Privacy Policy

FACTS WHAT DOES LENDFI DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
Why? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
  • Social Security number and income
  • Account balances and payment history
  • Credit history and credit scores

When you are no longer our customer, we continue to share your information as described in this notice.

How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons LendFi chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Do we share? Can you limit this sharing?
For our everyday business purposes
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes No
For our marketing purposes
to offer our products and services to you
Yes No
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes
information about your transactions and experiences
Yes No
For our affiliates’ everyday business purposes
information about your creditworthiness
No We don’t share
For our affiliates to market to you No We don’t share
For nonaffiliates to market to you No We don’t share
Questions Call 1-800-600-1321 or go to www.LendFi.com
Who we are
Who is providing this notice? LendFi (“LendFi”).                
What we do
How does LendFi protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does LendFi collect my personal information? We collect your personal information, for example, when you:
  • Open an account or deposit money
  • Pay your bills or apply for a loan
  • Use your credit or debit card
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing? Federal law gives you the right to limit only:
  • Sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply only to you unless you tell us otherwise.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Our affiliates include companies with that are your account (“Account”) issuing banks (“Banks”) and our program maangers (“Program Managers”)
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
  • LendFi does not share with nonaffiliates so they can market to you.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
  • Our joint marketing partners include financial service companies.

Other important information

We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you.

 

Analytics and Advertising Services Provided by Others

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the Internet. These entities may use cookies, device identifiers, web beacons and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, pages viewed, mobile network information, time spent on pages or in apps, links clicked and conversion information. This information may be used by LendFi and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://www.aboutads.info/choices. Your mobile device may also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes. Please review the settings of your mobile device for more information.

Voice Features

When you use Siri, the things you say will be recorded and sent to Apple to process your requests. Your device may also send Apple other information (collectively, your “User Data”). All of this User Data is used to help Siri on your iOS device and any paired Apple Watch understand you better and recognize what you say. If you have Location Services turned on, the location of your device at the time you make a request will also be sent to Apple to help Siri improve the accuracy of its response to your requests. You may choose to turn off Location Services or Siri at any time. To do so, access Settings on your iOS device. Information collected by Apple will be treated in accordance with Apple’s Privacy Policy, which can be found at https://www.apple.com/legal/privacy.

California Consumer Privacy Act (“CCPA”) Privacy Statement


The following CCPA Privacy Statement shall not apply to the collection, processing, sale or disclosure of any information (i) that a consumer provides to us to obtain a financial product or service from us, or (ii) about a consumer resulting from any transaction involving a financial product or service between us and the consumer; or (iii) we otherwise obtain about a consumer in connection with providing a financial product or service to that consumer.

To better understand your rights in respect of any such information excluded from the following CCPA Privacy Statement, please instead reference the Privacy Policy above.


This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy above (“we,” “us,” or “our”) and applies solely to consumers who reside in the State of California (“consumers” or “you”).

We adopt this statement to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this statement. For California residents, the provisions of this Privacy Statement prevail over any conflicting provisions of the LendFi Privacy Policy above.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Categories of Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES
K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal information does not include:

With respect to each of the categories of Personal Information listed in the table above, we obtain such Personal Information from a variety of sources, including from:

Use of Personal Information

With respect to each of the categories of Personal Information listed in the table above, we may use or disclose such Personal Information for any one or more of the following business purposes:

Sharing Personal Information

With respect to each of the categories of Personal Information listed immediately below, we may disclose such Personal Information to a third party for a business purpose.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

Category A:       Identifiers

Category B:       California Customer Records Personal Information categories

Category C:       Protected classification characteristics under California or federal law

Category D:       Commercial information

Category F:       Internet or other similar network activity

Category G:       Geolocation Data

Category I:       Professional or employment-related information

Category J:       Non-public education information

Category K:       Inferences drawn from other Personal Information

With respect to each of the categories of Personal Information listed immediately above, we may disclose such Personal Information for a business purpose to the following categories of third parties:

We do not, and will not, sell (as that term is defined by the CCPA) any Personal Information that we collect.

We do not disclose Personal Information of individuals we know to be under the age of 16 to any business or third parties for monetary or other valuable consideration as a “sale” under California law, without affirmative authorization.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the Personal Information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a request to us by either:

Only you or a person who you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. Your agent may be subject to the same verification procedures that we use to verify consumers who do not currently have a relationship with us. As permitted by law, we may require you to verify your own identity in response to a request even if you choose to use an agent. You may also make a verifiable consumer request on behalf of your minor child, though please understand that, in connection with your assertion of such rights on behalf of your minor child, we may require that you sign and submit a notarized consent form.

The verifiable consumer request must:

Verifying Your Request

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. We may otherwise limit our response to your request as permitted under applicable law.

Whenever feasible, we will match the identifying information provided by you to the Personal Information we maintain, or use a third-party identity verification service that complies with the CCPA. However, if we cannot verify your identity from the Personal Information that we maintain, we may request additional information from you, which shall only be used for the purposes of verifying your identity.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer, and you may consent to receive certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. You may revoke your consent to participate or receive such financial incentive at any time.

Changes to Our Privacy Statement

We reserve the right to amend this privacy statement at our discretion and at any time. When we make changes to this privacy statement, we will notify you through a statement on our website homepage.

Accessibility Statement

If you use assistive technology and the format of this privacy statement interferes with your ability to access information, please contact us at [email protected] To enable us to respond in a manner most helpful to you, please indicate the preferred format in which to receive the material and your contact information. Users who need accessibility assistance can also contact us at [email protected]

Contact Information

If you have any questions or comments about this statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (800) 600-1321
Website: www.lendfi.com
Effective Date: January 29, 2020