Effective as of September 1, 2016
SharedLending operates a platform available through the web at SharedLending.com, and on mobile devices and tablets (the "SharedLending Service" or "Service"). This policy applies to all SharedLending-authorized operations of the Service. We may refer to SharedLending as "we", "us", or "our". We may refer to you as "you", or "your". The purpose of this policy is to inform you about the information we collect, how we use and share that information, and the ways in which you can control how we use and share that information. By submitting your information through our Service, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your information in accordance with this policy.
1. Information We Receive or Collect From You
Registration Data: When you register, we ask you to provide certain information, which includes your email address, and a password for your account.
Payment Information: If you choose to subscribe to fee-based portions of the Service, or purchase add-on products or services, you will also be asked to provide (at a minimum) your name and credit card information ("Payment Information").
CORE Profile: You have the ability to provide a variety of information during your interactions with the CORE Profile 37 questions. SharedLending or third parties acting on our behalf receive data from you whenever you provide us with any of this type of information.
Usage: When you use the Service, we keep track of your activity, which may include how your score and sub-scores change as your answers change.
Technical Information: As is true of many internet-enabled services, SharedLending may collect certain non-personally identifiable technical information through the use of log files and servers. Web and application servers create log files automatically as part of their setup and configuration. Information in a log file may include IP address, browser type, Internet service provider, date/time stamps, MAC address, file requested, and other usage information and statistics.
Contact Information: The email address you provided as part of your Registration Data is not considered Contact Information for the purposes of this policy.
Device Information: If you access and use the Service from a computer, mobile phone, tablet, automobile, or other electronic device, we may collect information about those devices. For example, our servers receive and store information about your computer and browser, including your Internet Protocol (IP) address, browser type, and other related software or hardware information. If you access the Service from a mobile phone, tablet, automobile, or other electronic device, we may collect and store information such as device type, operating system version and type, unique identifiers (such as Android Advertising ID, VIN, MAC address, and IDFA), carrier, and other related information for that device.
Location Information: As part of registration for the SharedLending Service, you agree to provide us with, and allow us to use, your zip or postal code. Additionally, we may collect and use approximated or realtime location information, such as GPS location, from devices you use to access the SharedLending Service. We will provide you with notice and an opportunity to consent before we access and collect your realtime location information, and depending on your device manufacturer, you may have the ability to revoke this consent at any time.
2. Information We Receive or Collect From Third Parties
We may receive or collect information about you from third parties and combine and store it on our servers with other information we may have already received or collected from you. These third parties include:
Service partners that provide or make available advertising, features and functionality, and content on or through the Service. Advertising partners that collect and maintain information on their customers. These partners may provide SharedLending with certain information about those customers for the purposes of serving advertisements and/or marketing offers to their customers on the SharedLending Service.
Marketing companies and data providers that create, maintain, and distribute professional marketing lists or segments, or maintain and distribute other marketing, or similar data.
Governmental or quasi- or pseudo-governmental agencies or organizations that provide or make available, to the public, census and demographic data.
Third-party social media websites, applications, or services that you use, when we allow those websites, applications, or services to interact through the Service to provide personalized services to you. In some cases, those websites, applications, or services may automatically provide us with information about you to facilitate personalization unless you use the controls available on those websites, applications, or services to opt-out of such sharing.
People who store or post information about you, by your enabling connectivity with another website, application, or service where friends or others store such information. For instance, your friends may store information about you in places such as their friend lists, address books, or photos on other websites, applications, or services such as social media applications with which the SharedLending Service interacts.
3. Information Collection Technologies
If you agree, businesses you support will receive your CORE Profile information based on a unique link assigned to that business. If you access the Service and create a CORE Profile through this unique link, businesses will have access to your CORE Profile through a secure portal.
4. How We Use Information We Receive or Collect
Generally: SharedLending may use your Registration Data and/or other information or data we receive or collect, as well as data we derive or infer from combinations of the foregoing, for a variety of purposes, such as:
To facilitate the creation of and secure your account on the SharedLending Service.
To measure and analyze Service usage and enhance the user experience on our Service.
To send you information that you agreed to receive.
Email Address: We do not sell or give your email address to other companies for their own marketing purposes without your permission. However, we may use your email address or other Registration Data to provide you with technical support, and send you notices about the Service or other promotional offers you have elected to receive.
Contact Information: We do not sell or give your Contact Information to companies for their own marketing purposes without your permission. We do use Contact Information, however, to contact you, and to provide you with special offers and other information.
5. How We Share Information We Receive or Collect With Others
How Your Information Is Shared: SharedLending may share information we receive or collect in a variety of ways, such as:
When you give SharedLending permission through an affirmative election (for example, clicking "yes" in response to a message such as "share my email with this business").
If we contract or partner with third parties to provide specialized services on our behalf, such as credit card processors, customer support, bulk email processors who send out emails on our behalf, or parties who assist us with sweepstakes management and prize fulfillment. These companies are authorized to use your personal information only as necessary to provide these services to SharedLending. They are not authorized to use your personal information for their own, unrelated purposes.
If you have given permission to a third party for us to share data about you with them. For example, if you participate as a panelist in a survey with an analytics company, you may, as part of your agreement with that company, have authorized that company to receive data from us about you.
To integrate with other services. For example, you may have the option to integrate with your smartwatch or athletic tracker, which means that we have to share some of your information to synchronize your accounts on other services.
Sharing of Personally Identifiable Information:
We do not share personally identifiable information with third parties other than as described in this policy. However, we may share your information, including personally identifiable information, in order to (i) protect or defend the legal rights or property of SharedLending, or the legal rights of our business partners, employees, agents, and contractors (including enforcement of our agreements); (ii) protect the safety and security of SharedLending users or members of the public including acting in urgent circumstances; (iii) protect against fraud or to conduct risk management; or (iv) comply with the law, legal process, or legal requests. Additionally, we may share your data, including any personally identifiable information, with our successor in interest in the event of a corporate reorganization, merger, or sale of all or substantially all of our assets.
Sharing of Device Data: SharedLending may share information from devices you use to access the Service with its third-party vendors or service providers, manufacturing or distribution partners, or advertising partners. We share this information for a variety of purposes such as estimating the number of unique users, security and fraud detection, debugging problems with the SharedLending Service, and for providing you with more relevant advertisements.
Sharing of Anonymized, Non-Personally Identifiable or Aggregated Data: SharedLending may share with third parties, advertisers, and/or business partners anonymized, non-personally identifiable, or aggregated data we receive or collect, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Service, or information about the tips you favorite and lenders you recommend. We share such information for a variety of reasons, such as to analyze Service usage, improve the SharedLending Service and your user experience, improve the serving of advertisements, or for other similar purposes. The use and disclosure of such anonymized, non-personally identifiable, or aggregated information is not subject to any restrictions under this policy.
Information You Disclose in a Public Profile or in Public Forums:
The SharedLending Service offers publicly accessible and available community forums (such as health tips, lender reviews, life coaching advice, etc.),blogs, and pages on social media platforms. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. If your profile is public, any information you place in your user profile, including biographical information, the people you are following, and the people whom you allow to follow you, may be read, collected, and used by others who access them. To request removal of such information from our public forums, contact our User Support team. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why. To find out more about how to make your profile private, please see the section below on SharedLending Profile Visibility.
If your personally identifiable information is transferred as described in this policy, we will seek assurances from the recipients of such personally identifiable information (prior to the transfer) that they will safeguard the personally identifiable information in a manner consistent with this policy. We ask recipients of such information to enter into a contractual relationship with us that includes confidentiality and non-disclosure clauses, and provides the same level of commitment to and protections of information as provided in this Policy.
6. Managing Your Information
Modification of Your Registration Data: We provide you with the ability to modify your Registration Data, which you may do through the Settings section of our Service or by contacting User Support. For detailed instructions on how to modify your Registration Data or to otherwise access this information, visit our support site at http://help.SharedLending.com. We generally respond to email requests within 24 hours of receiving a request, but it may take up to 30 days depending on the volume of requests we receive.
Retention of Your Registration Data and other Information: We will retain and use your Registration Data and the other information we collect about you for as long as your account is active or as needed to provide you Services. We will retain and use this information for the purposes for which it was collected (as specified in this policy or as SharedLending discloses to its users outside of this policy), including, to provide the Service to you, comply with our legal obligations, resolve disputes, and enforce our agreements.
If you would like to delete your Registration Data, or if you would like more information on cancelling or deactivating your account, see the section below on Cancellation or Deactivation of Accounts.
Your Email Preferences: When you register for the Service, you may elect to receive promotional, marketing, or other similar emails tailored to your interests. You have the option to change this election in the Settings section of our Service. For information on how to opt in or out of receiving promotional, marketing, or other similar emails from us, visit http://help.SharedLending.com.
Additionally, you may also follow the unsubscribe instructions contained in the promotional, marketing, or other similar emails you receive.
We will send you transaction confirmation emails and other Service-related announcements when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Cancellation or Deactivation of Accounts: If you would like to request the cancellation or deactivation of your account, you should contact our user Support team for assistance. Cancellation or deactivation of your account does not ensure complete or comprehensive removal of the content or information you may have posted or otherwise made available publicly on the Service while you were a registered user. You should also contact our user Support team to request the deactivation of a profile you believe is fake or otherwise unauthorized.
SharedLending Profile Visibility: When you register for the SharedLending Service, your recommendations, reviews, and favorites will be public. When the visibility of your SharedLending profile is set to public, the Service will allow anyone to see the things you post. For example, if you post a review of a particular personal trainer or credit union, anyone will be able to read it. We provide you with the ability to change the degree of visibility of your SharedLending profile. For detailed instructions on how to adjust your SharedLending profile visibility settings, visit http://help.SharedLending.com.
Cached Profiles on Search Engines: Please note that although we may deactivate your account or make your profile private at your request, Internet search engines such as Google and Bing cache publicly available webpages for a period of time beyond the control of SharedLending, and may make your deactivated or formerly public profile available to users of their services on their platforms until such time as they refresh their webpage cache. Please consult with the applicable search engine to determine how you may remove webpages from their webpage cache.
7. Security and Content From Other Websites
Protection of Data From Loss:
We have implemented security measures designed to protect against theloss, misuse, and alteration of the information we collect or receivefrom you. For example, when you enter sensitive information (such as acredit card number) on our order forms, we encrypt the transmission ofthat information using secure socket layer technology (SSL). However,despite our efforts, no security measures are perfect or impenetrable.If you have any questions about security on our Service, you cancontact our user Support team.
Data Integrity: We will use personally identifiable information, if any, that we collect and receive from you in ways that are relevant and compatible with the purpose for which that information was collected or provided to us as more fully disclosed in this policy. We will take steps to ensure that all personally identifiable information collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with the purpose for which we received it.
Links to Other Websites: Our Service and certain advertisements on our Service include links to other websites whose privacy practices may differ from those of SharedLending. If you submit personal information to any of those websites, the privacy statements and practices of those websites govern their use of your information. We encourage you to carefully read the privacy statement of any website you visit.
8. Our Policies Concerning MinorsSharedLending prohibits registration by, and does not knowingly collect personal information from, anyone under 18 years of age. In the event we obtain actual knowledge that we have collected information from children under the age of 18, we will take measures to remove such information from our servers. If you believe that we might have any personal information from a child under 18, please contact email@example.com.
9. Your California Privacy Rights and "Do Not Track"
Pursuant to California Civil Code Section 1798.83, this policy sets forth that we only share personal information (as defined in California Civil Code Section 1798.83) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide personal information or when you choose to participate in a feature on the Service. If you do not opt-in or if you opt-out at that time, we will not share your personal information with that identified third party for direct marketing purposes.
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to "Do Not Track" browser settings. Like many other websites and online services, we do not currently alter our practices when we receive Do Not Track signals as there is no consensus among industry participants as to what "Do Not Track" means in this context. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com/.
10. European Union-Swiss Safe Harbor
SharedLending adheres to the set of data protection principles developed by the United States Department of Commerce, in collaboration with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland, which produced the U.S.-European Union Safe Harbor Framework Documents and U.S.-Swiss Safe Harbor Framework Documents. The privacy principles in this policy are based on these Safe Harbor Principles, including as they relate to personal information transferred from the European Union ("EU") and/or Switzerland to the United States ("U.S.").
11. Transfer of Information
Please note that the information you submit to us may be transferred to the U.S. and other countries to be processed by us or our service providers in order to provide the Service to you or for such other purposes as set forth in this policy. If you are not a resident of the U.S., you hereby consent and agree that we may collect, process, use, and store your information, as discussed in this policy, outside your resident jurisdiction, including in the U.S. Please be aware that U.S. law and the laws of other countries where we may store and process your information may offer different levels of protection for information than may be available in your country.
We will continue to evaluate this policy against new technologies, business practices, Safe Harbor requirements, and our users’ needs, and may make changes to the policy accordingly. Please check this page periodically for updates. If we make any material changes to this policy, we will post the updated terms of the policy on the Service, and provide you notice of such changes, which may include notice by email through a message sent to the email address you use to access the Service, or posting a message on the Service.
Any material changes to this policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of notice of the changes on the Service. These changes will be effective immediately for new users of the Service. Please note that at all times you are responsible for updating your information to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your information, you must notify us prior to the effective date of the changes that you wish to deactivate your account. Continued use of the Service following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Dispute Resolution: Questions or concerns regarding our use or disclosure of information may be directed to our user Support team. SharedLending will investigate and attempt to resolve complaints and disputes regarding use and disclosure of information in accordance with the principles contained in this policy. For complaints that cannot be resolved between SharedLending and the complainant, SharedLending agrees to cooperate with the respective data protection authorities located in the applicable country (or their authorized representatives) and participate in any dispute resolution procedures established by such authorities.
14. Contact Us