Last Updated: September 13, 2019
This Policy is incorporated by reference into our Terms of Service.
Types of Information We Collect on the Service:
Information you provide. When you use the Service, you may provide and we may collect personal information from you such as contact information (e.g., your name, email address, mailing address, and phone number), social security number, financial information (e.g., your bank routing numbers and other billing information), demographic information (e.g., age, education, and geographic location), and preferences. You may provide us with personal information in various ways on the Service. For example, you provide us with personal information when you apply for a loan, use the Service, or send us customer service-related requests.
Automatically Collected Information. We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically-collected information may include your IP address or other device address or ID, web browser, device type, the features of the apps you use, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users and may be associated with your personal information.
Third-Party Web Beacons and Buttons. We may also implement third-party content or advertising on the Service that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third party content on the Service. We may implement third-party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about you through such third parties’ browser cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and we do not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
Information from Other Sources. We may obtain information, including personal information, from third parties and sources other than the Service, such as our advertisers and partners (including through referrals of borrower applications). One of our partners, LendingClub Corporation (“Lending Club”), provides us with application information from certain small business borrowers who fulfill our credit requirements. This application information may include all personal information provided during the third-party application process. The information Lending Club and other third-party partners provide us will be governed by this Policy.
If we combine or associate information from other sources with personal information that we collect through the Service, we will treat the combined information as personal information in accordance with this Policy.
How We Use the Information We Collect
We use information we collect on the Service in a variety of ways, including the following:
- to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions, and otherwise to provide support to users.
- to analyze credit history, to enable financial service partners to implement automatic payments and fund transfers, to engage in collection activities as needed, and to contact users regarding transactions and their accounts.
- to extend pre-approved credit offers to certain applicants.
- to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.
- to contact you for administrative purposes such as customer service or send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. See the section below entitled “Your Choices” for information on how to opt-out of receiving promotional communications.
- to (i) personalize our Service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.
When We Disclose Information
We will share your personal information with third parties only in the ways we described in this Policy. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
- We work with numerous third parties that perform vital functions as part of our operations, including credit bureaus, collection agencies, electronic payment service providers, customer support call centers, and other third-party service providers. We share information with these parties only to the extent necessary to process customer transactions or to perform other specific services, like collections or identity verification.
- We work with third-party service providers that provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
- If you reached us through Lending Club or another third-party partner, we may send information back to the third-party partner, including which applications we have approved or denied, as well as performance of the associated loans.
- We may make certain automatically-collected, aggregated, or otherwise non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Service.
- We may disclose your information if we are required to do so by law or in good-faith believe the action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, to comply with bankruptcy proceedings, or to otherwise cooperate with law enforcement or other governmental agencies.
- We also reserve the right to disclose your information we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
- We may disclose and otherwise transfer information about our users, including personal information. to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
You may decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. If you wish to access or amend any personal information we hold about you, you may contact us at firstname.lastname@example.org. Your ability to amend your information will depend on your account type and account status. Any changes you make will be reflected in active user databases within a reasonable period. We may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by email at email@example.com or by writing to us at the address given at the end of this Policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted out from during that period. You will continue to receive administrative messages from us regarding the Service if you opt-out from receiving commercial messages from us.
We do not specifically respond to Do Not Track (“DNT”) signals. Some third-party websites do keep track of your browsing activities, including across other websites on the Internet, which enables these websites to tailor what they present to you. Your browser may allow you to set a DNT signal on your browser so that these third parties know you do not want to be tracked.
The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
The Service and products or services available through the Service are not intended for children under the age of 13. We request that persons under the age of 18 not use the Service without supervision from a responsible adult. If we knowingly receive a child’s personally identifiable information, we will immediately delete it from our system, review the circumstances and adjust controls as necessary to prevent recurrence. Contact us at the address or phone number at the bottom of this Policy if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13. You may also contact us at firstname.lastname@example.org.
We use certain physical, administrative, and technical safeguards to improve the integrity and security of personal data that we collect and maintain. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Service if a security breach occurs.
Although we may allow you to adjust your privacy settings to limit access to certain personal information, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. We cannot control the actions of other users with whom you may choose to share your information. Even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us as email@example.com.
The Service is hosted in the United States and is intended for visitors located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including personal information, on or to the Service, you consent to such transfer, storage, and processing.
Transfers to Other Countries
We may transfer information to other countries, for example, for customer service or to process transactions. We will protect your information as described in this Policy if your information is transferred to other countries. By using the Service, you consent to your information being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that the Service is appropriate or available in any particular jurisdiction.
Changes to this Policy
We may update this Policy to reflect changes to our information collection or retention practices. When we update this Policy, we will revise the “Effective Date” above and post the new Policy. We encourage you to periodically review this page for the latest information on our privacy practices.
Your California Privacy Rights
Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information (as defined by the statute) to any third parties for their direct marketing purposes. We will not sell or transfer customer personal information to third parties for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this statute or who have questions more generally about this Policy and our privacy commitments to our customers and Service users should not hesitate to contact us at the address below.
Accion Opportunity Fund / Opportunity Fund Community Development
111 W. St. John Street, Suite 800
San Jose CA 95113
Telephone: (408) 297-0204
Fax: (408) 297-4599