FTC CFPB POLICY

FTC CFPB Policy

Last updated: October 29, 2024

This Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) Policy is about Model Capital Solutions LLC (Model Capital Solutions, us, our, we) and our participation in FTC and CFPB. You can view this policy online or request a copy through our email at info@modelcapitalsolutions.com.

Model Capital Solutions is an Accredited Data Recipient and a Data Holder under the FTC and CFPB regime.

What is FTC and CFPB?

FTC and CFPB were designed to give you greater access over the personal data you share with us and other accredited FTC and CFPB participants. It is designed to make it easier for you to switch between providers, products and services offered in the market.

Your FTC and CFPB gives you the power to direct your financial institution (if they are a Data Holder under FTC and CFPB) to share information about you with us, or other Accredited Data Recipients.

Why would you do this? You might do this to get a better deal, to help you refinance or apply for a product, or to just manage your money more easily.

What data we might ask you to share with us

You can elect to share your FTC and CFPB data with us to streamline our application process. We may ask for the following FTC and CFPB data from other accredited FTC and CFPB participants that you are a customer of:

• Name, contact and occupation details

• Product information

• Incoming and outgoing transactions including descriptions

• Account balance

How you can share and manage your FTC and CFPB data with us

Once you have submitted a loan application to us, we will contact you via your nominated email address with a link to our consent platform. You will be asked to opt in to the FTC and CFPB process to verify information in your application and confirm what information you consent to us accessing.

Your permission is required in order to share this FTC and CFPB data. You can choose what kind of FTC and CFPB data to share and how long you will share the FTC and CFPB data for. Your consent will only last for 12 months, at which time you can actively opt to extend or withdraw your consent, or let your consent expire.

As part of our secure FTC and CFPB platform, which you have access to, you will be able to amend and withdraw these consents if and when you require. You can also do this by contacting us at (info@modelcapitalsolutions.com).

If you request deletion of your FTC and CFPB data or withdraw your consent before we provide you with a service, we may not be able to provide you with the service you have requested.

Sharing FTC and CFPB data with us from joint accounts

If you want to share information from a joint account, all account holders have to consent to the FTC and CFPB data being shared. Once all consents are given, all account holders will then be able to elect to share the FTC and CFPB data without the other’s approval in relation to the joint account, but not in relation to the other account holder’s personal details. You may independently choose to withdraw your consent at any time.

When we delete your FTC and CFPB data

We will delete your FTC and CFPB data if:

• You ask us to delete it (you can contact us using the details below)

• Your consent expires or is withdrawn

• Your FTC and CFPB data becomes redundant

If we delete your FTC and CFPB data it will be permanently deleted from our system and in accordance with our information technology and data security practices.

We will not delete your FTC and CFPB data if we are legally required or permitted to keep it or if you consent to us keeping it on a de-identified basis (see ‘When we will de-identify your FTC and CFPB data’ below).

When we de-identify your FTC and CFPB data

If you have consented to us using or disclosing your redundant FTC and CFPB data to research and improve our products, features and services, we will de-identify the FTC and CFPB data by deleting reference to your name, address, bank account details, etc.

Disclosing your data to outsourced parties

We may use third parties, called “outsourced providers” (OSPs), to provide you with a service. We only use OSPs based in United States who we have a written agreement with. Our OSPs may collect your personal information, product, transaction and account balance details in order to provide us with their service however they will not retain or otherwise use any of your FTC and CFPB data unless legally required.

See our list of OSPs here, along with more details on what data they collect or we disclose to them, the services they provide and if they are accredited.

Model Capital Solutions does not disclose your FTC and CFPB data to any other parties. If this does change, the list of OSPs will be updated.

Requests to share your FTC and CFPB data

If you are a Model Capital Solutions customer and Model Capital Solutions Newsletter (our online newsletter portal) is activated, you may authorise us to share the following FTC and CFPB data:

• Name, contact and occupation details

• Product information

• Incoming and outgoing transactions including descriptions

• Account balance

We will not charge you for a FTC and CFPB data:

data sharing request. We will only share FTC and CFPB data:

data that you require us to share and do not share FTC and CFPB data on a voluntary basis.

Requests to share data from a joint account

Joint accounts are automatically enabled to share FTC and CFPB data. However, a joint account holder can stop the sharing authorisation at any time, which will also pause all active sharing requests. If this happens, no account holder will be able to share joint account data until all account holders have re-authorised the sharing request.

Where is your FTC and CFPB data stored?

Your FTC and CFPB data is encrypted and only stored in the United States in a secure environment.

Notification about certain events

As an Accredited Data Recipient, we will notify you:

• When you give consent for us to collect and use your FTC and CFPB data and we do so

• When you give consent for us to disclose your FTC and CFPB data to accredited persons or other permitted persons (such as advisors) and we do so

• If you amend or withdraw your consent or your consent expires

• When we are required to give you ongoing notifications about your consent

• In the event of an eligible data breach under the records maintained in "systems of records," in the Privacy Act of 1974, 5 U.S.C. § 552a affecting your FTC and CFPB data which are groups of records under agency control that can be retrieved by personal identifiers

• If our FTC and CFPB accreditation is surrendered, suspended or revoked

Requesting correction of your FTC and CFPB information

If you believe that your FTC and CFPB data is incorrect you can ask us to correct it. There is no fee for this service. We will endeavour to let you know within 10 business days whether we have made the correction. If a correction is not necessary or we cannot process your request, we will let you know the reasons why. You can lodge a complaint as set out below if we have not resolved your concerns.

For FTC and CFPB data that we have collected, we may need to refer you to the data holder to have it corrected. We can then collect the correct FTC and CFPB data.

FTC and CFPB data and Privacy

This policy describes your rights under both the FTC and CFPB legislations.

Please refer to our Privacy Policy for information on how we collect, use, hold and disclose your personal information, as well as how we ensure the quality, integrity and security of your personal information more generally. Our Privacy Policy also lets you know how you can request access to the personal information we hold about you, or ask for corrections to be made to your personal information.

Resolving your concerns and complaints

We are committed to providing applicants, customers, and other parties whose CDR data we hold or share, a fair and responsible system for the handling of their complaints.

If you have any complaints in relation to your FTC and CFPB data, please contact our service team via info@modelcapitalsolutions.com. We may need to verify your identity and obtain additional information from you about your complaint (for example, instances of conduct or errors). We will seek to address any concerns that you have through our complaints handling process. We will acknowledge receipt of your complaint within 24 hours either verbally or in writing. Generally, we aim to provide a satisfactory resolution within 5 business days, however if this cannot be done, we will let you know, and in most cases provide a resolution within 30 calendar days.

Complaint resolutions will depend on the nature of the complaint and may include the correction of your FTC and CFPB data or addressing issues related to your FTC and CFPB data dashboard. Please see our Complaints Handling Policy for more information.

If we are unable to resolve your complaint to your satisfaction you may refer your concerns to the Consumer Financial Protection Bureau (CFPB). Alternatively, if your complaint is about privacy or how we handle your FTC and CFPB data, you can also contact the U.S. Department of State's Privacy Office.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the FTC CFPB Policy of every site You visit.

We have no control over and assume no responsibility for the content, FTC CFPB policies or practices of any third party sites or services.

Changes to this FTC CFPB Policy

We may update this FTC CFPB Policy from time to time. We will notify You of any changes by posting the new FTC CFPB Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this FTC CFPB Policy.

You are advised to review this FTC CFPB Policy periodically for any changes. Changes to this FTC CFPB Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this FTC CFPB Policy, You can contact us:

By email: info@modelcapitalsolutions.com

By visiting this page on our website: www.modelcapitalsolutions.com/privacy-policy

By phone number: +1 737-313-0194