V1.1
Privacy Policy
Zing America, Inc., d/b/a Coign (“Coign” or the “Company”) ("Coign," the “Company,” "we," "us"
and/or "our") is dedicated to protecting your personal information and informing you about how
we use it. This privacy policy (the "Privacy Policy" or the "Policy") is intended to provide
information to our visitors and users ("you" or "your") about how we collect, protect, share and
use your information when you use the Coign website, www.coign.com, including any subdomain
thereof (the “Website”), the Coign mobile application (the “App”) and/or products and services
offered, operated or made available by, or through, the Company (the Website, App and products
and services of Coign are collectively referred to as the "Services". Reference to the Services
includes any portion of the Services). Any capitalized term that is not defined in this Privacy Policy
shall have the meaning given to it in the Terms of Use. This Privacy Policy outlines how and when
Coign collects, protects, shares, and uses information that can identify you individually ("Personal
Information"), such as your name, email or telephone number. Personal Information does not
include information that is anonymous, aggregated, or can no longer be used to identify you as
an individual. Additional privacy rights and notices apply if you are a California resident. See the
section below called Your California Privacy Rights for more information about your rights under
California law.
Your use of our Website or App may include, but is not limited to, your requests for financial
products or services provided by third parties, such as MRV Banks (the “Issuing Bank”).
Information you provide through the Website or App to MRV Banks, or to us when we are acting
as a service provider of MRV Banks, will be governed by the MRV Banks’ Financial Privacy
Notice.
This Privacy Policy covers the privacy practices of Coign only. This Policy does not apply to the
practices of third party websites, services or applications, including MRV Banks or other third
parties with which we contract. These third party services are governed by each such third party’s
privacy policy. Coign is not responsible for the privacy policies and practices of websites other
than that of Coign, and Coign is not responsible for the failure of unaffiliated third parties to honor
their privacy obligations.
We may amend this Privacy Policy at any time by posting a revised version on our Website and
the App. The revised version will be effective at the time we post it.
Acceptance of Privacy Policy
By using the Website or App, you signify your acceptance of this Privacy Policy. If you do not
agree to the terms of this Privacy Policy, please do not use the Website or App. Your continued
use of the Website or App following the posting of changes to these terms will mean that you
accept those changes.
If you breach or violate the rules, restrictions, limitations, terms and/or conditions that apply to the
Website, the App or in connection with the Services, or otherwise communicated to you, Coign
may terminate, discontinue, suspend and/or restrict your ability to access, visit, and/or use the
Website, App and the Services, with or without notice. Coign may further restrict or refuse to
provide you with any future access and/or use of the Services. Finally, Coign reserves the right
V1.1
to take any technical, legal and/or other actions that it deems necessary and/or appropriate, with
or without notice.
Information We Collect About You and How We Collect It
We collect certain information from and about visitors and users of our Website, including:
● Information by which you may be personally identified, such as your name, social security
number, phone number, and other contact details;
● Information about your internet connection, the equipment and devices you use to access
our Website, the dates and times you use the Website, and other Website usage;
● payment information you provide; and
● any other information you may provide to us voluntarily through your use of our Services.
We collect this information:
● Directly from you when you provide it to us through the Website;
● Automatically as you navigate the Website, including IP addresses, and information
collected through cookies and other tracking technologies; and
● From third parties, for example, financial institutions with whom we contract to provide
financial services and other non-financial institution service providers.
Information You Provide To Us
The information we collect on or through our Website includes:
● Information you choose to provide to us when you use the Website to request or obtain
our Services or otherwise interact with us, which may include your name, residential
address, email address, date of birth, phone number, and income information (together,
your “Personal Information”);
● Information we may request from you if you enter a contest or promotion we sponsor or
when you report a problem with our Website;
● Records and copies of your correspondence with us,if you contact us; and
● Details of transactions and search queries you may carry out through the Website.
How We Use Information
In general, Coign uses information we collect through the Website to:
● Provide products and services you request;
● Improve our offerings to you, including to develop new products and services;
● Communicate with you or provide notices in connection with such products and services;
● Process and respond to customer inquiries and provide support;
● Detect security incidents and prevent fraud and illegal activities;
● Fulfill our legal requirements and enforce our agreements;
● Improve Website content, functionality, and usability;
V1.1
● Communicate with you, either directly or through our service providers, including for
marketing and promotional purposes;
● Improve our marketing and promotional activities; and
● For our other legitimate business purposes permitted by law.
The information collected in connection with a financial product or service provided by the Issuing
Bank may be used (as applicable) to:
● Generate your borrower profile or process your loan or account application on behalf of
the Issuing Bank;
● Enable automatic payments and fund transfers with other financial institutions; and
● Communicate with you concerning your account and transactions.
Information We Share
We may disclose aggregated information about our users, and information that does not identify
any individual, without restrictions.
Unless otherwise stated, we may disclose Personal Information that we collect or you provide as
described in this Privacy Policy:
● To our affiliates;
● To our Issuing Bank that you request an offer of credit from or who declines to approve
you for a loan when you request a loan offer;
● To our service providers, contractors, and other third parties who support our business
operations;
● To fulfill the purpose for which you provide any Personal Information;
● For any other purpose we disclose when you provide any Personal Information; and
● With your consent.
We may also disclose Personal Information:
● To law enforcement, government officials, or other third parties when (1) we are compelled
to do so by a subpoena, court order or similar legal procedure, (2) we need to do so to
comply with law, or (3) if we believe in good faith that the disclosure of your personal
information is necessary to prevent physical harm or financial loss or to report suspected
illegal activity;
● To enforce or apply the terms of this Privacy Policy and other agreements between you
and us, including for billing and collection purposes; and
● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety
of Coign, our service providers, our customers, or others.
Coign will not sell or rent any of your personal information to third parties and only shares your
personal information with third parties as described above.
How We Protect Information
No method of transmission over the Internet or electronic storage is 100% secure, however we
V1.1
care about the security of your information and take reasonable measures designed to protect
your personal information from unauthorized access and use by maintaining physical, electronic
and procedural safeguards in compliance with applicable law. These measures include computer
safeguards and secured files and buildings.
You are responsible for maintaining the secrecy of your unique password and account
information, and for controlling access to your email communications from us at all times.
However, we cannot ensure or warrant the security of any information you transmit to us or
guarantee that information may not be accessed, disclosed, altered or destroyed. By using our
Website and/or Services, you agree to assume all risk in connection with the information sent to
us or collected by us when you access, visit, and/or use the Service. This includes, without
limitation, any personally identifiable information that you provided to Coign. Coign and the Issuing
Bank are not responsible for any loss of such information or the consequences thereof.
In the event that any information under our control is compromised as a result of a breach of
security, we will take reasonable steps to investigate the situation and where appropriate, notify
those individuals whose information may have been compromised and take other steps, in
accordance with any applicable laws and regulations.
Third Party Websites
This policy only applies to our website. Our Services may contain links to other websites, apps
or online services not operated or controlled by Coign (“Third Party Sites”). The policies and
procedures described here do not apply to Third Party Sites. By providing links to Third Party
Sites or services we do not imply that we endorse or have reviewed such websites or services.
We suggest that you contact those sites directly for information about their data practices and
policies and we encourage you to read their privacy policies before providing any information to
them.
Do Not Track Signals
Our Website currently does not respond to “Do Not Track” (“DNT”) signals and operates as
described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future,
we will describe how we do so in this Privacy Policy.
Children’s Privacy
This Website is not intended for children or minors under the age of 18. We do not knowingly
collect personal information from, or market to, children under the age of 13. If we become aware
that a child under the age of 13 has provided us with personal information, we will take steps to
comply with applicable legal requirements to remove such information.
Your California Privacy Rights
This section provides additional details about the personal information we collect about California
consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”).
Personal information does not include publicly available information from government records;
V1.1
deidentified or aggregated consumer information; and information governed by the federal
Gramm-Leach-Bliley Act (GLBA), the federal Fair Credit Reporting Act, the California Financial
Information Privacy Act, or the Driver’s Privacy Protection Act.
In the last 12 months, we may have collected the following categories of personal information:
identifiers (such as name and contact information), demographic information (such as age and
gender), commercial information (such as products purchased), internet or other electronic
network activity information (such as browsing behavior), geolocation data, audio, electronic,
visual or similar information (such as customer support calls), and inferences we make (such as
preferred activities).
We may use or disclose the personal information we collect for one or more of the following
purposes:
● To fulfill or meet the reason you provided the information. For example, if you share your
name and contact information to request a price quote or ask a question about our
products or services, we will use that personal information to respond to your inquiry. If
you provide your personal information to purchase a product or service, we will use that
information to process your payment and facilitate delivery. We may also save your
information to facilitate new orders or process transactions.
● To provide, support, personalize, and develop our Website, products, and services.
● To create, maintain, customize, and secure your account with us.
● To process your requests, purchases, transactions, and payments and prevent
transactional fraud.
● To provide you with support and to respond to your inquiries, including to investigate and
address your concerns and monitor and improve our responses.
● To personalize your Website experience and to deliver content and product and service
offerings relevant to your interests, including targeted offers and ads through our Website
and via email or text message (with your consent, where required by law).
● To help maintain the safety, security, and integrity of our Website, products and services,
databases and other technology assets, and business.
● For testing, research, analysis, and product development, including to develop and
improve our Website, products, and services.
● To respond to law enforcement requests and as required by applicable law, court order,
or governmental regulations.
● As described to you when collecting your personal information or as otherwise set forth in
the CCPA.
● To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of our assets, whether as a going concern or as part
of bankruptcy, liquidation, or similar proceeding, in which personal information held by us
about our Website users and consumers are among the assets transferred.
We will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing you
notice.
Subject to certain exemptions, the CCPA provides California consumers the following rights:
Right to Know and Data Portability
V1.1
You have the right to request that we disclose certain information to you about our collection
and use of your personal information over the past 12 months (the “right to know”). Once we
receive your request and confirm your identity (see Exercising Your Rights to Know or
Delete), we will provide you with required information.
Right to Delete
You have the right to request that we delete any of your personal information that we collected
from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your
request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review
your request to see if an exception allowing us to retain the information applies. We may deny
your deletion request as allowed by law.
We will delete or deidentify personal information when required by law and will direct our service
providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
Emailing us at: help@coign.com; or
Writing us at: 9812 Falls Road #114-287, Potomac, MD 20854-3963
We cannot respond to your request or provide you with personal information if we cannot verify
your identity or authority to make the request and confirm the personal information relates to
you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or
authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive
confirmation within the 10-day timeframe, please contact us using the contact information
included in the section above called Exercising Your Rights to Know or Delete.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45)
days of its receipt. If we require more time (up to another 45 days), we will inform you of the
reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not
have an account with us, we will deliver our written response by mail or electronically, at your
option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your
request. The response we provide will also explain the reasons we cannot comply with a
request, if applicable. For data portability requests, we will select a format to provide your
V1.1
personal information that is readily useable and should allow you to transmit the information
from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee,
we will tell you why we made that decision and provide you with a cost estimate before
completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by
the CCPA, we will not:
● Deny you goods or services.
● Charge you different prices or rates for goods or services, including through granting
discounts or other benefits, or imposing penalties.
● Provide you a different level or quality of goods or services.
● Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
We do not sell the personal information we collect.
California consumers may make a rights request by contacting us at the information below.
For Nevada Residents
Nevada residents have the right to opt out of the sale of certain pieces of their information. We do
not sell “personal information” of Nevada residents, but, if you are a Nevada resident who has
questions or who wants to make this type of request, please send an email to help@coign.com.
Changes to this Policy
Coign may revise this Policy from time to time without prior notice to you, and any changes will
be effective immediately upon the posting of the revised Privacy Policy on the Website and the
App. You should bookmark and periodically review this page to ensure that you are familiar with
the most current version of this Policy. You can determine when this Policy was last revised by
checking the "Last Updated" legend at the top of the Policy.
Questions about this Policy
If you have any questions or concerns about this Policy, you can contact us at:
Coign
help@coign.com
833-690-2471
The following Privacy Notice applies if you request or receive a financial product or service
through Coign.
V1.1
Coign Financial Privacy Notice
F A C T S
WHAT DOES COIGN DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information.
Federal law gives consumers the right to limit some but not all sharing.
Federal law also requires us to tell you how we collect, share, and protect
your personal information. Please read this notice carefully to understand
what we do.
What?
The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
▪ Social Security number and income
▪ Account balances and account transactions
▪ Credit history and credit scores
When you are no longer our customer, we continue to share your
information as described in this notice.
How?
All financial companies need to share customers’ personal information to
run their everyday business. In the section below, we list the reasons
financial companies can share their customers’ personal information; the
reasons Coign chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does Coign share?
Can you limit this
sharing?
Yes
No
Yes
No
No
We don’t share
No
We don’t share
No
We don’t share
No
We don’t share
No
We don’t share
Questions?
Call (833) 690-2471 or go to coign.com
V1.1
Page 2
Who we are
Who is providing this notice?
Zing America, Inc., doing business as Coign (“Coign”)
What we do
How does Coign protect my
personal information?
To protect your personal information from unauthorized
access and use, we use security measures that comply with
federal law. These measures include computer safeguards
and secured files and buildings.
How does Coign collect my
personal information?
We collect your personal information, for example, when you
▪ Open an account or give us your income information
▪ Provide account information or give us your contact
information
▪ Pay us by check
We also collect your personal information from others, such as
credit bureaus, affiliates or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
▪ sharing for affiliates’ everyday business purposes –
information about your creditworthiness
▪ affiliates from using your information to market to you
▪ sharing for nonaffiliates to market to you
State laws and individual companies may give you additional
rights to limit sharing.
Definitions
Affiliates
Companies related by common ownership or control. They can
be financial and nonfinancial companies.
▪ Coign has no affiliates.
Nonaffiliates
Companies not related by common ownership or control. They
can be financial and nonfinancial companies.
▪ Coign does not share with nonaffiliates so they can market
to you.
Joint Marketing
A formal agreement between nonaffiliated financial companies
that together market financial products or services to you.
▪ Coign does not jointly market.