If you are a participant or potential participant in a Program Service, you (or the organization from which you have been provided access to the Program Services) may provide certain Personal Information to us through the Program Services – for example, when you register for a FORWARD account to access and use the Program Services, or when you consult with customer support, send us an email, or communicate with us in any way (for example, to make a support request).

The Personal Information we collect may include:

Personally identifiable information (such as your name, job title, home address, phone number, email address, income);

Personal information that you provide to us or that is collected on behalf of our Customer as it relates to your Program Service eligibility (such as gender, race and ethnicity, income, revenue, financial reports, housing status);

Contact information (such as your contact preferences);

Account log-in credentials (such as your email or username and password when you sign up for an account with us and the unique User ID assigned to you in our systems);

Troubleshooting and support data (which is data you provide or we otherwise access in connection with support queries we receive from you). This may include, for example, contact or authentication data, the content of your chats and other communications with FORWARD, and the Program Service you are using related to your help inquiry; and

Payment information (including your banking information and associated identifiers, mailing address, and background information, but only where you are eligible for payment related Program Services).

If you ever communicate directly with us, we will maintain a record of those communications and responses. Please note that if you choose not to provide your Personal Information to us, we may not be able to fulfill your request(s) (e.g., to enroll you in Program Services or to receive communications from us).

If you apply for employment with FORWARD, we collect certain personal information from you in relation to your application and candidacy for employment as described in detail in our Job Applicant Privacy Policy and Notice of Collection.

We use your Personal Information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service and Program Services.  We use your Personal Information to:

• provide, operate and improve the Service and Program Services

• provide information about our products and services

• establish and maintain your user profile on the Service or Program Services

• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in

• communicate with you about the Service or Program Services, including by sending you announcements, updates, security alerts, and support and administrative messages

• understand your needs and interests, and personalize your experience with the Service or Program Services and our communications

• provide support and maintenance for the Service or Program Services

• respond to your requests, questions and feedback

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.  All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

For research and development.  We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications.  We may send you FORWARD-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below. 

Handling contact and support requests.  If you fill out a “Contact Us” web form or request support as a Program Participant, or if you contact us by other means including via phone or email, we process your Personal Information to perform our contract with you and/or (if we have not entered into a contract with you) to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.

To comply with the law. We use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your Personal Information, such as when required by law.  

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your Personal Information and other individuals whose Personal Information we collect.  We make Personal Information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. 

We do not share your Personal Information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Service providers.  We may share your Personal Information with third-party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your Personal Information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Municipalities and Local Agencies.  The Program Services are designed to assist users with locating and applying for funding, loans and other forms of business recovery and growth projects and assistance.  As such, if you use the Program Services to apply for any such assistance, we will share your application and any information contained therein, with the applicable municipality, local agency or other governmental entity. 

Professional advisors. We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your Personal Information for the compliance, fraud prevention and safety purposes described above.  

Business transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Depending on your location, your jurisdiction, and applicable law, you may have the rights below with regard to the Personal Information we control about you. We will respond to your requests within the appropriate timeline under applicable law. Please note, however, that the rights described below are not absolute and, depending on applicable law or in certain cases, may be subject to conditions or limitations. In responding to any request to disclose/delete, FORWARD shall maintain a record of the requests as required under applicable law.

• The right of access, or the right to know, means that you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you. You can do so at any time by contacting us using the contact details provided under the “How to Contact Us” heading below. 

• If you are located in California, under the CCPA you have the right to request to know:

  • The specific pieces of personal information we have collected about you;

  • The categories of personal information we have collected, used, and/or disclosed about you;

  • The categories of sources from which we have collected personal information about you;

  • Business and/or commercial purposes for collecting and disclosing your personal information; and

  • The categories of third parties with whom your personal information has been disclosed or shared.

• The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. As mentioned above, you can do so at any time by contacting us using the contact details provided under the ”How to Contact Us” heading below.

• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights, and FORWARD will not discriminate against an individual for exercising any rights under the CCPA or other applicable privacy law, including, but not limited to, (a) denying goods or its professional services, (b) charging different prices or rates (including discounts/penalties) not directly related to the value provided to FORWARD for Personal Information, or (c) suggesting an individual will receive a different rate/price or level of quality of goods/professional services.

• The right to opt-out, if you are located in California under the CCPA, means you can opt-out of the sale or certain sharing of your Personal Information at FORWARD’s Privacy Rights page here. Note that FORWARD does not sell Personal Information, though in certain instances FORWARD does share Personal Information as described in this Privacy Policy.

• You can also ask us to correct or update your Personal Information; object to the processing of your Personal Information; ask us to restrict processing of your Personal Information; or request the portability of your Personal Information. Again, you can exercise these rights at FORWARD’s Privacy Rights page here.

• While you cannot opt out of service-related emails if you are an account holder, as this is an essential part of the Program Services, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you, or you can contact us using the contact information below.

• Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

• FORWARD does not engage in any automated decision making with User Personal Information.

If your Personal Information has been submitted to us by or on behalf of our Customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Customer directly. For more information on how our Customer uses your Personal Information, please see the Customer’s privacy policy.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, including no consistent standard of interpreting user intent. FORWARD takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your Personal Information. Where we are required by law to collect your Personal Information, or where we need your Personal Information in order to provide the Service or Program Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Service or Program Services by designating it as required at the time of collection or through other appropriate means.