Effective as of December 1, 2019
Through the use of or online inquiry regarding the products and services we offer (“Services”) or access to our Site, we may collect personal information about you, which is information that identifies you as an individual, relates to you as an individual, or that, along with other information, could identify you (“Personal Information”). We collect the following types of Personal Information:
Information provided by you
We do not require you to provide any Personal Information in order to navigate our Site. However, we collect Personal Information from you when you:
Information obtained from third parties
We may obtain Personal Information about you from third parties, such as credit bureaus and demographic firms, when you use our Site or Services. We may also obtain information about you from Payfone, the vendor that assists us in verifying and authenticating your identity via mobile device.
Cookies and other tracking technologies
Cookies. “Cookies” are small pieces of information that are stored by your web browser software on your computer’s hard drive or temporarily in your computer’s memory. We seek to place and store Internet cookies on your hard drive. Cookies can save any of the types of information noted above. Cookies enable us to personalize your viewing experience and allow us to track statistical information about navigation to and throughout certain areas of the Site and to promotions on other sites. We also utilize third parties that may place and store Internet cookies on your hard drive for web analytics. These third party cookies collect information about our Site traffic by tracking users across websites and across time and generating reports for us to better understand our Site users and to create audiences for our advertisements based on such understanding. Third party ad network providers that help us present ads on the Site may also place cookies on your device to service you with ads or other content personalized to your interests.
Social Media Widgets. Our Site includes social media features, such as Facebook, LinkedIn, and Twitter. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie to ensure the feature functions properly. These features may also provide you with personalized ad content. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
We share your Personal Information with our service providers, among our entities, in connection with the provision of the Services, a corporate restructuring, to prevent harm, to comply with the law, and to protect our legal rights. The legal basis for this is our legitimate interest in providing our Services, complying with the law, and protecting our rights and those of others.
At Synchrony, our goal is to protect your Personal Information submitted to us through this Site. We maintain reasonable physical, electronic, and procedural safeguards to protect and limit access to your Personal Information. However, no method of transmission over the Internet or electronic storage technology is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
You are responsible for maintaining the confidentiality of your account username and password. We recommend that you choose a unique password for your account and that you do not use any password that you also use for any other accounts which may contain your sensitive information, such as financial accounts or email accounts. You agree to immediately notify Synchrony of any unauthorized use of your password or account or any other breach of security. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.
If you access our Site from a public or shared computer, it may be possible for other users to review your online history. For this reason, you should always close your browser window after you finish any online banking session, including visiting our Site. If you access our Site from a shared computer, you should never set the Internet options to remember or store user IDs or passwords. Also, you should never go to websites or follow web links that are unfamiliar or seem suspicious to you.
THIRD PARTY LINKS
If you are a California user of our Services (“California Consumer”), you have certain rights with respect to the collection, use, transfer, and processing of your Personal Information, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
Collection of Personal Information
When California Consumers access our Site, we collect the following Personal Information:
Internet or Other Electronic Network Activity Information
The foregoing pieces of information have been collected about our consumers in the past 12 months.
Sources from which Personal Information is Collected
We collect your identifiers from you directly. We collect your Internet or other electronic network activity information from your interactions with our Site.
Business or Commercial Purposes for which Personal Information is Collected
Your Personal Information is used for the following purposes:
Third Parties with whom Personal Information is Shared
Synchrony shares your Personal Information with analytics and service providers, advertisers, business partners and law enforcement (if necessary).
In the preceding 12 months, we have not sold Personal Information about consumers.
In the preceding 12 months, we have not sold Personal Information about minors.
In the preceding 12 months, we have disclosed the following Personal Information about consumers for business purposes:
Right for You to Access Personal Information Collected, Disclosed, or Sold
You have the right to request that Synchrony disclose the Personal Information it collects, uses, and discloses about you to third parties:
Synchrony does not sell any Personal Information of California Consumers. This information will be provided to you free of charge, unless Synchrony determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period. This Right to Access is subject to certain restrictions and is not available to consumers who have requested information about, applied for, or maintain business credit through Synchrony. Synchrony employees and employees of Synchrony business partners and service providers also do not have a Right to Access under the CCPA.
Right of Erasure
You have the right to request that Synchrony and our service providers erase any Personal Information about yourself which Synchrony has collected from you upon receipt of a verifiable request. This right is subject to the same exceptions as for Right to Access requests.
You can submit your request by calling us at 1-844-894-3960 or visiting our request website at https://www.synchronycredit.com/ccpa/.
Synchrony provides California Consumers with an online webform to submit requests. The webform is accessible at https://www.synchronycredit.com/ccpa/. As stated in the webform, Synchrony must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity. Synchrony reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.
Right to Equal Service
Synchrony will not discriminate against you because you exercised any of your rights, including, but not limited to, by:
This section of our Policy provides certain required information to persons located in the European Union (“EU”), a European Economic Area (“EEA”) member state, or Switzerland. Before Synchrony collects any Personal Information from you, you are entitled under the EU General Data Protection Regulation (“GDPR”), to the information in this section of our Policy.
Purposes and Legal Basis for Processing Personal Information
Synchrony will only process your Personal Information for lawful purposes under the GDPR related to Synchrony’s business purposes arising from your relationship with Synchrony. Synchrony will ordinarily collect and process your Personal Information because it is necessary for the performance of a contract to which you are a party or because Synchrony has another legitimate interest in doing so. When Synchrony cannot rely on either of such legal grounds, it will seek your prior consent.
Rights of Residents of the European Union (EU)
If you use the Site and reside in the EU, EEA, or Switzerland, you are entitled by law to access, correct, amend, or delete Personal Information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions apply.
Right to Withdraw Consent
If Synchrony obtains your written consent to collect and process your Personal Information, you can subsequently withdraw such consent as to any further processing of information by emailing us at firstname.lastname@example.org.
Cross-Border Transfers of Personal Information
Retention of Your Personal Information
We will retain your Personal Information until the Personal Information is no longer necessary to accomplish the purpose for which it was provided. We may retain your Personal Information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, and unauthorized access, as necessary to protect our legal rights, or for certain business requirements.