service you access through the Online Services as any information that you share with third-party websites or services are not subject to this Privacy Policy
Personal Information that you share on Ascent-managed pages on social media platforms, such as Facebook, Instagram, and Twitter, and social media advertising services are subject to the privacy policies and terms of use of those platforms. Please refer to those policies before posting any content to those pages or to learn how to opt out from ads or otherwise manage ad preferences. You should NEVER provide Personal Information to Ascent through social media.
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”).
Ascent is providing you with this Notice at Collection (“Notice”) and Privacy Policy as required under CCPA and CPRA to provide you with timely notice, at or before the point of collection, about the categories of Personal Information to be collected from you, the purposes for which the Personal Information will be used, and retention periods.
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:
To partnered banks like DR Bank, Richland State Bank and Bank of Lake Mills, service providers like TransUnion and Socure, affiliates like Launch Servicing, LLC and AscentUP, and other trusted third parties like Second Street, Upland Software, Inc., OneSignal, and LearnWorlds, who assist us in operating the Online Services, providing you with AscentUP products and services running sweepstakes and contests, processing transactions (such as for your student loan or bootcamp loan application), conducting our business, or servicing you, so long as these parties agree to keep this information confidential, consistent with this Privacy Policy.
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.
We may update this Privacy Policy from time to time. Any updated Privacy Policy will be accessible from the footer of the website or other convenient location. The current version of the Privacy Policy, as indicated by the Last Updated date below, will become effective as soon as it is posted. Your use of the Online Services once a revised Privacy Policy has been posted constitutes your acceptance of the revised Privacy Policy.
If you have any questions about this Privacy Policy, please contact the Toll Free Number at +1 855-218-6733 or email us at [email protected].
Last Updated: March 21, 2024
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