Last Updated: August 31, 2023

Oak Street Funding^® and First Franchise Capital^® (collectively, “First Commercial Finance”) are committed to protecting your privacy and developing technology that gives you the most powerful, safe and secure online experience. This Privacy Policy applies to the First Commercial Finance website, including MyStreet powered by Oak Street Funding, and governs data collection and usage. By using the First Commercial Finance website, you consent to the data practices described in this Policy. Residents of North Dakota, please click here. Residents of California, please click here.

This Privacy Policy does not apply to information collected or used by any third party, or affiliates, including those that can be accessible via the Website. First Commercial Finance encourages you to review the privacy policies of Websites to which you choose to link from First Commercial Finance so that you can understand how those Websites collect, use and share your information. First Commercial Finance is not responsible for the privacy policies or other content on Websites outside of the First Commercial Finance family of Websites.

Before accessing, using, or interacting with the Website you should carefully review this Privacy Policy. We may change our Privacy Policy and Terms of Use from time to time and encourage you to review them whenever you interact with us.

 

User Consent: By choosing to interact with First Commercial Finance, including through our Website and by communicating with us via email, telephone or in person, you consent to the collection and use of information as described in this Privacy Policy and you represent that you are at least 18 years old. If you are under the age of 18 or you do not consent to the collection, use and/or disclosure of your personal information as set forth in this Privacy Policy, please exit and do not use our Website or other applications or services.

First Commercial Finance seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to everyone and, depending upon your jurisdiction, may not apply to you. Residents of North Dakota, please click here. Residents of California, please click here.

 

*Important Information about Procedures for Obtaining a Loan*

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who seeks to obtain a loan.

What this means for you: During due diligence performed for purposes of evaluating whether your loan meets our underwriting criteria, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also request your driver’s license or other identifying documents. We will maintain this information in accordance with the Security of your Personal Information section, below.

 

Collection of your Personal Information

For purposes of this Policy, unless noted otherwise, when we use the term “personal information,” we mean information that identifies, relates to, describes, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular person or household (“personal information”). Personal information” does not include: (i) publicly available information from government records or (ii) de-identified or aggregated consumer information.

First Commercial Finance may collect the following personal information:

• Personally identifiable information, such as your e-mail address, name, home or work address or telephone number.
• Anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.
• Information to fulfill our business obligations to customers of First Commercial Finance, including your credit history, credit score, account balance, loan balance, payment history, as well as sensitive personal information such as your social security number and driver’s license.
• Information collected when you register or update an online profile, which may include personal data such as your name and contact details.
• The content of electronic forms you submit via the Website, requesting us to provide services or information.

 

There is also information about your computer hardware and software that is automatically collected by First Commercial Finance. This information may include: your IP address, browser type, domain names, access times and referring Website addresses. This information is used by First Commercial Finance for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the First Commercial Finance Website.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through First Commercial Finance public message boards, this information may be collected and used by others. Note: First Commercial Finance does not read any of your private online communications.

 

Collection and Use of your Personal Information

First Commercial Franchise collects and stores information that you give us directly. For example, when you:

• Request a quote: we may collect your name, email contact information, phone number, company name, profession, and address.
• Apply for a loan
• Open an account
• Make your monthly payment
• Discussions with Account Manager: we may collect your name, email contact information, phone number, and any other information you choose to provide to us regarding your request.
• Conduct surveys

 

First Commercial Finance collects and uses your personal information to operate the First Commercial Finance Website and deliver the services you have requested. First Commercial Finance also uses your personally identifiable information to inform you of other products or services available from First Commercial Finance and its affiliates. First Commercial Finance may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

First Commercial Finance does not sell, rent or lease its customer lists to third parties. First Commercial Finance may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, First Commercial Finance may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries or permit third parties to use, sell, license, reproduce, distribute and/or disclose de-identified or aggregated, non-personally identifiable data that is derived through your use of certain services. All such third parties are prohibited from using your personal information except to provide these services to First Commercial Finance and you, and they are required to maintain the confidentiality of your information.

First Commercial Finance does not collect sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

First Commercial Finance keeps track of the Websites and pages our customers visit within First Commercial Finance, in order to determine what First Commercial Finance services are the most popular. This data is used to deliver customized content and advertising within First Commercial Finance to customers whose behavior indicates that they are interested in a particular subject area.

If First Commercial Finance purchases other businesses or their assets, sell our business assets, or are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information, including any category of personal data collected by First Commercial Finance, may be among assets sold or transferred and may be subsequently used by a third-party.

First Commercial Finance Websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on First Commercial Finance or the site; (b) protect and defend the rights or property of First Commercial Finance; (c) act under exigent circumstances to protect the personal safety of users of First Commercial Finance, or the public; and (d) meet our obligations under the Gramm-Leach-Bliley Act.

 

Use of Cookies

The First Commercial Finance Website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize First Commercial Finance pages, or register with one of the First Commercial Finance site or services, a cookie helps First Commercial Finance to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same First Commercial Finance Website, the information you previously provided can be retrieved, so you can easily use the First Commercial Finance features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the First Commercial Finance services or Websites you visit.

First Commercial Finance also uses Google Analytics to collect anonymized data points about how visitors use our Website, including the number of visitors to the Website, from where visitors navigated to get to our Website, and the webpages. This information is collected and maintained in an anonymous form and used to compile reports and help us improve our Website. If you choose to opt-out of Google Analytics, you can install a browser add-on in your browser across all websites (please note that First Commercial Finance is not responsible for the content of external websites).

 

Security of your Personal Information

First Commercial Finance secures your personal information from unauthorized access, use or disclosure in the following ways: the information you provide is maintained on computer servers in a controlled, secure environment, with limited access to such servers and password protection for all computers. When personal information (such as a credit card number) is transmitted to other Websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

While we make every effort to secure and protect the information in our possession, and account for the protection of information provided to our third-party service providers through us, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances. Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password(s) and your Account(s), and for all activities that occur under your Account(s). First Commercial Finance specifically reserves the right to terminate your access to your Account(s) and any contract you have with First Commercial Finance related to the use of the Website in the event it learns or suspects you have disclosed your Account or password information to an unauthorized third party.

 

Changes to this Policy

First Commercial Finance will occasionally update this Privacy Policy to reflect company and customer feedback. First Commercial Finance encourages you to periodically review this Policy to be informed of how First Commercial Finance is protecting your information.

 

Contact Information

First Commercial Finance welcomes your comments regarding this Privacy Policy. If you believe that First Commercial Finance has not adhered to this Policy, please contact First Commercial Finance by mail or e-mail:

Attn: Legal

8888 Keystone Crossing, Suite 1700

Indianapolis, IN 46240

Robert.Burt@oakstreetfunding.com

We will use commercially reasonable efforts to promptly determine and remedy the problem.