Privacy Policy

1. Introduction                          

This Consumer Privacy Policy (“Policy”) is provided by Congruit, Inc. (“we,” “us,” or “our”). We are a “nationwide specialty consumer reporting agency” as defined by Section 603(x) of the Fair Credit Reporting Act (FCRA). This means we collect and maintain specific types of consumer information on a nationwide basis to furnish consumer reports to third parties for permissible purposes, such as credit history (including banking details and loan repayment history).

The purpose of this Policy is to explain how we collect, use, share, and protect your personal information in compliance with federal and state law. We are committed to handling your information responsibly and transparently. This Policy outlines your privacy rights under federal laws like the FCRA and the Gramm-Leach-Bliley Act (GLBA), as well as certain state privacy laws.

2. Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you (“Personal Information”). As a consumer reporting agency, much of the information we collect is considered “consumer report information.” The categories of information we collect include:

  • Personal Identifiers: Such as your full name, alias, postal address, email address, telephone number, Social Security number, driver’s license number, and date of birth.

  • Consumer Report Information: This includes information bearing on your creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. Depending on the specialty nature of our agency, this may include:

  • Banking Details (e.g. number of accounts, whether those accounts are considered in good standing)

  • Payment Instrument Types (e.g. secured vs. unsecured credit cards, check writing history)

  • Tradelines (e.g. the number of accounts a consumer has, if those accounts are open or closed, current or in default, etc.)

  • Other Information: Any other information you provide directly to us, for example, when you contact us to dispute information in your file.

3. How We Collect Information

We collect Personal Information from various sources to ensure the accuracy and completeness of our consumer reports. These sources include:

  • Data Furnishers: We receive information from businesses that provide us with data, such as creditors or other CRAs (credit reporting agencies).

  • Public Records: We gather information from publicly available sources, including federal, state, and local courts and government agencies.

  • Our Clients: We may receive information from our clients (the users of our consumer reports) when they request a report.

  • From You, the Consumer: We collect information directly from you when you contact us to request a copy of your file, dispute information, or exercise your legal rights.

4. How We Use Your Information                 

Our primary use of your information is to compile it into consumer reports that we furnish to our clients for specific, legally defined "permissible purposes" under Section 604 of the FCRA. These purposes include, but are not limited to:

  • In response to a court order or federal grand jury subpoena.

  • In accordance with your written instructions.

  • For use in connection with a credit transaction involving the extension of credit to, or review or collection of an account of, the consumer.

  • For employment purposes, including hiring, promotion, reassignment, or retention decisions.

  • For the underwriting of insurance involving the consumer.

  • To determine your eligibility for a license or other benefit granted by a governmental instrumentality required by law to consider an applicant’s financial responsibility or status.

  • For use by a potential investor or servicer, or a current insurer, in a valuation or assessment of the credit or prepayment risks associated with an existing credit obligation.

  • For a legitimate business need in connection with a business transaction that is initiated by you, the consumer.

We also use your information for internal purposes, such as to maintain and operate our databases, ensure data security and integrity, and comply with our legal and regulatory obligations.

5. Information We Share and Disclose                 

We share and disclose your information by furnishing consumer reports to third parties who have a permissible purpose under the FCRA. The categories of third parties with whom we may share your information include:

  • Creditors and Lenders: For decisions related to extending credit.

  • Employers and Background Screening Companies: For employment screening, subject to your consent.

  • Insurers: For underwriting insurance policies.

  • Landlords and Property Management Companies: For tenant screening.

  • Government Agencies: As required by law or for determining eligibility for certain benefits.

  • Other Third Parties: To others who have a legitimate business need for the information in connection with a transaction initiated by you.

 

Disclosures Under the Gramm-Leach-Bliley Act (GLBA): The GLBA permits us to share your nonpublic personal information with non-affiliated third parties as permitted by law, including for purposes consistent with the FCRA. We do not sell your information to third parties for their own independent marketing purposes.

6. Your Rights Under the FCRA

 As a consumer, you have specific rights under the Fair Credit Reporting Act. We are committed to upholding these rights. 

  • You must be told if information in your file has been used against you.  Anyone who uses a consumer report to take adverse action against you, such as denying your application for credit, insurance, or employment, must tell you and must give you the name, address, and phone number of the agency that provided the information.

  • You have the right to know what is in your file.  You may request and obtain all the information about you in our files (your "file disclosure").

  • You have the right to dispute incomplete or inaccurate information.  If you identify information in your file that is incomplete or inaccurate, and you notify us directly, we must investigate unless your dispute is frivolous.

  • Consumer reporting agencies must correct or delete inaccurate, incomplete, or unverified information.  If our investigation reveals that the disputed information is inaccurate, incomplete, or cannot be verified, we must delete or modify it, typically within 30 days.

  • Your consent is required for reports to be provided to employers.  A consumer reporting agency may not provide a report to your employer, or a potential employer, without your written consent.

  • You may limit “prescreened” offers of credit and insurance you get based on information in your credit report.  You may opt-out of receiving such offers by calling toll-free 1-888-5-OPTOUT (1-888-567-8688) or visiting www.optoutprescreen.com (please note that this contact information is for opting out with the “Big Three” [Experian, Equifax, and TransUnion].  To opt-out with Congruit Inc, please contact us directly).

  • You may seek damages from violators.  If a consumer reporting agency, a user of consumer reports, or a furnisher of information violates the FCRA, you may be able to sue in state or federal court.

  • Identity theft victims and active duty military personnel have additional rights.  For more information, please visit the website of the Consumer Financial Protection Bureau (CFPB) at `www.consumerfinance.gov/learnmore`.

 To exercise any of these rights, please contact us using the information in Section 10 below.

7. Your Rights Under State Privacy Laws

Certain states have enacted comprehensive privacy laws that may grant you additional rights regarding your Personal Information. These laws include the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA).

Disclaimer:  The rights described below are subject to your state of residence and certain legal exemptions. Notably, most information collected, maintained, and disclosed by us as a consumer reporting agency is exempt from these state laws because it is governed by the FCRA. However, to the extent we process any Personal Information that falls outside the scope of the FCRA, you may be able to exercise the following rights.

  • Right to Know/Access: You may have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you.

  • Right to Correct: You may have the right to request the correction of inaccurate Personal Information we maintain about you.

  • Right to Delete: You may have the right to request the deletion of your Personal Information, subject to certain exceptions.

  • Right to Opt-Out of Sale/Sharing: You may have the right to opt-out of the "sale" or "sharing" of your Personal Information for cross-context behavioral advertising.

  • Right to Limit Use of Sensitive Personal Information: You may have the right to limit our use and disclosure of your sensitive Personal Information to specific purposes defined by law.

  • Right to Non-Discrimination/No Retaliation: We will not discriminate or retaliate against you for exercising any of your privacy rights.

To finalize this section and determine which rights apply to you, please provide us with your state of residence. You may exercise any applicable rights by contacting us using the information provided in Section 10.

8. Data Security

We have implemented and maintain a comprehensive information security program with administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of your Personal Information. We restrict access to your information to only those employees, agents, and clients who have a legitimate business need to know it. We train our employees on the importance of confidentiality and data security.

9. Data Retention

We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, to provide our services, to comply with our legal obligations under the FCRA and other applicable laws, to resolve disputes, and to enforce our agreements. Retention periods are determined by legal and regulatory requirements.

10. Contact Information

If you have any questions about this Privacy Policy, or if you wish to exercise your rights under the FCRA or other applicable privacy laws, please contact at:

Congruit Inc

Attn: Compliance Team

1703 McMullen Booth Rd, #207 

Safety Harbor, FL 34695

11. Changes to This Policy                                

We may update this Privacy Policy from time to time to reflect changes in our business practices or legal requirements. If we make material changes to this Policy, we will notify you by posting the updated policy on our website and updating the "Effective Date" at the top of this page. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.