1. What information do we collect from you?
A. Information provided by you
Funding Circle collects information supplied during the application process for borrowers and investors and at various times during your subsequent use of Funding Circle Services, including but not limited to, the following information (as applicable):
|Individual and business names||Name|
|Mailing address||Mailing address|
|Business address||Business address|
|Phone and e-mail details||Phone and e-mail details|
|Bank account information||Bank account information|
|Date of birth||Date of birth|
|Social security number||Social security number|
|Income, assets, debt, and other personal and business data||Income, assets, debt, and other financial data|
|Comments you make on blogs and discussion forums on the website||Comments you make on blogs and discussion forums on the website|
|Correspondence with us including by email, post facsimile, and telephone||Correspondence with us including by email, post facsimile, and telephone|
B. Cookies and tracking technologies
When you use Funding Circle 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. To the extent that they do offer an opt-out of targeted advertising, you may do so here. 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 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
2. Why do we collect this information?
Funding Circle may use information we collect about you to:
- determine your eligibility for a loan or suitability for a loan investment, as applicable;
- obtain, upon your authorization, a credit report, references, and other information from credit bureaus or other third parties in connection with your loan application;
- verify your identity;
- detect and guard against potential fraud and identity theft;
- manage and monitor your Funding Circle account and update your records;
- create a marketplace loan listing on the Funding Circle website, which includes a Funding Circle credit grade that is based on your credit history and financial circumstances;
- process your payments and other transactions;
- develop and improve our website, 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 website available to you and identify products and services you may be interested in; and/or
- send or facilitate communications with you.
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, including:
- To make available a loan listing to prospective investors.
- To make available additional loan and/or borrower information to investors who invest in a loan.
- To otherwise make available to prospective investors who are contractually required to implement safeguards to protect and maintain the confidentiality of the information we share.
- In order to provide, operate and improve Funding Circle Services, including, but not limited to:
- With unaffiliated third parties (“Trusted Partners”) who assist us in operating our website, 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 loan application or investor eligibility process (as applicable). Such information may include, amoung others, information about your loan performance.
- In order to enable Funding Circle to carry out our services and conduct our businesses, such as marketing, lending, loan servicing, and collections activities, including, but not limited to:
- With credit bureaus, consumer reporting agencies, financial institutions, collections agencies, and fraud prevention agencies in order to, among other things, perform various checks, locate borrowers, or recover debts.
- With business credit bureaus to report loan performance.
- In order to provide other services to borrowers or prospective borrowers, including, but not limited to:
- With third parties who may be able to help prospective borrowers secure credit, after we receive your consent.
- With a borrower’s franchisor (if applicable).
- 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 loan 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.
4. What will be displayed when a borrower’s loan lists on the Funding Circle website?
When a loan is approved, we will make available certain information about the loan and the borrower to prospective investors. This information may include business information, business financials, loan terms, and other loan information, as shown below.
|Business Information||Loan Information|
|Business Name||Business Bankruptcy|
|“Friendly” Listing Name||Date of Business Bankruptcy|
|Years of Operation||Debt Coverage Ratio|
|Industry||Asset Coverage Ratio|
|NAICS Code||Number of Guarantors|
|Business Location–City & State||Credit Score of Guarantor|
|Business activity||Part of Franchise Network|
|State of Incorporation||Prior Loan(s) with FC|
|Number of Employees||Amortization Table|
|Business Financials||Loan Terms|
|Income Statement||Loan Principal Amount|
|Balance Sheet||Interest Rate|
|FC Credit Rating|
5. 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.
6. 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.
7. 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.
8. Links to other sites
9. 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 website, products, and services are all directed to people who are at least 13 years of age or older.
10. Contacting us
747 Front Street, Floor 4
San Francisco, CA 94111