Privacy Policy

1Scope

This Privacy Policy applies to personal information we collect from:

• employers and their representatives who inquire about, book a call regarding, or partner with CIF to fund an Impact Loan program;
• employees of partner employers who apply for an Impact Loan or request free financial coaching;
• website visitors, form submitters, and individuals who book an Employer Impact Review;
• donors, supporters, and community members; and
• any other individuals who interact with our Services.

This Privacy Policy does not replace notices that may be provided at the time of collection, in loan program materials, in coaching agreements, or in separate terms governing specific programs or portals.

2Information We Collect

We may collect the following categories of personal information, depending on how you interact with us:

A. Information you provide directly

From employer prospects and partners:

• name and job title
• business or organization name
• work email address
• mobile or other phone number
• number of employees and general workforce information
• scheduling and availability details for an Employer Impact Review
• form responses, comments, and messages

From employee loan applicants and coaching participants:

• name and contact information
• identity verification information required to administer a loan
• banking and account details needed to disburse loan funds and collect repayments
• income, expense, and other financial information used to vet applications as required under IRS regulations applicable to charitable assistance
• the nature of the financial hardship or crisis prompting the request
• records you submit in connection with a request, inquiry, or complaint

B. Information collected automatically

When you use our Services, we and our vendors may automatically collect:

• IP address
• browser type and device identifiers
• operating system
• pages viewed and links clicked
• referral URL
• approximate geolocation derived from IP address
• session activity and timestamps
• cookies, pixels, tags, and similar technologies

C. Information from third parties

We may receive information from:

• partner employers who introduce or refer you to an Impact Loan program (limited to what is needed to confirm eligibility)
• analytics and advertising providers
• communications and messaging providers
• payment and banking service providers
• scheduling and form-management tools
• publicly available sources
• service providers acting on our behalf

D. Sensitive information

Depending on context, we may collect information that may be considered sensitive under certain laws, such as government-issued identifiers, financial account information, account credentials, and information about a financial hardship. We collect and use such information only as reasonably necessary to operate the Impact Loan and coaching programs and as permitted by law.

3How We Use Personal Information

We may use personal information for the following purposes:

• to provide and operate our Services
• to respond to inquiries and requests
• to schedule and conduct Employer Impact Reviews and coaching sessions
• to send confirmations, reminders, updates, and follow-up communications
• to evaluate, approve, disburse, service, and collect repayment on Impact Loans
• to verify identity and vet applications as required under applicable IRS regulations for a 501(c)(3)
• to provide free financial coaching
• to personalize content and improve user experience
• to maintain security, prevent fraud, and protect our rights
• to comply with legal, tax, and regulatory obligations and respond to lawful requests
• to conduct internal reporting, analytics, and service improvement
• to place outbound calls and send messages, including live calls and text messages, as described below and subject to applicable consent and opt-out rules

4Calls, Text Messages, and Voice Communications

If you provide us with a phone number, we may contact you at that number for program-related communications, subject to your consent choices and applicable law.

Depending on your interaction with us, these communications may include:

• inquiry and application follow-up
• Employer Impact Review confirmations and reminders
• loan status and repayment notices
• coaching scheduling and reminders
• account or service notices
• optional informational messages, if you have consented where required

These communications may be made by CIF personnel, by our service providers acting on our behalf, and using automated messaging technology.

Opt-out and revocation of consent

You may opt out of texts at any time by replying STOP. You may also revoke consent to receive calls or texts by any reasonable method that clearly communicates your request, including contacting us using the information in the "Contact Us" section below.

We will honor opt-out and revocation requests as required by law. Even if you opt out of marketing communications, we may still send non-marketing communications permitted by law, such as transactional loan servicing, informational, or legally required notices.

5Consent Records

Where we rely on consent for communications or data practices, we may maintain records of:

• the form or page where consent was collected
• the date and time of consent
• the wording presented at the time of consent
• the phone number or email address provided
• IP address or other submission metadata
• subsequent preference changes or opt-out requests

We retain these records for compliance, audit, dispute-resolution, and business continuity purposes.

6Cookies, Analytics, and Advertising

We and our service providers may use cookies and similar technologies to:

• remember preferences
• measure traffic and campaign performance
• understand website engagement
• improve design and functionality
• support security and troubleshooting

You may be able to manage cookies through your browser settings. Some browsers also allow you to send a "Do Not Track" signal, but because there is not a uniform industry standard for recognizing such signals, our Services may not respond to them in every context.

Where required by law, we will provide additional notice and choices.

7Loan Applicant Anonymity and Employer Relationships

Protecting the dignity of employees who apply for an Impact Loan is a core commitment, not boilerplate. An employee's decision to seek help is personal.

CIF itself does collect applicant information, including identity, banking details for disbursement and repayment, and financial information for vetting under IRS regulations. We collect it because we must to run the program responsibly, and we protect it accordingly.

Impact Loans are not reported to credit bureaus. Positive payment history may be shared with our Giving Credit partnership (givingcredit.org) only with your consent, so that responsible repayment can help build your credit if you choose to participate. We never blame or penalize an employee for being in financial crisis.

8Children's Privacy

Our Services are directed to employers, adult employees, donors, and community members. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided personal information to us, please contact us and we will take reasonable steps to delete it, subject to applicable legal requirements.

9How We Disclose Personal Information

We may disclose personal information to:

• service providers and contractors that help us host websites, manage forms, process payments and loan transactions, send communications, provide analytics, store records, secure systems, and operate the Services
• banking and payment vendors that disburse loan funds and process repayments
• the Giving Credit partnership (givingcredit.org), only with your consent, to report positive payment history
• professional advisors such as attorneys, auditors, and consultants
• government authorities, courts, law enforcement, or regulators when required or permitted by law
• parties involved in an actual or proposed merger, reorganization, or similar transaction
• other parties with your direction or consent

We do not sell or share your personal information. We do not sell personal information in exchange for money, and we do not share personal information with third parties for their own marketing purposes. As described in Section 7, we never share loan applicant identity or details with the partner employer.

10Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide services and communications
• administer and service loans and maintain loan records
• comply with legal, tax, accounting, and regulatory obligations applicable to a 501(c)(3)
• resolve disputes
• enforce agreements
• maintain safety, audit, and compliance records

Retention periods may vary by data type, legal requirements, and operational need. When personal information is no longer reasonably necessary, we will delete, de-identify, or securely dispose of it as required by law.

11Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including the banking and financial information provided by loan applicants. No method of transmission over the internet or method of storage is completely secure, so we cannot guarantee absolute security.

12Your Privacy Rights

Depending on your state of residence and subject to applicable exceptions, you may have the right to:

• know whether we process your personal information
• access personal information we hold about you
• request correction of inaccurate personal information
• request deletion of personal information
• obtain a copy of certain personal information in a portable format
• opt out of certain profiling, targeted advertising, sale, or sharing activities, where applicable
• limit the use or disclosure of sensitive personal information, where applicable
• appeal a denial of a privacy request, where required by law
• not be discriminated against for exercising privacy rights

Some of these rights may not apply to information we must retain to service a loan or to meet legal, tax, or regulatory obligations. To exercise available rights, contact us using the information below. We may need to verify your identity and authority before processing your request.

13State-Specific Disclosures

Residents of certain states may be entitled to additional disclosures or rights. Where required by law, we may provide supplemental state notices.

Colorado residents. CIF is based in Colorado. Under the Colorado Privacy Act, Colorado residents have the right to access, correct, and delete personal data, to obtain a portable copy, and to opt out of targeted advertising, the sale of personal data, and certain profiling. You may also appeal a denial of a request. To exercise these rights, contact us using the information in Section 18. If you are a resident of another state that grants privacy rights not fully described here, you may contact us to request the state-specific notice applicable to your jurisdiction.

14Text Message Program Disclosures

Where we offer an SMS or MMS messaging program:

• message frequency may vary
• message and data rates may apply
• consent is not a condition of purchase or enrollment
• reply STOP to opt out
• reply HELP for help, where supported
• wireless carriers are not liable for delayed or undelivered messages

We may use third-party messaging platforms to operate these programs.

15AI and Automated Communications

We may use automation, including AI-assisted tools such as a chatbot, to support communications, scheduling, message routing, reminders, chat assistance, and related operational functions.

Where we use automated communication technology, we do so for permitted program-related purposes and subject to applicable law, consent requirements, and opt-out rights. We do not use AI solely to make legally significant decisions about individuals, such as final loan approvals, unless permitted by law and appropriately disclosed, and a person remains involved in decisions that materially affect you.

16Third-Party Links and Services

Our Services may contain links to third-party websites, applications, calendars, scheduling tools, payment services, or social media features. We are not responsible for the privacy, security, or content practices of third parties. We encourage you to review their privacy policies before interacting with them.

17Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date and take any additional steps required by law. Your continued use of the Services after changes become effective means the updated Privacy Policy will apply, to the extent permitted by law.

18Contact Us

If you have questions about this Privacy Policy or wish to exercise applicable privacy rights, contact us at: