PAF Group LLC is committed to yourprivacy.  Our goal is to maintain yourtrust and confidence when handling personal and financial information aboutyou.


This Online Privacy Policy (“Privacy Policy”)describes how we collect information when you visit or use our website andother online services (“Online Services”). It also describes how we use andshare such information. PAF does not sell your personally identifiableinformation.


The terms “PAF”, “Park Avenue Finance”, “we,”“us,” or “our” mean PAF Group LLC and its affiliates. “You” means an individualwho visits our Online Services and does not refer to a business or otherentity.


How does PAF collect information online?


We collect information in a variety ofcontexts. For example, we may collect information:

•  Directly from you. We collectinformation directly from you, such as when you register for an account, applyfor or obtain a product or service, or communicate with us.

•  Automatically when you use ourOnline Services. We and others on our behalf may collect Device Data,Online/Mobile Activity Data, and other information automatically when youinteract with us online.

•  Other financial institutions.We may collect information from other financial institutions with whom you haveaccounts, if you elect to have an account aggregation service.


This Policy applies to information we collectwhen you use our Online Services, We may combine that information withinformation we collect in other contexts, such as from phone calls and emailswith you, from third-party data sources for fraud prevention, identityverification, and from publicly available data sources. We will treat suchcombined information in accordance with this Privacy Policy.


What Information does PAF collect?


Depending on how you interact online with us,we may collect various types of information. For example, when you register foran account, we may collect:

•  Contact or identity data, suchas your name, mailing address, email address, phone number, date of birth,government-issued identifier (e.g., tax ID number, Social Security number,driver’s license, or other government ID), citizenship, username and password,and other information that directly identifies you.

•  Transaction-related data, suchas financial information, business-related information, and other informationrelated to your transactions with PAF.

•  Demographic data, such asgender, marital status, age, household size/composition, education level,income, occupation, and employment status.


When you browse our website, we may alsocollect:

•  Device data, such as yourdevice type, web browser type and version, operating system type and version,display/screen settings, language preferences, internet protocol address,mobile network information, general location, cookie IDs, device IDs, mobile advertisingIDs, and likely connections among different browsers and devices that you use(collectively, “Device Data”).

•  Online/mobile activity data,such as login data, information about how you use and interact with our OnlineServices, when and how often you use our Online Services, the webpage fromwhich you clocked a link to come to our Online Services, and crash reports(collectively, “Online/Mobile Activity Data”).

•  Communications data, such asyour communication preferences and details or the content of yourcommunications with us.


If you disclose any information relating toother people to us or our service providers when you visit or use the OnlineServices, you represent that you have the authority to do so and to permit usto use the information in accordance with this Privacy Policy.


How does PAF use this information?


We use information for various purposesdepending on how you interact with us. For example, we may use your informationfor the purposes described below:

•  Providing, maintaining, andservicing your account, such as enabling you to apply for and obtain PAFproducts or services, communication with you, and providing online tools andfeatures.

•  Verifying your identity, suchas conducting identity verification when you apply for our products orservices, authenticating your login credentials, and verifying your location toallow access.

•  Detecting and preventing fraud,such as determining fraud risk.

•  Protecting against securityrisks, such as monitoring network activity logs, detecting security incidents,conducting data security investigations, and otherwise protecting againstmalicious, deceptive, fraudulent, or illegal activity.

•  Advertising and marketing, suchas sending you offers for products and services via mail, email, or textmessage, displaying online advertising, targeting our offers, and evaluatingand improving the effectiveness of our marketing efforts.

•  Conducting analytics andresearch, such as examining which parts of our website you visit, performingdebugging and error repair, and analyzing use of our Online Services.

•  Improving our products andservices, such as personalizing and optimizing your website experience,improving existing products and services, and developing new products andservices.

•  Carrying out legal and businesspurposes, such as complying with applicable laws, responding to lawsuits,subpoenas, or investigations, exercising our rights or defending against legalclaims, resolving complaints, performing compliance activities, regulatoryreporting, performing institutional risk control, and otherwise operating,managing, and maintaining our business.

•  Using aggregated andde-identified information, such as using or modifying the information describedin this Privacy Policy in a manner that does not allow us to reasonablyidentify you. For example, we may compile aggregated statistics to understandtrends. Information that has been aggregated and de-identified is no longersubject to this Privacy Policy.


How does PAF share this information?


We share information in a variety of contacts.For example, we may share your information with:

•  Affiliates. We may share yourinformation with our affiliates as permitted by applicable law.

•  Service providers. We use othercompanies to provide services on our behalf and to help us run our business. Wemay share information with these service providers, or they may collectinformation on our behalf, for various business purposes. For example, we useservice providers for hosting and securing our information systems.

•  Government entities and otherswith whom we share information for legal or necessary purposes. We shareinformation with government entities and others for legal and necessarypurposes, such as:

•  To respond to requests from ourregulators or to respond to a warrant, subpoena, governmental audit orinvestigation, law enforcement request, legal order, or other legal process.

•  To facilitate a merger,acquisition, sale bankruptcy, or other disposition of some or all of ourassets, in which case we may transfer your information to the relevant thirdparty.

•  For other legal purposes, suchas to enforce our terms and conditions, exercise or defend legal claims, or ifwe determine that disclosure is necessary and appropriate to protect the life,safety, or property of ourselves or others.

•  Recipients of aggregated andde-identified information. We may share aggregated and de-identifiedinformation with third parties for any purpose.


What online tracking technology does PAFuse?


We and third-party providers acting on ourbehalf use a variety of online tools and technologies to collect informationwhen you visit or use the Online Services, including Device Data andMobile/Online Activity Data. We may associate this tracking data with your PAFaccount if you have one.  These toolsinclude server logs, cookies and pixel tags.




At PAF, we prioritize your safety and security.We have information security practices in place that include administrative,technical and physical measures to protect information within our company.While we use industry-standard practices to protect your information, no methodof data transmission or storage is 100% secure, and we cannot ensure or warrantthe security of your information. Your use of our services is anacknowledgement that PAF is not liable or responsible for any informationsecurity breach despite our commercially reasonable information securitypractices and you hereby waive and release PAF from any and all claims relatedto an information security breach. If you suspect your interaction with us isno longer secure, please contact us




You can unsubscribe from marketing andinformational emails from PAF and its affiliates utilizing your personalinformation on by contacting PAF at




Our Online Services are not directed tochildren under 18. We do not knowingly collect personal information fromchildren through our Online Services. We kindly request that children do notprovide information to us through our Online Services.




We may change this Privacy Policy in thefuture. When we do, we will post the revised Privacy Policy on our website.Your use of the Online Services constitutes your agreement with the Policyterms.




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