LAST UPDATED:  February 5, 2015

Elevate Credit, Inc. Safe Harbor Privacy Policy

We, Elevate Credit, Inc. (the “Company”) have created this Safe Harbor Privacy Policy to help you learn about how the Company handles Personally Identifiable Information that is collected by our subsidiary in the United Kingdom, Elevate (UK) Ltd, and transferred to us in the United States to perform tasks on behalf of Think Finance (UK), Ltd.

The Company and its affiliated United States subsidiaries will adhere to the U.S.-EU Safe Harbor program (“Safe Harbor Program”) concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce, which include a set of frequently asked questions, (the “Principles”) with respect to such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format. More information about the Safe Harbor Program can be found at

The Company will verify, by a self-assessment, that it is complying with this Safe Harbor Privacy Policy.


“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and/or (4) can be linked to that individual.



The Company may receive Personal Information from our UK subsidiary, including, but not limited to, name, postal address, telephone number, e-mail address, bank account, credit card number or other payment account number (including the three (3) or four (4) digit validation code for your debit/credit card).

Any Personal Information we receive from our UK subsidiary may be used by us and our affiliates and our and their agents, partners, or licensees for the purposes indicated in this Privacy Policy, on the website, or at the time the information was collected offline. If we intend to use the Personal Information that we receive from our UK subsidiary for a purpose that is incompatible with these purposes, or if we intend to disclose it to a category of third party not previously identified, we will notify you and offer you the opportunity to opt out of such uses and/or disclosures.


The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party, or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Onward Transfers:

The Company works with third parties that provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail delivery services, credit card processing and other similar services. The Company may share Personal Information that we receive from our UK subsidiary with these third parties to enable them to provide services. These service providers are given access to Personal Information that we receive from our UK subsidiary to the extent needed to perform their functions, but are restricted from using the Personal Information for purposes other than providing services for us. We require that our agents and service providers that have access to Personal Information received from our UK subsidiary (a) subscribe to the Principles, (b) are subject to the EU Privacy Directive or another adequacy finding, or (c) enter into a written agreement with us that requires them to provide at least the same level of privacy protection as is required by the relevant Principles.

Data Security:

The Company shall take reasonable steps to protect the Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. The Company cannot guarantee the security of information on or transmitted via the Internet. We ask that you do your part by, at a minimum, keeping any computer passwords you use to access the Internet or the website strictly confidential.

Data Integrity:

The Company shall take reasonable steps to ensure that Personal Information we process is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information.


You can review the Personal Information (except debit/credit card data) that the Company maintains about you by logging onto your account from If you want to correct this information or review the debit/credit card data you can call 01284 717800. The Company may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. Finally, we are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared Personal Information about you, or limiting their use of Personal Information about you.

Safe Harbor Enforcement and Dispute Resolution:

If you have any questions or concerns, please write to us at the address listed below. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Safe Harbor Principles.

Contact Information:

In order to comply with the European Union‘s Safe Harbor Principles, the Company commits to the resolution of complaints about your privacy and our collection or use of your personal information. We have committed to resolve any complaints by European Union citizens relating to this policy, which cannot be resolved directly with our company, through the American Arbitration Association.

If you have any questions regarding this policy, please contact:

Elevate Credit, Inc.
Attention: General Counsel
4150 International Plaza, Suite 300
Fort Worth, Texas 76109

If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed by the Company, you should then contact:

International Centre for Dispute Resolution
A Division of the American Arbitration Association
Case Filing Services
1101 Laurel Oak Road, Suite 100
Voorhees, NJ 08043
Phone: (856) 435-6401
Toll Free Number in the U.S.: (877) 495-4185
Fax: (877) 304-8457
Fax number outside the U.S.: (212) 484-4178

Privacy Policy Changes:

This Safe Harbor Privacy Policy may be amended from time to time consistent with the requirements of the Safe Harbor. The Company will post any revised policy on this website. You can determine when this Safe Harbor Privacy Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to the Safe Harbor Privacy Policy will become effective upon our posting of the revised Safe Harbor Privacy Policy on the website. Use of the website following such changes constitutes your acceptance of the revised Safe Harbor Privacy Policy then in effect.