Credit Data and Your FCRA Rights

1. What Banrox Is in This Picture

There are three roles in the credit reporting system, and Banrox holds none of them.

Banrox is a viewer that you point at your own file. Banrox displays it, alerts you when it changes, and explains what the entries mean. Banrox cannot add to it, remove from it, or change it, and neither can anyone who tells you they can.

2. The Authorisation You Give Us

Banrox obtains nothing about you until you give a written instruction under 15 U.S.C. section 1681b(a)(2). That instruction is shown on its own, it is not bundled into the Terms of Service, and it is not pre-ticked.

The wording used when you create an account. The box you tick at signup says exactly this, and nothing more:

I authorize Banrox to obtain my Experian credit report and score as described above. I am the person named on this page and I am 18 or older.

The words "as described above" mean the text printed directly above that box on the signup page. That instruction names one bureau, Experian, so it lets Banrox obtain your Experian report and your Experian score, and nothing else. Banrox does not read one bureau's authorisation as covering another. Where a Banrox screen asks you to authorise a second or a third bureau, that screen names the bureau and you tick it separately, and the wording on the screen is the wording that binds. Whatever the screen, an authorisation Banrox asks you for will always name what it covers, will always be separate, and will never be pre-ticked.

What every Banrox authorisation is limited to, whichever screen you gave it on. Banrox obtains your consumer report and your score for one purpose: so that Banrox can display them to you and alert you when they change. Banrox uses them for nothing else. This is not only a promise on a page. 15 U.S.C. section 1681b(f) makes it unlawful for any person to use a consumer report, and not merely to obtain one, for a purpose the consumer did not authorise. The word the statute uses is "use". Section 8 lists by name the uses Banrox rules out.

What Banrox records today, and what is still being built. Banrox records that you gave the instruction and the date you gave it. Banrox does not yet store the exact wording that was displayed to you at that moment, or the internet address the instruction came from. Banrox is building that capture. Do not read this page as saying the evidence already exists, because today it does not. Until it is built, the version of the wording published on this page on the date you agreed is the wording Banrox will treat as the wording you were shown, and Banrox will not argue otherwise against you. You may ask for whatever record exists for you at [email protected], free of charge.

What withdrawal does. You may withdraw the instruction at any time in your account settings or by writing to [email protected]. From the moment Banrox receives it, withdrawal stops future pulls and stops monitoring. Banrox also stops displaying the report and the score it already obtained, and deletes its copy within 30 days, unless a law requires a record to be kept. Withdrawal does not delete the history the bureau holds, because that history is the bureau's, not Banrox's. Withdrawing does not close your account, does not cancel a paid plan by itself, and is never used against you.

To obtain your file Banrox and its partners must verify that you are you, which is why you are asked for your Social Security number, date of birth, address and identity questions. That information is used for verification and file retrieval, and for nothing else. See the Privacy Policy. Those identity questions are generated from your own credit file, so if they fail and Banrox has to turn you away, Banrox owes you the notice set out in Section 4.

3. Soft Pull and Hard Pull

Where a Banrox page says "soft pull, no credit impact," it is describing the inquiry Banrox makes. It is not a statement about what a lender will do after you click through to apply.

4. When Banrox Itself Owes You a Notice

Most of this page is about what other companies owe you. This section is about what Banrox owes you, because Banrox is a user of your consumer report and the same law binds Banrox too.

Sometimes Banrox has to refuse an account, refuse to show you your file, or close an account, because the identity questions did not match or because verification failed. Those questions are generated from your credit file. When Banrox refuses you or ends your access for that reason, federal law treats that as an adverse action based on a consumer report, and Banrox owes you a notice under 15 U.S.C. section 1681m(a). That duty binds any person who takes such an action, not only lenders, and 15 U.S.C. section 1681a(k)(1)(B)(iv) covers a determination that is adverse to you in a transaction you started yourself, which is exactly what a Banrox signup is.

What that notice will contain. Banrox sends it to you in writing or by email. It tells you the decision. It names the consumer reporting agency whose information was used, with that agency's address and its toll free telephone number. It says that the agency did not make the decision and cannot tell you why it was made. And it tells you the two things 15 U.S.C. section 1681m(a)(3) and (a)(4) give you: you may get a free copy of your report from that agency if you ask within 60 days of the notice, and you may dispute anything inaccurate or incomplete in it with that agency under 15 U.S.C. section 1681i. Banrox sends this notice whether or not you have a paid plan, and it costs you nothing.

The fraud and bot score, and the commitment that does not depend on it. Banrox scores a signup and a login for signs of automation, stolen credentials and account takeover. That score is built in part from device signals, network signals and behaviour signals. A high score can slow an attempt down, ask you for a further check, block it, or cause Banrox to refuse or to close an account. Banrox does not use that score to decide whether any lender approves you, and does not send it to a lender, an issuer or an insurer. The commitment that protects you does not turn on what goes into the score. Whenever Banrox refuses you, suspends you, or closes your account, and information from a consumer report is any part of the reason, Banrox sends you the notice described above.

An automated check can affect you at Banrox, and Banrox says so. Banrox does not approve, deny, price or underwrite any loan, card or insurance product, and no Banrox system decides your credit anywhere else. But the identity check and the fraud score are automated, they are about you, and they can cost you access to the service. That is a real decision and this page does not pretend otherwise. You can ask for a person to look at it by writing to [email protected] or [email protected]. Banrox tells you the general reason, lets you see the information the check used, corrects that information if it is wrong, reverses the block if the block was wrong, and answers within 10 business days. That review is described in the Privacy Policy and it is open to you in every state.

5. About the Scores You See

There is no single credit score. There are many models, and lenders choose which one to use.

• The score shown in Banrox is labelled with its model and the bureau it was calculated from. Read that label. It is the only thing that makes the number meaningful.
• An educational score is built to help you track direction. A lender may use a different model and see a different number for the same file on the same day, and that is normal, not an error.
• A score can move for reasons that have nothing to do with anything you did, including a change in another account's reported balance or a model update at the bureau.
• No company can promise a score increase, and Banrox does not. Anyone who promises you a specific score outcome for money is describing something the law does not allow them to promise.

6. Your Rights Under the Fair Credit Reporting Act

These rights come from federal law. They are free. You do not need Banrox, or any paid service, to use any of them.

• A free report. You are entitled to one free copy of your credit report from each of the three nationwide bureaus every 12 months, under 15 U.S.C. section 1681j(a). Equifax, Experian and TransUnion currently give a free report every week, which is more than the law requires and which they may stop offering. There are three ways to ask, all free: online at annualcreditreport.com, by telephone on (877) 322-8228, or by post to Annual Credit Report Request Service, P.O. Box 105281, Atlanta, GA 30348-5281. That is the only source authorised by federal law. You are entitled to a free report in four more situations: after an adverse action, if you ask the bureau named in the notice within 60 days of it; once a year if you are unemployed and certify that you intend to apply for a job within 60 days; once a year if you receive public welfare assistance; and if you have reason to believe your file contains inaccurate information because of fraud. Placing a fraud alert entitles you to a further free report, and an extended alert entitles you to two during the following 12 months.
• Dispute anything inaccurate. The bureau must investigate, normally within 30 days, and must delete or correct information it cannot verify. Disputing is free.
• Know who looked. Your file lists who obtained it and when.
• Adverse action explanation. If a company denies you or prices you worse because of your report, it must tell you and name the bureau it used. That company includes Banrox. Section 4 says what Banrox sends you and when.
• Security freeze. You may freeze and unfreeze your file at each bureau, free, which blocks most new credit being opened in your name.
• Fraud alert. You may place a free fraud alert on your file at any one of the three bureaus, and that bureau must tell the other two. An initial alert lasts one year. An extended alert lasts seven years, needs an identity theft report, entitles you to two free reports in the next 12 months, and takes you off prescreened credit offer lists for five years. If you are on active military duty you may place a free active duty alert under 15 U.S.C. section 1681c-1(c). It lasts at least 12 months and takes you off prescreened offer lists for two years.
• Identity theft block. Information that resulted from identity theft must be blocked from your file under 15 U.S.C. section 1681c-2, and the bureau has four business days from receiving your request to do it. Your request has to contain four things: proof of who you are, a copy of an identity theft report, a clear identification of the items you want blocked, and a statement that those items do not relate to any transaction you made. The bureau must also tell the company that reported the item. Get the identity theft report free at identitytheft.gov.
• Records from the company, not just the bureau. If you are a victim of identity theft, 15 U.S.C. section 1681g(e) lets you demand from the business itself, free, copies of the application and the transaction records a thief created in your name. The business has 30 days from your request. You need proof of identity and either a police report or a Federal Trade Commission identity theft affidavit. This is how you get the actual fraudulent application, which a bureau cannot give you.
• Limits on old information. Most negative information drops off after seven years, and most bankruptcies after ten.
• Damages, including against Banrox. You may sue a bureau, a furnisher, or a user of your report that violates the Act. Banrox is a user of your report. So you may sue Banrox: under 15 U.S.C. section 1681n for a wilful violation, which carries actual damages or statutory damages of 100 to 1,000 dollars, punitive damages, costs and reasonable lawyers' fees, or under 15 U.S.C. section 1681o for a negligent one. Nothing in the Terms of Service limits that claim. Section 18 of the Terms of Service excludes Fair Credit Reporting Act claims from every liability limit, without condition, and Banrox will not argue that any contract term capped or shortened one. The deadline is set by 15 U.S.C. section 1681p: two years from the date you discover the violation, and up to five years from the date it happened.

The free report notice federal law prescribes, and whether it applies here. There is a federal rule about advertising a free credit report. It is at 12 C.F.R. sections 1022.130 to 1022.138, with the disclosure at 12 C.F.R. section 1022.138. It bites in a narrow case: 12 C.F.R. section 1022.138(a)(2) defines a "free credit report" as a file disclosure from a nationwide bureau that is represented, expressly or by implication, to be available at no cost if you buy a product or service, or agree to buy one subject to cancellation. A report that is genuinely free, with nothing to buy and nothing to cancel, is outside the rule. Where the rule does apply, the page offering the report must carry this box at the top, and the words inside it are set by 12 C.F.R. section 1022.138(b)(4), so Banrox reproduces them exactly rather than paraphrasing them:

THIS NOTICE IS REQUIRED BY LAW. Read more at consumerfinance.gov/learnmore.

You have the right to a free credit report from AnnualCreditReport.com or (877) 322-8228, the ONLY authorized source under Federal law.

Take me to the authorized source.

Banrox does not today offer a free credit report in the sense that rule uses. No Banrox page offers you a file disclosure from a nationwide bureau on condition that you buy something or start a cancellable trial, so the box is not required on any Banrox page today. The rule is set out here so that it is written down before anyone at Banrox writes an offer that would trigger it. If that ever changes, the box goes on the page that carries the offer and on every page of the ordering process, in the form the regulation prescribes, and not in a legal document three clicks away. Whatever Banrox shows you, it is not the free report federal law entitles you to. The federal one comes from annualcreditreport.com, it costs nothing, it needs no account with anyone, and you never have to use Banrox to get it.

The Consumer Financial Protection Bureau publishes the official "Summary of Your Rights Under the Fair Credit Reporting Act". It is the model form at Appendix K to 12 C.F.R. Part 1022, in the version the Bureau adopted at 88 Fed. Reg. 58066 on 25 August 2023, for which compliance became mandatory on 20 March 2024. Read it at the eCFR text of Appendix K or at consumerfinance.gov/rules-policy. Banrox will also post you a paper copy, free, if you ask at [email protected] or call (888) 888-6401. Banrox does not charge for it and does not require an account for it.

7. How to Fix an Error, Free, Without Paying Anyone

Banrox does not run a dispute service. Banrox does not file a dispute for you, does not contact a bureau or a furnisher on your behalf, does not write or send a letter for you, and charges nothing for anything on this page. What follows is the free route, the same one the bureaus are required to give you. If any Banrox page, link or button uses the words "Dispute Center", it means this page and nothing else.

Banrox charges nothing for any of this and never will. A paid service cannot make a bureau do anything it is not already required to do for you at no cost. Anyone who says otherwise is selling you your own free rights.

1. Get your report from annualcreditreport.com so you are looking at the source, not a summary.
2. Write down exactly what is wrong and why, and gather anything that proves it: a statement, a payoff letter, a police report.
3. Dispute with the bureau that shows the error, online, by phone, or by mail. Mail with a return receipt gives you proof of the date.
4. Dispute with the company that reported the item as well. Doing both is what triggers the furnisher's own investigation duty under 15 U.S.C. section 1681s-2(b).
5. Keep everything. If the bureau does not fix a verifiable error, complain to the Consumer Financial Protection Bureau at consumerfinance.gov/complaint, which forwards it and requires a response.

8. What Banrox Does Not Do With Credit Data

• Banrox does not sell your credit report, your credit score, or anything derived from either, to anyone, at any price.
• Banrox does not give any other company anything taken from your credit report or your credit score, including anything derived from either, for any reason, whether or not Banrox is paid for it. That covers a referral to a provider, a removal request sent to a data broker on your behalf, a service provider, an advertising partner and a research partner. A referral carries only the contact and product interest fields listed in the Privacy Policy.
• Banrox does not use your credit data to target advertising to you.
• Banrox does not use your credit report, your credit score, or anything derived from either, to decide which marketplace products you are shown, to order them, to filter them, or to describe them. Your instruction lets Banrox obtain your file to show it to you and to alert you to changes, and 15 U.S.C. section 1681b(f) bars using a report for anything else, not only obtaining one. Building a shortlist of offers out of your file would be a use outside your instruction, so Banrox does not do it. Banrox does not run, and has never run, a prescreened offer of credit or insurance. See Fair Lending, ECOA and Equal Access.
• Banrox does not dispute anything on your behalf, and does not charge you for dispute help at any price, on any plan, or at no plan.
• Banrox does not obtain a report about anyone other than the person who authorised it. Obtaining a report without a permissible purpose is a federal offence, and Banrox treats it as grounds for immediate termination and referral to law enforcement.

Everything on this page is free, to everyone, and is published rather than sold. Nothing on this page sits behind a paid plan, a trial or an account. You do not need to be a member to read it or to use any of it. Banrox does not sell, provide or perform, and does not represent that it can or will sell, provide or perform, any service for the express or implied purpose of improving your credit record, your credit history or your credit rating, and Banrox does not sell, provide or perform any service that gives you advice or assistance with regard to improving any of them. Those are the two halves of the definition of a credit repair organization at 15 U.S.C. section 1679a(3)(A), and Banrox is outside both of them.

State law is wider than the federal law, so Banrox states its position against the wider test. Most states also have a credit services organization statute, and several reach further than the federal Act. Texas Finance Code section 393.001(3) is the usual shape: it covers a person who, for payment, provides or says it can provide, with respect to the extension of consumer credit by others, the improvement of a consumer's credit record or rating, or the obtaining of an extension of consumer credit for a consumer, or advice or assistance about either. The second limb reaches referral, matching and lead generation, and the third reaches credit education. Georgia goes further still: O.C.G.A. section 16-9-59 bans credit repair services organizations outright and offers no way to register. Banrox takes no fee for any of the activity those statutes describe. The credit education on this site is published free to everyone, referrals cost you nothing, and Banrox does not charge you, at any plan level, for advice or assistance about your credit record.

9. Accuracy and Availability

What you see in Banrox is what the bureau gave us at the time of the pull. Bureaus update on their own schedules, a lender may report on a cycle that has not closed yet, and outages happen. A figure in Banrox that differs from a figure at the bureau means the bureau's figure is the current one. If you see a discrepancy that matters, pull the report at the source and use that.

Banrox is not liable for a decision you make based on a display that was accurate when retrieved and has since changed at the source. That is not a disclaimer of our duty to show you the data correctly; it is a statement about who holds the master copy.

10. Questions

Write to [email protected] or call (888) 888-6401. For a complaint about a bureau, a furnisher, or about Banrox, see Complaints, Disputes and Regulator Contacts.