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United States This Privacy Policy has been updated effective January 1, 2023
This privacy policy (this "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 (collectively, "Funding Circle," "we", "us", or "our"), via our website at www.fundingcircle.com and its subdomains or any other website operated by us that display this Privacy Policy, by our mobile application, or by telephone, facsimile, email, or other means (collectively, and together with our website, "Funding Circle Services").
We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when business owners, designated agents, or other users of the Funding Circle services (collectively, “you”) use our website or any other Funding Circle Services.
Please read this Privacy Policy carefully. By accessing and using this website or any other Funding Circle Services, you confirm that you have read and understand this Privacy Policy in its entirety. You understand and acknowledge that we reserve the right to change or amend this 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 Privacy Policy. If any material changes are made to this 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.
Please also visit our Terms of Use which establish the rules, disclaimers, and limitations of liability governing your use of our website.
Funding Circle collects information when you use Funding Circle Services and supplied by you or your designated agent. When you use or websites or otherwise communicate with us, we may collect personal information that you provide to us, such as your name, date of birth, contact details, and business information.
If you apply for a loan for your business through the Funding Circle Services, we may collect the following types of information during the application process (as applicable):
| Borrowers |
|---|
| Individual and business names |
| Business and home address |
| Phone and e-mail details, including passwords |
| Bank account information |
| Date of birth |
| Social security number, drivers' 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 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 http://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/us/about/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 www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu, https://youradchoices.ca/choices, and 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 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 third parties to process your business loan. In addition to collecting personal information supplied by you or your designated agent, we use unaffiliated third parties to gather data on borrowers and prospective borrowers, 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:
By using Funding Circle Services and applying for a loan for your business, you acknowledge that our 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:
Important Information About Procedures for Applying a for New Loan
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 the business and each person who owns the business.
What this means for you:
When you apply for a business loan with us, we will ask for information about the owners of your business including their name, address, date of birth and other information that will allow us to identify them. We may also ask to see your driver's license or other identifying documents.
Your information, as collected by or provided to us, may be disclosed by us to the following categories of third parties:
In addition to the disclosures outlined above, we may disclose 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 Privacy Policy, or (b) to comply with applicable laws, contracts or other rules or regulations.
In accordance with applicable law, you may opt out of receiving marketing emails from us. If you wish to opt out of receiving marketing emails from us, please use the unsubscribe mechanism contained in each of our marketing emails or 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 https://www.ftc.gov.
Residents of California have additional rights described in the California Consumer Privacy Act Addendum provided below.
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 Privacy Policy and we have no control over their content. Please carefully review the policies of these sites before providing any personal information.
We do not knowingly collect personal information from children under the age of 13. 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 have any questions regarding this 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: (855) 385-5356, extension 3 (Mon - Fri, 8:00am – 5:00pm MT)
Email: us_data_request@fundingcircle.com
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), we provide this California Consumer Privacy Act Addendum (the “CCPA Addendum”) to California residents (“you”). This CCPA Addendum supplements the information contained in our Privacy Policy (“Privacy Policy”).
This CCPA Addendum does not apply to information we collect about individuals in their capacity as present or former job applicants, employees, contractors, shareholders, directors, or officers of Funding Circle.
Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular individual or household. “Personal Information” does not include publicly-available information, deidentified or aggregated information, or information covered by certain sector-specific privacy laws. “Sensitive Personal Information” refers to information that reveals social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless Funding Circle is the intended recipient of the communication; genetic data; and biometric information.
In the following charts, we identify (1) the categories of Personal Information and Sensitive Personal Information (as listed in the CCPA) that we plan to collect and use, and have collected and used within the preceding 12 months; (2) the categories of recipients to which we have disclosed each category of Personal Information or Sensitive Personal Information for our operational business purposes within the preceding 12 months; (3) the criteria we use to determine the retention period for each category of Personal Information or Sensitive Personal Information; and (4) the categories of Personal Information and Sensitive Personal Information we have sold or shared within the preceding 12 months, as “sale” and “sharing” are defined in the CCPA.
We do not sell Personal Information in the traditional sense of exchanging information for monetary payment. However, because the definitions of “Sale” and “Sharing” under the CCPA are defined broadly, and may include the disclosure of information to certain types of advertising and marketing partners and the disclosure of loan application information to investors and loan partners to facilitate our marketplace lending services, we provide California residents with the right to opt-out of any such Sale or Sharing of their Personal Information. For example, in an effort to provide you with additional business loan options, Funding Circle shares certain details of an application with Loan Partners to determine if the Loan Partner would be able to offer you a business loan. We do not knowingly Sell or Share the Personal Information of anyone under 16 years old.
Category | Examples | Category of Third Parties Information is Disclosed to for Operational Business Purposes | Retention Period Criteria | Sold or Shared? If so, to Which Categories of Third Parties? |
|---|---|---|---|---|
Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. |
| We use the following criteria to determine the period of time for which we retain each category of Personal Information:
| Yes
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, or bank account information. |
| See above | Yes
|
Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| See above | Yes
|
Internet or other electronic network activity | Browsing history, search history, information on interaction with an internet website, application, or advertisement. |
| See above | Yes
|
Professional or employment-related information | Current or past job history or performance evaluations. |
| See above | Yes
|
Inferences drawn from other personal information to create a profile | Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
| See above | Yes
|
Below, we provide this information related to Sensitive Personal Information:
Category | Examples | Category of Third Parties Information is Disclosed to for Operational Business Purposes | Retention Period Criteria | Sold or Shared? If so, to Which Categories of Third Parties? |
|---|---|---|---|---|
Identification numbers | Social security, driver’s license, state identification card, or passport number. |
| We use the following criteria to determine the period of time for which we retain each category of Personal Information:
| Yes
|
Login | Account log-in, financial account, debit card, or credit card number in combination with any required security or access codes, or credentials allowing access to an account. |
| See above | Yes
|
Precise geolocation | Data that is derived from a device and that is used or intended to be used to locate an individual within a geographic area of 1,850 feet. |
| See above | No |
Protected classification characteristics under California or federal law | Age (40 years or older), gender. |
| See above | Yes
|
We obtain the categories of Personal Information listed above (including Sensitive Personal Information) directly from you or from devices on which you use Funding Circle Services, as well as from the following categories of sources: third-party services, publicly-available databases, third-party businesses, investors, financial partners, social networking sites, and other third-party sources.
We use Personal Information (including Sensitive Personal Information) for a variety of business and commercial purposes, as described in our Privacy Policy above.
California residents may make the following types of requests under the CCPA:
You may request that we disclose the following information to you about our collection and use of your Personal Information (including Sensitive Personal Information) over the past twelve (12) months or other CCPA-specified period: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which we collected this Personal Information; (3) the categories of Personal Information that we have sold, shared, or disclosed to third parties, (4) the categories of recipients to whom this information was sold, shared, or disclosed; (5) the business or commercial purpose for selling, sharing, or disclosing Personal Information; and (6) the specific pieces of information we collected about you. You may request information collected about you after January 1, 2022, beyond this twelve (12) month period, subject to applicable law.
You may request that we delete Personal Information that we have collected from you. We may limit or deny your deletion request in certain cases, in accordance with exceptions specified in the CCPA.
You may request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
You may submit a Request to Know, Request to Delete, and/or Request to Correct by emailing us_data_request@fundingcircle.com or at https://fundingcircle.com/us/ccpa/.
We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as business name, business address, business tax identification, number, loan number, and phone number, and additional email addresses, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.
You may opt-out of the Sale or Sharing of Personal Information.
To opt-out of Sale or Sharing, please visit our “Do Not Sell or Share My Personal Information” page https://fundingcircle.com/us/ccpa/.
To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include proof of your registration with the California Secretary of State to conduct business in California; and/or a power of attorney from the California resident pursuant to Probate Code sections 4121-4130.
If you are making a Request to Know, Request to Delete, or Right to Correct on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the Request to Know or Request to Delete.
You have the right to be free from unlawful discriminatory treatment for exercising any of your CCPA rights.
If you have any questions or requests in connection with this CCPA Addendum or other privacy related-matters, please 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: (855) 385-5356, extension 3 (Mon - Fri, 8:00am – 5:00pm MT)
Email: us_data_request@fundingcircle.com