Privacy Policy

Our Policy Concerning Children

Our Website is not directed to children under 13, and we do not knowingly collect any personal information from children under the age of 13 through our website. If we become aware that a child under 13 has provided us with personal information through our website, we will take steps to delete such information.

Privacy Policies of Linked Sites and Advertisers

Our Website may contain links to other sites, as well as advertisements from companies linking to their own sites. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use your information, you should contact them directly.

Security

LendFriend has certain measures in place to maintain the security, confidentiality and integrity of the information gathered through the Website, and to help protect against the loss, misuse and alteration of such information.  While we take measures to protect your personal information against security breaches and unauthorized access, we cannot guarantee that our safeguards will be effective all of the time against all security threats.

How to Access and Update Your Information

You can access and update the information that you have provided to us as follows:

• If you are a LendFriend customer, you can access and update certain personal information in connection with your account or application by logging into your account online.
• You may contact us at contact@lendfriendmtg.com and request to review, amend or delete certain personal information collected by us.
• Please note that we may not be able to delete all information we collect through our Website.
• You may opt-out of receiving marketing emails at any time by following the steps to “unsubscribe” described in the footer of our marketing emails. Your opt-out will become effective in 10 days or less.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain, or use personal information from children under the age of 13. If we become aware that a child under the age of 13 has submitted personal information to us through the Website, we will immediately delete such information.

California Resident Privacy Notice Addendum

This Privacy Notice for California Residents (this "California Privacy Notice") is for California residents only and supplements, and does not replace, the information contained in the Better.com Privacy Policy.

It applies to visitors, clients, applicants, users, and others who reside in the State of California ("consumers" or "you"). This notice contains a description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

While we believe that much of the personal information we collect is exempted under the GrammLeach-Bliley Act exemption of the California Consumer Privacy Act of 2018 ("CCPA"), we are providing this notice to recognize certain rights of consumers under the CCPA. For example, this California Privacy Notice does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. In limited circumstances, we may collect information that identifies, describes, or is reasonably capable of being associated with you that is not related to your use of our financial products and services.

Any terms defined in the CCPA have the same meaning when used in this Privacy Notice 

Information We Collect

When you use our Website, we may collect personal information about you, such as your name, address, Social Security number, telephone number, email address, asset information, income information, or any other information that you submit on applications or other forms made available through the Website. We collect this information when you request a rate quote, begin an application, or make an inquiry

As part of our business, and in our efforts to serve you, we collect this information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

What is Collected:

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Personal information categories listed in the California Customer Records statute

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status.

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other similar network activity

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Geolocation data

Physical location or movements.

Sensory data

Audio recordings of your contact with our customer service team.

Professional or employment-related information

Current or past job history or performance evaluations

What is Not Collected:

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Non-public education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Inferences drawn from other personal information

Audio, electronic, visual, thermal, olfactory, or similar information.

Personal Information DOES NOT Include:

• Publicly available information from federal, state, or local government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-LeachBliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our customers or their agents. For example, from documents that our customers provide to us related to the services that we are asked to perform.
• Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
• Directly and indirectly from activity on our Website. For example, from submissions through our Website portal or Website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, credit reporting agencies, appraisers, and other service providers.
• From our affiliates.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide personal information to apply for a loan, we will use that information to process your application, payment, and facilitate loan closing. We may also save your information for legal or regulatory purposes, loan fulfillment, and/or loan servicing.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our response.
• To personalize your website experience and to deliver relevant content and product and service offerings, including targeted offers and other communications (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our business websites, products and services, databases and other technology assets.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or for other business purposes or that are otherwise set forth in the CCPA.
• To respond to audits or state or federal examinations by our regulators.

In some instances, we may use or disclose certain personal information that we collect which constitutes "sensitive personal information" under the CCPA. We do not, however, use that information outside of certain limited uses, such as the following: (i) providing and improving our products; (ii) detecting security incidents; (iii) resisting malicious, deceptive, fraudulent, or illegal actions; (iv) ensuring physical safety; (v) for certain non-personalized advertising; (vi) maintaining or servicing accounts, providing customer service, or similar uses; and (vii) improving our services.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. We limit the information that we send service providers, and require that our service providers only use shared personal information to perform the services requested in accordance with our Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

We may share personal information with third parties:

• Such as vendors who provide employment verification, degree verification, title, document import, or other necessary services;
• Such as our subsidiary and affiliated businesses that provide quality services or products you may be interested in;
• For any purpose to which you expressly consent;
• To protect our rights or the rights or safety of others; and
• As may be required by law or regulation.

Please note, we do not share SMS text opt-in data with any third parties.

Sale of Personal Information

In the preceding 12 months, we have not disclosed your personal information to third parties in connection with our online services to third party analytics purposes. Such disclosure for analytics and marketing/advertising purposes may constitute a "sale" of your personal information under the CCPA. You may opt out of the sale of your information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

Access to Information

Unless your personal information is excluded from the scope of the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, you have a right to know:

• The categories of personal information we have collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Requests Rights

Unless your personal information is excluded from the scope of the CCPA, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to exceptions.

Please note that the Gramm-Leach-Bliley Act and the CCPA allows us to keep certain forms of data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information.
• Provide a good or service that you requested and take actions reasonably anticipated within the context of our ongoing business relationship with you.
• Perform a contract between us and you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct

You have the right to correct inaccuracies in your personal information, taking into account the nature of the Personal Information and the purposes of processing the personal information.

Right to Obtain a Copy

You have the right to obtain a copy of your personal information that you previously provided to us in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another data controller without hindrance.

Right to Opt Out

You have the right to opt-out of the selling and sharing of your personal information. Once you make an opt out request, we will wait at least 12 months before asking you to opt in to personal information sales. You do not need to create an account with us to exercise your opt out rights.

You may also opt-out by broadcasting an opt out preference signal, such as the Global Privacy Control ("GPC") on browsers and browser extensions that support such a signal. To download and use a browser supporting the GPC browser signal, please visit: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Right to Appeal

If we refuse to take action regarding your exercise of any of the rights described in this section, you may appeal our refusal to do so by contacting us as provided below.

Exercising Your Rights

If you are a California resident, you can submit a request to us by:

• Calling us at 512-881-5099
• Emailing us at contact@lendfriendmtg.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the California resident about whom we collected personal information or an authorized representative of such a resident.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically (provided we can do so securely). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Non-discrimination

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

Information for Parents or Guardians

We do not knowingly collect or maintain information about children under the age of 16, unless that information is provided by a parent, legal guardian, or authorized adult.

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time to reflect changes in our business, legal or regulatory obligations. Any changes will be immediately effective upon the posting of the updated Privacy Notice.

Contact Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices