Effective Date: November 28, 2018
PRIVACY NOTICE
We respect your privacy and are committed to taking reasonable steps towards protecting your privacy online and managing your information responsibly. This Privacy Notice is intended to notify you of our online privacy practices, the type of information that may be collected and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, and who to contact with questions or concerns.
This Privacy Notice applies to the website located at www.instalend.com (the “Website”), to any phone, email, or mail operations concerning our operations, products, or services, as well as our marketing contacts with you. This Privacy Notice does not apply to other websites to which we may link, or to other companies or persons who might be listed as third-party contacts or suppliers on this Website, or to whom we may refer you if you call or write us. We may post links on this Website as a way of helping you locate related information and products easily. However, when linking to another website, you must review that website’s privacy notice because other websites may not treat information collected online in the same manner as we do.
By using this Website and/or by contacting us and providing any personal information, you consent to the collection and use of information by us in accordance with this Privacy Notice. If we decide to change our Privacy Notice, we will post those changes on this page.
Why We Collect Information:
We collect personal information because it helps us improve and deliver our Website, as well as to provide our services. In addition, your personal information helps us communicate to you our latest opportunities, news, special offers, and information and events about which you might like to hear. We may also collect your personal information to help us design and deliver our Website, and to deliver targeted marketing to you based on your interests and previous engagement with the Website. We also may correlate the personal information obtained from you with information from other sources. For example, if you provide us with your personal information, we may cross-check that against information that might be available through other entities.
What Information We Collect:
This section includes a general description of the type of information we may collect about you. Those who wish to communicate with us but do not wish to provide personally identifiable information online may contact us through the address or phone numbers provided on our Website. However, you should note that if you contact us by phone, online chat or via postal mail, you may still be submitting personally identifiable information to us, as described below.
We do not automatically collect personal information unless you voluntarily input or submit this information, such as during a registration or when signing up for alerts, ordering a product, submitting questions or comments, requesting information, or participating in online surveys, contests, promotions, crowdsourcing or other activities. If you voluntarily provide us with personally identifiable information, you consent to our use of it in accordance with this Privacy Notice.
Even if you do not submit personal information through the Website, we gather navigational information about where visitors go on the Website and information about the technical efficiencies of our Website and services (such as time to connect to the Website or time to download pages). This information allows us to see which areas of our Website are most visited and helps us better understand the user experience. This data helps us improve the quality of the Website by recognizing and delivering more of the features, areas, and services our visitors prefer. In this process of gathering information, we may collect personally identifiable and non-personally identifiable information (such as domain type, browser type and version, service provider and IP address, referring/exit pages, operating system, date/time stamp, and click-stream data). We may also create and use electronic records to compile statistics about how our visitors collectively interact with our Website by collecting, aggregating, and using information from or about you such as data about the type of browser and operating system used, which web pages you view, the time and duration or your visits to our Website, the search queries you use on this Website, whether you clicked on any items or links on the Website, whether you have clicked on any links in any emails sent from us or third parties on our behalf, whether you have chosen to opt-out of certain services or information sharing, and whether you have viewed or ordered certain products or services, to improve our products and services.
In order to permit third parties to facilitate ACH payments and other payment functionalities, we will also collect personally identifiable information that includes but is not limited to: first name, last name, email address, physical address, date of birth, social security number and bank account/financial information.
How We Collect Information:
We collect information in three primary ways:
1. You Give Us Information: We collect information from you when you submit it to us through our Website.
2. We Collect Information Automatically: We automatically collect certain types of information when you visit our Website or use our products and services. For example, we automatically collect various types of technical information when you use our Website.
3. We Collect Information from Other Sources: We may obtain information about you from outside sources. For example, we may obtain commercially available information about you from third parties, such as credit information to prevent fraud, or purchase e-mail lists from third parties for advertising and marketing purposes. We may also receive information from third-parties who provide services for us through web-beacons and other technologies.
Use of Cookies:
The Website uses a common browser feature known as a cookie, which assigns a unique identification to your computer browser and session. Cookies are typically stored on your computer’s hard drive and are used to help maintain an expected user experience by tracking clicks as you go through the pages within our Website and informing the Website that each of your clicks comes from you individually when needed. We may also use cookies to tell us whether you have previously visited the Website. We may also use cookies that can be set by third parties with whom we have entered into agreements that may enable us to obtain analytic information about the use of our Website. You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies that may have been placed onto your computer. However, you should be aware that all features of the Website may not operate correctly if cookies are rejected or disabled. We will not use shared local objects, commonly referred to as “FLASH cookies,” in a manner inconsistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service. FLASH cookies are cookies that are placed on your computer that are not removed through normal browser management tools.
Use of Web Beacons, Clear GIFs, Pixel Tags and JavaScript:
We also may use "pixel tags" (also called “action pixels,” "web beacons" or "clear gifs") and/or JavaScript plug-ins, placed on our Website and in our emails to you. These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message that are used, for example, to record web pages and advertisements clicked on by a user, or to track the performance of email marketing campaigns. These files help us analyze our users' online behavior and measure the effectiveness of our Website and our communications. We also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these files on the Website and/or in e-mails to use information obtained from them such as pages viewed, items purchased, e-mails opened, and items clicked on in e-mails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you.
Server Logs and Widgets:
A web “server log” is a record of activity created by a computer that delivers certain web pages to your browser. Certain activities that you perform on our Website may record information in server logs, such as if you enter a search term into a search box located on the Website. The server log may record, for example, the search terms or the link you clicked on to bring you to our Website. The server log may also record information about your browser, such as your IP address and the cookies set on your browser.
A “widget” is generally an application that can be embedded in a webpage. Widgets can provide real-time information to the webpage. Widgets are often provided by third-parties; we may provide widgets on our website. Widgets may enable the third parties that provide them to collect data about users visiting the Website.
Search Queries on Our Website:
We may provide you with options to search for information on our Website. If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.
Surveys, Contests, Crowdsourcing and Promotions:
From time to time, we may request information from users via surveys, contests, and promotions. Participation in these surveys or promotions is completely voluntary and you have a choice whether or not to disclose any requested information. If you choose to participate, we may ask you for additional information, which may include contact information (such as name, email, and address) or other demographic information (such as postal code, age, or gender) to provide better services and options to you. We use the information you provide to administer our contests, sweepstakes and other promotions, in addition to the other purposes described in this Privacy Notice. If your information gathered via a survey will be used in a manner different from that described in this Privacy Notice, that proposed use will be described in the survey instructions. For example, the instructions might alert you if the information will be shared with anyone in addition to those parties identified in this Privacy Notice, such as a third party sponsoring the survey.
How We Use the Information We Collect:
We use the information we collect internally in our business for many business purposes, such as to: (i) suggest products or services of interest and connect you with other Investors or Borrowers; (ii) analyze trends and conduct research about improving our products and services; (iii) provide support and respond to questions from users and Website visitors; (iv) improve our Website, products and/or services; (v) learn about users’ needs; (vi) contact users for research, informational, and marketing purposes; (vii) track traffic patterns and Website usage, including customizing our recommendations and promotions to you based upon your information and prior registrations; (viii) enable online registration and provide customer service with respect to registration; (ix) correlate information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts; (x) provide specific relevant marketing, promotional, or other information to you; (xi) address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues; (xii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiii) comply with law, or based on our good-faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud and reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website or the public; and, (xiv) process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
We may also share personally identifiable information and non-personally identifiable information externally with our affiliates, licensees, and joint venture partners, as well as with other third-party service providers who help us provide operational services for the Website and our business, which might include: business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, credit and debit card payment gateways and processors and the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts, entities that obtain information such as demographic information, that might be aggregated with other information we have about you, judicial, administrative and/or legal or financial accounting providers if information must be reviewed or released in response to civil or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, as we believe is necessary or appropriate to prevent physical harm or financial loss or in connection with any investigation of suspected or actual illegal activity, and with other service providers that may be involved in the other types of services and activities discussed in this Privacy Notice.
We may also use your personally identifiable information to contact you in ways other than e-mail or regular mail, such as via telephone contact, facsimile, or SMS, consistent with your disclosed communications preferences.
We may also share your personally identifiable information with certain ACH payment providers (such as Dwolla) in order to facilitate payment for the Site and Services (as such term is defined in our Terms and Conditions of Use) and other financial transactions in and around the Site and Services.
Business Transfers
If the owner of the Website or any of its assets are acquired, or in the event that it goes out of business or enters bankruptcy, user information could be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and consent to the use of your personal information by any acquirer or successor in accordance with this Privacy Notice.
Your Choices About the Information We Collect
If you do not consent to the ways in which we may use your personal information, please do not submit any personal information to us. If you do not wish to receive emails containing information, special offers, or other promotions from us, please click the relevant unsubscribe link located in those emails. If you do not wish to receive other marketing materials from us or if you do not want us to share your personally identifiable information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out from information sharing or receiving information, or both, as the case may be. Please direct your opt-out request to:
Your California Privacy Rights
We collect various types of personal information about you during the course of your relationship with us as a customer. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.
If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third-Party Direct Marketing Opt-Out Form, so you may request that your personal information not be disclosed to third parties for their direct marketing purposes:
Privacy of Children Who Visit the Website
We recognize the importance of children's safety and privacy. The Website is not designed to attract children, and is not intended for use by any children under the age of 13. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), the Company does not request, or knowingly collect, any personally identifiable information from children under the age of 13. If we become aware of any mistaken or inadvertent collection of information from a child under the age of 13 through their misuse of our Website, we will take all necessary measures to promptly delete such information from our records. We ask all parents and guardians to assist us in our efforts to comply with COPPA by prohibiting children under the age of 13 from providing the Company with any of their personal information or using the Website without parental oversight and assistance.
Visitors to the Website Outside of the United States
If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using this Website or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.
Links
For your convenience, the Website may contain links to other websites. We are not responsible for the privacy practices, advertising, products, or content of those websites. None of the links should be inferred to imply that we endorse or have any affiliation with the linked websites.
Security
We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information and to protect you against the criminal misuse of that information.
While we use these security measures to protect your information, please note that no data transmitted over the Internet or stored and used for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the Website will not become publicly available. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software.
Questions / Changes in Notice
If you have questions or concerns with respect to our Privacy Notice, you may contact us at support@instalend.com. We may elect to change or amend our Privacy Notice; in such event, we will post the changes in our Privacy Notice on the Website. If you are concerned about how your personal information is used, please visit our Website often for this and other important announcements and updates.