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United StatesThis Investor Privacy Policy has been updated effective December 22, 2020
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 https://www.fundingcircle.com/us/invest, https://www.fundingcircle.com/us/investors, https://investor-portal.fundingcircle.us/us/investors, and their subdomains, by our mobile application, 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 and understand 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 as required by applicable law. You understand that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
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.
Funding Circle collects information when you use Funding Circle Services and supplied by you or your designated agent during the investor application process, including but not limited to, the following information (as applicable):
| Investors |
|---|
| Full Name |
| Mailing Address |
| Business Address |
| Phone and e-mail details, including passwords |
| Bank account information |
| Date of birth |
| Social security number, driver’s license, or other government IDs |
| Income, assets, debt, and other personal and business data |
| Other information provided in correspondence with us including by email, post, facsimile, and telephone |
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 (collectively, “Technologies”). These Technologies help 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.
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services, to provide tailored advertising, and to evaluate our marketing efforts. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
We do not process “do not track” (DNT) signals. For more information on our use of cookies, including instructions on how to opt out, please visit https://www.fundingcircle.com/about-us/cookie-policy.
You may stop or restrict the placement of tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, https://www.youronlinechoices.eu/, http://youradchoices.ca/choices/, and https://www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings menu to exercise this choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
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, MAC address, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, 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.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
Information from financial partners to process loans. In addition to collecting personal information supplied by you or your designated agent, 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.
This information includes the categories of information described above, and also includes:
Government IDs
Criminal records
Household records
Employment information, such as visa permit number
By using Funding Circle Investor Services, you acknowledge that unaffiliated, third-party providers will have 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.
Funding Circle may use information we collect about you to:
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.
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.
We do not “sell” your personal information as the term is defined under the California Consumer Privacy Act (CCPA), nor have we sold personal information in the preceding 12 months. Your information, as collected by or provided to us, may be shared by us (currently and in the preceding 12 months) with the following categories of third parties:
Category | Examples | Category of Third Parties Information is Disclosed to |
Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, address, telephone number, driver's license or state identification card number, bank account information. |
|
Protected classification characteristics under California or federal law | Age (40 years or older). |
|
Records of Personal Property | Records of personal property (current and past addresses) |
|
Professional or employment-related information | Current or past job history. |
|
In addition to the sharing outlined above, we may share any information we maintain about you with the following parties:
International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
While we take appropriate physical, technical and organizational measures to safeguard the personal information that you provide to us, unfortunately no system is 100% secure. To the fullest extent permitted by applicable law, we accept no liability if communications are unintentionally disclosed, 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.
In accordance with applicable law, you may have the right, subject to verification of your identity:
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 service provider to whom we have disclosed your personal information may send you.
To request deletion of your personal information, subject to certain exceptions prescribed by law.
To request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you wish to exercise any of the above rights, please contact us using the details specified under the heading “Contacting us” below. Note that we will require you to take steps to verify your identity before you may exercise the rights listed above such as by requesting you provide us with your account information, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to out customer support staff, as required by applicable law.
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: https://www.ftc.gov.
Our websites may offer links to sites of other companies and associations. While we 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.
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 nor do we have actual knowledge of any sale of personal information of minors under 16 years of age, as the term “sale” is defined under the CCPA. Our websites, products, and services are all directed to people who are at least 13 years of age or older.
If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
If you have any questions regarding this Investor Privacy Policy, you may contact us using the information below.
Address:
Funding Circle USA, Inc.
Attn: Data Protection Officer
707 17th Street, Suite 2200
Denver, CO, USA 80202
USA
Telephone: (877) 226-9058 (Mon – Fri, 7:30am – 4:30pm PT)
Email us: us_data_request@fundingcircle.com
