Investor Privacy Policy

This Investor Privacy Policy has been updated effective April 31, 2019

Funding Circle Investor Privacy Policy

This privacy policy (this Investor Privacy Policy) governs the collection, storage, and use of information and data collected by Funding Circle USA, Inc. or any of our U.S. affiliates, including Funding Circle Securities, LLC, member FINRA/SIPC (collectively, Funding Circle, we, us, or our), via our websites at www.fundingcircle.com/us/invest, www.fundingcircle.com/us/investors, https://investor-portal.fundingcircle.us/us/investors, and their subdomains, or by telephone, email, or other means (collectively, and together with our websites, Funding Circle Investor Services).

We have prepared this Investor Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use our websites or any other Funding Circle Investor Services.

Please read this Investor Privacy Policy carefully. By accessing and using our websites or any other Funding Circle Investor Services, you confirm that you have read, understand, and agree to this Investor Privacy Policy in its entirety. You understand and acknowledge that we reserve the right to change or amend this Investor Privacy Policy at any time, which will be reflected by the effective date above. Please check this webpage regularly to stay informed of updates to this Investor Privacy Policy. If any material changes are made to this Investor Privacy Policy, advance notice of the changes will be posted in the first section of this webpage. Your continued use of Funding Circle Investor Services constitutes your agreement to this Investor Privacy Policy and any future revisions.

If you do not agree to this Investor Privacy Policy in its entirety, you must refrain from using our website or any other Funding Circle Investor Services.

Please also visit our Investor Terms of Use which establish the rules, disclaimers, and limitations of liability governing your use of our websites.

1. What information do we collect from you?

A. Information provided by you

Funding Circle collects information supplied during the investor application process and at various times during your subsequent use of Funding Circle Investor Services, including but not limited to, the following information (as applicable):

Investors
Name
Mailing address
Phone and e-mail details
Bank account information
Date of birth
Social security number
Government issued identification
Income, assets, debt, and other financial data
Other information provided in correspondence with us including by email, post facsimile, and telephone

B. Cookies and tracking technologies

When you use Funding Circle Investor Services, we and our third-party service providers may utilize cookies and other similar technologies (such as web beacons or pixel tags) to capture and remember certain information. This individual and aggregate information helps us to improve your website experience, provide you with better tools, and operate our business in other ways described under the heading “Why do we collect this information” below. You have the ability to disable cookies in your browser settings; however, doing so may affect the functionality of certain features of our website.

We and our third-party service providers may also employ cookies and other similar tracking technologies that collect your information across multiple websites and over time. We use these tracking technologies to provide tailored advertising and evaluate our marketing efforts. We do not process “do not track” (DNT) signals. Our third-party service providers may also not respond to DNT signals. Third-party service providers are not permitted to use the information collected on our behalf, except to help us conduct and improve our business.

C. Device specific information and tracking technologies

When you use Funding Circle Investor Services, we and our third-party service providers may collect device specific information. This information, including but not limited to your internet protocol address, geographical location, browser type, operating system, length of visit, and pages viewed, is saved automatically in log files. We use the information in these files to improve the functionality of our services and in other ways described under the heading “Why do we collect this information” below.

D. Third-party information

In addition to collecting personal information supplied by you, we use unaffiliated third parties to gather data on investors, including prospective investors, from financial institutions, consumer reporting agencies, and other information service providers for purposes described under the heading “Why do we collect this information” below. By using Funding Circle Investor Services, you grant our unaffiliated, third-party providers the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution or consumer reporting agency according to the terms of such third-party provider’s privacy policy. We do not have access to and do not store the username(s) or password(s) that you use to access your financial institution(s).

2. Why do we collect this information?

Funding Circle may use information we collect about you to:

determine your suitability for a loan investment;
obtain, upon your authorization, a credit report, references, and other information from credit bureaus or other third parties;
verify your identity, and create, manage and monitor your Funding Circle account and update your records;
process your payments and other transactions;
develop and improve our websites, products, and services;
improve customer acquisition through the use of advertising campaigns and other means, such as targeted marketing;
enforce our agreements;
carry out statistical analysis and market research and testing;
comply with our legal and regulatory obligations, and carry out regulatory checks;
make our websites available to you and identify products and services you may be interested in; and/or
send or facilitate communications with you.

Important Information About Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you:

When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

3. How and when is your information shared with other parties?

Your information, as collected by or provided to us, may be shared by us with other parties as provided below.

Your information may be shared:

With our affiliates, or any third party who acquires all (or substantially all) of our business and/or assets in connection with an acquisition.
In order to operate our marketplace lending platform.
In order to provide, operate and improve Funding Circle Investor Services, including, but not limited to:

With unaffiliated third parties (Trusted Partners) who assist us in operating our websites, providing market research and marketing our products and services, or servicing our loans, so long as the Trusted Partner contractually agrees to keep such information confidential.
With your representative(s) to the extent such a representative assists or assisted you with the investor eligibility process.

In order to enable Funding Circle to carry out our services and conduct our businesses, such as marketing, loan servicing, and collections activities, including, but not limited to:

With credit bureaus, consumer reporting agencies, financial institutions, collections agencies, and fraud prevention agencies.

For legal reasons, including, but not limited to:

When required by applicable law.
With law enforcement or other government bodies, such as to comply with subpoenas, bankruptcy proceedings, or similar legal processes or for the purposes of limiting fraud.
When we believe sharing such information is necessary to enforce our site policies or any investor agreement, protect our or other’s rights, property, or safety, and/or to comply with a judicial proceeding, court order, or legal process.

In aggregated form, with third parties for marketing, advertising, research, or other business purposes.

We may continue to share your information as described in this Investor Privacy Policy after your use of Funding Circle Investor Services has ended. However, you retain all the rights listed in this Investor Privacy Policy on an ongoing basis, regardless of your status as a current or previous user of Funding Circle Investor Services. Notwithstanding any other provision in the Investor Privacy Policy, we may share your information with your consent.

4. Do we sell your personal information?

We will never sell or rent your personal information to any third party unless we have your consent. And, if you do consent, but later change your mind, you may contact us directly using the details described under the heading Contacting us below and we will stop any such activity as soon as is reasonably practicable.

5. Storage and security

While we take appropriate physical, technical and organizational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties, incorrectly delivered, or fail to deliver.

The personally identifiable information that you provide and that we collect will be stored and maintained by Funding Circle for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) for which such information was collected, in accordance with this Investor Privacy Policy, or (b) to comply with applicable laws, contracts or other rules or regulations.

6. Your rights

You have the following rights:

To update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and
To opt out of any marketing communications that we or any Trusted Partner to whom we have disclosed your personal information may send you.

If you wish to exercise any of the above rights, please contact us using the details specified under the heading Contacting us below.

Please note that the Fair Credit Report Act (FCRA) requires each of the nationwide credit reporting agencies—Equifax, Experian, and TransUnion—to provide you with a free copy of your credit report, at your request, once every 12 months. For more information, visit: http://www.ftc.gov.

7. Links to other sites

Our websites may offer links to sites of other companies and associations. While we may monitor the quality of content provided on these sites, these external sites are not subject to this Investor Privacy Policy and we have no control over their content. Please carefully review the policies of these sites before providing any personal information.

8. Children’s Online Privacy Protection Act

We comply with the requirements of the Children’s Online Privacy Protection Act. We do not knowingly collect personal information from children under the age of the 13. Our websites, products, and services are all directed to people who are at least 13 years of age or older.

9. Contacting us

If you have any questions regarding this Investor Privacy Policy, you may contact us using the information below.

Address:

Funding Circle
85 2nd Street, Suite 400
San Francisco, CA 94105
Attn: Legal Department

Telephone: (855) 849-1940 (Mon – Fri, 7:30am – 5:30pm PT)
Email: support@fundingcircle-invest.com