Intercontinental Capital values your patronage and protecting your confidential information is a priority. Our policies and procedures reinforce the fact that we strongly believe in protecting the confidentiality and security of the information we collect about you as a customer, potential customer or former customer. We have adopted the following policies and procedures to safeguard the personal information about you in our possession.

Introduction

This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.

Our Privacy Pledge

·         We do not sell or rent customer information.

·         We share customer information with certain employees and with companies providing services on our behalf in order to service your needs.

·         Our policy is to require all employees and companies providing services on our behalf to keep customer information confidential.

·         Our privacy policy applies to potential customers as well as current and former customers.

Safeguarding Personal Information

·         We have adopted policies and procedures designed to protect your personal information from unauthorized use or disclosure.

·         We have implemented physical, electronic and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access. These include among other things, procedures for controlling access to customer files, building security programs and information technology security measures such as the use of passwords, firewalls, virus prevention and use detection software.

·         We continue to assess new technology as it becomes available and to upgrade our physical and electronic security systems as appropriate.

·         Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing or developing our products or services.

·         Our policy, which governs the conduct of all of our employees, requires all employees to safeguard personal information about the consumers and customers we serve or have served in the past. 

Intercontinental Capital Security Policy

Intercontinental Capital takes strong steps to safeguard your personal and sensitive information through industry standard physical, electronic and operational policies and practices. All data is considered highly confidential Data can only be read or written through defined service access points, the use of which his password-protected. The physical security of the data is achieved through a combination of network firewalls and severs with tested operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Information We Collect About You

We collect information about you to help us serve your financial needs, to provide you with quality products and services and to fulfill legal and regulatory requirements. We consider non-public information about you in our possession to be personal information, even if you cease to be a customer. The personal information we collect about you may include among other things:

·         Identifying information, such as your name, age, address, phone number and social security number

·         Employment information

·         Financial information such as your income, assets and liabilities, as well as information about your savings, investments, insurance and business.

Intercontinental Capital does not alter its behavior or change its services upon receiving Do Not Track requests.

Typically, we collect this information on applications and other forms you complete, through conversations you may have with our loan originators and processors, with our other representatives, and in some cases, over our website. We may also collect information from a wide range of other sources in order to process and/or underwrite your loan. These sources may include among others, employers, attorneys, banks, title insurers, insurance companies and credit reporting agencies.

We will use this information to pull a credit report from a credit bureau to determine your credit worthiness as well as to help our underwriters to assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during the lending process such as: 

·         Enabling our financial services partners to implement automatic payments and funds transfer

·         Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account

·         Implementing collection activities as needed

·         Maintaining regular communications with you as may be necessary to execute loan application, loan agreement and certain stipulations such as identity verification, income verification and employment verification

In addition, we gather names and email addresses of people who contact us through our website with questions about our company or lending operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people.

Lastly, we (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website, as discussed further below.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Communications from Our Site

When you submit an application and/or create a profile on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and the bank accounts, and confirmation of successful submissions of loan requests and portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

Links to Third Party Websites

Intercontinental Capital is not responsible for the information practices employed by sites linked to or from our website. In most cases, links to non- Intercontinental Capital websites are provided solely as an access point to obtain information on products and topics that may be useful to the users of the Intercontinental Capital website. Third party websites may have different privacy policies and/or security standards governing their sites.

Notifications

Intercontinental Capital will send you email notifications from time to time, and these are required elements of your transactions on our website, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements, terms and condition updates and privacy policy update notifications. Generally you may not opt out of these eservice related emails.

Sharing Information With Companies That Provide Services For Us

We share personal information about you, as required or permitted by law, with third parties, such as service providers who assist us in the day to day operations of our company in the administration, processing, servicing and sale of your loan. These third parties include among others, title companies, appraisers, insurance companies, underwriting services, processing services, printing companies, software providers, marketing services and purchasers of loans. Our policy is to require third party service providers to enter into confidentiality agreements with us, prohibiting them from using any personal information they obtain for any other purpose other than those for which they were retained or as required by law. We may also disclose information about you, when necessary or required, in legal and arbitration proceedings and to government agencies.

Web-related Information Collection

We use web beacons or pixel tags in conjunction with cookies on our website, including session ID cookies, non-persistent cookies. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser and load the pages according to a user’s preferences for that particular site, including the personalization of content. Cookies are also used to gather statistical data, such as which pages are visited, what is downloaded, the ISP’s domain name and country of origin, and the addresses of sites visited before and after coming to our site, as well as your “click stream” activity, meaning the paths taken by visitors to our site as they navigate from page to page and transactional attributes in accordance with information you voluntarily submit in the course of using our site. This data is aggregated for analysis to ensure proper functioning of our site, in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing activities. At no time do any of our cookies capture any personal information. More importantly, using cookies also helps us protect the security of your account. Session ID cookies follow your activities on our site so that we can ensure that no one is making changes to your profile, applying for loans or making loans on your behalf. This information is encrypted and no personal data about you is stored on our servers. We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our website, to improve its usability and for evaluating our marketing events. We may also use that information to recognize your computer when you visit our website. Most browsers allow you to refuse to accept cookies. Blocking cookies, however, can also have a negative impact on the usability of many websites. We also use third-party tracking services that use cookies or other tracking technology to track non-personal information about visitors to our site in the aggregate such as web page views, other sites visited and referral page information to track the effectiveness of our marketing campaigns to bring visitors to our site. We use respective web beacons to gather information that lets use tune and improve our user’s browsing experience, as well as track user responsiveness to various advertising campaigns and user activities. Intercontinental Capital utilizes information such as “click stream” and transactional data, and use all information collected in the aggregate, for anonymous purposes. No personal or sensitive information is transmitted to advertising partners. However, certain partners may collect incoming IP addresses in connection with your visits to our site.

California Do Not Track Notice

Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites, to the extent the operator engages in that collection. At this time, we do not track our customer’s personal information over time and across third-party websites and therefore this requirement does not apply to us. California law also requires website and online service operators to disclose whether third parties may collect personal information about their user’s online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our site unless you directly provide it to us and we provide it to them with your consent.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our customers. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Link to Other Sites

We may offer links to partner’s sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled or to facilitate our customers’ more effective use of our website, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy and may have different privacy policies or approaches to the handling of information. Intercontinental Capital has no control over the content of these sites. Please consult the privacy policies on these sites before you provide them any of your personal information.

We also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that you when you connect to our website you are actually on our site. SSL also ensures that all data entered into the website is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For encryption protection, we use 128-bit secure browser for login and transactions. The application process utilizes “CAPTCHA” technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering the text shown in the image. We subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.

Session time-outs

We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever received an email purporting to come from Intercontinental Capital that asks for your password, you should immediately contact Intercontinental Capital.

What you can do

You can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use specifically characters in place of letters. We also recommend that you change your password often. You can also install and update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this site and/or changing your password on that email account frequently.

If you use a computer that is accessed by other people, such as in a public library or internet café, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using your site, you should log out completely, then close the browser window and clear the browser’s cache file.

You should also be aware of fraudulent attempts to gain access to your account information known as “phishing”. Phishing is a tactic used by scammers in which unsuspecting people are brought to a website by a genuine-looking email purporting to be from a legitimate company. The phony or “spoof” email takes the person to a website that looks legitimate but in fact is not. Either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. Intercontinental Capital will never ask for login information to gain access to customer’s account and access sensitive information. Intercontinental Capital will never ask you for your login information in the context of any email, physical mail, phone call or otherwise. In general, you can protect yourself against phishing by never providing personal or login information via an email instead, go to the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain.

Changes To Our Privacy Policy

We may make changes to our privacy policy in the future. If you choose to receive e-mail messages or newsletters from us, you may later modify your choice by contacting us at 1-877-828-9569. You also will be given the opportunity, in any general bulk commercial e-mail that we send to you, to opt out of receiving such messages in the future. We will attempt to address your request immediately but it may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as processing requests, conditional loan offers, requests for additional information, service updates or announcements, administrative notices and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional e-mail communications will only affect future activities or communications from us. Note: If we have already provided your information to a third party as part of your loan application then you may have to change your preferences directly with that third party.

You may instruct us not to call you for marketing purposes by informing us at 1-877-828-9569.  Our employees are trained through Policies and Procedures to take action on your instructions within 30 days. Please note that we may still need to contact you for legitimate business reasons such as servicing of your loan or other non-marketing purposes.

If you do not want us to send you postal mail for marketing purposes, you may remove your name from current and future mailing lists by contacting us at 1-877-828-9569.

Contacting Us

If you have any questions about this privacy policy, please write us at 50 Jericho Quadrangle, Ste. 210, Jericho, NY 11753 or call us at 1-877-828-9569.