TERMS OF SERVICE

for the International Organization for Migration

 

Effective as of: 12-September-2023

 

Welcome to International Organization for Migration’s (“IOM”) web portal located at www.travelloans.iom.int (“Website”). IOM is committed to protecting your privacy. This “Terms of Service” is the collective agreement between “you,” the “user” who utilizes our Website and IOM. 

 

IOM is an intergovernmental organization with privileges and immunities that promotes humane and orderly migration to governments and migrants throughout the world by assisting with the resettlement of refugees arriving in the United States, including, but not limited to providing penalty and interest-free financing for transportation through a revolving fund utilized by the IOM Travel Loan Program (“Program”).

 

Nothing in these Terms of Service affects the privileges and immunities enjoyed by IOM as an intergovernmental organization.

 

IMPORTANT INFORMATION ABOUT USING THIS WEBSITE.

 

This Terms of Service is being provided in English. If you do not understand the terms as presented or do not agree to the terms below, do not click to agree or use the Website. You may instead call us at 866-466-5660 to receive assistance.

 

THIS TERMS OF SERVICE INCLUDES IMPORTANT NOTICES ABOUT YOUR CONTACT INFORMATION, HOW WE SHARE YOUR INFORMATION, AND HOW IOM HANDLES TRAVEL LOAN PROGRAM PAYMENTS, WHICH MAY APPLY TO YOU. YOU ARE NOT REQUIRED TO PROVIDE A MOBILE PHONE NUMBER OR EMAIL ADDRESS TO INTERACT WITH IOM. HOWEVER, CERTAIN CONTACT INFORMATION MUST BE PROVIDED TO USE THE WEBSITE.

 

BY CLICKING AGREE AND PROVIDING CONTACT INFORMATION THROUGH THE WEBSITE, YOU ACKNOWLEDGE THE TERMS OF YOUR CONSENT (IMMEDIATELY FOLLOWING) HAVE BEEN HIGHLIGHTED AND ARE CONSPICUOUSLY DISPLAYED FOR YOUR REVIEW.

 

The Website is provided for users to access information, make payments, and utilize other services, including, but not limited to the services associated with Program and for use by the recipients of benefits in the Program (“Participant(s)”) that have received assistance in the form of a “Travel Loan” and have an “Account” with IOM. By accepting these Terms of Service, you acknowledge that you have read, understand, and agree to be bound by all of the terms below. You may print up these Terms of Service at any time by clicking on the links available on the Website.  

 

If you are a California resident, you acknowledge and agree that there are additional rights provided to you under state law, that can be found in the California Supplement located below. The rights set forth in the CA Supplement are meant to supplement the rights and obligations of California residents.

 

CONSENT - Important Notice Regarding your Contact Information

 

By providing information on the Website, irrespective of whether you are Registered User, such as your address; telephone number, including mobile telephone number(s); email address; internet software (e.g. Skype) or any other contact information you provide to IOM, or its Servicers, as defined below (“Contact Information”), you hereby consent to have IOM, along with any other company servicing your Travel Loan, if applicable (referred to as a “Servicer”), contact you at your Contact Information, which you understand could result in charges.  

 

YOU FURTHER AGREE THAT IOM, AND/OR THE SERVICER, MAY USE ANY METHOD OF CONTACT TO REACH YOU THROUGH THE CONTACT INFORMATION, INCLUDING BUT NOT LIMITED TO PRERECORDED OR ARTIFICIAL VOICE MESSAGES, TEXT MESSAGES, VIDEO AND AUTOMATIC DIALING DEVICES, WHICH COULD RESULT IN CHARGES.  

 

You acknowledge all the Contact Information you provide is private to you and no third-party has access to it. You take sole responsibility for maintaining the privacy of your Contact Information. You further understand that for you to revoke your consent to be contacted through any particular Contact Information point, or if at any time any Contact Information point is no longer private, or its use causes inconvenience to you, you must either contact the Servicer, if not IOM, through means identified by the Servicer or IOM at (866) 466-5660 or via email at iomloans@iom.int.

 

Electronic Communication.  If you provide your email address to IOM, you hereby authorize IOM, or any applicable Servicers, to contact you via electronic mail using any email address you have provided in lieu of paper correspondence. You further agree to the terms of this section.  

 

§  Consent to Receive Electronic Communications. By providing an email address within your Contact Information, you consent to receive information about any Account(s), if applicable, and any other related documentation that could be provided in writing directly or indirectly related to your Account(s) in electronic format, which includes, but is not limited to billing statements, communication related to payments, banking and/or debit card information, and information provided electronically or in writing that is directly or indirectly related to your Account, whether or not considered Personal information (as defined below in the Privacy Policy (collectively referred to as “Account Information”).

 

§  Acknowledgement. When you submit an email within your Contact Information, you acknowledge the email you provide is personal and private to you, is password protected, not shared with another person and is not an employer provided email.  

 

§  Privacy Obligations. You understand and acknowledge that if you have an Account, the Account Information is private and it is your sole responsibility to maintain the privacy of any email communication you receive, including, but not limited to where you view your email or any disclosure of information when accessing or viewing the Account Information.  You assume all responsibility and liability for any unauthorized disclosure of any personal information through your email and take sole accountability for any disclosure resulting from viewing any email from IOM. 

 

§  Hardware and Software Requirements. By providing your email address within your Contact Information, you further agree that you have access to the hardware and software requirements necessary to review, upload and/or print electronic documents, including any applicable Account Information. The software and hardware requirements include having a valid email address that is personal and private to you, along with the ability to open a PDF document through a free Adobe® or similar viewing program.  If, at any time, you no longer have access to the necessary requirements, you agree to call IOM at (866) 466-5660 or contact us via email at iomloans@iom.int to update your Contact Information and/or revoke your consent to electronic delivery. You understand that IOM will notify you if there is any change in the hardware or software requirements that could impact your ability to access electronically formatted documents.  Your continued use of the electronic documents after such time will serve as reaffirmation that you have sufficient hardware/software to view such documents.

 

§  Revocation of Consent.  You understand that in order to revoke your consent to be contacted via any particular Contact Information point, or if at any time any piece of your Contact Information is no longer private or contact via any Contact Information point causes inconvenience to you, you must contact us and notify us in writing of this issue. You may revoke consent at any time by contacting iomloans@iom.int. No fees shall be assessed against you if you choose to revoke your consent. If you withdraw consent, IOM will cease providing electronic documents and will only send paper copies of any applicable Account Information to the address of record at the time of revocation.

 

§  Paper Copies.  You are always entitled to receive a paper copy of any electronic documents, along with any applicable Account Information.  You simply need to contact IOM by calling us at our toll-free telephone number, (866) 466-5660, or by emailing your request to iomloans@iom.int. Upon receipt of your notice, IOM will mail a paper copy of any of the documents originally delivered in electronic format within 30 days.  Alternatively, at your request, IOM will email you electronic copies of any of the documents in .pdf format. No fees shall be assessed against you for your request(s), whether delivered by mail or email.

 

§  New Contact Information.  As long as your consent is valid, you understand you must notify IOM of any change in your Contact Information. You take sole responsibility for failure to provide IOM with updated Contact Information.

 

§  Fees.  Where permitted by law and where applicable, fees may be assessed for certain types of payment options available on the Website. If fees apply, the Website will include notice where such fees would apply. Other payment options are always available that do not include any fees, which you may utilize by calling (866) 466-5660. 

 

GENERAL TERMS

  

The Website is provided “AS IS” with no warranty of any kind associated with the performance of the Website. IOM reserves the right to change the Terms of Service at any time. Such changes, modifications, additions, or deletions shall be effective immediately upon posting to the Website, which will be reflected by an updated Effective Date. You acknowledge and agree that it is your responsibility to review the Terms of Service periodically. Your continued use of the Website will constitute your agreement to the Terms of Service with an updated Effective Date. Your consent, rights, and obligations provided in these Terms of Service extend to any services provided by us in connection with any Accounts you have.

 

By using the Website, you acknowledge and agree that you are at least eighteen (18) years of age and are the individual whose information is being provided on the login information. OUR WEBSITE IS NOT DESIGNED FOR CHILDREN, AND WE DO NOT KNOWINGLY COLLECT INFORMATION FROM ANY PERSON WE KNOW IS UNDER THE AGE OF 13.  

 

Special Notices for Account Information

 

Account Registration. The Website allows Participants to generate a personally created login with a username and password (“Registration/Registering”) utilizing Personal Information or User Information (as defined in the Privacy Policy included below). By Registering, you become a “Registered User” and agree that all information you provide to IOM or its Servicer, directly or indirectly provided in connection with the Program, regardless of type, is true and accurate, and that you will maintain and update this information as required in order to keep your information current, complete, and accurate.

 

Each Registered User hereby grants IOM and any Servicer, the right to use and share your Account Information in connection with services associated with the Program, as permitted by applicable law..  

 

Registered User(s) are solely responsible for maintaining the confidentiality of his/her/its/their Registration information and will take steps to ensure that others do not gain access. Registered Users may not transfer or share the Registration information with anyone. Access to the Website is personal to a single Registered User. Each Participant that has an Account shall have the right to create a separate Registration. These Terms of Service prohibit any third-party, even if authorized by law to act on behalf of a Registered User through the Website. If you are not an authorized Registered User under these Terms of Service, you may contact our office by calling our toll-free number. Each Registered User is responsible for preventing such unauthorized use. IOM hereby states, and Registered User acknowledges, that IOM shall have the right to assume that any contact utilizing the Account Information within the Website(s) is being received directly from the applicable Registered User, not from any third-party. IOM reserves the right to immediately terminate access to the Website by a Registered User that has violated these Terms of Service.

  

NOTICE: SEE BELOW FOR IMPORTANT INFORMATION REGARDING ACCOUNTS

 

Under certain state and federal laws, you have the right to receive notice of certain rights if you have an Account and Travel Loan, which may or may not apply to you. Please note the notices in this section do not contain a complete list of the rights you have under state and federal law.   

 

§  Some states consider IOM to be a debt collector because it is collecting money due on Travel Loans provided to Participants. Under the law of these states, IOM must inform you that IOM is a debt collector, and this is an attempt to collect a debt and any information obtained will be used for that purpose.

 

§  IOM is the creditor of the Program and is attempting to collect a claim. Any information obtained on the Website(s) will be used for that purpose.

  

§  As required by law, you are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obligations associated with any Account you have.

 

§  California. The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov.

 

§  California. “You may request records showing the following: (1) that IOM or its Servicer has the right to seek collection of the debt; (2) the debt balance, including an explanation of any interest charges and additional fees; (3) the date the debt became delinquent or the date of the last payment; (4) the name of the creditor and the account number associated with the debt; (5) the name and last known address of the debtor as it appeared in the creditor's records prior to assignment of the debt; and (6) the names of all persons or entities other than the debt collector to which the debt has been assigned, if applicable. You may also request from us a copy of the contract or other document evidencing your agreement to the debt. A request for these records may be addressed to: [insert debt collector's active mailing address and email address, if applicable].”

 

§  District of Columbia. “You have the right to request off of the following concerning your debt: (1) Documentation of the name of the original creditor as well as the name of the current creditor or owner of your debt; (2) Your last account number with the original creditor; (3) A copy of the signed contract, signed application, or other documents providing evidence of your liability and its terms; (4) The date that your debt was incurred; (5) The date of your last payment, if applicable; and (6) An itemized accounting of the amount claimed to be owed including the amount of the principal, the amount of any interest, fees, or charges, and whether the charges were imposed by the original creditor, a debt collector, or a subsequent owner of the debt. You may request the above information by contacting us by phone or email at the following: (866) 466-5660 or at iomloans@iom.int.

 

§  Massachusetts. NOTICE OF IMPORTANT RIGHTS. You have the right to make a written or oral request that telephone calls regarding your debt not be made to you at your place of employment. Any such oral request will be valid for only ten days unless you provide written confirmation of the request postmarked or delivered within seven days of such request. You may terminate this request by writing to the creditor.

 

§  New York City. If you speak a language other than English, you may obtain language access services or obtain notices in certain languages, other than English, by calling 866 (Translations and descriptions of commonly used debt collection terms are available in multiple languages on the New York City Department of Consumer Affairs website at www.nyc.gov/dca.

 

Links to Third-Party Sites

The Website may contain links to other websites, icons to various forms of social media or other third-party widgets (“Linked Sites”). The Linked Sites are not under the control of IOM, and we are not responsible for the contents of any Linked Site, including, without limitation any third-party link contained with such a Linked Site, or any changes or updates to a Linked Site, any webcasting, or any other form of transmission received from any Linked Site. IOM is providing these Linked Sites to you only as a convenience or as required by law, and the inclusion of any Linked Site does not imply endorsement by IOM of the Linked Site, any association with its operators, or any warranty of any kind, either express or implied by us for the content or use of the Linked Site. If you decide to access these Linked Sites, you acknowledge you are not required to utilize or access any Linked Site and are leaving the IOM Website, and you do so at your own risk. We are not responsible for information provided by you to Linked Sites. Linked Sites may contain information or material that some people may find inappropriate or offensive. These Linked Sites are not under IOM’s control, and you acknowledge that we are not responsible for the accuracy, copyright compliance, legality, decency, or any other aspect of the content of such Linked Site, nor are we responsible for errors or omissions in any references to other parties or their products and services.

 

Termination of Website 

IOM reserves the right to modify or discontinue the Website, and/or your access, to all or part of the Website, including any specific features, with or without notice to you. IOM shall not be liable to you, or any third-party, if we decide to exercise such right. Modifications may include, without limitation, changes in the payment processing, hardware or software requirements, limitations in use based on changes in the law. Any new features are subject to these Terms of Service.

 

You further agree that IOM may, in our sole discretion, terminate or suspend your personal access to all or part of the Website, with or without notice, and for any reason, including, without limitation, breach of the Terms of Service. Any suspected fraudulent, abusive, or illegal activity may be grounds for terminating your relationship and may be referred to appropriate law enforcement authorities. We reserve the right to seek all remedies available at law and in equity for violations of this Terms of Service, including the right to terminate, suspend, or block access from the Website for any reason, without advance notice, and at any time.

 

Upon termination or suspension, regardless of the reasons therefore, user’s right to use any the Website, IOM may immediately deactivate or delete User’s Registration information, and all related information and files in User’s Registration, and/or bar any further access to the Website. IOM shall not be liable to User or any third party for any claims or damages arising out of any termination, or suspension, or any other actions taken by IOM in connection therewith.

 

PRIVACY POLICY

 

IOM understands that your privacy is important. By using the Website or any of our applications, products, services, features, tools, or resources (collectively referred to as “System”), you are agreeing to these terms related to your privacy.  

 

Classification of information – What we collect

IOM recognizes two types of information on our IOM Website.    

§  The first type of information includes personal information knowingly disclosed to IOM by you, either directly or indirectly through the Website, or later obtained in connection with the services associated with the Program or your Travel Loan used to help identify you, including, but not limited to your name; telephone number; physical address; email address; and where applicable, credit card or debit card numbers or other billing information that is collected on individual basis pursuant to your voluntary disclosure; non-public, personally identifiable data that IOM has lawfully acquired from each Participant, or received on each Participant’s behalf, in connection with any applicable Account or associated Travel Loan; or related to the services provided by IOM, such as your Account Information (“Personal Information”). 

§  The second type of information includes information about the services that you use on the internet and how you use them, such as device-specific information, mobile network information, server log information, location information, unique applications numbers regarding your use of certain material; general information about your technology interface or preferences; information about the websites you visit; your internet protocol (IP) address to measure website traffic and to help provide more personalized services; information regarding your browser and other technical specifications required to use the IOM Website; cookies, log files, web beacons or other identifiers created when you use the internet; and other website use information collected on an aggregate basis resulting from your use, but is specifically limited to the information gathered on the System and does not extend to any Third-Party Applications, unless specifically incorporated in this policy (“User Information”).  IOM treats User Information as non-personal because it does not contain personally identifiable information, such as name, address, phone number and email address, unless otherwise distinguished by local and/or federal law, or IOM provides you the written option of sharing certain Personal Information. 

§  It is important to note that any information shared with others or publicly posted without security or privacy terms is no longer considered “confidential” through no fault of IOM (“Public Information”).  IOM is not responsible for maintaining the confidentiality of any Public Information. You take sole responsibility for your disclosure and resulting Public Information.  

Cookies 

A cookie is a piece of data stored on the user's hard drive containing information about the user. IOM will not use cookies when you use the Website. IOM does not track user browser activities, including “do not track” settings, and therefore IOM does not respond to any such detected settings because collected Personal Information is never shared with unauthorized third parties. 

  

Log Files

IOM uses IP addresses to analyze trends, administer the Website, track user's movement, ensure adequate privacy and security, and to protect your information. IOM does not capture demographic information in the log files.

             

Use

IOM generally, but not exclusively, uses Personal Information we receive to provide you with services and products and also collect information that is necessary for the System to work properly, including, but not limited to: (1) contacting you in connection with your communication with IOM; (2) using your Personal Information to provide the services you request; (3) tracking information about your visits to the Website; (4) Your use of the System to allow us to provide better service; (5) using certain online preferences in the aggregate across all users to evaluate the System and develop additional products and services to offer; (6) sending or initiating direct marketing programs, such as newsletters or information about new products or services we are offering; (7) using content from social media platforms where you discuss our products or use a hashtag related to our products; (8) providing information about your usage or preferences to our third-party vendors and providers; and (9) other purposes necessary to carry out our obligations under these Terms of Service. 

 

The Website collects certain User Information automatically and stores it in log files. The information may include User Information and other information, such as, but not exclusively, your IP addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of the Website, including a history of pages you view.  The IOM Website does not restrict the use of cookies, which are the pieces of data that a website transfers to a user’s hard drive for record-keeping purposes, or web beacons, which are transparent pixel images that are used in collecting information about website usage, email response and tracking. While IOM does not utilize cookies or web beacons for its own services, this information may be used by your web browser or operating system. In addition, IOM does not track your use of Third-Party Applications, does not provide targeted advertising to users, and therefore does not respond to Do-Not-Track (DNT) signals. You may have choices with reference to the management of cookies and web beacons on your computer. All major browsers allow you to block or delete cookies from your system. You may choose to block or restrict cookie use, which should not impact your ability to use the Website.  If you have any difficulty using the Website, please contact IOM by calling us at our toll-free telephone number, (866) 466-5660, or by emailing your request to iomloans@iom.int. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.

 

Payment options may be available to Registered Users and where applicable, IOM uses a payment processor to process payment card and bank account transactions. Any Personal Information you provide for such payments is authorization that the payment processor is allowed to securely process your payment card and bank account information to make a payment to your Travel Loan, to verify the accuracy of the payment card or bank account information, and to save the payment card and bank account information for future payments, if voluntarily chosen by you.

 

IOM may be required by law enforcement, government agencies, or judicial authorities to disclose the Personal Information obtained, or contained within the Website, to the appropriate governmental authorities. IOM will disclose such Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement or government agency investigation. IOM will fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

 

Limitations

We may share aggregated, user Information publicly and with our partners, like Servicers, publishers, advertisers, or connected websites, such as trends about the general use of our Website, but not Personal Information.  We will not share your information with third parties to directly market their products to you.  

 

We may share Personal Information with subsidiaries, licensees, suppliers, distributors, affiliates, assigns, successors, Servicers, or other related entities (“Affiliates”) necessary to complete any requests from you as the user; to provide you services; or through the belief that access, use preservation or disclosure of the Personal and User Information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request; enforce this Terms of Service; investigate any potential violations; detect, prevent or otherwise address fraud, security or technical issues; and protect against harm to IOM, users or the public as required or permitted by law.

 

 

Security

IOM follows generally accepted industry standards to protect User and Personal Information, including maintaining administrative, physical and technical safeguards, both during transmission and after receipt.  No method of transmission over the internet, or method of electronic storage, is 100% secure and IOM does not guarantee absolute security. IOM works hard to protect your User and Personal Information from unauthorized access to or unauthorized alteration, disclosure or destruction of Information, specifically, but not limited to: (1) IOM encrypts many of its services using SSL; (2) IOM reviews its information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems; and (3) IOM restricts access to Personal Information by its employees, contractors and agents who need to know that Personal Information in order to process it for us.

 

Trusted Behavior Expectations 

Users are expected to protect IOM’s network and its database, in accordance with state and local privacy laws. You must not upload, post, host or transmit any worms, viruses, code of a destructive nature, unsolicited email, SMSs, or “spam” messages. You agree not to modify, adapt, or hack Website. You further agree not to reproduce, duplicate, copy, sell, resell, or exploit any portion of the Website, use of the Website, or access to any Secure Area without the express written permission of IOM.

 

Maintenance and Storage

It is IOM’s policy to limit the storage of any User and Personal Information received via the Website. Nothing in this agreement requires you to use the System or provide Personal Information, but if you provide Personal Information in connection with the services offered by IOM, IOM may store your Personal Information in connection with providing those services.   

 

Contact Information

If you have any questions or concerns pertaining to this Privacy Policy, please contact us at iomloans@iom.int.

CA Supplement - Click to expand

FOR CALIFORNIA CONSUMERS – CA SUPPLEMENT

  

Under the California Consumer Privacy Act of 2018 (“CCPA”), all visitors, users, and others who reside in the State of California (“CA Residents/you/your”) are provided additional rights regarding their personal information, including sensitive information, as defined by the CCPA, and further detailed below (collectively referred to within the definition of “Personal Information” for any CA Residents).

 

This Privacy Notice for California Residents (“CA Supplement”) applies to all CA Residents using the IOM Website and describes the rights granted to CA Consumer(s) under the CCPA. The continued use of the IOM Website(s) by any CA Consumer demonstrates the agreement of the CA Consumer to the terms contained in this CA Supplement. This CA Supplement is intended to supplement other policies included on the IOM Website, including, but not limited to the Terms of Service and Privacy Policy (“Policies”). In the event of any conflict between the Policies and this CA Supplement, the CA Supplement shall control. Any waivers referenced within any Policies shall not apply to the rights set forth herein.

 

If you would like to receive this notice in a different format to accommodate a disability, please contact iomloans@iom.int.

 

If you are a CA Consumer, when you use the Website, you consent to our collection, use, and disclosure of Personal Information as described below. If you do not agree with this CA Supplement, you may choose to not use the Website. This CA Supplement may change from time to time. The use of this CA Supplement after we make changes is deemed to be acceptance of those changes, so please check the CA Supplement periodically for updates.

 

This CA Supplement contains capitalized words within quotation marks (not grammatically required) that serve as defined terms, including, but not limited to terms that have been defined within the Policies. In the event of a conflict the defined term within the CA Supplement shall prevail.  

 

Cookies and Tracking

 

We do not track or plant cookies. As such, we will not honor or respond to any “do not track” request because collected Personal Information is never shared with unauthorized third parties. We do not allow third-party behavioral tracking.

 

CAlifornia Resident Rights and Choices

 

Please note that our office does not sell any of your Personal Information. We also do not offer any financial incentive programs as part of our services.

 

You have the right under the CCPA, and certain other privacy and date protection laws, as applicable, to:

 

§  To request the disclosure of certain information about our collection and use of Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable CA Consumer request, in accordance with the CCPA (“Verified Request”), we will disclose to you:

o   what categories of your Personal Information are being collected by us, and if any of the categories have been disclosed;

o   the purpose of gathering or using your Personal Information;

o   if any of your Personal Information is shared;

o   the length of time we shall retain each category of your Personal Information, or the criteria used to determine that period of time each category is retained;

o   the categories of sources from which your Personal Information is collected;

o   the categories of third parties to whom your Personal Information is shared or disclosed;

o   the specific pieces of Personal Information we have collected about you; and

o   the length of time we shall retain each category of your Personal Information, or the criteria used to determine that period of time each category is retained (“Disclosure Data”).

§  To request we correct any inaccurate Personal Information, and that we correct the error, as directed by you;

§  To opt-out of the sharing of your Personal Information;

§  To receive equal service and pricing, even if you exercise your rights under the CCPA;

§  To access Personal Information, including, the Disclosure Data, as applicable;

§  To delete any of your Personal Information that we collected from you and retained;

§  Limit the use of your sensitive Personal Information to a use what is necessary to perform the Services;

§  To sue for data breach; and

§  To obtain information of any financial incentives, for the collection of Personal Information, sale of Personal Information, or the deletion of Personal Information, and to enter any financial incentive program if you give us a prior opt-in consent to any such program.

 

Please note that we are not required to:

 

§  Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

§  Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or

§  Provide the Personal Information to you more than twice in a 12-month period.

 

 

 

 

 

MAKING YOUR REQUEST

 

If you, or any authorized agent, wish to exercise your rights under the CCPA, please contact us by using any of the methods set forth below. Authorized agents should submit a written authorization form signed by the CA Consumer with any request. Please note that you, or an authorized agent on your behalf, may only make an access rights request twice within a 12-month period.

 

Your “verifiable consumer request” for data access and information deletion must include (this is not required for opt-out requests):

 

§  Enough information to match your identifying information to our personal information (e.g., your full name, mailing address, date of birth, email address, last four digits of your social security number and/or account or other reference number), which should include at least two personal data points that we have in our records for general requests and/or deletions; or 

§  Enough information to match your identifying information to our personal information (e.g. your full name, mailing address, date of birth, email address, last four digits of your social security number and/or account or other reference number), which should include at least three personal data points that we have in our records and a signed declaration under penalty of perjury that you are the CA Consumer whose Personal Information is the subject of the request for requests seeking access to specific pieces of Personal Information or deletion of sensitive Personal Information. Please note your data rights request may be manually or electronically signed by any process that satisfies the California Uniform Electronic Transactions Act. As a result, a signed declaration can be provided electronically, if it includes the statement: Under penalty of perjury, I certify that the information in this declaration is true, accurate and complete and that it is my intention that this electronic request [e.g., email, interactive webform] to exercise a data right under the California Consumer Privacy Act shall carry the same force and effect as if I had manually signed this request.

 

We are not obligated to make a data access or information disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

 

Response Timing and Format

 

We will acknowledge receipt of your request within 10 business days. We endeavor to respond to a verifiable CA Consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable CA Consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

 

We do not charge a fee to process or respond to your verifiable CA Consumer request, unless it is determined to be manifestly unfounded, excessive, or repetitive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate for the reasonable fee before completing your request.

 

Denials for Requests to Delete

 

Under the CCPA, we may deny your request for deletion if one of the following reasons applies:

 

§  Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

§  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;

§  Debug to identify and repair errors that impair existing intended functionality;

§  Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

§  Comply with the California Electronic Communications Privacy Act;

§  Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;

§  To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

§  Comply with a legal obligation; or

§  Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.

 

If we cannot honor your request to delete, we will notify you of the information that cannot be deleted and include the reason why.

 

 

HOW TO CONTACT US

Call us at: (866) 466-5660

Email us at: iomloans@iom.int

You may submit a request for more information about your Personal Information by clicking the link to “Request information about what we collect, share, and disclose”

You may submit a request for deletion or correction of your Personal Information by clicking the link to “Request a deletion or correction of my Personal Information”

If you are a Registered User, you may access your Account Information via the secure login system on the Website, where you may be able to update certain Personal Information.

 

 

 What We Collect

 

We have collected and our Website collects and/or has collected non-public “Personal Information” defined below, as required by the CCPA for CA Residents, over the last twelve (12) months, that identifies, relates to, describes, references, and is capable of being associated with you, which may include one or more of the categories listed below, but also includes previously delineated “Personal Information,” as set forth in the Policies.

 

We will not collect any additional categories of information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Personal Information does not include:

 

§  Publicly available information from government records.

§  Deidentified or aggregated CA Consumer information.

§  Information excluded from the CCPA’s scope, such as:

o   Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or

o   Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

  

PERSONAL INFORMATION

Categories

Examples

Identifiers

Name, alias, postal address, email address, account name, unique personal identifier, demographic information, telephone numbers, online identifier, internet protocol address, credit report data, or other similar identifiers, including those received by skip-tracing sources, including sensitive personal information listed below. 

Participant and Account Information

As further listed under the California Customer Records Statute, including any material, regardless of form, on which information that identifies, relates to, describes, or is capable of being associated with, a particular individual, is recorded, such as employment information, bank account data, credit card information, medical information, insurance information, current or past job history, or other information contained in the records related to any Account that we may hold, including email address, username, and Password. Other information associated with an Account may include tax returns, financial statements, loan and credit applications, signature cards or other Account documentation containing the consumer’s signature, including electronic signatures.

Characteristics of protected classifications

gender, age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, and/or sexual orientation

Internet activity

Browsing or search history, information about your interaction with the IOM Website, such as internet protocol (“IP”) addresses or other electronic markers for security monitoring purposes.

Geolocation data

Search engine optimization data, web traffic, and/or process server acquired data; physical location

Audio, electronic, visual, thermal, and olfactory information

Call recordings, if applicable

Employment-related information

Information gathered about the CA Resident’s employer for purposes of contact, associated with the ability to provide Services, and provided to facilitate certain Services, Account information that includes professional or employment-related information, places of employment

Education information

as defined in the Family Educational Rights and Privacy Act, non-public educational records such as student identification codes, class registration agreements, grade reports, and student financial and financial aid information

Inferences drawn from any of these pieces of information identified in creating any profile about a CA Consumer

CA Resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Sensitive personal information

Account Information, including, but not limited to personal information that reveals a CA Resident’s social security number, driver’s license, state identification card, or passport number; account log-in information, financial account, debit card and/or credit card numbers in combination with any required security or access code or expiration date, bank account numbers and routing numbers and associated check or bank draft information, password, or credentials allowing access to an Account; a CA Resident’s precise geolocation; racial or ethnic origin, religious or philosophical beliefs, union membership; contents of CA Resident’s mail, email, or text message, unless the business is the intended recipient of the communication; a CA Resident’s genetic data; processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a CA Resident’s health; and/or personal information collected and analyzed concerning a CA Resident’s sex life or sexual orientation

 

USE OF INFORMATION

Please note that we DO NOT sell your Personal Information

 

We may use your Personal Information for one or more of the following business purposes:

Addressing any fraudulent activity or allegations of identity theft related to an Account

Complying with any legal obligation associated with an Account

Lawful, internal uses related to the services, such as gathering Personal Information to obtain payment on Accounts, submitting any legally allowed information related to Account payment information to a consumer reporting agency

Fulfilling or meeting the reason you provided the Personal Information

Providing, supporting, personalizing, and developing our IOM Website

Creating, maintaining, customizing, and/or securing any Password protected access areas

Processing your requests, purchases, transactions, and payments, and preventing transactional fraud

Providing support and response to any of your inquiries, including any investigation necessary to address your concerns, and monitor, and improve our responses

Personalizing the IOM Website’s experience, delivering content, product, and service offerings relevant to your interests

Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations

To ensure appropriate right party contact and verification purposes in performing services on behalf of Participants

To fulfill or meet the reason you provided the information. For example, if you share your Personal Information to make a payment, we will use that information to process your payment

To provide you with information, products, or services that you request from us or to respond to inquiries received from you on your behalf regarding the services provided on behalf of Participants

Monitoring or auditing activities related to a current interaction with the CA Consumer and concurrent transactions

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Debugging to identify and repair errors that impair existing intended functionality

Short-term, transient use, provided the Personal Information is not disclosed to another third party and is not used to build a profile about a CA Consumer or otherwise alter an individual consumer’s experience outside the current interaction

Undertaking internal research for technological development and demonstration

Undertaking activities to implement, operationalize, improve, upgrade, or enhance the services performed on behalf of our clients and consumers (including CA Residents), as well as the tools used to provide those services, including analytics and other information analysis tools

To respond to law enforcement or other governmental requests and as required by applicable law, court order, or governmental contracts or regulations

As necessary or appropriate to protect the rights, property, or safety of CA Residents, us, our clients, or others

As described to you when collecting your Personal Information, or as otherwise set forth in the CCPA

 

WHERE WE GET OUR INFORMATION

 

The sources that our Personal Information comes from include:

Servicers and other parties necessary to perform services requested by you, including, but not limited to services associated with any Participant Account(s) (e.g., letter vendors, skip-tracing vendors, payment processing vendors, call analytics vendor and/or electronic signature service providers)

Personal Information received from the IOM Website, whether on a computer or mobile application

Email, text and other electronic messages between a CA Consumer and us, related to the Services

Personal Information orally received from a CA Consumer during a telephone call related to the Services

Written correspondence sent to our office regarding an Account

Directly from CA Residents, including Personal Information that CA Residents input into the IOM Website, to utilize the services

Pieces of information from limited sources, including data received from: the Client upon placement of a CA Resident’s Account; the Client to supplement Account Information

Publicly accessible sources (e.g., property records, social media, or court records)

From a third party with your consent (e.g., your authorized representative and/or attorney)

 

WHO WE SHARE OR DISCLOSE PERSONAL INFORMATION TO

 

We may share or disclose the Personal Information we collect about CA Residents as described herein, or otherwise disclosed to you at the time the Personal Information is collected, including with:

Consumer reporting agencies

Providers we use to help deliver our services, such as letter vendors, skip-trace vendors, applications and website vendors, payment service providers, monitoring and auditing service providers, warehouses, and delivery companies

Legal authorities, as required by law

Third parties, as requested and authorized by CA Residents

Third parties, allowed by law, such as spouses, legal representatives, and/or attorneys

Other third parties, authorized by law, that we use to help us run our business, such as legal, tax, banking, and other service professionals, insurers, brokers, auditors, and state and federal regulators;

 

EQUAL SERVICING

CA Residents that are Participants will not receive any variation in the service or pricing of the services, or your Account, because of you, exercising of your rights under the CCPA.

 

We will not discriminate against you for exercising any of your CCPA rights, which ensures that we will not:

§  Deny you any access to services;

§  Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties (any offers or settlements that may be presented, are granted in connection with our contractual agreements and do not correspond in any way to the rights granted under the CCPA);

§  Provide you a different level or quality of services; or

§  Suggest that you may receive a different price or rate for services, or a different level or quality of services.

 

We do not provide any financial incentive programs for the collection, sale, request for deletion of any Personal Information, or other utilization of the rights granted under the ccpa.

 

Contacts for More Information

 

Call us at: (866) 466-5660

Email us at: iomloans@iom.int

 

Changes to our CA Supplement

 

We reserve the right to amend this CA Supplement at our discretion and at any time.