Last Updated: January 15, 2024
Lending Club Finance LLC ("we," "us," "our," or the "Company"), located at 595 Market St #200, San Francisco, CA 94105, is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website thelendingclub.online, use our services, or apply for a loan.
By accessing our website or submitting an application, you consent to the practices described in this policy. If you do not agree with the terms of this Privacy Policy, please do not access the site or use our services.
1. Information We Collect
We collect information that you provide directly to us, information collected automatically when you use our services, and information from third-party sources.
a) Personal Information You Provide
When you apply for a loan, create an account, or contact us, we may collect the following categories of personal information:
- Identity Information: Full legal name, date of birth, Social Security Number (SSN), government-issued identification (driver's license, state ID, passport)
- Contact Information: Email address, phone number, mailing address, residential address
- Financial Information: Annual and monthly income, employment status, employer name and contact information, bank account numbers, routing numbers, credit/debit card information, existing debts and obligations
- Employment Information: Current employer, job title, length of employment, employer phone number, work address
- Banking Information: Bank name, account number, routing number, mobile banking credentials (if voluntarily provided for verification purposes)
- Document Uploads: Copies of identification documents, pay stubs, bank statements, proof of address, debit/credit card images for verification
- Electronic Signature Data: Digital signatures, selfie photographs for identity verification, IP address at time of signing, geolocation data, browser and device information
b) Information Collected Automatically
When you visit our website, we automatically collect certain information about your device and usage, including:
- Device Information: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution
- Usage Data: Pages visited, time spent on pages, click patterns, referring website, date and time of access
- Location Data: Approximate geographic location based on IP address; precise location only when you grant permission during agreement signing
- Cookies and Similar Technologies: Session cookies, persistent cookies, web beacons, and pixel tags (see Section 6 for details)
c) Information from Third Parties
We may receive information about you from third-party sources, including:
- Credit reporting agencies (credit reports, credit scores, payment history)
- Identity verification services
- Fraud prevention databases
- Public records and databases
- Marketing partners and advertising networks
2. How We Use Your Information
We use the information we collect for the following purposes:
a) Loan Processing and Servicing
- Evaluate and process your loan application
- Verify your identity, income, and employment
- Perform credit checks and assess creditworthiness
- Determine loan eligibility, amounts, interest rates, and terms
- Generate and manage loan agreements
- Process loan disbursements and repayments
- Set up and manage automatic payment deductions
- Service your loan account throughout the loan term
b) Communication
- Send application confirmations and status updates
- Deliver loan agreements and related documents
- Send payment reminders and account notifications
- Provide verification codes (OTP) for secure transactions
- Respond to your inquiries and customer service requests
- Send SMS notifications about your application and account status
c) Legal and Compliance
- Comply with applicable federal and state laws and regulations
- Fulfill Truth in Lending Act (TILA) disclosure requirements
- Meet anti-money laundering (AML) and Know Your Customer (KYC) obligations
- Respond to legal process, court orders, and government requests
- Detect, prevent, and investigate fraud and unauthorized transactions
- Enforce our terms of service and loan agreements
d) Business Operations
- Improve our website, products, and services
- Analyze usage patterns and trends
- Conduct internal research and analytics
- Maintain records for auditing and reporting purposes
3. Information Sharing and Disclosure
We do not sell your personal information to third parties for marketing purposes. We may share your information in the following circumstances:
a) Service Providers
We share information with trusted third-party service providers who assist us in operating our business, including:
- Email delivery services (for sending notifications and documents)
- SMS messaging providers (for text notifications and verification codes)
- Payment processors (for loan disbursement and collection)
- Cloud storage and hosting providers
- Identity verification and fraud prevention services
- Document management and electronic signature platforms
These service providers are contractually obligated to use your information only for the purposes of providing services to us and are required to maintain the confidentiality and security of your data.
b) Credit Bureaus and Reporting Agencies
We may report your loan payment history, account status, and related information to one or more of the major credit reporting agencies (Equifax, Experian, TransUnion). This reporting may affect your credit score positively or negatively depending on your payment behavior.
c) Legal Requirements
We may disclose your information when required by law, including:
- In response to a subpoena, court order, or other legal process
- To comply with federal or state regulatory requirements
- To cooperate with law enforcement investigations
- To protect our rights, property, or safety, or that of our customers or others
- In connection with a merger, acquisition, or sale of assets
d) With Your Consent
We may share your information with third parties when you have given us explicit consent to do so.
4. Data Security
We take the security of your personal information seriously and implement a variety of measures to protect it:
- Encryption: All data transmitted between your browser and our servers is encrypted using 256-bit SSL/TLS encryption
- Secure Storage: Personal and financial data is stored on secure servers with restricted access controls
- Access Controls: Only authorized personnel with a legitimate business need can access your personal information
- Authentication: Multi-factor authentication (OTP via email and SMS) is required for sensitive operations such as signing loan agreements
- Monitoring: We continuously monitor our systems for potential vulnerabilities and security breaches
- Employee Training: Our staff receives regular training on data protection and privacy best practices
While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to implementing and maintaining reasonable safeguards.
5. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:
- Active Loans: For the duration of your loan term plus 7 years after the loan is fully repaid or closed
- Declined Applications: For up to 3 years from the date of application
- Signed Agreements: Indefinitely, as legal records of the transaction
- Communication Records: For up to 5 years
- Website Usage Data: For up to 2 years
We may retain certain information for longer periods as required by applicable laws, regulations, or for legitimate business purposes such as resolving disputes and enforcing agreements.
6. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience:
a) Types of Cookies We Use
- Essential Cookies: Required for the website to function properly (e.g., session management, form submissions). These cannot be disabled.
- Functional Cookies: Remember your preferences and settings to provide a personalized experience.
- Analytics Cookies: Help us understand how visitors interact with our website, which pages are most popular, and how to improve our services.
b) Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, disabling essential cookies may affect the functionality of our website, particularly the loan application process.
7. Third-Party Links and Services
Our website may contain links to third-party websites, services, or applications that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit. Third-party services we may link to or integrate with include:
- Google Fonts (for website typography)
- Font Awesome (for website icons)
- Google Maps (for office location display)
8. Your Rights and Choices
You have the following rights regarding your personal information:
- Access: You may request a copy of the personal information we hold about you.
- Correction: You may request that we correct any inaccurate or incomplete personal information.
- Deletion: You may request that we delete your personal information, subject to certain legal exceptions (e.g., we must retain records for active loans and regulatory compliance).
- Opt-Out of Communications: You may opt out of receiving promotional emails by clicking the "unsubscribe" link in any marketing email. You may opt out of SMS notifications by replying "STOP" to any text message. Note that transactional communications related to your loan account cannot be opted out of.
- Do Not Track: Our website does not currently respond to "Do Not Track" browser signals.
To exercise any of these rights, please contact us using the information provided in Section 12 below. We will respond to your request within 30 days.
9. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):
- Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting the information, and the categories of third parties with whom we share it.
- Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
- Right to Opt-Out of Sale: We do not sell your personal information. However, if this practice changes, you will have the right to opt out.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
- Right to Correct: You have the right to request correction of inaccurate personal information.
- Right to Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive personal information (such as SSN and financial data) to purposes necessary for providing our services.
To submit a CCPA/CPRA request, please email us at info@thelendingclub.online or call us at +1 (840) 242-7410. We may need to verify your identity before processing your request.
10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we may have collected information from a child under 18, please contact us immediately.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page
- Post the revised policy on our website
- Notify you via email if the changes are significant and you have an active account with us
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our services after any changes constitutes your acceptance of the updated policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Lending Club Finance LLC
595 Market St #200
San Francisco, CA 94105
Phone: +1 (840) 242-7410
Email: info@thelendingclub.online
Business Hours: Monday - Friday, 9:00 AM - 6:00 PM (Pacific Time)
For privacy-specific inquiries, please include "Privacy Request" in the subject line of your email. We aim to respond to all privacy-related requests within 30 calendar days.
