If you have a consumer Lending Product with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information. Additionally, please refer to your applicable user account agreement for terms and conditions governing your use of the Lending Product.
Personally Identifiable Information We Collect
If you interact with a Platform that offers our Lending Products, we will receive from the Platform (via Synapse Financial) certain of your Personally Identifiable Information and process that Personally Identifiable Information to provide you with our Lending Products:
- Create an Account. When you create an account with a Platform, we may collect information such as your name, email address, Social Security Number or other tax identification number, address, telephone number, date of birth, gender, videos, and photographs that may contain images of your face such as your driver’s license or government-issued identification card.
- Loans and Credit Reporting. For loan decisions, origination, and servicing, and for any credit reporting requirements, we may collect information such as your income, employment information, credit history, education information, address, debt to income ratio, credit score, and prior repayment history.
- Financial Information. We may collect information regarding an external financial account such as the financial institution name, account name, account type, branch number, account number, routing number, international bank account number (“IBAN”), information, data, passwords, authentication questions, materials or other content, transaction, and available balance information. We may also collect income history, expense and spending history analysis, credit history, credit reports, and information regarding transactions and transaction history, including but not limited to ACH, wire and card transactions, available account balance, card data, loan and debit amounts, loan types, payment plans, loan balances, linked bank accounts, salary and other income, sources of wealth, and other assets.
- Background Check Data. We may collect information such as credit and criminal checks, supporting research, and screenings, to the extent required or permitted by local law.
- Recipients’ or Senders’ Data. When you send or request money through a Platform, we may receive your name, address, telephone number, IP address, date of birth, and financial account information about the recipient or sender of the funds. The extent of data required about a recipient or sender may vary depending on the Platform product you are using to send or request money.
- Contact Information. We may collect contact information such as your name, email address, and telephone number.
In some cases, we may receive certain Personally Identifiable Information about you from merchants, recipients and senders of funds, data providers, identity verification providers, and credit bureaus as permitted by law.
How We Use Your Personally Identifiable Information
We use the Personally Identifiable Information we collect to provide the Lending Products to you, to improve our Lending Products and services, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
- Provide the Lending Products, including verifying eligibility requirements, determining creditworthiness, enabling performing data and transaction processing, fund transfers and automatic payments, analyzing transaction history to combat regulatory and other security concerns, assisting with the investigation of a dispute, facilitating credit checks and credit reporting, handling user inquiries, implementing collection activities as needed, and managing the relationship;
- Improve, enhance, modify, add to, and further develop our Lending Products;
- Comply with legal obligations, audit requirements, and regulations applicable to providing the Lending Products;
- Confirm a person’s identity and authority as a representative or agent;
- Conduct record keeping and otherwise manage the business;
- Verify you, your identity, that the data provided is credible, and prevent fraud;
- Protect you, Platforms, Synapse Credit, and our related entities and take measures to prevent fraud, malicious activity and other privacy and security-related concerns from impacting you, Platforms, Synapse Credit and our related entities;
- Provide customer support to you or to Platforms, including to help respond to your inquiries related to our Lending Products or Platforms’ applications or websites;
- Send you technical notices, statements, updates, security alerts, and support and administrative messages;
- Investigate any potential misuse of our Lending Products or Platforms’ applications or websites, including criminal activity or other unauthorized access to our Lending Products;
- Communicate with you about our Lending Products or to inform you of any changes to our Lending Products;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business;
- Comply with applicable law and regulation, including but not limited to those relating to Synapse Credit’s licensing requirements; and
- For any other purpose with your consent.
We may share the information that we collect about you in the following ways:
- To third parties to whom you authorize to access your account information or to place transactions in your account;
- With a joint account holder as applicable;
- For our everyday business purposes, such as processing your transactions, maintaining your account(s), or reporting to credit bureaus;
- With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, financial service providers, credit bureaus, or collection agencies;
- With other parties to transactions when you use the Lending Products, such as other users, merchants, and their service providers. We may share your information with other parties involved in processing your transactions. This includes other users that you are sending or receiving funds from, and merchants and their service providers. This information might include: (i) information necessary to facilitate the transaction and (ii) information to help other participant(s) resolve disputes and (iii) detect and prevent fraud;
- To information technology providers or other service providers around the world that act under our instructions regarding the processing of certain data. These entities will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the information, and to process information only as instructed;
- To independent external auditors or other service providers. Such service providers will be subject to any necessary contractual obligations regarding the protection and processing of such Personally Identifiable Information;
- To support our audit, compliance, and corporate governance functions;
- To the extent that we are required to do so by law or regulation;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
- To any other person or entity where you consent to the disclosure.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
The Lending Products are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA’s privacy rights described below do not apply to Personal Information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. The CCPA’s privacy-related rights also do not apply to certain types of Personal Information that is subject to the Federal Credit Reporting Act (FCRA).
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
Collection of Personal Information
For a list of the purposes for which we have collected this Personal Information, please see the “Collecting and Using Information – How We Use Your Personally Identifiable Information” section above.
Disclosure of Personal Information
We do not knowingly collect or sell the Personal Information of minors under 16 years of age.
Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know and/or Delete
You may submit a request to know or delete by emailing us at email@example.com or by calling us 1(800)258-9194.
As mentioned above, if you are a California resident who has a Lending Product with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
Our Process for Verifying a Request to Know or Delete
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.