Effective Date: December 9th, 2022
Last Updated November 2nd, 2022
Introduction
Regional Management Corp. and its subsidiaries and affiliates (“Regional Finance,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using the websites on which this policy appears (“Sites”) and the services provided through our Sites (“Services”). For investment information, including information regarding our business and results of operations, please visit our investor website at RegionalManagement.com.
If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.
This Privacy Policy covers the following topics:
We collect Personally Identifiable Information from you through your use of the Sites and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide
We may collect the following Personally Identifiable Information that you voluntarily provide to us in using our Sites and Services:
Information as You Navigate Our Sites
We automatically collect certain Personally Identifiable Information through your use of the Sites and Services, such as the following:
Information Collected from Other Sources
We may receive certain Personally Identifiable Information about you from third parties. For example, we may receive information about your credit history from a credit reporting agency or income information from your employer.
Third Party Information
In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, when you fill out our online forms you may provide the contact information of another individual. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.
We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Sites and Services, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
We may share the information that we collect about you in the following ways:
Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons). To learn more about how we use cookies and your choices regarding our use of cookies, please see our Cookie Policy.
To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws.
For example, to facilitate your loan request and to service your loan, you may provide us your financial information by linking your bank account(s) with Plaid. To link your bank account, you will provide your bank account information, including but not limited to, the financial institution name, your bank account username and password, account type, account number, and routing number. We use Plaid to enable us to offer this service. For more information regarding Plaid’s collection of this personal information, please see Plaid’s Privacy Policy.
Also, if you use the Dealer Login feature on rmcretail.com, you will be directed to a third-party website operated by MeridianLink, Inc. For more information regarding MeridianLink’s collection of this personal information, please see MeridianLink’s Privacy Policy.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites does not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
Review and Request Changes to Your Personally Identifiable Information
You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us as provided in the “How to Contact Us” section below.
Marketing Communications
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at customerservice@regionalmanagement.com.
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
The Sites and Services may contain links that will let you leave them and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on the Sites and Services. We accept no responsibility or liability for these other websites.
The Sites and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA’s privacy rights described below do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
The CCPA’s privacy-related rights also do not apply to certain types of Personal Information subject to the Federal Credit Reporting Act (FCRA). Some of our services are subject to the FCRA and, therefore, exempt from the CCPA on that basis.
If you are California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here [hyperlink] for more information on our collection and use of your Personal Information in that capacity.
Notice of Collection of Personal Information
We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:
We collect Personal Information directly from California residents and from credit reporting agencies, credit bureaus, employers, medical providers, advertising networks, internet service providers, data analytics providers, and government entities. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated above in the Section “How We Use Your Information” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
Sale, Sharing, and Disclosure of Personal Information
The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the category of recipients to whom we disclosed the Personal Information.
| Category of Personal Information | Category of Service Providers | Category of Third Parties |
| Name | Printing and mailing providers, Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), State regulators (Wisconsin only), Government agencies, Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans), Bank partners |
| Alias | Department of Justice (e.g., to determine whether subject to certain active service member protections) | |
| Social Security number | Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans) |
| Email address | Email service provider, Fraud detection provider | Credit, bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Government agencies, Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans) |
| Postal/home address | Printing and mailing providers, Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), State regulators (Wisconsin only), Government agencies, Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans), Bank partners |
| Telephone number | Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Government agencies, Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans) |
| Date of birth | Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member, Insurance claim provider protections), Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans) |
| Government-issued identification number | Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Vehicle history provider, Collections, Insurance claim provider, Retailers (for retail loans) |
| Age (40 and older) | Printing and mailing providers | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Vehicle history provider, Collections, Debt sellers, Insurance claim provider, Retailers (for retail loans) |
| Sex/gender | Insurance claim provider | |
| Gender identity/expression | Insurance claim provider | |
| Citizenship or immigration status | Printing and mailing providers | Insurance claim provider |
| Disability | Insurance claim provider | |
| Military or veteran status | Department of Justice (e.g., to determine whether subject to certain active service member protections), Vehicle history provider, Collections, Insurance claim provider | |
| Medical information (e.g., application and claims history, medical provider, death certificates) | Insurance claim provider | |
| Medical condition | Insurance claim provider | |
| Income | Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Collections, Insurance claim provider, Retailers (for retail loans), Bank partners |
| Records of personal property | Fraud detection provider | Credit bureaus, Department of Justice (e.g., to determine whether subject to certain active service member protections), Collections, Insurance claim provider, Retailers (for retail loans) |
| Loan Data | State regulators (Wisconsin only) | |
| Marital status | State regulators (Wisconsin only), Vehicle history provider, Collections, Insurance claim provider | |
| Bank account number | Fraud detection provider | Credit bureaus, Collections, Retailers (for retail loans) |
| Debit card number | Fraud detection provider | Credit bureaus, Collections, Retailers (for retail loans) |
| Insurance policy number | Fraud detection provider | Credit bureaus, Collections, Insurance claim provider |
| Financial account login credentials | Credit bureaus, Collections | |
| Professional or employment-related information | Printing and mailing providers | Credit bureaus, Debt sellers, Insurance claim provider, Retailers (for retail loans), Bank partners |
| IP address | Data analytics provider, Email service provider, marketing agency, Fraud detection provider | Credit bureaus, Advertising networks, Vehicle history provider, Collections |
| Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology | Data analytics provider, Email service providers, Fraud detection provider | Advertising networks |
| Information regarding consumer’s interaction with website, application or advertisement | Data analytics provider | Advertising networks |
| Records of products or services purchased, obtained or considered | Credit bureaus, Retailers (for retail loans) | |
| Inferences drawn from the above | Advertising networks |
We disclosed Personal Information for the business and commercial purposes identified in the prior section of this policy.
We have not sold or shared Personal Information in the twelve (12) months preceding the Last Updated Date of this Privacy Policy. We do not knowingly sell the Personal Information of minors under 16 years of age. We do not use Sensitive Personal Information for purposes other than those the CCPA and its regulations allow for.
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
Your Rights
If you are a California resident, you have the following rights with respect to your Personal Information:
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or collect by calling us toll-free at (833) 708-4357 or by completing our webform, available here.
As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.
For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.
To contact us for questions or concerns about our privacy policies or practices please email us at customerservice@regionalmanagement.com.
Regional Management Corp.
979 Batesville Road,
Suite B
Greer, SC 29651
(864) 448-7003
