Privacy Policy

Achroma, Public Benefit Corporation (“Achroma”) has created this privacy policy in order to demonstrate our firm commitment to privacy. It governs all privacy-related matters between customers and consumers and Achroma and Achroma’s website (the “Site”).
Overview

Achroma respects your privacy and is committed to complying with this privacy policy (the “Privacy Policy”). To that end, we employ and maintain physical, electronic, and procedural safeguards to ensure your non-public personal information is protected. This Privacy Policy is one of those safeguards and describes our information collection and sharing practices that apply to the information collected on our website: Achroma.io and through the origination process with Achroma. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

BY ACCESSING OR USING ACHROMA’S WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, AND UNDERSTAND OUR PRIVACY POLICY.

This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.

If you feel that we are not abiding by this privacy policy, you should contact us immediately at:

Achroma, Public Benefit Corporation
team@achroma.io
940 Lincoln Street
Denver, CO 80203

Updates

This Privacy Policy was last updated 6/3/2019. We reserve the right to modify this privacy policy to reflect changes to our information practices at any time with notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of Achroma’s website following the posting of changes to these terms will mean you accept those changes.

How and why we collect personal information

Achroma primarily collects information by specifically requesting it from you. Generally, this occurs when you register at the Site or request information or a service. Usually, we and our service partners use your information to operate the Site and to deliver value-added services to you. Our website also uses your information to inform you about other products or services available from us.

Achroma gathers two types of information about you:

  • Data, including non-public personally identifiable information, that users provide through optional, voluntary application on our website
  • Data that Achroma gathers through aggregate tracking, including by tallying webpages that are viewed by users throughout our website.

For the purposes of this Privacy Policy, non-public personal information includes any information you provide to Achroma that has not been made lawfully available to the public, including but not limited to, your email address, your first name, your last name, your social security number or other tax payer identification number, your date of birth, and your loan number.

Information we collect when you browse our website

We do not access information about your identity while you browse our website. Although we collect information about the date, time and area of our website that you visited, you remain anonymous to us. Only if you decide to apply for a loan with us directly or through a broker, do we collect any personally identifying information about you.

Cookies and Usage Reports

By placing a small file known as a “cookie” on your computer (or other device), Achroma passively gathers information about all visitors’ use of our website for several reasons, including, but not limited to, the following: statistics collection and analysis, System optimization, analytics (as described below), market research, and maintenance of user login information. The information that we track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the System, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the System), how you were directed to the site, which specific pages you access on the site, how long you view each page, the time and date you access our site and the total number of visitors to the site and any portions thereof. We may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the site. This data helps us improve our respective products and services.

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the site (or some portion thereof) and its capabilities, or cause some features of the site to function improperly or more slowly.

Third-Party Service Providers and Web Beacons

We use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Websites and how we can improve them. Google Analytics collects information such as how often users visit a Website, what pages you visit when you do so, and what other websites you used prior to coming to such Website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network.

How to Opt Out of Promotional Correspondence

We may send you emails with promotional offers only if you opt in to receiving such emails. If you would no longer like to receive information, newsletters or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions, or alternatively you may contact our Customer Service (as provided below) in order to unsubscribe or have your email address removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.

Online Account Management

If you elected to subscribe to any online services provided via the Site, including the ability to access any password-protected areas of the Site, you will be required to submit personal information (including some Collected Information) for the purpose of verifying your identity and your authority to manage the account. This Collected Information will be used exclusively by Achroma and affiliated third parties for internal use and to respond to your service requests.

How We Use the Information That We Collect

We and our third party services providers collect and use the Collected Information to operate the Site and deliver the Services, including to provide certain services and improve the user experience, address Site integrity or security issues, and conduct research and analysis to maintain, protect, develop, and improve the Site, sell certain merchandise, and, additionally, use any information submitted by you as described below or elsewhere in the Privacy Policy. We may send you information that you request from us, promotional materials regarding Achroma or any other entity or individual affiliated with our corporate family, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries or requests regarding the Services or the Site, or respond to your questions or requests for information about or from us. We may also use Collected Information as necessary to ensure compliance with any of our policies and any applicable law, regulation or order.

Except as set forth in this Privacy Policy, we will not use, disclose, or transfer your Collected Information unless:

  1. you expressly authorize us to do so;
  2. it is necessary to allow our service providers, agents, or other third parties to provide products or services for or to us;
  3. it is necessary in order to provide the Site or the Services;
  4. subject to applicable legal restrictions, we are sending you other information that may be useful to you;
  5. subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements;
  6. it is necessary to protect the confidentiality or security of your records;
  7. it is necessary in connection with other business purposes including, without limitation, verifying identity, age, or payment details; investigating complaints about the System; risk assessment, security, fraud and crime prevention/detection; monitoring, research and analysis; marketing, customer purchasing preferences, and trends; and dispute resolution;
  8. it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity;
  9. subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of one of our companies or the merger of one of our companies into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which our company is not the survivor; or
  10. it is otherwise necessary for us to disclose it as required or permitted by law.

With Whom We Share the Information That We Collect

In addition to the uses mentioned or described elsewhere in this Privacy Policy, we may catalog and add Collected Information to our database which may be shared with our affiliates.

We do not sell, rent, or lease our user lists or the identity of individual users to third parties, except as permitted or required by applicable law. However, we may use and disclose certain aggregated, anonymized information, such as Site usage data, to our trusted business partners. Such information may also be shared as permitted or required by applicable law.

We may also disclose Collected Information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose Collected Information to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

As we grow and develop our business, it is possible that our corporate structure or organization might change or that we might merge or otherwise combine with, or that portions of our business might be acquired by, another company. In any such transactions, customer information generally is, and should be expected to be, one of the transferred business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Job Applicants

Any personal information you provide to us when applying for a job position with us will be used solely to consider and act upon your application. We may retain your personal information for a period of time, but only for as long as necessary for such purposes. We may disclose your personal information to our agents for the purpose of evaluating your qualifications for the particular position you applied for, or other available positions. We may also disclose your personal information to third parties hired by us to collect, maintain, and analyze candidates for job positions.

Your Choices Regarding Our Privacy Practices

When submitting information, corresponding, making requests for information, and otherwise interacting with us and our representatives through or in connection with the Site, including by utilizing the Services, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Any promotional email we send to you will contain a link which will allow you to opt out of receiving any further correspondence.

How We Protect Information Collected About You

We take commercially reasonable measures to secure and protect information transmitted via or stored on the System. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure. Achroma has developed, implemented and maintained a comprehensive information security program to address any security concerns or issues.

Linked Websites

For your convenience, some hyperlinks may be posted on the Site that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control, and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit.

If you initiate a transaction on a website to which our Site links, even if you reached that site through Achroma, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal information that is collected about you is used and protected.

User-Provided Content

Any information, communications, or material of any type or nature that you submit to the Site by e-mail, posting, messaging, uploading, or otherwise (collectively, a “Submission”) is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of the System and we are therefore not responsible for any Submissions contained on a Website.

Additionally, in the event that we offer a message board or any other interactive or social-type feature on a Website, including comments to blog posts, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information. We encourage you to be wary of giving out any personal information, or any personal information of others to which you may have access, in such forums. The information you post can be collected and used by other people. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.

Social Media Platforms and Websites

Any Submission that you submit to any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. We encourage you to review the applicable privacy policy and terms of use of any such social media platform or website prior to making any such Submissions.

Right to Verify the Accuracy of Information We Collect

Keeping information accurate and up to date is important to us. An individual may see and correct their personal information that they provided to us, subject to certain legal or contractual limitations. Contact us as described above if you wish to verify your personal information.

Information Collected From Children

The System is intended for a general audience and is not intended for use or view by children under 13 years of age, and we do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. If you are under the age of 13, you are not permitted to submit information to the Site.

All information submitted through our Websites must be submitted by the parents or legal guardians of the children to whom any such information relates.

Visiting the System From Outside the United States

If you are visiting the Site, or any part thereof, from outside of the United States, please be aware that your information may be transferred to, stored, or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share your information, as described in this Privacy Policy.