Privacy Policy

Draft for compliance review by Masha. Effective date: [EFFECTIVE DATE]

CashOtter is operated by [LEGAL ENTITY NAME]. Mailing address: [MAILING ADDRESS].

1. Scope and responsibility

This Policy describes how [LEGAL ENTITY NAME], operating as CashOtter, handles personal information through this website, referral requests and optional request-related texts. CashOtter is an advertising and referral service, not a lender. Independent lenders and our lender-network partner have their own privacy practices; review their notices when your request is referred or you visit their websites.

2. Information we collect

Information you enter: name, email address, mobile phone, home address, city, state, ZIP code, date of birth, Social Security number, driver's license or state ID information, military status, requested amount, employment and income information, income source, employer and work phone, pay frequency and next pay date, direct-deposit preference, residence and employment duration, bank name, checking-account routing and account numbers, and time with your bank. We collect the form values you choose to enter and consent choices you make.

Request and consent records: session and request identifiers, landing-page variant, progress step, submission outcome, referral response identifiers, selected tracking parameters and consent text, version, choice and timestamps. We save limited progress once an email or phone is known so the form and optional reminders can use it.

Device and advertising information: IP address, browser user-agent information, source URL and advertising parameters such as campaign tags and click identifiers. Cookies and browser storage may contain session, saved-form, attribution and privacy-choice data. When configured and not suppressed by Global Privacy Control, Meta tools may collect page views, form interactions and referral-completion events as explained below.

Communications: information you provide when contacting support or replying to texts, and delivery, opt-out and provider message records used to operate the text program.

3. How we use information

We use information to check the request's completeness and service area, transmit permitted requests for lender review, prevent duplicate submissions, return request results, save limited progress, operate optional request-related texts, record permissions and opt-outs, measure referral activity, troubleshoot the service and respond to support or privacy requests. We do not make underwriting or credit decisions.

We use contact hashes to apply opt-outs and text-frequency limits. Hashing transforms a contact value; it does not mean all associated records are anonymous.

4. Lender-network sharing and service providers

We share the details you enter with our lender-network partner and the lenders in its network, which California law treats as a sale. You can opt out on the Do Not Sell page. One or more lenders may review a permitted request, and you may be sent to a lender that can continue. Data sent for review includes contact, identity, income and bank information, including the Social Security number and bank details necessary for that review.

Service providers supporting hosting, storage, technical operations and text delivery process the information needed for those services. Our text delivery provider receives the destination number and message for delivery. We may disclose information when legally required, to respond to lawful process, or to protect rights and service security, subject to applicable law. We do not characterize lender-network recipients as mere website service providers.

5. SMS / text message privacy

Mobile numbers and text message opt-in data and consent are not shared with or sold to any third parties or affiliates for marketing or promotional purposes.

The separate CashOtter text checkbox authorizes only our request-related text program. We retain its exact wording, version, timestamp and whether it was checked, separately from lender-network TCPA permission. Text delivery providers may process the mobile number and consent information as needed to provide the program, not for their own marketing.

Your mobile number is also a contact field in a referral request. If you separately authorize a lender-network request, the number and the separate lender contact choice are included for request review and permitted request-related contact; our CashOtter text opt-in is not passed as lender marketing permission. This does not authorize selling our text-program opt-in to others. Any separate lender-network contact permission is presented independently in the form.

Reply STOP to cancel at any time; reply HELP for help, or contact support@cashotterloans.com. An unchecked or withdrawn CashOtter text choice does not authorize reminders. We retain suppression records to honor cancellations and avoid repeated messages. See the SMS / Text Message Terms for program details.

6. Cookies, browser storage and Meta

The website uses browser storage for session identifiers, attribution and optional saved-form progress. Saved-form storage excludes your full Social Security number and full bank routing and account numbers. Browser settings can restrict cookies or storage; doing so may affect saved progress and attribution.

The Meta pixel and Conversions API operate only when both required settings are configured. When enabled, the pixel records PageView, FormStart and Lead events; the server may send a Lead event with an event identifier, source URL, IP address, user agent, advertising click and browser identifiers and hashed email and phone for matching. A Lead event records referral completion, not credit approval. Meta may use these data under its own privacy terms. These integrations are suppressed when Global Privacy Control is detected.

We use PostHog to understand how visitors use this site. It records page views, clicks and which step of the form was reached, never the answers you type, and it does not run if your browser sends a Global Privacy Control signal or you opt out.

We do not represent that the website implements every browser Do Not Track signal. We specifically honor supported Global Privacy Control signals as described below.

7. California privacy rights and other choices

Subject to eligibility and applicable exceptions, California residents may request access to or knowledge of personal information, correction of inaccurate information, deletion, and information about disclosure, sale or sharing. They may opt out of sale or sharing and exercise applicable rights regarding sensitive personal information. We do not discriminate for exercising legally protected rights.

Submit sale or sharing opt-outs through the Do Not Sell or Share My Personal Information page. It records hashed email or phone preferences. A stored opt-out or a Global Privacy Control signal on a request prevents that request from being sent to our lender-network partner. Opting out does not recall data already transmitted. A new referral cannot be processed while the relevant sharing restriction applies.

For access, correction, deletion, sensitive-information requests or an authorized-agent request, contact support@cashotterloans.com. We may need proportionate information to verify identity and authority before acting. The website's opt-out form is not an automated access or deletion service. Rights in other states may apply to you; contact us to exercise them. Applicable legal exceptions and response requirements govern our handling of requests.

8. Retention

We retain request records, limited abandoned-form progress, consent evidence, delivery records and suppression hashes as needed for referral administration, consent accountability, fraud prevention, support and applicable legal requirements. The website does not currently enforce an automatic deletion schedule for these server records; this Policy does not promise deletion after a fixed number of days. Browser-saved form progress has a seven-day expiry check, but that does not establish a server-record retention period.

We do not retain full Social Security numbers, full license numbers or full bank numbers in our lead-attempt records. Those values are used for a permitted referral transmission; retained operational copies redact them, and stored bank references contain only last-four digits. Recipients may retain transmitted data under their own policies.

9. Security

We use HTTPS for website transmission and server-side access restrictions for operational records. Sensitive numbers are excluded or redacted from retained lead records as described above. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Do not send Social Security or full bank numbers by email or text when contacting support.

10. Children and external websites

The service is intended for adults aged 18 or older and is not directed to children. We do not knowingly seek information from children under 13. If you believe a child has provided information, contact us so we can review and take appropriate action. Linked lenders and other external websites have their own policies, which are not controlled by this Policy.

11. Changes and contact

We will identify the effective date of the final Policy and subsequent changes. Any materially different use of information remains subject to applicable notice and consent requirements. This draft awaits compliance review and does not assert a finalized legal identity or effective date.

Contact [LEGAL ENTITY NAME] at support@cashotterloans.com, telephone [SUPPORT PHONE], or by mail at [MAILING ADDRESS]. For questions about a loan, contact the lender using your loan agreement.