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Privacy Policy

 

Privacy Notice

This Privacy Notice applies to your interaction with LendingClub Bank, National Association and LendingClub Corporation or any of their subsidiaries, as may be applicable (collectively “LendingClub,” “we,” “us,” “our”). This Privacy Notice is effective as of February 1, 2021.

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We take your privacy and the security of information about you seriously. This Online Privacy Policy explains how we collect and use personal information through our website, www.lendingclub.com, mobile application(s) and all related applications, services and tools (collectively, our “Service”), including how we may use such information for advertising purposes. Our data sharing practices are also governed by the LendingClub Privacy Notice, which explains the choices you may have in the use and sharing of information about you.

This policy is incorporated into LendingClub’s Terms of Use, and your consent to this policy is a material term of our Terms of Use. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of personal information about you as described in this Online Privacy Policy, our Privacy Notice, and our Terms of Use.

    • FACTS
      FACTS
    • What does LendingClub do with your personal information?
      What does LendingClub do with your personal information?
    • FACTS
      Why?
    • What does LendingClub do with your personal information?
      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.
    • FACTS
      What?
    • What does LendingClub do with your personal information?
      The types of personal information we collect and share depend on the product or service you have with us.
      This information can include:
      – Social security number and income
      – Account balances and transaction history
      – Credit scores and employment information
    • FACTS
      How?
    • What does LendingClub do with your personal information?
      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 LendingClub chooses to share; and whether you can limit this sharing.

    • Reasons we can share your personal information
      Reasons we can share your personal information
    • Does LendingClub share?
      Does LendingClub share?
    • Can you limit this sharing?
      Can you limit this sharing?
    • Reasons we can share your personal information
      For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
    • Does LendingClub share?
    • Can you limit this sharing?
    • Reasons we can share your personal information
      For our marketing purposes — to offer our products and services to you
    • Does LendingClub share?
    • Can you limit this sharing?
    • Reasons we can share your personal information
      For joint marketing with other financial companies
    • Does LendingClub share?
    • Can you limit this sharing?
    • Reasons we can share your personal information
      For our affiliates’ everyday business purposes — information about your transactions and experiences
    • Does LendingClub share?
    • Can you limit this sharing?
    • Reasons we can share your personal information
      For our affiliates’ everyday business purposes — information about your creditworthiness
    • Does LendingClub share?
    • Can you limit this sharing?
    • Reasons we can share your personal information
      For our affiliates to market to you
    • Does LendingClub share?
    • Can you limit this sharing?
    • Reasons we can share your personal information
      For nonaffiliates to market to you
    • Does LendingClub share?
    • Can you limit this sharing?

    • To limit our sharing
    • – Call 888-596-3157 — our menu will prompt you through your choice(s) or
      – Contact us at: privacy@lendingclub.com*

      Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. 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.

    • Who we are
      Who we are
    • Who we are
      Who is providing this notice?
    • LendingClub Bank, National Association and LendingClub Corporation

    • What we do
      What we do
    • What we do
      How does LendingClub protect my personal information?
    • To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
    • What we do
      How does LendingClub collect my personal information?
    • We collect your personal information, for example, when you:
      – open an account or deposit money
      – pay your bills or apply for a loan
      – buy securities from us
      – use your credit or debit card
      – make deposits or withdrawals from your account
      – make a wire transfer

      We also collect information about you from others, such as credit bureaus and other companies.
    • What we do
      Why can’t I limit all sharing?
    • Federal law gives you the right to limit only:
      – sharing for affiliates’ everyday business purposes – information about your creditworthiness
      – affiliates from using your information to market to you
      – sharing for nonaffiliates to market to you

      State laws and individual companies may give you additional rights to limit sharing.
    • What we do
      What happens when I limit sharing for an account I hold jointly with someone else?
    • Your choices will apply to everyone on your account – unless you tell us otherwise.

    • Definitions
      Definitions
    • Definitions
      Affiliates
    • Companies related by common ownership or control. They can be financial and nonfinancial companies.
      – LendingClub Bank, National Association
      – LendingClub Corporation
    • Definitions
      Nonaffiliates
    • Companies not related by common ownership or control. They can be financial and nonfinancial companies.
      – Nonaffiliates with whom we share can include other financial services companies, lenders, insurance companies, retailers, membership clubs, or other consumer service providers such as data processors, service providers, and companies that help us market our own products and third-party products that we believe may be of interest to you.
    • Definitions
      Joint Marketing
    • A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
      – Our joint marketing partners include other financial services companies, banks, lenders, insurance companies, or other consumer service providers.

    • Other important information
      Other important information
    • Other important information
      For California residents
    • We do not sell personal information under California law. We will not share your non-public information with nonaffiliates for their marketing purposes except with your express consent or as otherwise authorized by California law. We will not disclose personal and financial information about you with companies we own or control (affiliates) or with companies we do business with to provide financial products and services (joint marketing partners) if you instruct us not to do so by following the instructions on the form called “Important Privacy Choices for Consumers,” which contains additional choices for California residents. To make a request under California privacy law, you may email us at californiaprivacy@lendingclub.com* for more information or fill out a request form at https://www.lendingclub.com/californiaprivacy.
    • Other important information
      For Vermont residents
    • We will not share information we collect about you with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account. We will not share information about your creditworthiness with our affiliates except with your authorization or as required or permitted by law. We may share information about our transactions or experiences with you within our corporate family without your consent.
    • Other important information
      For Nevada residents
    • We provide you this notice under Nevada state law. You may be placed on our internal Do-Not-Call List by calling us at 888-596-3157 or sending a message to privacy@lendingclub.com*

      LendingClub Bank, National Association Attn: Compliance Department
      2701 N Thanksgiving Way, Lehi, UT 84043

      Nevada law also requires us to provide you the following to obtain additional information:

      Office of the Attorney General
      100 North Carson Street
      Carson City, NV 89701
      Telephone: 775-684-1100
      Email: AgInfo@ag.state.nev.us*
    • Other important information
      For Alaska, Illinois, Maryland, and North Dakota Customers
    • We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization.
    • Other important information
      For Massachusetts, Mississippi and New Jersey Customers
    • We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing – without your authorization.

 

Online Privacy Policy 

This Online Privacy Policy applies to all online and offline interactions with LendingClub Bank, National Association and LendingClub Corporation or any of their subsidiaries, as may be applicable (collectively “LendingClub,” “we,” “us,” “our”) as more specifically noted below and our practices relating to the personal information we collect from you. This Online Privacy Policy is effective as of February 1, 2021.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT 
In connection with the products and services that we offer (each, a “Service”), including but not limited to all LendingClub owned websites and the subdomains thereof (collectively, the “Site”) and the group of financial service technologies that LendingClub or any of its affiliates have developed to enable the services we facilitate or provide (collectively, the “LC Platform”), we collect information you provide LendingClub when you interact with us directly or through a third-party, such as when you register for a Service, apply for a loan or to be an investor, sign up for our mailing list, or otherwise communicate with us. We use all of the information we collect to operate, maintain, improve and provide to you the features and functionality of Services and to create new features. The types of personal information we collect depends on the Services you request and use. Below is a list of categories of personal information we collect and have collected and disclosed for a business purpose, the sources from which the information was collected, the business purposes for which the information was collected, and categories of third parties with whom the information was shared in the last 12 months. We may use this information for the purposes specified below or for any other purposes that we may specifically disclose at the time you provide or we collect your information.

Identifiers.

  • Types. This information may include a real name, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address or other communication information, account name, social security number, driver’s license number or state identification card number, passport number, or other similar identifiers or identity verification information. This information may also include club membership or reward-based program identifiers. 
  • Sources. We collect this information from you, and from third parties, including information we request from credit reporting agencies, and service providers. This information may include information you provide and that we receive through referral activities. With your permission, we may access and import your contact list available through your email accounts. 
  • Purposes. We use this information to verify your identity, facilitate transactions, to advertise to you, and to create your customer profile and account. We may use your contact list information, if you choose to provide it, so that we may invite your friends and contacts to use Services and to provide credit to you for referrals. Certain personal information must be supplied during the customer registration processes in order to meet our legal obligations, facilitate credit eligibility decisions, protect against fraud and complete your transaction. We may use this information to communicate directly with you, such as to send you direct mail and email marketing messages or advertising or to suppress such messages. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of Services, technical and security notices). For more information about your communication preferences, see “Control Over Information” below. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.

Financial Information.

  • Types. This information may include payment and bank information, wire transfer information, credit card number, debit card number, full credit report, transactional information for financial accounts, account information including interest rates and balances, income information, and any other financial information available. 
  • Sources. We may receive financial information that you provide to us directly or through third-party services. We may also receive information about you from third parties, including information requested from credit reporting agencies such as TransUnion, Equifax, and/or Experian, and from other partners. We will collect information, which may include your credit history and credit scores, from credit bureaus and other partners. 
  • Purposes. We use this financial information to process your transactions, to improve and expand our Services, and to determine your financial health. If you register with us, we will use financial information about you to facilitate and service your account. If you register as an investor, we will use financial information about you to facilitate investing. We use this information to process your loan application or transactions, and enable payments and fund transfers with financial institutions. We use this financial information in connection with securitizations and other investment products with an interest in your loan. We use this financial information for creditworthiness if you are a borrower, assess risks related to your transaction, and to help investors determine whether to commit to or purchase your loan. If you consent to have Lending Club request your financial information directly from your financial institution, we may work with a third party, such as Plaid or Finicity, to access and collect such information on our behalf. By providing your financial information to the third party, you acknowledge and agree that such information accessed, collected, or transmitted by the third party for this purpose will be governed by the privacy policy of the third party. Plaid’s privacy policy is available at https://plaid.com/legal. Finicity’s privacy policy is available at https://www.finicity.com/privacy
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.

Commercial Information.

  • Types. This information may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This information may include details about property used to secure a loan, such as vehicle information and location. Commercial information may also include information about the utilities you use, rewards and points-based incentive programs, program membership information, and information about your mobile device and carrier. 
  • Sources. We may receive commercial information that you provide to us directly or through third-party services. We may receive information about your property from public records or from third parties, including information we request from credit reporting agencies, and from other partners. We may receive information about services you obtain directly from your service provider such as a healthcare provider. If you ask us to use your utility payment history to help determine your eligibility for a Service, then we may receive this information from your utility or a service provider that collects the information on our behalf. By providing your information to the third party, you acknowledge and agree that information accessed, collected, or transmitted by the third party for this purpose will be governed by the privacy policy of the third party. Financial transaction information may also include commercial information about purchases, purchasing or consuming habits and tendencies. 
  • Purposes. We use this information for creditworthiness and determining financial health, to improve and expand our Service, and perfecting security interests. For example, information about your automobile may be used to register a security interest if that automobile is used as collateral for a loan. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.

Business Information.

  • Types. This information may include information about your business, such as legal business name and company practice name, and other information about your company or practice such as fax, telephone number, website, relevant email addresses, physical address, business-related licensing information such as a license number, federal tax identification or social security number, and business or practice bank account information. This information may be collected, for example, when you become part of a LendingClub business program, apply for a business-related loan, or apply for a Service as self-employed. 
  • Sources. We may receive business information that you provide to us directly or through third-party services. We may receive information about your property from public records or from third parties, including information we request from credit reporting agencies, and from other partners. For example, we may also collect this information from your registration application submitted through provider agreement, business loan application, or from a personal loan application if you are self-employed. 
  • Purposes. We use this information for processing your application, facilitating transactions, for verification purposes, and to improve or expand our Services. We use this information in connection with securitizations and other investment products with an interest in your loan. When you submit registration information to request to participate in the Lending Club Patient Solutions Program, we will use this information to verify the identity of the healthcare providers and the practice. We will also use the required information to facilitate activities and transactions that need to occur during the patient financing process. This includes maintaining regular communications with the healthcare practice concerning an application for financing or a completed funding, such as requesting additional information or assistance. We may also use this information to contact the practice if there is a problem completing a transaction or to discuss a refund, or a problem with a patient’s application. We may also use this information to enable our financial services partners to implement automatic payments. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.

Network Activity and Location Information. 

  • Types. This information may include, but is not limited to, your browsing history, search history, geolocation data, and information regarding your interaction with an Internet web site, application, or advertisement. 
  • Sources. We collect this information from you and from third-parties such as advertising service providers and marketing analytics and information service providers. This information may be passed to us via cookies, pixels, or other tracking technologies described in Section 3 below. Geolocation data may be collected from your device, your browser, or from other sources such as metadata stored in images or files you provide to us. 
  • Purposes. We use this information for security, processing your application, facilitating transactions, marketing, for verification purposes and to improve or expand our Services. For example, we use this information to better understand the effectiveness of our advertising activities and efficiency in our application process. We also use this information to better advertise to you and to track your use of our websites and the selections you make in order to satisfy regulatory obligations. Please refer to Section 2 below, which provides detailed information about our use of tracking technologies. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, parties to a company transaction, and legally interested parties as described in Section 3 below. 

Audio, Visual, and Electronic Information.

  • Types. This information may include a picture of you, digital or digitized signature, or voice recordings from phone calls. We may also collect any other communications between you and LendingClub. 
  • Sources. We collect this information from you or from third-parties. For example, we may collect a copy of a government issued ID that includes a picture from you, and we may collect a picture of you and your signature when you visit our offices. Your signature or digital or digitized signature may also be on documents we collect from you. We may collect this information from third-party service providers that provide member support and operations-related services. 
  • Purposes. We use this information for information security, fraud detection and prevention, quality control, and for processing your application, facilitating transactions, for verification purposes and to improve or expand our Services. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, parties to a company transaction, and legally interested parties as described in Section 3 below. 

Professional, Education, or Employment-related Information.

  • Types. This information may include work history, employer and employment information, profession, job title, work address and phone number, and other information related to your profession. 
  • Sources. We collect this information from you, and from third parties, including information we request from credit reporting agencies, and service providers. Information you may provide and that we receive through referral activities. 
  • Purposes. We use this information to determine your creditworthiness if you are a borrower, assess risks related to your potential loan, and to help investors determine whether to commit to or purchase your loan. We may also use this information to enable or implement automatic payments. We may use this information for verification purposes, to improve or expand our Services, and for offering Services to you. This information may be used as professional information. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.

Other Sensitive Information.

  • Types. This information includes other information related to your transactions with us or provided to us through linked accounts and systems, such as information about medical or educational services purchased with a loan, insurance information such as automotive insurance numbers relating to an automobile loan or health insurance information. This information may also include detailed information about your purchases from bank, credit card, and other financial or transactional accounts. 
  • Sources. We may receive other sensitive information that you provide to us directly or through third-party services such as healthcare and educational service providers. This information may be included in application information, and may also be provided as part of a transaction with a service provider. 
  • Purposes. We use this information for processing your loan application, facilitating transactions, for verification purposes, regulatory requirements, to improve or expand our Services, and to offer Services to you. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, originating banks other than LendingClub Bank, National Association, as applicable, purchasers, prospective purchasers, credit bureaus, parties to a company transaction, and legally interested parties as described in Section 3 below.

Inference Information. 

  • Types. This information includes inferences drawn from any of the information in categories listed above. This information may indicate characteristics about you, such as preferences, habits, behavior patterns, and physical characteristics. For example, your picture may reveal physical characteristics, and transactional information may reveal patterns in spending, behavior, preferences, and other information. 
  • Sources. We gather the information above from a variety of sources as described in each category. 
  • Purposes. We may use this information to improve or expand our Services or for marketing purposes. 
  • Sharing. We share information in this category with LendingClub companies, third-party service providers, other third parties, parties to a company transaction, and legally interested parties as described in Section 3 below.

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION.

Like most websites and online services, we and our third-party partners automatically collect certain types of usage information when you use or attempt to use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, which could include cookies, web beacons, Flash cookies (locally stored objects), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). These tracking technologies collect information about how you use a Service (e.g., the pages you view, the links you click, and other actions you take in connection with a Service), information about your browser and online usage patterns (e.g., IP address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email, links clicked), and information about the device(s) you use to access a Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and depending on your mobile device settings, your geographical location data (which could include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device), or we may be able to approximate a device’s location by analyzing other information, like an IP address. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising and content displayed on another device, and so that we may recognize and contact you on the various devices you may use. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for a Service. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

Our websites include social media features, such as the Facebook Like button. These features may collect your IP address and other information such as the page(s) you are visiting on our websites, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy policy of the company providing it.

We use or may use the data collected through tracking technologies to (a) remember information so that you will not have to reenter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our websites; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.

If you would prefer not to accept cookies, most browsers will allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Blocking or deleting cookies may negatively impact your experience using a Service, as some features and services within our Services may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects—including how to manage privacy and storage settings for Flash cookies—on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and Services offered.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third-Party Tracking and Online Advertising” below. 

3. SHARING OF INFORMATION

We may share personal information about you in the instances described below. For further information on your choices regarding information about you, see the “Control Over Information” section below.

We may share personal information about you with:

  • Originating Banks. Originating banks that originate your loan, other than LendingClub Bank, National Association, as applicable. If you request a loan, you are also providing information to the potential originating bank, and additional information may be provided to that bank after your loan originates. The use of information about you by your originating bank is also governed by that bank’s privacy policy; 
  • LendingClub Companies. Other companies and brands owned or controlled by LendingClub and other companies owned by or under common ownership as LendingClub, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use information about you in the same way as we can under this Policy; 
  • Third-Party Service Providers. Third-party vendors and other service providers that perform services on our behalf, such as operational support services, data processors and companies that help us market our own Services and third-party products or services that we believe may be of interest to you. We work with a number of service providers who support our operations, including but not limited to electronic payment service providers and customer support call centers. We share information with these third parties to process the transactions you initiate or to perform other specific services on our behalf, such as collections or identity verification, creating and providing targeted advertisements, or providing marketing analytics services. Our service providers are legally required to keep personal information private and secure and adhere to applicable state and federal laws and regulations and to only use the personal information we provide in order to provide such services to us; 
  • Other Third Parties. Third parties at your request, such as financial services companies, lenders, insurance companies, retailers, membership clubs, or other consumer service providers. For example, if we are unable to offer you a loan, you may be given the option to allow us to share personal information about you to third parties who may be interested in offering you a loan. We will share this information at your direction, which may be provided through interaction with or selection of a third-party offer presented on one of our websites; 
  • Purchasers. If we sell your loan or a security interest in your loan, we may provide the purchaser of your loan with information about you and credit information, which may be used to process your loan and for other purposes. We may provide the purchaser with information about you and other information associated with your loan for the purchaser to satisfy a regulatory or legal obligation, even after the purchaser has sold the loan to another party. The information we share about you will be subject to the purchaser’s privacy policy in addition to our own. Purchasers may also use this information for their direct marketing purposes. To opt-out of such sharing, please see Section 4 below; 
  • Prospective Purchasers. Prospective purchasers of your loan to evaluate the quality of the loan and other service providers involved in the sale or potential sale of your loan or an interest in your loan. For example, a loan purchaser may need information about you to determine the risk associated with the loan; 
  • Credit Bureaus. We may share personal information about you with credit bureaus to meet our credit reporting obligations; 
  • Parties to a Company Transaction. Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and 
  • Legally Interested Parties. Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Services; and/or (c) to exercise or protect the rights, property, or personal safety of LendingClub, our visitors, or others.

We may also share information with others in an aggregated or otherwise de-identified or anonymized form that does not reasonably identify you directly as an individual.

4. CONTROL OVER INFORMATION

Data sharing settings and modifying or deleting information about you: If you have established an online account with us (“Online Account”), you can access and modify information about you (such as name, email address, and mailing address) that we collect online and maintain by visiting your profile in the Online Account. This section of the website is password protected to better safeguard information about you. As a registered user, you can update your password, email address, physical address, phone number, and certain bank account information at any time on the website. Requests to change any other information in your profile or remove your name or comments from our website or publicly displayed content can be sent to us at support@lendingclub.com*. We will respond to your request within a reasonable timeframe, but no longer than may be required under applicable law (see Section 9 below for requests under California privacy law). We may not be able to modify or delete information in all circumstances. Due to the regulated nature of our industry, we are under legal requirements to retain data and are generally not able to delete consumer transactional data, loan application data, or other financial information upon request. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain information about you for at least seven years to be in compliance with applicable federal and state laws regarding recordkeeping, reporting, and audits. 

Opt-out from third-party sharing for direct marketing purposes: As set forth in Section 9 below, if you are a resident of California and have previously opted in to have personal information about you shared with third parties for their direct marketing purposes, but no longer wish to have such information shared, please email us at privacy@lendingclub.com* to request to not have your information shared in this manner. 

How to control your communications preferences: You can update your email preferences and stop receiving promotional email communications from us by clicking on the “Unsubscribe” link provided in such communications. We make every effort to process all unsubscribe requests within a reasonable amount of time. You may not opt out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of our Services, technical and security notices).

5. THIRD-PARTY TRACKING AND ONLINE ADVERTISING

Interest Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third-party online advertising networks, social media companies and other third-party services, to collect, information about your use of our websites over time so that they may play or display ads about our Services, on other devices you may use, and on other websites, apps or services. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site and other information. We and our third-party partners may combine this information with information collected offline or from other sources. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. 

Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook Like button, Google Plus, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to a Service, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to a Service. We may also work with third-party partners who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

Your Choices:

  • Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative (NAI) online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance (DAA) resources at http://www.aboutads.info/choices
  • Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. 
  • Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. 
  • Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again. 

Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our websites or Services on your browser or mobile device, login to your Online Account, or otherwise engage with us. We may share a unique identifier, like a user ID or hashed email address, with Google to facilitate our Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at https://www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

6. HOW WE PROTECT AND STORE INFORMATION ABOUT YOU

Keeping information safe: LendingClub understands that the information collected and shared with us by our customers, investors and business partners contains sensitive data. We take our role in safeguarding information about you seriously. We maintain a security program that draws on industry standards and best practices. We take a defensive, in-depth approach to implementing physical, administrative, and technical safeguards to protect information against unauthorized access or misuse. The safeguards include preventive, detective, and corrective controls, for example: physical safeguards like access badges and a video monitoring system; administrative safeguards like an employee security training program, employment background checks, and access controls; and technical safeguards like perimeter security, encryption, two-factor authentication, and regular security monitoring with layered and complementary controls. In addition, we use:

  • Encryption & website certificates. Encryption protects the information you share with us from the moment it leaves your computer until it reaches our systems. Look for the secure locked padlock on your browser, which signifies a secure web connection. Consult your web browser documentation for more information. 
  • Session time-outs. We employ session time-outs that will log you out of the website automatically after a period of inactivity. This reduces the risk of others being able to access your account if you leave your computer unattended. 
  • Passwords. You should never share your password with anyone. Your password is not known to any LendingClub employee or third party, and we will never ask for your password by phone or email. If you ever receive a communication claiming to be from LendingClub that asks for your password, you should immediately report it by contacting us at security@lendingclub.com*. 
  • Identity theft protection. In order to protect your identity at LendingClub, we have developed and implemented an identity theft prevention and response program that is designed to detect, prevent, and mitigate identity theft when borrowing or investing through the LendingClub platform. We utilize authentication technology to verify the identities of our customers, and have established processes, procedures, and training for LendingClub employees to identify and respond appropriately to identity theft indicators. 

We also periodically review and adjust security safeguards as the threat landscape evolves. Ultimately no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, our policy is to take reasonable steps to investigate the situation and, where appropriate, communicate with affected individuals. 

Data storage and transfer: Information collected through our websites may be stored and processed in the United States or any other country in which we or our affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

7. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from anyone under the age of 13 through our Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at privacy@lendingclub.com*.

8. LINKS TO OTHER WEBSITES AND SERVICES

Services may present links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on third-party websites.

9. YOUR CALIFORNIA PRIVACY RIGHTS

In California, you may opt in to have personal information about you shared with third parties for their direct marketing purposes. Consistent with California Civil Code Section 1798.83, if you no longer wish to have personal information about you shared with third parties for their direct marketing purposes, please email us at privacy@lendingclub.com* to request to not have your information shared in this manner. 

The California Consumer Privacy Act (CCPA) provides for additional rights for California consumers. Your rights under the CCPA include: a) the right to request that a business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of personal information the business has collected; b) the right to request that a business delete certain personal information about the consumer which the business has collected from the consumer; c) the right to request that a business that collects personal information about the consumer disclose to the consumer the categories of personal information it has collected about that consumer, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom the business shares personal information, and the specific pieces of personal information it has collected about that consumer; d) the right to request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer the categories of personal information that the business sold or disclosed; and e) the right to opt-out of the sale of personal information. 

These rights do not apply to personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (GLBA), including certain information relating to financial services we offer such as information about financial accounts, credit information, or information collected as part of the application process. Most of the information we collect is subject to the GLBA (“GLBA Information”) and therefore not subject to the CCPA and the rights described above. However, GLBA Information may be subject to a different California law called the California Financial Information Privacy Act. Your privacy choices under this law are set forth in the form called “Important Privacy Choices for Consumers.”

To the extent your information is subject to the CCPA, you may exercise your rights under the CCPA by submitting the form at https://www.lendingclub.com/californiaprivacy. You will be asked to provide certain identifying information to verify your consumer request, such as your name, social security number, date of birth, email address, and your mailing address. You will be required to verify your email address. You may also send an email to californiaprivacy@lendingclub.com* for more information. If you have a loan with us, access to your loan information is conveniently available by logging into your account.

LendingClub does not sell your personal information as described in the CCPA. 

LendingClub does not sell personal information of minors as described in the CCPA.

You have a right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the CCPA. Also, you may designate an authorized agent to make a request under the CCPA on your behalf.

10. HOW TO CONTACT US 

If you have any questions about this Privacy Policy or our websites, please contact us at privacy@lendingclub.com*. 

If you have a privacy or data use concern, please contact us first at privacy@lendingclub.com*. If we have not addressed your privacy or data use concern satisfactorily, please contact our U.S.-based, privacy and data usage third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

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11. CHANGES TO OUR PRIVACY POLICY

We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective as of the published effective date. If there are substantial changes to our sharing practices, we will provide you with notice 30 days prior to the effective date which we will post in our Policy Update page of our website. After the 30-day notice, your continued use of any Service constitutes express acceptance to all changes to the Privacy Policy. This Policy was last updated on February 1, 2021.