This document was last updated on April 1st 2020
What is Personal Information?
What Personal Information do we Collect?
We may collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:
In addition, we may collect your personal information in connection with the financial-related services that you may seek from us, including for example, having us suggest the credit cards, loans and other financial products that, based on (i) our experience and (ii) the information you provide to us, will most likely accept you.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.
From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
Privacy and our Website
You can visit our website without telling us who you are or revealing any information about yourself, including your e-mail address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.
In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:
Where you request information from us, we may use the e-mail address that you provide to send you information about offers on products and services that we believe may be of interest to you. If you have asked us to put you on an e-mail mailing list, provide you with certain information on a regular basis, or if we send you information about our offers on products and services by e-mail, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each e-mail and on the site where you signed up).
Our Website and Cookies
When you visit the website, we place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs.
Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.
Blocking cookies in your browser
Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.
Blocking advertising ID use in your mobile settings
Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers
You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins.
What about Third Party Websites?
Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. LendingArch is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
Why Do We Collect Personal Information?
LendingArch collects personal information to enable us to manage, maintain, and develop our business and operations, including:
How Do We Use and Disclose Your Personal Information?
We may use or disclose your personal information:
In addition, we may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When do we Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that assist LendingArch in the provision of services to you and third parties whose services we use to conduct our business.
Such third parties may include lenders and dealerships who may wish to provide you with goods or services. They may also include related parties who process and store your personal information for us.
For example, our third party service providers may provide certain information technology, data processing, and advertising/marketing, and call center services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America, Canada and in Europe (including the United Kingdom and Russia), India or Asia (including China). As a result, your personal information may be used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement agencies in those countries.
Where you have requested us to do so (either expressly or by your actions), we may share your personal information with persons who may consider you and/or your application for a loan, credit card or other product or service. In connection with this, LendingArch and/or our third party business affiliate to perform a credit check on you to confirm your financial situation and your initial and ongoing eligibility for the products and services you have requested.
Further, your personal information may be disclosed:
Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.
How is Your Personal Information Protected?
LendingArch endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please inform our Customer Care department of this change. If our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Access to Your Personal Information
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Customer Care department, and if our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Customer Care department. If our Customer Care department is unable to help you, please contact our Privacy Officer using the contact information below
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
NOTICE TO CALIFORNIA RESIDENTS
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information (the “Notice”).
California law provides California residents with the following privacy rights:
Access personal information: Individuals exercising this right may request access to the categories and specific pieces of their personal information we have collected in the prior 12-month period.
Disclosure: Individuals exercising this right can receive additional information regarding the sources from which we collect information, the purposes for which we collect and share personal information, the information of theirs we hold, and the categories of parties with whom we share their information.
Deletion: Individuals exercising this right can ask us to delete their personal information we have collected, though we may be permitted to retain personal information for certain purposes.
Non-Discrimination: Users may freely exercise these rights without fear of being denied goods or services.
“Opt Out” of Sales: As permitted by applicable law, we may share your personal information for monetary or other valuable consideration (under California law, this is considered a “sale”). You may opt out of such a “sale” of your personal information to third parties. You can exercise your right to opt-out
by emailing our Privacy Officer as per below.
CCPA Scope and Exclusions
The description in this Notice of our Privacy Practices and your Privacy Rights apply only to California residents whose interactions with us are limited to:
Visiting our consumer websites,
Signing up for email alerts,
Commenting on or contributing to our blogs,
Establishing an account that may or may not include financial products or services, or
Applying for our job openings on our websites or third party sites (however, note that the CCPA does not extend Privacy Rights to job applicants).
The description in this Notice of our Privacy Policies and CCPA Privacy Rights do not apply to the personal information we collect, use or disclose about:
Consumers who initiate or complete the process of applying for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“FIPA”), or
Representatives of businesses that seek to obtain our products or services, or to provide products or services to us. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request
The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We will ask you to verify your identity when you submit a request.
California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
Inquiries or Concerns?