1. Information We Collect
We may collect the following information from you and about you.
- Information You Provide to Us. We may collect and keep any personal information you provide to us through our website or in any other manner, such as email. This includes information that identifies you and financial information. Information that identifies you may include your name, email address, date of birth, mailing address, telephone number, and Social Security number. Financial information may include your income, assets, or debts. We use this information to provide you with services. We may also collect information you provide to use about others, including their name, email address, date of birth, mailing address, telephone number, and Social Security number. In addition, we gather the names, email addresses, and other personal information provided by people who contact us through our website with questions about our company or apply for employment.
- Information from Third Parties. We may obtain information about you from vendors, contractors, service providers, and other third parties. You authorize LendKey and the lenders we work with to obtain a personal credit profile from credit bureaus for credit pre-qualification, application for credit, employment applications, and identity verification. You further agree that we may verify your identity and the information you provide us with third parties.
We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our website, to improve its usability and for evaluating our marketing effectiveness as described above. We may also use that information to recognize your computer when you visit our website (if you select the “remember me on this computer” option), and to personalize our website for you. We may also use that information to recognize your computer and display certain marketing messages when you or someone using your computer visit(s) our website and/or other websites. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools,” “Internet Options,” “Privacy,” and selecting “Block all cookies” using the sliding selector). However, blocking cookies can also have a negative impact on the usability of our website.
Cookies may have long-term expiration dates and can stay in your hard drive for months at a time. While you can remove them as instructed by the “help” content in your chosen browser, disabling cookies will prevent you from using our website. As with many transactional websites, cookies must be enabled in order to use our website.
- How LendKey responds to “Do Not Track” Signals. Some web browsers have a “Do Not Track” function that allows you to tell websites that you do not want to have your online activities tracked. LendKey is not currently set up to respond to these “do not track” signals.
2.How We Use Information
- Provide services and products you request;
- Provide customer service;
- Manage your relationship with us;
- Communicate with you by email, social media, text messaging, postal mail, or telephone or through marketing messages when you or someone using your computer visit(s) our website and/or other websites about products or services we offer or are offered by third parties;
- Enforce our terms and conditions;
- Operate our business;
- Enable our financial services partners to implement automatic payments and fund transfers;
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account; or
- Comply with our legal obligations or as otherwise permitted by law.
Certain personal information must be supplied during the registration processes, as indicated below, in order to (a) enable users to login to the website, (b) determine eligibility for loans using our proprietary credit scoring process, (c) verify your identity and the identity of any proposed cosigners, (d) establish borrowers’ ability to request loans by verifying that they are at least 18 years of age, (e) identify or guard against potential fraud, and (f) abide by anti-terrorism laws and regulations.
We may use your financial information to provide loan offers to you from Lenders or to match you with potential loans and services that you may be eligible to receive.
When you register with us and authorize or request it, we may obtain a credit report from a credit bureau to determine your creditworthiness. We will also use both your required and optional information to facilitate other activities and transactions with you. This may include assigning you a borrower credit grade based on your academic characteristics and financial information.
We use aggregated information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We use non-identifying and aggregated information to help optimize our website based on the needs of our users.
In addition, we gather the names and email addresses of people who contact us through our website or email us with questions about our company. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people, for example job applicants who submit resumes.
Online Behavioral Advertising
Online behavioral advertising (known as “OBA” or “internet-based advertising”) involves the collection of information from a computer or other device about a visitor’s web browsing activity over across non-affiliated Web sites to allow us to deliver advertisements based on that visitor’s Web site browsing history, including, but not limited to, web pages viewed, search terms used, or the manner in which you navigate a Web site. Companies we work with may place cookies on your devices and use related tracking technologies to support our OBA efforts. If you do not want your information collected and used by the companies involved in our OBA efforts, you can opt out by following the OBA Opt-Out procedure.
Opting Out of Online Behavioral Advertising
3. How and When Your Information Is Shared With Other Parties
We may share your information with:
- Service Providers. LendKey shares your personal information with authorized service providers that perform services on our behalf. These entities include credit bureaus, fraud databases, collection agencies, electronic payment service providers, customer support call centers, and companies that support surveys, marketing services, data analytics, data processing, or other services and features that we offer. We share information with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services on our behalf. These third parties are not permitted to share or use such information for any other purpose. Third parties or their servers may be located within or outside of the United States.
- Special Notice to California Residents. We will not share any personal information about you with any of our affiliated companies to the extent prohibited by applicable California law or to the extent your prior consent to share is required by applicable California Law.
- Special Notice to Vermont Residents. We will not share any personal information about you with our affiliated companies to the extent prohibited by applicable Vermont law or to the extent your prior consent to share is required by applicable Vermont law.
- Additional Disclosure. We may disclose your personal and financial information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to establish, protect, or exercise our rights, defend against legal claims, or as otherwise required by law. We may also disclose your personal and financial information to respond to a subpoena or similar investigative demand, court order or request for cooperation from a law enforcement or other government agency, or legal process served upon us. We may also share your information with third parties in connection with a substantial company transaction, such as the potential or actual sale of all or a portion of our business, a merger, consolidation, asset sale, or bankruptcy.
- The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- The names and addresses of the third parties that received that information; and
- If the nature of the third party’s business cannot be determined from its name, examples of the products or services marketed.
We may provide this information in a standardized format that is not specific to you. The designated email for these requests is email@example.com.
How You Can Access or Correct Your Information. You can access all of your personal and personally identifiable information that we collect from you through this website by visiting your profile in the My Account section of our website. This section of the website is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone number, and financial account information at any time on the website, and if you need to change any other information in your profile, you can contact us at firstname.lastname@example.org.
Non-Personal and Aggregate Information. We may retain and share non-personal information we collect and information about you and other customers collectively that is not personally identifiable. This includes (for example) information about your computer and visits to our website and/or other websites. We may combine it with non-personal information we obtain from other sources, and may share any aggregated information in any form with third parties. You may not access or correct your non-personal or aggregate information.
4.How We Protect Your Personal Information
Safeguards. We use appropriate physical, technical, and procedural safeguards to protect your personal information from unauthorized access and disclosure. We encrypt the transmission of your personal information over the internet and only permit authorized employees, business partners, Lenders, and third-party service providers to have access to your personal information. We encourage you to take care when you handle or disclose your personal information, including passwords. No system can be completely secure, and we do not warrant that your personal information, transactions, or communication will always remain secure.
Children’s Privacy. We do not knowingly collect, maintain, or use personal information from our website about children under age 13. If we learn that we have collected information from a child under the age of 13, we will promptly take all reasonable steps to delete the information.
You may choose not to provide us with personal information. However, we will be unable to provide you with our Services if you do not provide us with personal or financial information. Furthermore, due to the nature of our services, you may not opt out of the transfer of personal information to Lenders.
LendKey Technologies, Inc.
Attn: Compliance Department
104 W. 27th Street, 4th Floor
New York, NY 10001
Last Updated: December 6, 2017