Lenmo Inc., a Delaware corporation, (“Lenmo” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:
- The types of information we may collect or that you may provide when you create a Lenmo account or use the Lenmo platform and related services, whether through a mobile or desktop application (collectively, the “Platform”).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect:
- When you create a Lenmo account or access the Platform.
- In email, text, and other electronic communications sent through the Platform.
Lenmo works with a number of business partners that perform essential functions as part of our operations, including credit bureaus, electronic payment service providers and collection agencies. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services, like collections. Our business partners are legally required to keep your information private and secure. In addition, since all loans originated through Lenmo are made directly to borrowers by lender participants on the Platform, if you request a loan, certain information will be shared with potential lenders on the Platform.
This policy DOES NOT apply to information that:
- We collect offline or on any other websites you may access through the Platform.
- You provide to, or is collected by, any third party.
These third parties have their own privacy policies, which we encourage you to read before providing information on or through them. While we do our best to ensure your privacy, we cannot be responsible for the privacy practices of third parties.
Information We Collect and How We Collect It
We collect information from and about users of the Platform:
- Directly from you when you provide it to us.
- Automatically when you use the Platform.
- From external sources, such as your Facebook, Google or Twitter account (each, an “External Source”).
- From third-party vendors or business partners.
Information You Provide to Us
When you create an account, or use the Platform, we may ask you to provide information by which you may be personally identified, including:
- Your contact information, such as your name, email address, mailing address, telephone number.
- Your date of birth, social security number; bank account information (including account and routing numbers) and proof of identification (like a driver’s license).
- Information about your employer, current income, assets, and certain expenses, including, without limitation, tax returns, W-2, brokerage statements, and pay stubs.
- Information an External Source makes available to us based on your privacy settings in the External Source, such as your name and email address; or any other identifier by which you may be contacted online or offline (all of the above, collectively, “Your Personal Information”).
In addition, other types of information you may provide to us include:
- The information you post, upload, display, transmit to other users, or otherwise make available on the Platform (collectively, “Content”).
- Information we may request when you report a problem with the Platform.
- Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
- Details of transactions you carry out on the Platform, such as loan requests you make or loans you extend. You may be required to provide financial information before extending any loans through the Platform.
The Platform may, in certain circumstances, allow you to share Content with others. As a result, some of your Content may be shared publicly or with third parties. Although you may set privacy settings for certain information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Content is transmitted to others at your own risk. We cannot control the actions of third parties who have access to your Content and therefore, cannot and do not guarantee that such Content will not be viewed by unauthorized persons.
Automatic Information Collection and Tracking
When you download, access, and use the Platform, it may use technology to automatically collect:
- Usage Details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including location data, logs, and other communication data and the resources that you access and use on or through the Platform.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Stored Information and Files. The Platform also may access metadata and other information associated with other files stored on your device.
- Location Information. The Platform collects real-time information about the location of your device.
If you do not want us to collect this information you may opt out at any time through your device’s privacy settings. For more information, see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
- Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your mobile device. However, if you select this setting you may be unable to access certain parts of the Platform.
- Web Beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Lenmo, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Information we Receive from Third Parties; Third Party Information Collection
We may receive information about you from third parties, including information we request on your behalf, in the case of borrowers, from credit reporting agencies such as TransUnion, Equifax, and/or Experian and, in the case of lenders, from third parties to verify your status as an “accredited investor.” We may also work with different third-party data partners to supplement the information we collect directly from you for fraud or identity verification purposes. We may also receive information about you if you access the Platform through a third-party connection or log-in, such as Facebook or a referral partner, or otherwise link an account to the Platform, that third party may pass certain information about you and your use of its service to us which you have permitted the third party to share with us, and any information you have made public in connection with that service. For example, if you access the Platform through your Facebook account, Facebook will provide the data regarding who your “friends” on Facebook are, and the Platform will identify other users on the Platform that are your friends. Similarly, your friends that access the Platform via Facebook will see that your user account on the Platform is designated as one of their friends on Facebook. You should always review and, if necessary, adjust your privacy settings on third-party websites, applications and services before linking them to the Platform. You may also unlink your third-party account from the Platform by adjusting your settings on the third-party service. If you unlink your third-party account, we will remove the information collected about you in connection with that service.
When you use the Platform or access its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
- Advertisers, ad networks, and ad servers.
- Content and application providers.
- Analytics companies.
- Your mobile device manufacturer.
- Your mobile service provider.
Our Platform may include social media features, such as the Facebook Like button, Google Plus, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Platform, and they may set a cookie or employ other tracking technologies.
In addition, we display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Platform while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
We do not control these third parties’ tracking technologies or how they may be used. Information collected by third parties is governed by their privacy practices. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below.
Children Under the Age of 13
The Platform is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please immediately contact us at firstname.lastname@example.org.
How We Use Your Information
Generally, we use information that we collect about you or that you provide to us, including Your Personal Information, to:
- Enable you to login and create a profile on the website.
- Verify your age and identity.
- Guard against potential fraud.
- Operate, develop, provide and improve the Platform and its contents, and to research and develop new services.
- Enable our financial services partners to implement automatic clearing house (ACH) payments and fund transfers.
- Fulfill any purpose for which you provide it. For example, allowing you to add and save new bank account information to your account.
- Provide you with notices (i) about your account, (ii) when updates to the Platform are available, and (iii) of changes to the Platform.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and Lenmo or any other user, including for billing and collection.
- Contact you if there is a problem completing a transaction you requested or to discuss a problem with your account.
More specifically, when you register as a borrower participant on the Platform, we will use Your Personal Information to:
- Obtain your credit report from one or more credit bureaus; and
- Assign you a borrower score, using our proprietary algorithm, based upon Your Personal Information, information included in your credit report and your account history for loans you have previously received on the Platform (your “Lenmo Platform Score”).
Any part of your credit report (other than your identity) including, but not limited to, your VantageScore 4.0 credit score, your debt-to-income ratio, your annual income and account history, as well as your Lenmo Platform Score, will be shared with lender participants on the Platform to help such potential lenders to assess your loan request in the context of your overall financial situation. For privacy purposes, borrower participants and lender participants remain anonymous on the Platform and are identified only by the initials of their names. However, we may disclose information related to the identity of borrower participants who are in default under the terms of any loan they receive, either to third-party collection agencies or to the lender participant who funded the loan.
In addition, when you register as a lender participant on the Platform, we may request additional information or documentation in order to verify you meet certain eligibility requirements under applicable law including, but not limited to, your status as an “accredited investor.”
The usage information we collect helps us to improve the Platform and to deliver a better and more personalized experience by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize the Platform according to your individual interests.
- Speed up your use of the Platform.
- Recognize you when you use the Platform.
We may use location information we collect to identify areas to advertise or ways promote the Platform, to verify the identity of Platform participants, and for other business reasons.
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see “Your Choices About Our Collection, Use, and Disclosure of Your Information” below.
We may use the information we collect to display advertisements to our advertisers’ or business partners’ target audiences. Even though we do not disclose Your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose Your Personal Information that we collect or that you provide:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties that we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Lenmo’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Lenmo about users of the Platform is among the assets transferred.
- To third parties to market their products or Platforms to you if you have not opted out of these disclosures. [We contractually require these third parties to keep Your Personal Information confidential and use it only for the purposes for which we disclose it to them.] For more information, see “Your Choices About Our Collection, Use, and Disclosure of Your Information”
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To respond to your request for customer service.
- If we believe in good faith that such disclosure is necessary or appropriate to protect the rights, property, or safety of Lenmo, or any other person. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding Your Personal Information. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
- Targeted Advertising by Lenmo. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ or business partners’ target-audience preferences, you can opt-out by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email to email@example.com.
- Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email to firstname.lastname@example.org. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative (NAI) online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance (DAA) resources at http://www.aboutads.info/choices.
Accessing and Correcting Your Personal Information
You can review Your Personal Information by logging into the Platform and visiting your account profile page.
You may also send us an email at email@example.com to request access, or a change, to Your Personal Information. We cannot delete Your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We reserve the right to verify your identity in connection with any request regarding Your Personal Information to help ensure that we provide the information we maintain to the individual to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
Your Privacy Rights
California Residents: California Civil Code Section 1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of Your Personal Information to our affiliates or third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at: Attn: Legal Department, Lenmo Inc., 1111 Broadway Suite 300, Oakland, CA 94607.
Vermont Residents: We will not share information we collect about you with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account.
Nevada Residents: We provide you this notice under Nevada state law. You may be placed on our internal Do-Not-Call List by emailing us at email@example.com, or writing us at: Attn: Legal Department, Lenmo Inc., 1111 Broadway Suite 300, Oakland, CA 94607.
Nevada law also requires us to provide you the following to obtain additional information:
Office of the Attorney General
100 North Carson Street
Carson City, NV 89701
We have implemented measures designed to secure Your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and credit report information will be encrypted using SSL technology. In addition, we employ session time-outs that will log you out of the Platform automatically after a period of inactivity. This reduces the risk of others being able to access your account if you leave your computer unattended.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to any part of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect Your Personal Information, we cannot guarantee the security of Your Personal Information transmitted through the Platform. Any transmission of Your Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Our retention periods for Your Personal Information are based on business needs and legal requirements. We retain Your Personal Information for as long as is necessary for the purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. When we no longer need Your Personal Information or aren’t otherwise required by law to retain such information, we either irreversibly anonymize the information (in which case, we may further retain and use the anonymized information) or securely destroy the information. In addition, Federal and state agencies may require that we provide aggregated demographic and loan funding information about the borrower participants on our Platform.
Communications from Us
When you register on our Platform, you will receive emails that confirm specific actions you requested. For example, you will receive notifications confirming (i) your registration, (ii) the successful verification of email addresses and bank accounts, (iii) the confirmation of successful submissions of loan requests and loan closings, and (iv) for other legal or security purposes. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any emails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and Platform operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback e-mails, you may opt out by writing to firstname.lastname@example.org or by following the unsubscribe instructions located at the bottom of each email communication.
Attn: Legal Department
1111 Broadway Suite 300
Oakland, CA 94607
Or email us at: