Privacy Policy

Your privacy and data security are fundamental to everything we do at Scratch Financial. Learn how we protect your personal information.

Last Updated: September 18, 2024

1. Introduction

Welcome to Scratchpay, operated by Scratch Financial, Inc. ("Scratch Financial," "we," "us," or "our"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our mobile application, or apply for our veterinary financing services.

We are committed to protecting your privacy and maintaining the security of your personal information. This policy applies to all users of our services, including pet owners who apply for financing, veterinary partners, and website visitors.

Key Privacy Principles

  • We only collect information necessary to provide our services
  • We use bank-level security to protect your data
  • We never sell your personal information to third parties
  • You have control over your information and privacy choices

2. Information We Collect

Personal Information You Provide

When you apply for Scratchpay financing, we collect:

  • Identity Information: Full name, date of birth, Social Security number
  • Contact Information: Email address, phone number, physical address
  • Financial Information: Income, employment details, bank account information
  • Pet Information: Pet's name and basic details for treatment tracking
  • Veterinary Information: Treatment details and costs from your veterinarian

Information Collected Automatically

  • Device Information: IP address, browser type, operating system
  • Usage Data: Pages visited, time spent on site, referral sources
  • Location Data: General geographic location based on IP address
  • Cookies: Small data files to improve your experience

Information from Third Parties

  • Credit Bureaus: Credit reports and scores for underwriting decisions
  • Banking Partners: Account verification and payment processing
  • Veterinary Partners: Treatment information and payment requests
  • Identity Verification: Services to prevent fraud and verify identity

3. How We Use Your Information

Primary Uses

  • Provide Services: Process applications, make lending decisions, and manage accounts
  • Payment Processing: Collect payments and manage your financing plan
  • Customer Support: Respond to inquiries and resolve issues
  • Legal Compliance: Meet regulatory requirements and prevent fraud

Secondary Uses

  • Improve Services: Analyze usage patterns to enhance our platform
  • Communication: Send account updates, payment reminders, and service announcements
  • Marketing: Share relevant offers and information (with your consent)
  • Risk Management: Detect and prevent fraudulent activities

Legal Basis for Processing

We process your personal information based on:

  • Contract Performance: To provide the financing services you requested
  • Legal Obligations: To comply with financial regulations and anti-fraud laws
  • Legitimate Interests: To improve our services and prevent fraud
  • Consent: For marketing communications and optional services

4. Information Sharing

We do not sell, rent, or trade your personal information. We may share your information only in the following circumstances:

Service Providers

  • Payment Processors: To handle transactions and payments
  • Credit Reporting Agencies: To assess creditworthiness and report account status
  • Technology Partners: For data storage, security, and platform functionality
  • Customer Service: To provide support through authorized representatives

Veterinary Partners

  • Treatment costs and approval status to facilitate care
  • Payment confirmations for completed treatments
  • Account status for ongoing payment plans

Legal Requirements

  • Court orders, subpoenas, or other legal processes
  • Government agencies for regulatory compliance
  • Law enforcement for fraud investigation or prevention
  • Legal proceedings involving debt collection or disputes

Business Transactions

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

5. Data Security

We implement comprehensive security measures to protect your personal information:

Technical Safeguards

  • Encryption: All data is encrypted in transit and at rest using industry-standard protocols
  • Secure Servers: Information stored on servers with restricted access and monitoring
  • Regular Security Audits: Third-party assessments of our security practices
  • Vulnerability Testing: Ongoing testing to identify and address potential security risks

Administrative Safeguards

  • Access Controls: Limited access to personal information on a need-to-know basis
  • Employee Training: Regular privacy and security training for all staff
  • Background Checks: Screening of employees with access to sensitive data
  • Incident Response: Procedures for detecting, reporting, and responding to security incidents

Physical Safeguards

  • Secure facilities with restricted access
  • Surveillance systems and security personnel
  • Secure disposal of physical records
  • Environmental controls to protect equipment

Data Breach Response

In the unlikely event of a data breach, we will:

  • Immediately investigate and contain the incident
  • Notify affected users within 72 hours when legally required
  • Provide clear information about what happened and what we're doing about it
  • Offer free credit monitoring services if appropriate

6. Your Rights and Choices

You have several rights regarding your personal information:

Access and Portability

  • View Your Information: Request a copy of the personal information we hold about you
  • Data Portability: Receive your information in a commonly used format
  • Account Dashboard: Access and review your account information online

Correction and Updates

  • Update Information: Correct inaccurate or incomplete personal information
  • Profile Management: Update contact preferences and communication settings
  • Account Changes: Modify payment methods and contact information

Communication Preferences

  • Marketing Opt-Out: Unsubscribe from promotional emails and messages
  • Communication Channels: Choose preferred methods for account notifications
  • Frequency Settings: Adjust how often you receive non-essential communications

Deletion Rights

You may request deletion of your personal information, subject to legal and contractual obligations. Note that we may need to retain certain information for:

  • Active loan servicing and payment processing
  • Legal compliance and regulatory requirements
  • Fraud prevention and security purposes
  • Legitimate business interests and dispute resolution

7. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience and analyze website usage:

Types of Cookies

  • Essential Cookies: Required for basic website functionality and security
  • Performance Cookies: Help us understand how visitors use our website
  • Functional Cookies: Remember your preferences and settings
  • Marketing Cookies: Used to deliver relevant advertisements

Managing Cookies

You can control cookie settings through your browser preferences. However, disabling certain cookies may limit your ability to use some features of our website.

Third-Party Analytics

We use services like Google Analytics to understand website usage. These services have their own privacy policies and cookie practices.

8. Children's Privacy

Our services are designed for adults aged 18 and older. We do not knowingly collect personal information from children under 13. If we discover that we have inadvertently collected such information, we will promptly delete it.

Parents or guardians who believe their child has provided personal information to us should contact us immediately using the information provided in the Contact section below.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

  • Update the "Last Updated" date at the top of this policy
  • Post the revised policy on our website
  • Send email notifications for significant changes
  • Provide notice through our mobile application

Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy.

10. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Privacy Officer

Scratch Financial, Inc.
Attn: Privacy Officer
123 Financial District
San Francisco, CA 94105

Email: privacy@scratchpay.com
Phone: 1-855-727-2824
Hours: Monday - Friday, 9:00 AM - 6:00 PM PST

Data Protection Rights Requests

To exercise your privacy rights or submit a data protection request, please:

  • Use our online privacy request form at scratchpay.com/privacy-request
  • Email us at privacy@scratchpay.com with "Privacy Request" in the subject line
  • Call our privacy hotline at 1-855-727-2824

We will respond to your request within 30 days and may require verification of your identity to protect your privacy.