Last updated: December 23, 2022
This privacy policy (“Privacy Policy”) governs the collection, storage, and use of information and data collected by Lendotics, or any of our affiliates (collectively, “BCCUSA,” the “Company,” “we,” “us,” or “our”) via our website www.Lendotics.com, and its subdomains, or affiliate websites, by our mobile application, or by telephone, facsimile, email, or other means. Lendotics recognizes, respects, and strives to protect the personal privacy rights of all our users, visitors, and customers (“you”). We are committed to providing security and privacy regarding the collection, use, and disclosure of your personal information
The Privacy Policy explains how we collect, retain, share, and protect your personal information. We ask that you read it carefully.
- Personal Information
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual consumer or device (“personal information”).
1.1. Personal Information Does Not Include
Publicly available information from government records
De-identified or aggregated consumer information
In California – personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), and California Financial Information Privacy Act (FIPA).
AS A COURTESY, THE FOLLOWING DISCLOSURES INCLUDE INFORMATION THAT IS EXEMPT FROM CALIFORNIA CONSUMER PRIVACY ACT. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CALIFORNIA CONSUMER PRIVACY ACT.
1.2. How We Obtain Your Personal Information:
Directly from you
You enter or provide us with information, whether online or by email, phone, or document upload.
For example, your contact information that you provide, an application for a loan, or documents you provide to verify your identity.
Directly & indirectly from you based on activity on our website
For example, from submissions through our website or website usage details collected automatically.
From vendors or third-parties that interact with us in connection with the services we perform
For example, companies that work with us to market our products to you, credit reporting agencies from which we check your credit in connection with our products and services, or other vendors that provide data we use in underwriting or protecting you and our products from fraud and identity theft.
1.3. Categories of Personal Information We Collect
We collect the following categories of personal information:
”Sensitive Personal Information” such as Social Security numbers (SSNs), Driver’s license, financial account or card numbers, Precise geolocation, Racial and ethnic characteristics, Religious and philosophical beliefs, Union membership, Contents of mail, email and text messages, Genetic and biometric data.
“Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number;
“Other Personal Information” such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, bank statements, credit card number, debit card number, tax transcripts, credit data, or any other financial information, medical information, or health insurance information;
“Protected Classification Characteristics” such as age (40 years or older), date of birth, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information;
“Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
“Internet or Network Activity” such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement;
“Biometric Information” such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, or gait;
“Sensory Data” such as audio, electronic, visual, thermal, olfactory, or similar information;
“Professional and Employment Related Information” such as current or past job history or performance evaluations; and
“Inferences” such as profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
1.4. How We Use Your Personal Information:
We may use or disclose the personal information we collect for one or more of the following purposes:
Performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing advertising or marketing services, providing analytic services, providing storage, or providing similar services on our behalf. This includes:
To fulfill or meet the reason for which the information is provided.
To provide you with information, products, or services that you request from us or may be of interest to you.
To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Helping to ensure security and integrity of our products and services.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
To improve our website and present its contents to you.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To comply with our legal or regulatory obligations.
As described to you when collecting your personal information or as otherwise set forth in the California Consumer Privacy Act.
Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
1.5. How Long We Retain Your Personal Information
Based on contractual requirements in our role as service provider and/or legal requirements to the contrary, such as a legal hold, personal information is maintained for a specified period of time, as required by legal, regulatory, or industry requirements. Additional information is such as customer applications and vendor agreements as maintained for business purposes.
1.6. How We Disclose Your Personal Information:
We may disclose your personal information to a service provider, contractor, or third party. When we disclose personal information to a service provider or contractor, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract or as otherwise permitted by law. We disclose personal information to third parties as follows:
Businesses for whom we are a service provider.
Service providers or contractors such as vendors that provide data we use in underwriting or in protecting you and our products from fraud and identity theft.
Third parties, including those to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you:
With our bank / lending relationships we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial information, Internet or Network Activity, Biometric Data, Professional and Employment Related Information, Inferences;
With our advisors such as lawyers, banks, consultants, and insurers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial information, Internet or Network Activity, Biometric Data, Sensory Data, Professional and Employment Related Information, Inferences;
With governmental and regulatory agencies we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial information, Internet or Network Activity, Biometric Data, Sensory Data, Professional and Employment Related Information, Inferences;
With credit reporting agencies and vendors we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial information, Professional and Employment Related Information, Inferences;
With our data labeling and organization software providers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Inferences;
With our data analytics providers and website hosting we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Inferences, Sensory Data, Internet and Network Activity;
With our secure file sharing providers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Inferences;
With our income tax and business verification providers we disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Inferences;
With our word processing, document creation software, screen recording, and signature management vendors we disclose Identifiers, Other Personal Information, Internet and Network Activity;
With our data security and device management vendors we disclose Identifiers, Other Personal Information, Internet and Network Activity;
With our legal filing and search vendors we disclose Identifiers, Other Personal Information;
With our communication platforms we disclose Identifiers, Other Personal Information, Internet or Network Activity;
With our lead providers and advertising providers we disclose Identifiers, Other Personal Information, Geolocation, Internet or Network Activity; and
With our business and online review companies we disclose Identifiers, Other Personal Information.
- DESCRIPTION OF YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
Section 2 of this Privacy Policy applies solely to visitors, users, customers, and others who reside in the State of California (“consumers”). In addition to the disclosures provided in Sections 1 and 3, we adopt Section 2 of this Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this section of the policy.
AS A COURTESY, THE DISCLOSURES ABOVE IN SECTION 1 INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.
The CCPA provides California residents with specific rights regarding their personal information—the Right to Know, the Right to Delete, the Right to Correct, the Right to Opt-Out of the Sale of Personal Information or Sharing of Personal Information, the Right to Limit the Use of Sensitive Personal Information, and the Right to Non-Discrimination. This section describes your CCPA rights.
2.1. Right to Know:
You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past 12 months (“Request to Know”). Once we receive and verify your Request to Know, we will disclose to you either:
Categories of Personal Information Collected, Disclosed, Sold, and/or Shared
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
If we disclosed your personal information to third parties, the corresponding categories of personal information.
If we sold or shared your personal information for cross-contextual behavioral advertising, the categories of personal information sold or shared.
Specific Information
The specific pieces of personal information we collected about you.
2.3. Right to Delete:
You have the right to request that we delete your personal information (“Right to Delete”). Once we receive and verify your request, we will delete, de-identify, or aggregate your personal information (and direct our service providers to do the same), unless an exception applies.
We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers to:
Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
Comply with a legal obligation.
Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Additionally, we may deny your request to delete if we are unable to verify your identity or have reason to believe that the request is fraudulent.
2.3. Right to Correct
You have the right to request that we correct your inaccurate personal information (“Request to Correct”). Once we receive and verify your Request to Correct, we will use commercially reasonable efforts to correct your inaccurate personal information in our records.
2.4. Right to Limit the Use of Sensitive Personal Information
You have the right to direct a business that collects your sensitive personal information to limit its use to uses which are necessary to perform the services or provide the goods reasonably expected. However, we only use Sensitive Personal Information to provide the goods and services requested by you; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our products, services, and devices.
2.5. Right to Opt-Out:
The CCPA gives consumers the right to opt-out of 1) the sale of their personal information and 2) the sharing of their personal information for cross-context behavior advertising. We address each below:
Sale: We do not sell your personal information. We do not sell the Personal Information of minors under 16 years of age without affirmative authorization.
Sharing: We do not share your personal information. Our site is not intended for or directed to minors. We do not knowingly share the personal information of minors under 16 years of age. (“Sharing” means the disclosure of personal information for cross-contextual behavioral advertising.)
2.6. Right to Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
2.7. Employees / Former Employees / Applicants
If you are an employee, former employee, owner, officer, director, or job applicant with Lendotics, please email us at Privacy@Lendotics.com for a copy of our California Employee Disclosures and Privacy Policy with information on your rights and how to exercise those rights. This information was previously provided to you in relation to your employment or application for employment.
- HOW TO EXERCISE YOUR RIGHTS UNDER THE CCPA
Section 3 of this Privacy Policy applies solely to visitors, users, customers, and others who are residents of California. Any terms defined in the CCPA have the same meaning when used in this section of the policy. This section describes how to exercise your rights under the CCPA, if applicable.
AS A COURTESY, THE DISCLOSURES ABOVE IN SECTION 1 INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA. THE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.
3.1. How to Submit a Request Yourself
To make a Request to Know, Request to Delete, or Request to Correct, please contact us by either:
Calling us at 352-995-2374
Contacting: Privacy@Lendotics.com
Making a Request to Know, Request to Delete, or Request to Correct does not require you to create an account with us. However, if you already have an existing online account, we will require you to log in to submit a request.
Only 1) you or 2) a person authorized by you to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
Requests must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Given the sensitivity of your personal information that we collect and retain, we will need to verify your identity with at least 3 separate pieces of information such as name, address, account number, date of birth, last 4 of your Social Security Number, phone number, etc.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
3.2. How Authorized Agents May Submit a Request
Before we can respond to a Request to Know, Request to Delete, or Request to Correct submitted by an authorized agent, we need to confirm not only that person or entity’s authority to act on behalf of a consumer and verify the identity of the authorized agent. If you are authorized to submit a request on behalf of a California resident, please email us at Privacy@Lendotics.com and provide the following information:
To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
written permission from the California resident, or
power of attorney
To verify your identity, please attach copies of the following to your request email:
Valid Government Issued ID (not expired) AND
a Utility Bill, Bank Statement, or similar documentation to verify your name and address
To verify the identity of the consumer for whom you are submitting the request, please attach two or more of the following with your request email (three or more are required when requesting a consumer’s specific information):
Valid Government Issued ID (not expired),
utility bill,
bank statement,
email address,
last 4 of the SSN, or
last 4 of the account number.
3.3. Response Timing and Delivery Method
We will acknowledge receipt of a Request to Know, Request to Delete, or Request to Correct within 10 business days and will respond within 45 days. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Cookies and website trackers
Network advertisers that we partner with may use data collected on this site to customize ads to you on other web sites as you browse the web. Some of these ads are targeted to your interests and preferences based on your browsing history, which is stored in a cookie on your computer. Your browsing history on our site may be tracked in these cookies even if ads are not being displayed. These cookies do not contain your name or other personal information about you. Consistent with Section 2.4, the use of cookies and trackers is limited as to California residents. For more information, or to opt out of this type of information collection, please visit: http://www.networkadvertising.org/managing/opt_out.asp
4.1. What is a cookie?
A cookie is a small text file that a website saves on your device when you visit our website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of your online activity. Cookies on our website may be delivered in a first party (set by the website) or third party (set by another website) context and may also be set in association with emails you receive from us.
Cookies help us enhance your experience when using our website. They also help us understand how people use our site, such as which pages are most popular, so that we can better serve you.
4.2. Cookies used on our website
4.2.1. Essential cookies
These cookies are essential for enabling your use of our website and providing access to features such as your profile, account information, and other secure areas of our website. These cookies do not gather information about you that could be used for marketing purposes and do not remember where you have been on the Internet. This category of cookies cannot be disabled.
4.2.2. Analytics cookies
We use cookies from service providers to collect information about how visitors use our website. These cookies collect aggregated information to give us insight into how our website is being used. We anonymize IP addresses in these services, and the anonymized data is transmitted and stored by the service providers.
To view an overview of the privacy of your Google Analytics cookies please go here: https://support.google.com/analytics/answer/6004245
You may install a Google Analytics Opt-Out Browser Add-On by going here: https://tools.google.com/dlpage/gaoptout
4.2.3. Third party website cookies
Third party cookies are cookies set by someone other than us for purposes such as collecting information on your behavior, demographics, or personalized marketing. When using our website, you may encounter embedded content or you may be directed to other websites. The other websites and embedded content may use their own cookies. We do not have control over the placement of cookies by other websites, even if you are directed to them from our Site.
4.3. How to control and delete cookies
Many of the cookies on our website can be enabled or disabled through your browser. To disable cookies through your browser, follow the instructions usually located within the “Help,” “Tools,” or “Edit” menus in your browser. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually completed through your browser function.
- Third party data processing
Lendotics is committed to fully complying with the laws and regulations, such as the Fair Credit Reporting Act, The Right to Financial Privacy Act, and the California Financial Information Privacy Act (Chapter 241,Statues of 2003) which became law on July 1, 2004 as “Division 1.2” of the Financial Code (sections 4050 et seq.) that have been established to protect the confidentiality of customer information. For individual principal shareholders, officers, and directors, if we obtain and use information from a third party, other than the government, such as a consumer report, we will notify you. You are entitled to request that credit reporting agencies remove your name from lists supplied to us. The make such a request, you need to contact each credit reporting agency separately.
Lendotics offers account linking and aggregation services through third party, Plaid Inc. (“Plaid”). If you consent to have Lendotics request your financial data directly from your financial institution, we work with Plaid to complete your request. Lendotics uses Plaid to gather your personal information and data from financial institutions. The information gathered includes but is not limited to transactions, account balances, and account numbers. By using Plaid, you grant Lendotics and 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, through Plaid, to Lendotics. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy located at https://plaid.com/legal/#consumers. By using Plaid, you also understand and agree that Lendotics will collect, retain, and use the information obtained via Plaid to offer you new products and services.
- Do not call policy
This Section 6 constitutes the Company’s Do Not Call Policy under the Telephone Consumer Protection Act for all consumers. Lendotics maintains an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days and will be effective for at least five years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers that appear on the Lendotics Do Not Call list.
- Marketing communications opt-out
You can choose to no longer receive e-mail marketing communications from us and you may express your choice where indicated on the applicable email to opt out. To opt out of direct mail send your request with your name, business name and address to: Lendotics, 405 Fifth Avenue South, Suite 7, Naples, Fl 34102. Please note, however, that such requests will only remove you from our list and the list of any non-affiliate performing services on our behalf. We are not responsible for the use any other party may make of the information once it has been transferred in accordance with this Privacy Policy and you will need to contact such entity to have your information removed from their database.
- Nevada residents disclosure
We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions in the “Marketing Communications Opt-Out” Section 6. For more information contact us at Support@Lendotics.com. Or contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; 702-486-3132; BCPINFO@ag.state.nv.us.
- Vermont residents disclosure
Except as permitted by law, we will not share information we collect about you with non-affiliates or affiliates unless we have first requested your permission and you authorize us to do so.
- Do not track signals
Our site does not respond to Do Not Track signals configured in your web browser.
- Social Media
We encourage you to review your privacy options and settings with the social media platforms and business review sites that you may use to understand what choices you have about sharing information on those platforms and networks.
- Changes to our privacy policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will notify you by email or through a notice on our website homepage.
- How to contact us
If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Privacy Support Phone: 352-995-2374
Privacy Support Email: privacy@Lendotics.com
Website: www.Lendotics.com
Postal Address: Lendotics
Attn: Lendotics Privacy
405 Fifth Avenue South
Suite 7 Naples, FL 34102
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