F2f Privacy Policy

Effective Date: September 21, 2023

Our Commitment to Privacy

Your privacy is very important to us. Part of our operation of the F2F Lending, Inc. (“F2F”) platform necessarily involves the collection and use of personal information about you. This privacy policy explains what type of information we collect and what we do with that information to allow you to make choices about the way your personal information is collected and used. This privacy policy may change from time to time, so please check it often.

Applicability of Privacy Policy

This privacy policy applies to all information we collect through our web and mobile applications from current and former F2F users, including you. When you are no longer our customer, we continue to share your information as described in this policy. 

Throughout this policy, we use the terms “information” and “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.

What Information Do We Collect?

When you visit the website or our mobile application, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use the F2F platform.

If you open a F2F account, we collect the following information from you:

• Account Information. Text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
• Identification Information. Your name, street address, telephone number, and email.
• Device Information. Information about you: (a) from your mobile      device such as your device type, device model, machine or mobile device identification number, geo-location, time zone, system OS, app version, cellular network, language setting, advertisement ID, browser type, and IP address; and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
• Social Web Information. Including but not limited to your Facebook      connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your friends contact      information. We also allow you to import data from other social web services, including but not limited to Google, X (Twitter), Facebook, AppleID and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve the F2F platform and fight fraud).      
• Financial Information. F2F does not collect financial data. For some services, F2F uses Plaid Technologies, Inc. (“Plaid”) to gather your data from financial institutions. In using the F2F platform, you grant Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal). We will request your permission before granting such access.

We are committed to providing a safe, secure, and all-around great platform. Therefore, before permitting you to use the F2F platform, we may require additional information from you we can use to verify your identity, address, or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you, including your FICO score and social security number from third parties such as identity verification, fraud prevention, and similar services. 

When you are using the F2F platform, we collect information about your account transactions, and we may collect information about your computer or other access device for fraud prevention and other similar purposes. 

When you engage us to provide services, our payment processor, Dwolla, will collect all information necessary to complete the transaction, including your name, credit card information, billing information, and direct deposit/ACH information. Dolla’s services are covered by the Dwolla privacy policy (https://www.dwolla.com/legal/privacy/). When you engage us to provide services, our e-signing processor will collect all information necessary to complete the setting up a new or existing loan with us.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.

Information from Children

The F2F platform is not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

Automatic Anonymous Information

When you visit our site, we collect certain technical and routing information about your computer. For example, we log environmental variables such as browser type, operating system and CPU speed, and the Internet Protocol (“IP”) address of your originating Internet Service Provider, to try to bring you the best possible service. We also record search requests and results to try to ensure the accuracy and efficiency of our search engine. We use your IP address to track your use of the site, including pages visited and the time spent on each page. We collect this information and use it to measure the use of this website and to improve its content and performance. All of the information that is automatically submitted to us by your browser is considered anonymous information. To the extent we share such information with third parties, it is not traceable to any particular user and will not be used to contact you.

Cookies

When you visit our website, use our mobile application, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies to recognize you as a customer; customize the F2F platform, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across the F2F platform.

Certain aspects and features of the F2F platform, including our website, are only available through the use of Cookies. If you choose to disable or decline Cookies, your use of the F2F platform may be limited or not possible. 

Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

Security

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial, and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your F2F password with anyone.

If F2F learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the F2F platform, you agree that F2F may communicate with you electronically. F2F may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@f2flending.com.

How Do We Use Information We Collect?

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun, and customized experience. We may use your personal information to:

• Provide the services and customer support you request;
• Process transactions and send notices about your transactions or your network activity;
• Resolve disputes, collect fees, and troubleshoot problems;
• Prevent potentially fraudulent, prohibited, or illegal activities, and enforce our User Agreement;
• Create an account connection between your F2F account and a third-party account or platform;
• Customize, personalize, measure, and improve our services and the content and layout of our website;
• Send you updates about new products and services that we are offering to customers;
• Compare information for accuracy and verify it with third parties; and
• Perform other duties as required by law.

If you elect to share your geolocation information, we will use this information to enhance the security of the F2F platform and we may use this information to provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content.

We collect personally identifiable information only for providing the services you request, generating statistical studies, conducting marketing research, improving products and services, sending you surveys, and notifying you of new products and any other changes to our site or services that may affect you. When you submit personally identifiable information to us, you understand that you are agreeing to allow us to access, store, and use that information for those purposes.

We will not sell or give any personally identifiable information to any third parties.

We may be required by law enforcement or judicial authorities to provide personally identifiable information to the appropriate governmental authorities. If requested by law enforcement or judicial authorities, we will provide this information on receipt of the appropriate documentation. We may also release information to law enforcement agencies or other third parties if we feel it is necessary to protect the safety and welfare of our personnel or to enforce our terms of use.

How We Share Personal Information with Other Parties

F2F does not share your personal information with third parties for their promotional or marketing purposes. We may share your personal information with: 

• Companies that F2F plans to merge with, acquire or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this      policy, you will receive prior notice and the opportunity to communicate      preferences you may have, if applicable.
• Law enforcement, government officials, or other third parties if F2F is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal      activity, or to investigate violations of the F2F Terms and Conditions, or      as otherwise required by law.
• Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendors behalf.
• The other F2F user participating in the transaction and depending on the privacy setting of each F2F account transaction, your F2F friends and the F2F friends of the other user participating in the transaction, or the public, through the F2F feed on      our website and mobile application and elsewhere on the internet.
• Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
• Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
  • For the purposes of this privacy policy, an “account connection” with such a third party is a connection you authorize or enable between your F2F account and a non- F2F account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, F2F and the third-party will exchange your personal information and other information directly. Examples of account       connections include: linking your F2F account to a social media account or social messaging service; connecting your F2F account to a third-party data aggregation or financial services company, if you provide such company with your F2F account log-in credentials; or using your F2F account to make payments to a merchant or allowing a merchant to charge your F2F account.
  • If you connect your F2F account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the       third-party about you and your use of the third-party’s service. For example, if you connect your F2F account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.
  • Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that F2F shares with a       third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the accounts or platforms privacy practices.
  • If you choose to use Siri or iMessage to lend or borrow money via F2F or to otherwise use the F2F platform, such use is subject to Apple’s terms and conditions for use of iMessage and/or Siri, as applicable, and the terms of the F2F Terms and Conditions. By using Siri or iMessage, you authorize us to share some of your F2F account data (including your friends list, list of persons you have transacted with most recently and most frequently, transaction instructions, and       transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data shared with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to F2F on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.

F2F does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of F2F and is subject to the terms of use and privacy policies of such third parties.

Opt-Out Policy

If at any time you do not wish to receive offers and emails from us, we ask that you tell us. You may remove your name from our mailing list by sending us an email addressed to privacy@f2flending.com and indicating in the subject line “No Offers or Email” or by responding to a SMS message from F2F with “Stop”.

Links To Other Sites

The F2F website or mobile application may contain links to other third-party websites. F2F does not control the information collection of third-party websites that can be reached through links from the F2F website. We encourage our users to be aware when they are leaving the website and to read the privacy statements of any third-party website that collects personally identifiable information.

Will F2F Refuse Service, Charge Me a Different Rate, or Provide Different Quality Service if I Decline to Provide Certain Data?

In order to use the F2F platform to transfer funds through the U.S. monetary system, a user must comply with applicable federal laws and rules. These applicable laws and rules may require the disclosure and retention of information regarding the identity of senders and recipients of funds.

F2F will not discriminate against you for exercising any rights you may have under the California Consumer Privacy Act or any other applicable law or rule. F2F does not base its prices or the quality of its services on the exercise or non-exercise of legal privacy rights.

Rights for Certain Consumers

If you are a resident of a state that has adopted privacy regulation, you may have additional certain rights regarding your personal information. This includes:

• Right to Know. You may have the right to know what personal information we      collected about you, including the categories of personal information, the      categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
• Right to Access and Data Portability. You may have the right to request a copy of the      personal information that we collected about you during the 12 months      before your request.
• Right to Deletion. You may have the right to request that we delete information that we collected from you and retained.
• Right to Opt Out of Selling or Sharing. You may have the right to opt-out of having      your personal information sold or shared. Some web browsers allow consumers to automatically exercise their right to opt-out of sale/sharing with all businesses they interact with online by initiating an opt-out preference signal. We will honor such opt-out preference signals.

In order to request, deletion or a copy of your personal information, you may forward verifiable consumer requests to F2F through one of the following methods:

• Email F2F at privacy@f2flending.com; or
• By clicking the appropriate link on our web site

Only you, or someone legally permitted to act upon your behalf, may make a verifiable consumer request. For example, you may make a verifiable consumer request on behalf of your minor child.

In order to submit a verifiable consumer request to F2F, the request must both provide sufficient detail for F2F to be able to appropriately ascertain your identity and give sufficient clarity for F2F to understand the nature of the request. F2F will determine the criteria for a verifiable consumer request based upon the nature of the request and account.

If you have submitted a verifiable consumer request, F2F will respond in a timely manner consistent with applicable law. If F2F is unable to verify or denies your request, F2F will submit an appropriate response. If you would like to appeal our decision to deny your request, please do so by using the secure messaging portal that we emailed to you after you submitted a data subject rights request. If you have any questions or concerns, please email us at privacy@f2flending.com.

Transfer of Customer Information

Customer lists and information are properly considered assets of a business. Accordingly, if we merge with another entity or if we sell our assets to another entity, our customer lists and information, including personally identifiable information you have provided us, would be included among the assets that would be transferred.

Changes To Our Privacy Policy

F2F is always improving. As F2F evolves we may occasionally update this privacy policy. If we modify this privacy policy, we will post the revised privacy policy to the website, and we will also revise the “effective date” stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our mobile application, the website, or by sending you an e-mail. It is your responsibility to periodically review this privacy policy; users are bound by any changes to the privacy policy by using the F2F platform after such changes have been first posted.

How To Contact Us

If you have questions or concerns regarding this privacy policy, or any feedback pertaining to your privacy or the F2F platform that you would like us to consider, please email us at privacy@f2flending.com