Effective Date: May 7, 2017
HLP is a new kind of company taking a radical approach to helping relieve the burden of student loan debt. From unprecedented expertise, personnel and tools to faster service and open conversations, we’re all about helping our Clients get ahead and achieve success. Whether you’re just exploring options or engaging us for immediate help, our organization works to help our Clients to accomplish the goals.
1. HOW AND WHY WE COLLECT INFORMATION ABOUT YOU
1.1. Information you provide us
1.1.1. Personal Information
We collect personal information from you to help you use our services. When we say “personal information,” we mean information that specifically identifies you.
We collect this information in a number of ways. You are asked to provide personal information to us while discussing your application with us, or providing feedback to us. Examples of personal information include:
- Your Name
- Your Address
- Telephone Number
- Email Address
- Student Loan Account Numbers
- Social Security Number
- Employment Information
- Salary Information
We may supplement the personal information you submit to us with information from third-party sources. For example, in an effort to protect the integrity of your account and if permitted under applicable law, we may supplement your registration Information with address standardization data to verify the address you have entered is valid and to protect you against identity theft.
Finally, we never intend to collect personal information from children under 18 years of age. If we learn or are notified that we have collected this information from a child under the age of 18, we will promptly remove the data from our system.
1.2. Information we collect about you
1.2.1 Aggregate Information
Aggregate information, which is data we collect about your use of our or third party websites or services, from which personal information has been removed. Aggregate data is used to help us understand consumer trends, needs, interests, and preferences so we can improve our products and services.
HLP also collects demographic information, which is anonymous, and may include:
- Date of Birth
- Geographic Area
1.2.2. Credit Reports
HLP is not a lender and does not pull credit reports on its Clients when providing its core services. As a company engaged in providing paid services, HLP transmits data to credit reporting agencies, but only if a Client of the company has not fulfilled the terms of payment included in the Client Fee Agreement.
1.2.3. Website Use and Logging Data
HLP also collects information about your computer or mobile device to improve and evaluate your use of our website and our services. We may gather data such as your browser type, operating system, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device.
Please note that any information, photos, contact information, email addresses, videos, and other content you post to your profile on HLP’s blog is available to everyone using that service. The information you share is available to everyone accessing that service, and may be read, collected or used by others for any purpose, including sending you unsolicited messages.
1.2.4. Information We Get from Others
Like other advertisers, we contract with third parties to place advertisements for our services on websites that are not our own. We place these ads where we think they are likely to be most relevant. These advertisements on third-party websites allow us to track responses to our ads. We and our affiliates use this information to track the performance of our advertising and marketing campaigns by using tools like cookies and other technologies. We use these tools to collect and store information about your visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site. We don’t gather Personally Identifiable Information during this process.
Cookies are designed to transfer a small amount of data to your browser by servers within a domain. That data is only read by designated servers within that domain. It functions as your computer’s identification card and will enable HLP to improve your experience by securely maintaining your authenticated session and preferences.
Most Internet browsers are set up to accept cookies automatically. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it.
1.2.6 Contacting us by Telephone
If you communicate with us by telephone, we will monitor or record the call. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of HLP services.
2. USE OF YOUR PERSONAL INFORMATION
We may in the future use personal information to facilitate your use and our operation of our website, and to improve our services.
Here are some examples of ways in which we use your personal information:
- Contacting you regarding issues with your account
- Allowing our partners to process the repayment program you have selected with the U.S. Department of Education
- Sending you information about new services you have contracted HLP to provide
Sharing your personal information
We don’t sell or rent your personal information to anyone. HLP only shares your personal information with unaffiliated third parties as permitted or required by law. When HLP shares your personal information with partners who perform functions on our behalf, we require the security and confidentiality of your information, as well as limiting their use of the information to reasonably and necessarily to carry out their work with us and comply with applicable laws and regulations and to provide the service you have specifically contracted HLP to provide. Third parties we share your information with may include, but are not limited to:
- Our loan servicing companies who provide your statements, process your payments, and service your loan
- U.S. Department of Education
- Credit reporting agencies (only if the payment terms of your Client Fee Agreement have not been fulfilled)
- Auditors and examiners
Finally, personal information may be disclosed or transferred as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of HLP.
3. PROTECTING YOUR PERSONAL INFORMATION
3.1. What we do to protect your personal information
HLP takes the privacy and security of its members personal information seriously. We maintain administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity.
We protect personal information you provide in connection with your services. Access to your own personal information is only available to HLP personnel that require access to fulfill your services. To protect the security of your personal information, never share your password to anyone. Please notify us immediately if you believe your password has been compromised.
Whenever we save your personal information, it’s stored on servers, and those of our partners and in facilities that only selected HLP personnel and our contractors have access to. We encrypt all data that you submit through HLP’s website during transmission using Transport Layer Security (TLS) in order to prevent unauthorized parties from viewing such information.
3.2. Steps you can take to help us keep your information safe
There are many steps you can take to help us keep your information safe. First and foremost, choose complex, independent passwords for each website and service you maintain an account with. This helps keep any breach of any of your accounts isolated to one service. Also, don’t use anything related to your birthday, address, phone number, PIN number or any other easily guessable information in your password.
HLP urges your caution when using a public computers or networks, like at a coffee shop or library. To best protect your personal information and login information, don’t use such computers to access your sensitive accounts, and if you must do, ensure that you logout of your account entirely.
In recent years, individuals, businesses and even governments have seen a rise in “phishing” attacks. Phishing occurs when someone attempts to obtain your password or other sensitive information. Scammers often do this by impersonating a trusted user, or offering a compelling reason to open a malicious email attachment, click on a link or give over information. We never ask for your sensitive personal information, such as password, over email or other unsecure methods or through any site not under the my-hlp domain. Please notify us at email@example.com if you ever receive suspicious correspondence from us.
|Reasons we share your information||Does HLP share?||Can you limit this sharing?|
|For our everyday business purposes—such as to process your transactions, maintain your account(s)||Yes||No|
|For our marketing purposes—to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||No||We don’t share|
|For our affiliates’ everyday business purposes—information about your federal student loan history||Yes||No|
|For our affiliates’ everyday business purposes—information about your creditworthiness||No||We don’t pull credit reports because we are not a lender.|
|For our affiliates to market to you||Yes||Yes|
|For non-affiliates to market to you||No||We don’t share|
4. YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION
We want you to be aware of the choices you have in limiting the sharing of your personal information. Please refer to the below table to review your options in sharing with us:
Your Rights As a California Resident
Residents of the state of California have the right to request certain information from us with respect to the types of personal information we share with third parties for their direct marketing purposes, as well as the identities of the third parties we have shared such information with during the immediately preceding calendar year.
If you are a new customer, we can begin sharing your information 45 days from the date we sent you the privacy notice. When you are no longer our customer, we may continue to share your information as described in this policy. However, you can contact us at any time to limit our sharing and to restrict online marketing and direct mail. Please contact at this number if you want to restrict the use of your information (HLP Customer Service: 1-888-411-1919)
When you post information to our blog within the HLP website, you should also be aware that anything you post on our blog can be used, read, or collected by other users of the online community services and could be used to send you unsolicited messages.
We don’t respond to “do not track” signals or similar mechanisms – where a visitor to HLP’s website requests that we disable the collection of information about the visitor’s online activities, including navigation around our website and the service. We may also permit third parties to collect aggregate usage information on our website, and they may also not respond to “do not track” signals.
4.1. Changing and Updating Your Personal Information
We want to provide you with the resources you need to keep your information with us correct and up-to-date. You can access and maintain your personal and personally identifiable information by contacting your HLP Advisor.
5. COMPLAINTS & CONCERNS