Privacy Policy

This Privacy Policy (the "Policy") applies to the Seashine Financial, LLC, its parents, affiliates and subsidiaries.  The Policy describes the treatment of information that is provided by you or collected through any of our online interfaces to which a copy of the Policy is posted, including www.seashinefinancial.com (the “Website”), modules we have placed on third party sites, other social media services and Seashine’s mobile applications (the “Applications,” and together with the “Website,” the “Services”). It also explains how we collect, use and share information based on users’ interactions with online advertisements, both on the Services and on online interfaces owned by third parties, or through other means of digital and nondigital communication. 

1. GENERAL PROVISIONS

1.1 Data Security.  Your privacy is very important to Seashine, and we are committed to protecting your personal information from unauthorized access or use. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

1.2 Preventing Identity Theft. In order to help us protect your personal information, it is important that you always keep your account information safe. We recommend that you not share your username, password, or PIN with anyone.

Seashine will never initiate  a request for you to email your sensitive information (e.g., taxpayer identification number, username, password, PIN or account number). If you receive an email asking for your sensitive information, you should be suspicious of the request and promptly contact us to report the suspicious activity.

Please be aware, however, that in certain telephone transactions we may ask for your taxpayer identification number, account number, one time PIN, or other information to verify your identity before conducting the transactions you have requested.  We will never request that you disclose your personal ID, password or PIN under any circumstances.

Additional information regarding identity theft and the steps you can take to help protect yourself from fraud can be found on the Federal Trade Commission website.

1.3 Children’s Privacy.  We do not use the Services to knowingly solicit personal information from or market to children under the age of eighteen (18). We request that such individuals do not provide personal information through the Services. If a parent or guardian becomes aware that his or her child has provided us with information, he or she should promptly contact us, and we will delete such information from our files. For additional information regarding the Children's Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website.

1.4 Credential Privacy.  You have the responsibility to help us protect your accounts. If you reveal your username, password, or other credentials to any person or third party, you authorize that person or third party to initiate changes to your Account and grant them access to all stored sensitive personal information.

1.5 Social Media Platforms.  Seashine may interact with registered users of various social media platforms. Please note that any content you post to such social media platforms (e.g., pictures, information or opinions), as well as any personal information that you otherwise make available to users (e.g., your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review this information carefully in order to better understand your rights and obligations with regard to such content.

1.6 Retention Period.  We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required by law.

1.7 Cross-Border Transfer. Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any country or territory other than that of the United States. We may store and process your personal information in any country where we have facilities or in which we engage service providers, and, by using such Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

1.8 State Privacy Laws. In addition to the federal laws concerning the collection and use of personal information that are applicable to financial institutions, some states have privacy laws and regulations that supplement these federal laws and provide additional rights to citizens of those states. For information regarding those state laws and the procedures that Seashine has in place to comply with those laws, please go to the “State Privacy Notice” link.

1.9 Changes to Seashine’s Privacy Policy.  From time-to-time, we may make changes to this Policy in order to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We encourage you to review the Policy periodically to ensure that you understand how we collect, use and share information through the Services. If we do make changes to the Policy, we will let you know by posting the revised Policy with a new "Last Updated” date posted at the top of the Policy.

Any changes to the Policy will become effective when the revised Policy is posted on the Website, relevant Application or other Seashine online interface, as applicable. By continuing to use the Services following such changes, you are agreeing to accept the terms of any revised Privacy Policy.

1.10 Conveyance of Information.  It is possible that Seashine, its subsidiaries, affiliates, joint venture companies, or any combination of them, could merge with or be acquired by another legal entity. In such event, or in the event of any other proposed or actual purchase, sale (including a liquidation, realization, foreclosure, or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance, or financing of all or any portion of Seashine or of any of the business or assets or shares of Seashine or a subsidiary or division thereof, Seashine may share your information with third parties. You will have the opportunity to opt out of any such transfer if, in our discretion, the new entity plans to handle your information in a way that differs materially from this Privacy Policy. 

1.11 Linked Websites. The Services may contain links to third-party websites not controlled by Seashine. We encourage you to be aware when you leave the Services and to read the privacy policies and terms of use of any such websites that may collect your personal information as they will likely differ from those of the Services. Seashine does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness or reliability of their information.

In addition, Seashine is not responsible for the information collection, use and disclosure practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer or provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.

2. COLLECTION OF INFORMATION

2.1 Types of Information We Collect.  We collect two basic types of information through the Services: personal information and anonymous information. 

"Personal information" refers to information that identifies (whether directly or indirectly) a particular individual, such as information you provide on our forms, surveys, applications or similar online fields. Examples may include your name, postal address, email address, telephone number, Social Security number, date of birth or account information.

"Anonymous information" means information that does not directly or indirectly identify you and cannot reasonably be used to identify you as a particular individual. Examples may include information about your Internet browser, information collected through tracking technologies such as location information, demographic information that you provide to us (e.g., your household income) and aggregated or de-identified data.

2.2 How We Collect Your Personal Information.  We collect personal information from you or about you when you provide this information to us directly. For example, we may obtain personal information when you: i) request information, products or services from us; ii) register for an account on our website; iii) submit an application for services; iv) respond to surveys;  v) contact account support; or vi) otherwise interact with us. We may also receive information about you from other online and offline sources that you connect to your account with us, such as social media platforms and other third parties.

If you submit any personal information relating to other people, whether to us  or to our service providers, in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.

2.3 How We Collect Your Anonymous Information.  We and certain trusted service providers operating on our behalf, may collect information about your activity on the Services using tracking technologies, including:

Cookies.  Cookies are pieces of information that are stored directly on the device that you are using. They allow us to collect information such as the type of browser you are using, the amount of time you spend using the Services, the websites or applications you visit and the preferences you have set up for your accounts. We use this information to personalize your experience, enhance security, facilitate navigation, display material more efficiently, recognize the device that you are using to access the Services and understand how the Services are used. The Services do not use cookies that capture unencrypted personal information about you.

Pixel tags, web beacons, clear GIFs and other similar technologies. These are typically small pieces of data that are embedded in images on the Website, our Applications, advertising, or certain email communications. They may involve the transmission of information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We may use these technologies to bring together other anonymous information we collect about you.

Location tracking on mobile devices. Certain applications on mobile devices may transmit information to us about your location. An example includes your physical location when you navigate our Services using your mobile device. We may use that information to improve the products and services we provide to you as well as improving our services generally in your area.

Browser or Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the Application) you are using. We use this information to ensure that the Services function properly.

Application Information. When you download and use an Application, we and our service providers may track and collect usage data, such as the date and time the Application on your device accesses our servers and what information and files have been downloaded to the Application based on your device number.

IP Address. Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, helping diagnose server problems, administering the Services, for analytics purposes and to deliver personalized advertisements. For advertising and analytics purposes, we may share your IP address with third-party advertising partners.

2.4 Other Technologies.  We may use other technologies, such as the capture of screenshots while you are using the Services, to understand how you navigate and use the Services. This information helps us to better understand how the Services are used and how to improve them.

We may associate this tracking data with any personal information you provide, in which case we will treat it as personal information.

3. HOW WE USE YOUR INFORMATION

3.1 How We Use Personal Information That We Collect.  We may use information that we collect in order to, among other things:

• Provide you with, or evaluate your eligibility for, products and services that you request from us.
• Communicate with you about your accounts or transactions with us.
• Send you important information regarding the Services, changes to this Policy and/or other similar administrative information.
• Allow you to participate in surveys, sweepstakes, contests and similar promotions, and to administer such promotions (note that these promotions may contain additional disclosures regarding our collection and/or use of your information).
• Consistent with local law, required disclosures, and choices and controls that may be available to you: i) send you offers and promotions for our products and services, or products and services that may be of interest to you; ii) personalize content and experiences on the Services; iii) provide you with advertising based on your activity on the Services and on third-party websites and applications.
• Verify your identity and/or location (or the identity or location of your authorized representative) for security, fraud prevention and other risk control purposes.
• Optimize or improve our products and services.
• Detect, investigate and prevent activities that may violate our policies or be illegal.
• Comply with our legal and regulatory obligations.
• Enforce our Terms and Conditions and otherwise protect our rights and operations.

3.2 How We Use Anonymous Information.  Information collected through tracking technologies is used for many purposes including, for example, to:

• Provide useful features to simplify your experience when you use or return to the Services.
• Deliver relevant content based on your preferences, usage patterns and location.
• Monitor and evaluate the use and operation of the Services.
• Analyze traffic on the Services and on websites or mobile applications of third parties.   

4. HOW WE SHARE INFORMATION

4.1 How We Share Information That We Collect. We may share your personal information with third parties to whom you authorize us, directly or indirectly, to disclose your personal information in connection with products or services we provide to you.

We may share your anonymous information with trusted service providers, such as advertising and media companies, to analyze and report website trends and distribute our advertisements on websites and mobile applications where we have paid to advertise. These advertisements may use tracking technologies to capture information. We may associate the information collected by these technologies with your identity.  We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.  If your information is tracked or shared, you will be provided with a notice of the tracking and be provided the opportunity to opt out of non-essential tracking and sharing.

Seashine will never share your sensitive personal information with non-affiliated parties without your express consent.  Seashine will never share any of your information for the purposes of other companies to advertise to you.


Who is providing this Notice?         
Seashine Financial, LLC, and its subsidiaries and affiliates

Important Definitions

Affiliates

List of affiliates:

• Seashine Capital Management, LLC
• Seashine USA, Inc.
• Seashine Investment Group, Inc.
• Seashine Property Services
• American Interbanc Mortgage, LLC
• Seashine Asset Management, Inc.
• Seashine Owner Co., LLC

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Seashine does not share your information with non-affiliates so they can market to you.

Joint Marketing

A formal agreement between non-affiliated companies that together market financial products or services to you.

Seashine does not participate in joint marketing.

4.2 Opting Out of Tracking & Sharing.  If your anonymous information is being tracked or shared, you will be alerted through the website and provided an opportunity to opt out tracking or sharing according to your preference.  In order for behavioral advertising opt-outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access the Services from a different device, log in under a different screen name or change web browsers, you will need to opt out again.  

Please note that even if you opt out, you may still see online advertising from Seashine. Opting out from tracking and sharing means that the ads you do receive will not be based on your preferences or behavior. You may also still see targeted pages based on your habits as you navigate our website.

If we are not tracking or sharing your anonymous information, no such message is provided. 

You may have other privacy protections under applicable state laws. To the extent these state laws apply, we will comply with them when we share information about you. See our State Privacy Notice to see if the state you are a resident of provides you additional rights. 

4.3 Opting Out of Seashine Advertising.  The email address you provide for your online account may be used to notify you of services, special offers, or other information that we think may be of interest to you. If you wish to unsubscribe to email advertising, you may do so by: i) clicking the unsubscribe option within the email you receive; ii) updating your preferences in your account settings; or iii) calling us at (888) 401-0285.  

4.4 Use of Do Not Track Settings.  There is no industry standard for how “Do Not Track” consumer browser settings should work on commercial websites. Due to the lack of such standards, our websites do not respond to “Do Not Track” consumer browser settings.

Contact Us

If you have any questions or comments about this Policy or if you need this information in an alternate accessible format, we encourage you to contact our account services department at NewAccounts@SeashineFinancial.com or call 888-401-0285. We accept relay calls.