**Simula Financial Privacy Policy**
Simula Financial Counseling is dedicated to ensuring the confidentiality and protection of personal information, which may include data that directly or indirectly identifies an individual. This information, referred to as “Personal Information,” includes but is not limited to the categories listed below in the section “Our Collection of Information.” This Privacy Policy outlines Simula Financial Counseling’s data protection measures, offering an overview of how we handle Personal Information from clients, prospective clients, job applicants, website users, and other third parties.
The policy also addresses individuals and organizations outside Simula Financial Counseling, such as clients and prospective clients who share their Personal Information with us. It covers users who interact with Simula Financial Counseling via our website, social media platforms, and email communications, including messages that link to this Privacy Policy (collectively referred to as “Internet Communications”). It further explains how Simula Financial Counseling collects, uses, discloses, and secures Personal Information when providing its services or conducting Internet Communications (collectively referred to as the “Services”).
### Collection, Use, and Disclosure of Personal Information
Simula Financial Counseling collects Personal Information in the process of delivering services to clients and potential clients, as well as from individuals interacting with us through our website and Internet Communications. We may also gather Personal Information from external sources and third parties as detailed below.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.”
#### Information We Collect
When you provide us with your Personal Information, you are consenting to the collection of the following:
– Data about you, including your name, trade name (DBA), contact details such as address, phone number, email, social media profiles, and date of birth (for individuals), as well as your credit card information, Employer Identification Number (EIN), and Social Security Number (SSN).
– Financial details, such as income, expenses, loan or debt information, account balances, payment histories, and transaction records with financial service providers or creditors.
– Additional information from third-party sources, including consumer reporting agencies, the Better Business Bureau, Yelp, credit bureau reports, or other relevant communications regarding your payment histories, creditworthiness, income, and financial obligations.
By sharing your Personal Information, you also authorize us to access and use this data for the purposes mentioned below.
#### How We Use Your Personal Information
By providing your Personal Information to Simula Financial Counseling, you authorize us to use this data for various purposes, including:
– Delivering our services to you and acting on your behalf.
– Building a comprehensive understanding of your financial standing and creditworthiness.
– Offering additional services that may benefit you.
We may also use your Personal Information for the following:
– Responding to your inquiries and providing customer support.
– Personalizing your experience with our services and assisting you in using them.
– Analyzing and improving our business operations and website performance.
– Managing our recruitment processes.
– Providing you with our services and managing any matters for which you engage us.
– Informing you of developments and updates that might interest you.
– Executing or managing various contracts.
– Complying with legal, regulatory, and professional obligations, including anti-money laundering requirements. If we are unable to collect certain Personal Information, Simula Financial Counseling may be unable to offer specific services.
#### Disclosure of Personal Information
By providing us with your Personal Information, you consent to Simula Financial Counseling sharing your data with third parties, including but not limited to:
– Service providers and related entities, such as independent contractors, marketing service providers, and other necessary individuals or organizations needed to deliver or manage our services.
– Legal authorities or law enforcement to prevent fraud, comply with legal requirements, or respond to subpoenas, court orders, or other legal processes.
**Disclosure of Personal Information**
When you provide Personal Information to Simula Financial Counseling, you are giving your consent for us to share and disclose that information to third-party individuals or entities, as necessary, and in accordance with applicable law. This includes, but is not limited to, sharing your Personal Information with the following:
– **Service providers and related entities**: This includes independent contractors, marketing service providers, and other entities or individuals needed to administer and perform our services.
– **Third parties, such as law enforcement**: We may disclose your Personal Information when required for fraud detection and protection, or in response to legal requests like subpoenas, or as required by federal, state, or local laws.
### Notice Regarding Your Right to Opt-Out
You have the right to opt-out of Simula Financial Counseling’s sharing of your Personal Information. However, there are circumstances where opting out is not allowed, specifically:
– When sharing is required to process or administer a financial transaction that you have requested or authorized.
– When sharing is necessary with service providers who carry out business operations for Simula Financial Counseling, or entities marketing our services on our behalf.
– When sharing information with your creditors, service providers, collectors, and other relevant parties necessary to perform services and manage your transactions with us.
– When disclosing information to prevent fraud, respond to legal processes, or comply with federal, state, or local laws.
– In the event of a sale or transfer of your account or Simula Financial Counseling’s business assets, your Personal Information may also be shared or transferred.
To exercise your right to opt-out, you must notify us by sending an email to info@pagasacash.com. Your opt-out will only take effect once we receive and process your request. If we do not receive your opt-out notice within 30 days from when this policy is provided to you, we will proceed with sharing your information with non-affiliated third parties as outlined above.
### Confidentiality, Security, and Retention of Personal Information
At Simula Financial Counseling, we take great care to protect the confidentiality of the information entrusted to us. We maintain appropriate physical, electronic, and procedural safeguards to protect Personal Information. These measures are intended to secure your data, although we cannot guarantee they are infallible.
We also require our contractors, suppliers, and vendors to uphold reasonable and appropriate data security protections, in accordance with relevant data protection laws and regulations.
We retain your Personal Information for as long as necessary to meet our legal obligations or to fulfill the purposes for which the data was originally collected, as well as other purposes described in this Privacy Policy.
### Log Files
Simula Financial Counseling uses log files as part of our standard website operations. These files track visitors to our site and collect data such as IP addresses, browser types, Internet Service Providers (ISPs), timestamps, referring/exit pages, and click counts. None of this information is linked to personally identifiable details. This data is used for analyzing trends, managing the site, tracking user movements, and collecting demographic data.
### Children’s Information
Simula Financial Counseling does not intentionally collect Personal Information from children under the age of 13. If you believe that your child has provided us with such information, please contact us immediately. We will promptly work to remove any such information from our records.
### Third-Party Privacy Policies
Third-party ad servers or networks may use technologies such as cookies, JavaScript, or web beacons in the advertisements and links appearing on Simula Financial Counseling’s website. These technologies automatically collect your IP address when ads are delivered through your browser. They are used to measure the effectiveness of their ad campaigns or personalize the advertising content you see on various websites.
Simula Financial Counseling does not have access to or control over these cookies or technologies used by third-party advertisers. For more detailed information, please consult the privacy policies of the relevant third-party ad servers. These policies will provide more details about their data practices and options for opting out.
You can manage your cookie preferences directly through your browser settings. For more specific information about cookie management for your browser, visit the browser’s help or settings page.
**For California Residents**
In accordance with California’s “Shine the Light” law, California residents have the right to opt-out of having their Personal Information shared with third parties for direct marketing purposes. If you wish to exercise this right, please send an email to **info@pagasacash.com** indicating your desire to opt out of such sharing.
Please note that our website does not respond to “Do Not Track” signals from browsers. However, we do not collect or permit any third parties to collect nonpublic personally identifiable information about individual consumers’ online activities over time and across different websites or online services.
Our website uses **Google Analytics**, a tool provided by Google, Inc. (“Google”) to help website owners understand how visitors engage with their website. This tool provides us with various reports about how visitors interact with our website, helping us make improvements. **Google Analytics** collects information anonymously, using cookies and IP addresses, without identifying individual visitors. To learn more about Google Analytics, you can visit:
[Google Analytics Privacy Information](http://www.google.com/analytics/learn/privacy.html).
If you wish to opt-out of Google Analytics tracking, you can install the **Google Analytics Opt-out Browser Add-On**. For more information and to install the add-on, visit:
[Google Analytics Opt-out Browser Add-On](https://tools.google.com/dlpage/gaoptout?hl=en).
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**For Nevada Residents**
We are providing this notice in accordance with Nevada state law. If you prefer not to receive marketing calls from us, you can request to be added to our internal “Do Not Call” list by calling **(888) 535-5560**. Additionally, Nevada law requires us to provide the following contact information:
**Bureau of Consumer Protection**
Office of the Nevada Attorney General
555 E. Washington St., Suite 3900
Las Vegas, NV 89101
Phone: **702‐486‐3132**
Email: **BCPINFO@ag.state.nv.us**
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**For Vermont Residents**
In compliance with Vermont law, we will not share any information we collect from Vermont residents with non-affiliated companies, except as allowed by law, such as with your consent or in order to service your accounts. We will also not share information about your creditworthiness with our affiliates unless you provide authorization or consent. However, we may share information related to our transactions or experiences with our affiliates without requiring your consent.
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**Changes to This Privacy Policy**
We reserve the right to update or modify this Privacy Policy at any time, with or without prior notice. If any changes are made to this policy that impact the services we provide, **Simula Financial Counseling** will post the updated Privacy Policy on our website and take any additional steps we deem reasonable to inform users.
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**Contact Us**
If you have any questions or concerns about how we handle your Personal Information, please feel free to reach out to us via email at **info@pagasacash.com**.
**Last Updated:** 4/12/2024
Another page **Responsible Lending Act**
At **Simula Financial Counseling**, we are dedicated to promoting responsible and ethical lending and marketing practices. We partner exclusively with lenders and other entities that adhere to the following regulations, ensuring that consumers receive fair and transparent treatment when seeking lending services.
**Truth in Lending Act (TILA)**
The **Truth in Lending Act (TILA)** requires lenders to fully disclose all terms and conditions of a loan offer before the borrower electronically signs or agrees to the loan agreement. It also mandates that lenders comply with lending laws in each state where they operate. TILA aims to ensure transparency in the loan application process, enabling consumers to clearly understand the terms of their loan and their obligations for repayment.
**Fair Credit Reporting Act (FCRA)**
The **Fair Credit Reporting Act (FCRA)**, enacted in 1970, governs the collection and use of consumer credit information. This federal law limits access to credit reports and ensures the accuracy, fairness, and privacy of consumer data held by credit reporting agencies. It sets clear rules on how consumer information should be handled to protect consumers’ rights.
**Equal Credit Opportunity Act (ECOA)**
The **Equal Credit Opportunity Act (ECOA)** prohibits discrimination against individuals applying for credit. Lenders are barred from making credit decisions based on factors such as age, race, ethnicity, gender, marital status, or health condition. Regulation B of the ECOA specifies what practices are permissible and what practices are not, ensuring fair treatment for all credit applicants.
**Fair Debt Collection Practices Act (FDCPA)**
The **Fair Debt Collection Practices Act (FDCPA)** is a federal law that sets guidelines for debt collection activities. It regulates how debt collectors can communicate with consumers, prohibiting unfair, deceptive, or abusive practices. Since **Simula Financial Counseling** is a marketing company, not a lender or loan broker, we do not engage in debt collection activities or contact you regarding any outstanding debts.
**Telephone Consumer Protection Act (TCPA)**
The **Telephone Consumer Protection Act (TCPA)** governs how companies can communicate with consumers via telephone, text, and fax. Originally enacted to address “junk faxes,” the law has since been updated to regulate calls and SMS messages to mobile phones using automated dialing systems. When using our website, you will be asked to consent to communications from **Simula Financial Counseling** and our partners, which may include calls, text messages, pre-recorded voice messages, or automated calls to the phone number you provide. By giving your consent, you agree that we may contact you using technology that generates artificial or computer-generated voices. While this consent is not mandatory for using our website, it may be required for us to share your information with our partners, which could affect your ability to be matched with lenders. If you prefer not to consent to such communications, you may submit your information to us in writing via U.S. mail to the address listed on our website.
**Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act)**
The **CAN-SPAM Act**, passed in 2003, regulates commercial email communications. It requires that recipients be given an easy way to “opt-out” of receiving future emails and imposes penalties for violations. The law ensures that marketing emails provide clear ways for consumers to stop receiving unsolicited messages.
By following these laws, **Simula Financial Counseling** upholds a culture of ethical lending and marketing practices, ensuring consumers are treated fairly and their rights are respected.
