Privacy Policy

1. Scope

This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information when an authorized affiliate submits a consumer-directed financial-assessment request through an integrated CRM; when we access or analyze authorized credit information; when we communicate with you; or when you visit certezzadata.com.

Additional notices, agreements, authorizations, or disclosures may apply to a particular service. If those terms conflict with this policy, the more specific terms will govern to the extent permitted by law.

2. How information reaches us

A participating affiliate marketer ordinarily communicates directly with the consumer. The affiliate presents a disclosure identifying Certezza as the technology and data-processing provider and obtains the consumer’s authorization. The affiliate’s CRM records the authorization and submits the request to Certezza through an integrated connection.

Certezza may retrieve authorized credit information, create a debt-profile summary or program-category assessment, and return the result through the CRM. The affiliate may use that result to discuss potentially relevant education or financial-assistance programs with the consumer. Certezza may support multiple affiliates and providers.

3. Information we collect

Identifiers and contact information

We may collect your name, postal address, email address, telephone number, date of birth, account or CRM identifiers, and other information used to identify, authenticate, or communicate with you. Our website contact form collects your name, email address, optional phone number, and message. Please do not submit sensitive information through that form.

Credit and service information

When reasonably necessary to provide services you request, and with any authorization required by law, we may process credit reports, credit scores, tradeline and account details, balances, payment history, debt obligations, credit inquiries, public-record data, and other information contained in or derived from a consumer report.

Sensitive personal information

Some services may require sensitive personal information, such as a Social Security number or partial Social Security number, date of birth, government-issued identification, financial account details, authentication information, or precise information contained in a consumer report. We use sensitive personal information only as reasonably necessary to provide requested services, verify identity, prevent fraud, maintain security, and comply with law.

Communications and records

We may collect correspondence, call or SMS details, call-recording identifiers, documents, service preferences, consent and authorization records, the disclosure version presented, authorization method, date and time, one-time-code verification result, IP and available device information, CRM request identifiers, and revocation records.

Website and device information

When you visit the website, our hosting and infrastructure providers may automatically process limited technical information, such as your IP address, browser type, device information, requested pages, and the date and time of your request.

4. Sources of information

We may collect personal information from:

• You, including information and instructions provided during an affiliate interaction;
• Authorized affiliate marketers and their integrated CRM systems;
• Consumer reporting agencies, when authorized and permitted by law;
• Service providers and business partners involved in providing a requested service;
• Your authorized representatives or other parties you direct us to contact;
• Public records, government sources, and other legally available sources; and
• Our website, security systems, and business technology providers.

5. How we use information

We may use the information we collect to:

• Verify identity, eligibility, authorizations, and service requests;
• Access a consumer report pursuant to the consumer’s written instructions and disclosed purpose;
• Assess current debt obligations and the consumer’s general financial position;
• Create summaries and identify potentially relevant education or financial-assistance program categories;
• Return authorized results through an integrated CRM to the affiliate assisting the consumer;
• Facilitate an authorized referral to an identified participating provider;
• Send service-related notices and, where permitted, information about our services;
• Operate, maintain, secure, evaluate, and improve our business, website, and services;
• Prevent fraud, abuse, and other harmful activity; and
• Comply with applicable law, enforce agreements, and protect legal rights and safety.

6. How we share information

We do not sell personal information for monetary consideration or share it for unrelated cross-context behavioral advertising. We may disclose information as directed by the consumer and for the assessment, CRM return, and referral purposes described below.

Service providers

We may provide information to vendors that support our operations, technology, security, communications, document management, customer service, artificial-intelligence-assisted processing, professional services, consumer-report access, and website hosting or email delivery, including Amazon Web Services. We require service providers to handle information only for appropriate business purposes and subject to applicable confidentiality and security obligations.

Consumer reporting and service-related parties

When authorized by you and permitted by law, we may disclose or exchange information with consumer reporting agencies, the affiliate that presented the authorization, its integrated CRM, your authorized representatives, service providers, and a participating provider identified to you when reasonably necessary for an authorized assessment or referral.

Legal, safety, and business purposes

We may disclose information as required or permitted by law, in response to valid legal process, to investigate fraud or security concerns, or to protect the rights and safety of Certezza and others. Information may also be transferred as part of a merger, acquisition, financing, reorganization, or sale of all or part of our business.

7. FCRA and consumer reports

Permissible purpose and authorization

Certezza accesses a consumer report only after receiving evidence of the consumer’s written instructions or another permissible purpose under the Fair Credit Reporting Act ("FCRA"). In our current workflow, the consumer reviews a disclosure and authorizes access by written or electronic signature, or by affirmatively accepting the disclosure and entering a one-time code sent to a designated phone number or email address. The code verifies identity and acceptance; it does not replace the disclosure.

We use consumer-report information only for the disclosed financial assessment and authorized referral purpose. We do not use it to approve or deny credit, establish credit terms, underwrite a transaction, or determine eligibility for employment, housing, insurance, or another benefit.

Copies, disputes, and revocation

A consumer may request a copy of information processed by Certezza or report a suspected error through the affiliate or by contacting us. We verify identity before release. We investigate errors in our own processing or presentation. If disputed information originated with a consumer reporting agency or data furnisher, we identify the source and provide instructions or reasonable assistance for contacting the responsible organization. Certezza is not a consumer reporting agency or data furnisher and cannot alter an underlying source record it does not control.

Authorization may be revoked prospectively through the affiliate or by contacting Certezza. Revocation does not affect processing already completed under the authorization or records we must retain by law.

Adverse action

Certezza does not make eligibility decisions and does not take adverse action. Any third-party provider that independently uses a consumer report for a decision covered by the FCRA is responsible for its own permissible purpose, certifications, and legally required notices.

8. AI and automated tools

Certezza may use automated and artificial-intelligence-assisted tools to organize, summarize, classify, and analyze authorized information and identify potentially relevant program categories. Information may be processed by contracted technology providers acting on our behalf. Outputs may be incomplete or inaccurate and should be reviewed in context. These tools are not used by Certezza to make lending, underwriting, employment, housing, insurance, or other eligibility decisions.

9. Cookies and online activity

Our website and its infrastructure may use cookies or similar technologies that are necessary to deliver pages, maintain security, remember basic preferences, and diagnose performance. Your browser may allow you to delete or block cookies, although doing so can affect website functionality. If we introduce analytics, advertising, or other nonessential tracking technologies, we will provide any notice or choice required by applicable law.

Because there is not yet a uniform industry standard for browser “Do Not Track” signals, our website does not currently respond to them. Where required, we will recognize legally applicable browser-based opt-out preference signals.

10. Data retention

We retain personal information only for as long as reasonably needed for the purposes described in this policy, including providing services, maintaining consumer-report access certifications, disclosure and authorization evidence, audit records, resolving disputes, preventing fraud, enforcing agreements, and meeting legal or regulatory obligations. Retention periods vary based on the type and sensitivity of information, the nature of our relationship, and applicable requirements.

11. Security and disposal

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information, including consumer-report information. We limit access based on role and business need and use reasonable measures to securely dispose of consumer-report information when retention is no longer required. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Your choices and rights

Depending on your jurisdiction and subject to legal exceptions, you may have the right to request access to or confirmation of personal information we process; obtain a portable copy; request correction or deletion; opt out of certain sales, sharing, targeted advertising, or profiling; or limit certain uses of sensitive personal information. You may also have the right to appeal a decision about your request and to exercise your rights without unlawful discrimination.

We do not sell personal information or share it for cross-context behavioral advertising. To submit a privacy request, email or write to us using the contact information below and describe your request. We may ask for information needed to verify your identity and authority. An authorized agent may submit a request where permitted by law, but we may require proof of authorization and direct identity verification. We will respond within the time required by applicable law.

Communication choices

You may opt out of promotional email by using the unsubscribe method provided in the message or contacting us. If you consented to SMS, message frequency varies and message and data rates may apply; reply STOP to opt out or HELP for assistance. Entering a credit-access verification code does not by itself authorize promotional texts. We may still send nonpromotional communications concerning requested services, security, transactions, or our ongoing relationship.

13. International processing

Certezza operates in the United States. If you provide information from another country, it may be transferred to, stored in, and processed in the United States or other locations where our service providers operate. Privacy laws in those locations may differ from the laws where you live. Where required, we use appropriate safeguards for such transfers.

14. Children’s privacy

Our services are not directed to individuals under 18, and we do not knowingly collect personal information from children under 18. If you believe a child has provided us with personal information, please contact us so we can investigate and take appropriate action.

15. Changes to this policy

We may update this Privacy Policy periodically. When we do, we will revise the updated date at the top of this page. We encourage you to review this page for the latest information about our privacy practices.