Firstmark Services Privacy Center
Effective Date: May 4, 2023
If you have a loan owned by affiliated subsidiaries of Nelnet Inc. (“Nelnet-owned loans”) that is serviced by Firstmark we will use and share any information that we collect from or about you in accordance with the U.S. Consumer Privacy Notice , which offers you certain choices with respect to the use and sharing of your personal information.
If you have a loan owned by Nelnet Bank, Inc. (“Nelnet Bank”) that is serviced by Firstmark please see Nelnet Bank’s Privacy Notice , which offers you certain choices with respect to the use and sharing of your personal information.
Information We Obtain
We obtain certain personal information in connection with the Site, including:
- Contact information, such as name, email and postal address, and phone number;
- Login credentials, such as user name and password;
- Account information and preferences, such as email preferences and paperless registration;
- Bank account information, such as account number and routing number;
- Payment card information, including card number and expiration date;
- Social Security number or other government-issued identifier;
- Demographic information, such as date of birth;
- Documents or other content you upload to the Site and/or through our chat or email interfaces, such as letters, notices, and supporting material for concerns or questions you may have relating to your account(s) with Firstmark; and
- Other personal information you submit to us, such as through chat, email, or other communications, or sign-up forms.
In addition, when you interact with the Site, or open or view our emails, we may obtain certain information using various automated technologies, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your devices, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data and dates and times of visits to the Site. These technologies help us (i) remember your information so you will not have to re-enter it; (ii) understand how you use and interact with the Site and with our electronic communications with you such as our emails; (iii) tailor the Site around your preferences; (iv) measure the usability of the Site and the effectiveness of our communications; and (v) otherwise manage and enhance the Site and our other services, and help ensure they are working properly.
How We Use The Information We Obtain
We may use the information we obtain about you to:
- Provide our services to you;
- Establish and manage your account(s) with us;
- Process and fulfill transactions in connection with our services;
- Communicate with you (including providing you with offers and other communications about our services), respond to your inquiries, and offer customer support;
- Personalize your experience with the Site and our other services;
- Operate, evaluate, develop, manage and improve the Site and our business (including operating, administering, analyzing and improving our services; developing new services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and servicing activities and other internal functions);
- Perform analytics (including market research, trend analysis, financial analysis and anonymization and aggregation of personal information);
- Increase and maintain the safety and security of our Site and other services, and prevent misuse;
- Protect against, identify, and prevent fraud and other criminal activity, claims and other liabilities; and
We also may use the information we obtain about you for other purposes disclosed at the time your information is collected.
We may use third-party analytics services on the Site, such as Google Analytics. These analytics providers that administer these services use automated technologies such as cookies, web server logs and web beacons to help us analyze your use of the Site. The information collected through these automated technologies (including IP address) may be disclosed to these analytics providers who use the information, for example, to evaluate use of the Site. To learn more about Google Analytics and how to opt out, please visit https://tools.google.com/dlpage/gaoptout.
The Site is not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices, and http://preferences-mgr.truste.com.
Third-Party CAPTCHA Services
Information We Share
We may share the information we obtain about you with affiliated and non-affiliated third-party vendors to perform certain services on our behalf, such as website hosting, data analytics, payment processing and other services.
In addition, we may disclose information about you: (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise or defend our legal rights; (iv) to protect, defend or enforce our policies, terms or agreements; (v) when we believe disclosure is necessary or appropriate to address security or to prevent physical or other harm or financial loss; (vi) in connection with an investigation of suspected or actual illegal activity; or (vii) otherwise with your consent.
We also reserve the right to transfer information we have about you in the event we sell or transfer all or a portion of our business or assets (such as in the event of a merger, acquisition, joint venture, consolidation, restructuring, divestiture, dissolution liquidation or other corporate change), including during the course of any due diligence process.
We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
We recognize the importance of protecting children’s online privacy. The Site is intended for a general audience and is not directed to children. We do not knowingly collect personal information online from children under the age of 13.
Other Online Services And Third-Party Features
For your convenience and information, the Site may contain links or references to other services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Firstmark we are not responsible for these third parties’ information practices.
How To Contact Us
U.S. Consumer Privacy Notice for Nelnet Customers
The notices referenced in this section affect only loans that we service and that are owned by affiliated subsidiaries of Nelnet Inc. (“Nelnet-owned loans”) and by Nelnet Bank.
If you have a Nelnet-owned loan please see this U.S. Consumer Privacy Notice which details the privacy practices with affiliates and other third parties, and will help you understand how information is shared and the choices you have regarding your information. For your Nelnet-owned loans, please complete the online Privacy Options Form to opt out of sharing certain information with affiliates or nonaffiliated third parties.
If you have a loan owned by Nelnet Bank, Inc. (“Nelnet Bank”) please see Nelnet Bank’s U.S Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information. For your Nelnet Bank loans, please complete the online Privacy Options Form or call 800.446.4190 to opt out of sharing certain information with affiliates or nonaffiliated third parties.
U.S. Consumer Privacy Notice for non-Nelnet Customers
P.O. Box 82522
Lincoln, NE 68501-2522
California Privacy Notice
Last Updated: May 4, 2023
This California Privacy Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).
This California Privacy Notice does not apply to information we collect, process or disclose pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. If you have an account that we service, please see the applicable U.S. Consumer Privacy Notice section, which offers you certain choices with respect to the use and sharing of your personal information.
- If you have a loan owned by affiliated subsidiaries of Nelnet Inc. (“Nelnet-owned loans”) which we service, this California Privacy Notice does not apply to you. We use and share any information that we collect from or about you in accordance with the U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
- If you have a loan owned by Nelnet Bank, Inc. (“Nelnet Bank”) which we service, please see Nelnet Bank’s U.S Consumer Privacy Notice , which offers you certain choices with respect to the use and sharing of your personal information.
If you do not have an account serviced by us, and if we do not otherwise have contact information on file about you, then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that we do not link information we may collect about non-accountholders (e.g., IP addresses, device identifiers or other information collected through automated means) to named actual persons. Accordingly, if you do not have an account with us and if we do not otherwise have contact information on file about you, and you request access to, correction of, or deletion of your personal information, we will not be able to process your request at this time.
Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Privacy Notice) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, description, state identification card number, bank account number, credit card number, debit card number, or other financial information, education information, medical information and health insurance information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, medical condition, disability, citizenship status, and military and veteran status
- Online Activity: Internet and other electronic network activity information, including, but not limited to, information regarding your interaction with our websites, or applications
- Sensory Information: audio, electronic, visual, and similar information
- Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
- Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Helping to ensure security and integrity;
- Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
- Debugging to identify and repair errors;
- Undertaking internal research for technological development and demonstration;
- Managing career opportunities with us; and
- Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.
We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
Retention of Personal Information
Sources of Personal Information
During the 12-month period prior to the Last Updated date of this California Privacy Notice, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you contact us
- Your devices, such as when you use our online services
- Our affiliates
- Vendors who provide services on our behalf
- Our business partners
- Data analytics providers
- Recruiting and talent agencies
- Job references, such as your employers
- Data brokers, such as background check services
Sale or Sharing of Personal Information
We do not sell your personal information in exchange for monetary compensation. We do not share your personal information with third parties (such as online advertising services) for cross-context behavioral advertising purposes.
Disclosure of Personal Information
During the 12-month period prior to the Last Updated date of this California Privacy Notice, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Personal Information||Categories of Third Parties|
|Additional Data Subject to Cal. Civ. Code § 1798.80||
In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Privacy Notice, we may have disclosed personal information about you to government entities and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions, or divestitures.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information collected about you.
- Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
How to Submit a Request
To submit an access, correction, or deletion request, please call 833.531.2511 or go to our Privacy Request Portal and follow the instructions provided. To submit a request as an authorized agent on behalf of someone else, please go to our Privacy Request Portal and follow the instructions provided. For questions or concerns about our privacy policies and practices, please contact us at AskPrivacy@nelnet.net.
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to, correction of or deletion of your personal information, we may require you to verify your email address or phone number in our records and/or provide any of the following information:
- Full name & surname
- State of residence
- Physical address
- Telephone number
- Nature of your relationship with our company (Website visitor/Job Applicant/Employee/Former Employee/Contractor/Business Partner Personnel)
- Email address
In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.