1. Introduction

Welcome to Arrowhead Advance. This Privacy Policy explains how Wakpamni Lake Community Corporation d/b/a Arrowhead Advance ("Arrowhead Advance," "we," "us," or "our") collects, uses, discloses, and protects your personal information when you visit our website, apply for a loan, or use our services.

We are committed to protecting your privacy and handling your personal information with care and respect. This Privacy Policy applies to all information collected through our website, mobile applications, phone communications, email, and any other interactions you have with us.

🔒 Our Privacy Commitment

We implement industry-standard security measures to protect your personal and financial information. We will never sell your personal information to third parties for marketing purposes.

Scope of This Policy

This Privacy Policy covers:

  • Personal information collected when you visit our website
  • Information provided during the loan application process
  • Data collected during your relationship with us as a borrower
  • Communications between you and Arrowhead Advance
  • Information obtained from third-party sources for verification purposes

Tribal Jurisdiction

Arrowhead Advance is operated by the Wakpamni Lake Community Corporation, an entity of the Oglala Sioux Tribe. As a tribal entity, we operate under tribal law and federal regulations. State privacy laws may not apply to our operations. However, we are committed to maintaining high standards of privacy protection for all our customers.

2. Information We Collect

We collect various types of information to provide and improve our services. The information we collect falls into several categories:

Personal Identification Information

When you apply for a loan or interact with our services, we collect:

  • Full Name: Legal first, middle, and last name
  • Date of Birth: To verify your age and identity
  • Social Security Number: Required for identity verification and credit reporting
  • Government-Issued ID: Driver's license, state ID, or passport information
  • Citizenship Status: U.S. citizenship or permanent resident status

Contact Information

  • Physical Address: Current residential address including street, city, state, and ZIP code
  • Mailing Address: If different from residential address
  • Phone Numbers: Mobile, home, and work phone numbers
  • Email Address: Primary email for communications

Financial Information

  • Employment Information: Employer name, address, phone number, position, and length of employment
  • Income Details: Gross monthly or annual income, pay frequency, and income source
  • Bank Account Information: Bank name, account type, account number, and routing number
  • Payment History: Information about your loan payments and account activity

Credit and Background Information

We obtain information from third-party sources to evaluate your loan application:

  • Credit Reports: Information from credit bureaus about your credit history and score
  • Banking History: Reports about your banking activity and account status
  • Identity Verification: Data used to confirm your identity and prevent fraud
  • Public Records: Information from public sources as permitted by law

Technical and Usage Information

When you visit our website or use our online services, we automatically collect:

  • Device Information: IP address, browser type, operating system, device identifiers
  • Usage Data: Pages visited, time spent, links clicked, referring website
  • Location Data: General geographic location based on IP address
  • Cookies and Similar Technologies: Data collected through cookies, web beacons, and similar technologies

Communications

  • Records of communications between you and our customer service team (phone calls, emails, chat messages)
  • Your responses to surveys or feedback requests
  • Marketing preferences and opt-out requests

📝 Voluntary Information

Most of the information we collect is necessary to process your loan application and provide our services. However, some information, such as survey responses or marketing preferences, is voluntary. You can choose not to provide voluntary information, though this may limit our ability to offer certain features or communications.

3. How We Use Your Information

We use the information we collect for various legitimate business purposes:

Loan Processing and Servicing

  • Application Evaluation: Assessing your eligibility for a loan and determining appropriate loan terms
  • Identity Verification: Confirming your identity and preventing fraud
  • Credit Decisions: Making lending decisions based on your creditworthiness and ability to repay
  • Account Management: Maintaining your loan account and processing payments
  • Collections: Pursuing collection of past-due amounts if necessary

Communication

  • Transactional Communications: Sending important notices about your loan, payments, and account status
  • Customer Service: Responding to your questions, concerns, and service requests
  • Payment Reminders: Sending reminders before scheduled payments
  • Account Updates: Notifying you of changes to your account or our services

Legal and Regulatory Compliance

  • Legal Obligations: Complying with applicable tribal, federal, and other legal requirements
  • Regulatory Reporting: Meeting reporting requirements under applicable laws
  • Fraud Prevention: Detecting, preventing, and investigating fraudulent activity
  • Legal Proceedings: Responding to legal process, court orders, or government requests

Business Operations

  • Service Improvement: Analyzing usage patterns to improve our website and services
  • Risk Management: Assessing and managing business and operational risks
  • Internal Analytics: Understanding customer needs and preferences
  • Quality Assurance: Monitoring and improving service quality

Marketing (With Your Consent)

  • Product Information: Informing you about our services and products
  • Promotional Offers: Sending information about special offers or new products
  • Surveys and Feedback: Requesting your feedback to improve our services

⚠️ Marketing Communications

You can opt out of marketing communications at any time by following the unsubscribe instructions in our emails, adjusting your account preferences, or contacting us directly. Opting out of marketing communications will not affect transactional communications related to your loan account.

4. How We Share Your Information

We share your personal information only as described in this Privacy Policy and as necessary to provide our services. We do not sell your personal information to third parties for their marketing purposes.

Service Providers

We share information with third-party service providers who perform services on our behalf:

  • Payment Processors: Companies that process ACH transactions and payments
  • Identity Verification Services: Providers that help verify your identity and prevent fraud
  • Credit Reporting Agencies: Bureaus that provide credit reports and to whom we report loan activity
  • Banking Partners: Financial institutions that facilitate fund transfers
  • Technology Providers: Companies that host our website, manage our data, and provide technical infrastructure
  • Customer Service Providers: Third parties that help us provide customer support
  • Analytics Services: Providers that help us understand website usage and improve our services

All service providers are bound by confidentiality obligations and are only permitted to use your information to provide services to us, not for their own purposes.

Credit Reporting

We may report your loan and payment information to one or more consumer reporting agencies (credit bureaus). This information becomes part of your credit file and may affect your credit score. Late payments, missed payments, or defaults will be reported and can negatively impact your credit.

Collection Agencies

If your account becomes delinquent, we may share your information with collection agencies or attorneys for the purpose of collecting the debt you owe.

Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity. You will be notified of any such change and any choices you may have regarding your information.

Legal Requirements and Protection

We may disclose your information when required by law or when we believe disclosure is necessary to:

  • Comply with legal process, court orders, or government requests
  • Enforce our Terms of Service or other agreements
  • Protect our rights, property, or safety, or that of our users or the public
  • Detect, prevent, or investigate fraud, security issues, or technical problems
  • Protect against legal liability

Tribal Entities

As an enterprise of the Wakpamni Lake Community Corporation, we may share information with other tribal entities and departments as necessary for tribal governance, oversight, and economic development purposes.

With Your Consent

We may share your information with other parties when you provide explicit consent for us to do so.

🛡️ Third-Party Confidentiality

We require all third parties with whom we share your information to maintain appropriate security measures and to use your information only for the specific purposes for which it was shared. We do not authorize third parties to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements.

5. Data Security

We take the security of your personal information seriously and implement comprehensive security measures to protect it from unauthorized access, use, disclosure, alteration, or destruction.

Security Measures

Our security practices include:

Technical Safeguards

  • Encryption: We use industry-standard SSL/TLS encryption (256-bit) to protect data transmitted between your device and our servers
  • Secure Storage: Personal information is stored in encrypted databases with restricted access
  • Firewalls: Network security includes firewalls and intrusion detection systems
  • Secure Protocols: We use secure communication protocols for all data transfers
  • Regular Updates: Systems and security software are regularly updated and patched

Administrative Safeguards

  • Access Controls: Access to personal information is limited to authorized personnel who need it to perform their job functions
  • Employee Training: Staff members receive regular training on data privacy and security best practices
  • Confidentiality Agreements: Employees and contractors sign confidentiality agreements
  • Security Policies: We maintain comprehensive information security policies and procedures
  • Incident Response: We have procedures in place to respond to and report security incidents

Physical Safeguards

  • Secure Facilities: Physical access to areas where personal information is stored is restricted
  • Device Security: Company devices are password-protected and encrypted
  • Secure Disposal: Physical documents containing personal information are securely destroyed when no longer needed

Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify you in accordance with applicable law. Notification will include:

  • A description of the breach and the types of information involved
  • Steps we are taking to address the breach
  • Recommendations for steps you can take to protect yourself
  • Contact information for further questions

Your Role in Security

While we implement strong security measures, you also play a role in protecting your information:

  • Create strong, unique passwords for your account
  • Never share your account credentials with others
  • Log out of your account when using shared or public computers
  • Be cautious of phishing attempts and never provide personal information in response to unsolicited communications
  • Contact us immediately if you suspect unauthorized access to your account
  • Keep your contact information up to date so we can reach you about security matters

⚠️ No Guarantee

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously work to enhance our security measures and protect your data to the best of our ability.

6. Your Privacy Rights

You have certain rights regarding your personal information. The specific rights available to you may vary depending on applicable law.

Access and Information

You have the right to:

  • Know what personal information we collect about you
  • Request access to your personal information
  • Request copies of documents related to your loan
  • Receive information about how we use and share your data

Correction and Update

You have the right to:

  • Update your contact information through your online account or by contacting customer service
  • Request correction of inaccurate personal information
  • Update your banking information for payments
  • Modify your communication preferences

Marketing Opt-Out

You can opt out of marketing communications by:

  • Clicking the "unsubscribe" link in marketing emails
  • Adjusting preferences in your online account
  • Contacting customer service at (888) 459-1315
  • Sending an email to support@arrowheadusadvance.com

Note: Opting out of marketing communications will not stop transactional communications related to your loan account, such as payment reminders or important account notices.

Deletion Requests

You may request deletion of your personal information, subject to certain limitations:

  • We must retain certain information to comply with legal and regulatory obligations
  • Information related to active loans and pending applications cannot be deleted
  • We may retain information necessary for business purposes such as fraud prevention and legal defense
  • Credit reporting agencies may continue to maintain information we previously reported

Do Not Track

Some browsers have "Do Not Track" features that signal websites not to track users. Currently, there is no universally accepted standard for how to respond to Do Not Track signals. Our website does not currently respond to Do Not Track signals, but we limit tracking as described in the Cookies section of this policy.

Exercising Your Rights

To exercise any of these rights, you can:

  • Log into your online account to update certain information
  • Call customer service at (888) 459-1315
  • Email us at support@arrowheadusadvance.com
  • Write to us at our mailing address (see Contact section)

We will respond to verified requests within a reasonable timeframe as required by applicable law. We may need to verify your identity before processing your request to protect your privacy and security.

🏛️ Tribal Jurisdiction Note

As a tribal entity operating under tribal law, certain state privacy laws may not apply to our operations. However, we are committed to respecting your privacy rights and will work with you to address your privacy concerns to the extent feasible under our tribal and federal legal obligations.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website, analyze usage, and improve our services.

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and recognize you on return visits.

Types of Cookies We Use

Cookie Type Purpose Duration
Essential Cookies Required for the website to function properly. Enable basic features like page navigation and access to secure areas. Session or up to 1 year
Functionality Cookies Remember your preferences and choices (such as language or region) to provide enhanced, personalized features. Up to 2 years
Analytics Cookies Help us understand how visitors interact with our website by collecting and reporting information anonymously. Up to 2 years
Advertising Cookies Used to deliver relevant advertisements and track campaign effectiveness. Up to 1 year

Other Tracking Technologies

  • Web Beacons: Small graphic images embedded in web pages or emails that track whether a page has been viewed or an email opened
  • Pixel Tags: Small code snippets that allow us to measure user actions and website traffic
  • Local Storage: Technology that allows websites to store data in your browser for improved performance

Third-Party Cookies

We may allow certain third-party services to place cookies on your device for:

  • Analytics services (such as Google Analytics)
  • Advertising networks
  • Social media integration
  • Fraud prevention services

Managing Cookies

You can control and manage cookies in several ways:

  • Browser Settings: Most browsers allow you to refuse or delete cookies. Instructions are usually found in the browser's "Help" or "Settings" menu
  • Opt-Out Tools: You can opt out of interest-based advertising through industry opt-out pages
  • Mobile Devices: Mobile devices offer settings to limit ad tracking

⚠️ Impact of Disabling Cookies

If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. Essential cookies are necessary for the website to work, and disabling them may prevent you from using our services.

8. Children's Privacy

Arrowhead Advance services are intended for adults only. We do not knowingly collect, use, or disclose personal information from children under the age of 18.

Age Verification

To apply for a loan, you must be at least 18 years old. We verify age during the application process and will not approve applications from individuals under 18.

Parental Notice

If you are a parent or guardian and believe that your child under 18 has provided personal information to us, please contact us immediately at support@arrowheadusadvance.com or (888) 459-1315. We will take prompt steps to delete such information from our systems.

COPPA Compliance

Our website and services are not directed to children, and we do not knowingly collect personal information from children as defined by the Children's Online Privacy Protection Act (COPPA) or similar laws.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notification of Changes

When we make changes to this Privacy Policy, we will:

  • Update the "Last Updated" date at the top of this policy
  • Post the revised policy on our website
  • For material changes that significantly affect your rights, we may provide additional notice through email or prominent website notices

Your Continued Use

Your continued use of our services after the effective date of an updated Privacy Policy constitutes your acceptance of the revised policy. If you do not agree with the changes, you should discontinue use of our services and contact us about closing your account.

Review Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information and your privacy rights.

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Privacy Questions?

We're here to help address your privacy concerns

Hours:
Monday - Friday
9 AM - 5 PM MST

Mailing Address

Arrowhead Advance
Attn: Privacy Officer
Wakpamni Lake Community Corporation
[Physical Address]
[City, State ZIP]

Response Time

We will respond to your privacy inquiries and requests within a reasonable timeframe, typically within 30 days. For complex requests, we may need additional time and will inform you of any delays.

📝 Written Requests

For formal privacy requests (such as access, correction, or deletion of personal information), we may require written verification of your identity to protect your privacy and security. Please include your full name, address, phone number, and a description of your relationship with Arrowhead Advance when submitting written requests.