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Lenmo Privacy Policy & Federal Privacy Notice

 

 

Welcome to Lenmo. We believe that consumers deserve the utmost respect when it comes to the privacy of their personal information. This Privacy Policy applies to the Lenmo platform (“Lenmo”, “we,” “us” or “our.”). We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use Lenmo’s websites, services, and mobile applications. This Privacy Policy also explains your choices for managing information preferences, including opting out of certain uses of your personal information. By accessing or using Lenmo’s site or services, you consent to this Privacy Policy. If you have questions or complaints regarding our privacy policy or practices, or if you need assistance in exercising any of your choices under this policy, please contact us at contactus@golenmo.com. This policy applies to all current and former Lenmo customers. Note that, in order to use our services, you must be 18 years of age or older.

INFORMATION LENMO COLLECTS ABOUT YOU

I. Information Provided by You We collect personal information about you that you provide while you use www.golenmo.com or any associated websites, desktop or mobile applications. We collect most of this information during the registration and/or application process for borrowers and investors. Additional information may be gathered during your subsequent use of the site, or when we communicate with you via telephone, email or other means. Certain personal information must be supplied during the investor and/or borrower registration processes in order to meet our legal obligations, verify your identity, determine eligibility for credit, protect against fraud, and complete your transaction. The following categories of information may be collected: Your basic identifying information (for example, your name, address, email, telephone number, and date of birth);

  1. Your Social Security number;
  2. Your employment and income information;
  3. Your bank account information;

For a loan to be used with a merchant or service provider the identity of the merchant or service provider and the name of the party that will receive the good or service;

II. Any personal information you provide us. In addition, we gather names and email addresses of people who contact us with questions. We collect this information only for the purpose of responding to inquiries. If you use our “refer-a-friend” feature, we will collect information from you in order to process your referral request. If you use the comments section of our blog on www.golenmo.com/blog, you should be aware that information you submit is stored there and will be visible to other users of the website.

III. Information Collected From Third Parties When you check your rate for a loan through Lenmo (open a borrower account), we will collect information from credit bureaus and other third parties to determine your eligibility for credit, perform analysis, and assess risks related to your potential loan and help investors determine whether to commit to your loan. We also collect information throughout the life of your loan through Lenmo from credit bureaus and other third parties in order to assess risks associated with your loan and provide information to investors interested in buying or selling your loan or to provide you with marketing offers. If another company refers you to Lenmo or assists you in any way in the application process, we may also collect your information from that company in order to process your application. The following categories of information are generally collected for loan applicants and borrowers:

  1. Your identifying and application information (for example, your name, address, email, telephone number, date of birth, social security number, and employment information);
  2. Your credit score, credit history and other information related to your creditworthiness, identity, and financial transactions;
  3. Your bank account information and recent transactions;
  4. If you applied for a loan to be used with a merchant or service provider, information related to any dispute you submit regarding the merchant or service provider;
  5. If you register as an investor through Lenmo, we will collect information from credit bureaus and other third parties to verify your identity and bank account information and assess risks related to your account.  If another company refers you to Lenmo or assists you in any way in the registration or investing process, we may also collect your information from that company in order to process your registration or request or to update your account information.
  6. Information Gathered Based on Your Activity on the Lenmo Platform

In order to provide services to you, improve our business and maintain records required by law, Lenmo collects information about your transactions and activity. For borrowers, this includes your payment history. For investors, this includes your fund transfers and purchases. For all members, Lenmo collects information about your computer and your visits to www.golenmo.com or the Lenmo phone application, such as your IP address, geographical location, browser type, referral source, length of visit, button clicks and page views.    

IV. Tracking Technologies Cookies and Web Beacons. Lenmo and our marketing partners and service providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. We may receive reports on this activity on an individual and aggregated basis. We use cookies when you sign in to your account to keep track of your personal session, help authenticate your account, and detect fraud. Cookies are also used to gather statistical data, such as which pages are frequently visited, what is downloaded, and the address of sites visited immediately before or after coming to our site. You can control the use of cookies within your web browser. However, if you reject cookies, your ability to use some features or areas of our websites may be limited. Third Party Technologies. We also partner with third parties to manage our advertising on other sites and evaluate our overall site performance. Our third party partner may use technologies such as cookies to gather information about your activities on our websites and other sites in order to provide you advertising based upon your browsing activities and interests or help us track the success of our marketing efforts or overall site performance. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out of certain advertising networks by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

V. Do-Not-Track Signals Lenmo does not process or respond to “do not track” signals or other similar signals whereby a visitor to a website requests that it disable collection of information about the visitor’s online activities over time and across different websites.

HOW LENMO USES YOUR INFORMATION

I. Processing Your Transaction If you register as a borrower, Lenmo will use your information to facilitate your loan or loan request. This may include:

  1. Generating your borrower profile, processing your loan application and verifying your identity and application information;
  2. Assigning you a Lenmo score;
  3. Enabling automatic payments and fund transfers with other financial institutions;
  4. Implementing collection activities as needed;
  5. Communicating with you concerning your Lenmo account and transactions;
  6. Addressing any disputes you may raise concerning your account.

If you register as an individual investor, Lenmo will use your information to facilitate marketplace investing. This may include:

  1. Generating your investor profile;
  2. Enabling automatic payments and fund transfers with other financial institutions;
  3. Communicating with you concerning your Lenmo account and transactions;
  4. Addressing any disputes you may raise concerning your account.
  5. Analysis & Data Optimization

Lenmo also uses your information to conduct analyses related to our services and our websites. We use this information to improve our services and credit model. We also use this information to improve our websites’ usability and to evaluate the success of particular marketing campaigns and other activities.

II. Marketing & Surveys Lenmo may also use your personal information to select you for certain marketing offers, newsletters, surveys and/or requests for feedback regarding your experience. Lenmo may use your personal information both to select you for an offer and to communicate that offer to you.

III. Optional Marketing Communications Receipt of marketing communications via email is voluntary. If you do not wish to receive these communications, please sign into your Lenmo Account, select “Settings” from the drop-down menu, and disable communication types you no longer wish to receive in the section titled “Communication Preferences.” You may also contact us at contactus@golenmo.com  and we will assist you in disabling optional communications.

HOW LENMO SHARES YOUR INFORMATION

We will share your personal information with nonaffiliates (companies not related by common ownership or control) and among affiliates (companies related by common ownership or control, including but not limited to the companies covered by this policy) only in the ways that are described in this privacy policy. By law, you are permitted to limit some types of sharing, but not others. Lenmo shares your information with third parties as permitted by law, including in the following specific ways: Originating Banks. All loans originated through Lenmo are made by a third party bank. If you request a loan through Lenmo, you are also providing your information to the potential originating bank, and further information may be provided to that bank after your loan originates. The use of your information by your originating bank is governed by that bank’s privacy policy. Third Party Service Providers. Lenmo relies on third party service providers to help us conduct our business and marketing activities, such as maintaining our files and records, offering customer service, sending marketing communications, or facilitating fund transfers. Lenmo may share your information with such companies, which are authorized to use your personal information only as necessary to provide these services to Lenmo. Information may also be shared among affiliates (including but not limited to the companies covered by this policy) for this purpose where one affiliated company provides services to or on behalf of another affiliated company in connection with your account. Potential Purchasers of Loan. Lenmo shares your information, including your Lenmo Score, on an anonymous basis to allow potential purchasers to decide whether to commit to your loan. This information is also contained anonymously in loan data files available through Lenmo’s Developer Tools and Marketplace Performance pages. Although your credit information is displayed, your identity is never shared with investors until your loan has been purchased. Purchasers of Loan. If Lenmo sells your loan originated through our platform, we may provide the purchaser of your loan with your personal and credit information. Information is only released to loan purchasers that are qualified financial institutions with adequate protections to safeguard your personal information. Information provided to investors in connection with sales of our fractional Borrower Payment Dependent Notes (“Notes”) will not include personal identifying information. For more information on Notes, please see our Prospectus. Referral Partners. If you were referred to Lenmo by another company (a “Referral Partner”) or person, Lenmo will share your information as necessary to honor the terms of its agreement with that Referral Partner or person and to process your transaction. In some cases, Lenmo may share with a Referral Partner for that Referral Partner’s own business purposes, such as to analyze and improve its business and provide targeted marketing offers to you. Your rights with respect to this sharing are discussed in the following section. Credit Bureaus. Lenmo may share your personal information with credit bureaus to meet our credit reporting obligations. Affiliates. Lenmo affiliates, including entities covered by this policy and other companies related by common ownership or control may share your information with each other, including information related to your creditworthiness, for purposes of general business analysis or to present targeted marketing offers to you or others. Your rights with respect to this sharing are discussed in the following section. Legal Requests & Regulatory Requirements. Lenmo may also share information to comply with, or to allow investors or potential investors to comply with, any applicable law, regulation, legal process or governmental request; or for the purposes of limiting fraud; or in connection with an audit or the sale of Lenmo to a third party. Sharing of Anonymized Data. Lenmo may share aggregated and anonymized data sets including your information with third parties, including but not limited to business partners, service providers, loan purchasers, potential loan purchasers, and among Lenmo affiliates. No personally identifiable information will be included in these data sets.

IMPORTANT PRIVACY CHOICES

Consent to information sharing with third-party companies (Referral Partners): By accepting this privacy policy, you agree that Lenmo may immediately begin sharing your information with any third party company that referred you to Lenmo so that that company may use your information for their own business purposes, including to market to you. For example, if you were referred to Lenmo by another company through a website link or telephone transfer, Lenmo may share some of your information, such as the existence and terms of your loan, with that company. You may revoke this consent at any time by following the procedures outlined below. If you revoke consent we will not subsequently share your information with these companies except as necessary to complete the transaction you initiated. Right to restrict information sharing with companies we own or control (affiliates): Lenmo may share your information among affiliated companies whether or not those companies are covered by this policy. Federal law gives you the right to limit this sharing where it includes information about your creditworthiness other than your transactions and experiences with Lenmo or is used for the purpose of marketing to you. If you would like to opt-out of this type of sharing, please follow the instructions below. We may begin sharing your information related to your creditworthiness or any information to be used for marketing purposes 30 days from the date that we first provided this notice if you have not opted-out. If you would like to exercise your right to opt-out of information sharing by a company affiliated with Lenmo but not covered by this policy, you must consult that company’s privacy policy for instructions on how to exercise your right to opt-out of their information sharing.

ADDITIONAL FACTS ABOUT YOUR PERSONAL INFORMATION

I. How you can change your personal information You can access the personal information you have provided to us by logging in to the “profile” page of your account.  As a registered investor or borrower, you can update your password, email, phone number, or home address at any time.  As a registered borrower, you may update your password, email, phone number, bank account information or mailing address at any time, though certain changes prior to loan origination may require you to submit a new loan application. To change other information, contact us at contactus@golenmo.com. We will respond to your request within a reasonable time. We will retain your information for a minimum of seven years and as long as needed to provide you services, comply with our legal obligations, resolve disputes, conduct analysis, audits, or to enforce our agreements or as otherwise required by law.

II. How Lenmo Secures Your Information Lenmo uses significant safeguards, including physical, technical (electronic), and operational controls to protect your personal information, both during transmission and once received. If you have any questions about the security of your information, you can contact us at contactus@golenmo.com. Lenmo equips all servers with an Extended Validation (EV) Secure Socket Layer (SSL) certificate to ensure that when you download our platform you can tell that you are actually on our site and that all data entered into the platform are transmitted to us in a secure encrypted channel. Once on our system, personal information can only be read or written through defined service access points, the use of which is password-protected. Data security is achieved through technical safeguards that include a combination of encryption, firewalls, intrusion detection system, malware detection system, and data loss prevention systems. Lenmo also conducts vulnerability scans of applications and systems regularly. Access to the system is tightly controlled and limited to only those who have a need to access information. Administrative safeguards such as a security awareness program, background checks, and internal information use policy ensure that only trained and trusted staff are permitted to access personal information. Some additional features of our security program include:

a.     Secure Data Center

We store all sensitive financial information in state-of-the-art, highly secure data centers that are audited per SSAE 16 Type II and/or SOC 2 Type II standards. Physical access to the data centers is strictly controlled and we use the latest threat prevention technologies such as network and web application firewalls, VPN, antivirus, Web filtering and antispam technologies.

b.     Session Time-Outs

We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

c.     Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password. You should always choose a password that is difficult for others to guess and change your password frequently.

III. Additional Steps You Should Take to Ensure the Security of Your Information Lenmo sends important communications regarding your account via email. You should, therefore, take steps to secure and restrict access to your email account and change your email account password frequently. You should also be aware of fraudulent emails known as “phishing,” from companies claiming to be Lenmo and requesting your login information or other account information. Lenmo will never ask for your login information in an email.  

IV. Changes to this policy Any updates to the privacy policy become effective when posted on the websites. If we make any material changes, we will notify you by email or by providing the revised privacy policy in your account on the Lenmo platform. Your continued use of our services following the update means that you accept Lenmo’s updated privacy policy. For additional information, or if you have any questions regarding this policy or the privacy practices at Lenmo, please submit your questions or comments directly to conactus@golenmo.com. You can also send questions or comments to:

Lenmo, Inc.

Attn: Compliance Department

1111 Broadway Suite 300

Oakland, CA 94607

1-844-890-8900

Effective date: July 23, 2018

Federal Privacy Notice Rev. 3/2018

WHAT DOES LENMO DO WITH YOUR PERSONAL INFORMATION?

I. Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

II.  What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  1. Social Security Number and income
  2. Account balances and transaction history
  3. Credit history, credit scores, and employment information

When you are no longer our customer, we continue to share your information as described in this notice   III. How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Lenmo chooses to share; and whether you can limit this sharing.

IV. Reasons we can share your personal information

Privacy policy

Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice (except where we have received your affirmative consent to begin sharing information sooner, through our privacy policy or otherwise). When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? Email us at contactus@golenmo.com or call us at 1-844-890-8900.
V. Other Important Information Telephone Communications: Lenmo and its authorized agents, service providers and partners may monitor and/or record all telephone communications in accordance with applicable law. Vermont Residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Nevada Residents: We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by calling 1-844-890-8900 or emailing contactus@golenmo.com. Nevada law also requires us to provide you with the following to obtain additional information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; Phone: 702.486.3132; Email: BCPINFO@ag.state.nv.us.

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