Zendable, Inc. and its affiliates (collectively, "Zendable", "we", "us", "our") are committed to your privacy and security online. This policy describes the ways we collect, use, share and protect your personal information in connection with your use of www.zable.com and any of its subdomains (the “Site”) and the products and services offered on the Site by Zendable and other third parties that it has partnered with.
- Our services
- What Information we collect
- How we collect information
- How we use the information we collect
- What information we share
- How we protect and retain your information
- Links to or from other websites and services
- How you can access or change your personal information
- Children’s privacy
- Your choices
- Information for California consumers
- How you can contact us
Zendable collects, uses, stores and shares information in connection with its products and services including:
- the referral and loan comparison services we offer when you visit the Site and request conditional offers from Zendable and other third-party licensed lenders ("Creditors") for whom we may act as marketer, service provider, and/or loan servicer of their loan;
- as servicer and administrator to third party loan investors on whose behalf it is acting; and
- when you authorize Zendable to send or receive your information to third parties to access certain additional products or services on the Site.
We reserve the right in our sole discretion to make changes to how we operate and provide our services, including adding new services, modifying existing services, or suspending, discontinuing, or terminating your access to any or all portions of our services, as described below.
What Information we collect
The types of personal information we collect depends on the products and services you use. The information includes:
- Your name, address, phone number, email, date of birth, social security number and documents or other media that verifies your identity such as your driver’s license, and passport;
- Information such as your credit history, credit scores and other information provided by consumer reporting agencies;
- Information about your loan account and your payment history;
- Information we receive from third party data partners for verification purposes including to verify your identity and manage risk;
- Your bank information such as your bank, your account numbers, bank account credentials, and transaction information;
- Information about your employer, current income, assets and certain expenses, including with respect to your current employment, employment offers, bank account credentials and transaction information, tax returns, W-2, and pay stubs;
- Information about your computer, mobile phone or other access device and anonymous information about your web request, Internet Protocol (“IP”) address, geolocation data, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Site, domain names, landing pages, pages viewed, your use of third-party applications, and other information that assists us in analyzing and improving the Service.
Please note that Zendable only provides its services and offerings to consumers based in the United States and therefore, is not subject to the General Data Protection Regulation (GDPR).
How we collect information
We collect information about you:
- Directly from you when you register on the Site and use the Site and our products and services; fill out forms or fields such as when you request a loan offer, or apply for a loan or to be an investor; through the services you opt in to, such as choose automatic bank account verification; from your transactions, including your loan repayments; and your communications with us.
- Automatically from you when you visit the Site or use the products and services available on the Site:
- We collect certain information from your computer, mobile phone or other access device that is automatically reported by your browser or mobile device each time you access the Site;
- We automatically record certain log file information such as IP address, browser type, and what you do on our Site;
- We (or companies we work with) may place small data files called cookies or pixel tags on your computer or other device.
- You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of the Site. The help legal section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.
- From third party service providers including information we request on your behalf from credit reporting agencies such as TransUnion, Equifax, and/or Experian, information we receive from third party data partners who supplement and/or verify information we collect from you, and information we access from public records or websites.
- From third party referral partners that you engage with who may pass certain information about you and your use of their service to us. This information could include any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before visiting the Site.
How we use the information we collect
We collect this information from or about you in order to:
- provide you and other customers with access to the products and services offered through the Site;
- improve our insights so we can tailor our content and advertising, and provide you with offer recommendations and/or insights that are most relevant to you;
- provide notices and other information to you about, or in connection with, these products and services;
- provide customer support;
- detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, fulfill legal requirements and enforce our agreements;
- debug to identify and repair errors that impair existing intended functionality;
- provide, maintain, develop and improve our services, your experience, and to protect Zendable and its users; and
- improve your experience accessing the products and services offered through the Site by recognizing you as a customer and remembering information you previously provided so that you will not have to re-enter it.
What information we share
All financial companies need to share customers’ personal information to run their everyday business. Subject to any applicable legal exemptions including the Gramm-Leach Bliley Act, and/or the California Consumer Privacy Act, we may share your personal information, including non-public personal information with:
- Service providers who help with parts of our business operations such as fraud prevention, servicing, bill collection, debt collection, marketing and technology services, and product development;
- Credit reporting agencies to report account information, at your direction and otherwise as permitted by law;
- Debt collection companies that purchase your loan from a Creditor if it has been charged off;
- Companies that we plan to merge with or be acquired by, or companies we plan to sell, divest or transfer all or a portion of our products and/or services to, including any back-up service provider or back-up administrator we, or any Creditor engage in the event we stop operating;
- Law enforcement, government officials, or other third parties when (1) we are compelled to do so by a subpoena, court order or similar legal procedure, (2) we need to do so to comply with law, or (3) if we believe in good faith that the disclosure of your personal information is necessary to prevent physical harm or financial loss or to report suspected illegal activity; and
- Other third parties but only if you consent or direct us to do so.
If you select a loan offer from Cross River Bank when you sign your promissory note, your loans may be automatically allocated as follows:
- We may purchase your loan from Cross River Bank.
- Investors may purchase your loan directly from us. We provide information about you included in your application, including personally identifiable, financial, and credit information, and your loan terms to these investors and their agents and trustees in advance of their purchase of your loan.
- As the servicer of your loan we will also share information we obtain in servicing your loan, including about your repayments, to investors, who become the Creditor of your loan, any subsequent purchaser of your loan, and each of their agents or trustees.
Zendable will not sell or rent any of your personal information to third parties and only shares your personal information with third parties as described above.
Information that has been deidentified so that it does not identify a specific user is not considered personal information. Federal and state laws allow you to restrict the sharing of your personal information in certain instances such as sharing your information so that third parties can market to you. However, because we will not share your information in these instances without your express consent, there is no need for you to opt-out from the information we share.
How we protect and retain your information
We care about the security of your information and take reasonable measures designed to protect your personal information from unauthorized access and use by maintaining physical, electronic and procedural safeguards in compliance with applicable law. These measures include computer safeguards and secured files and buildings.
You are responsible for controlling access to your account and email communications from us at all times. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information may not be accessed, disclosed, altered or destroyed.
In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify via email, mail, or telephone those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Links to or from other websites and services
How you can access or change your personal information
You can review and edit some of your personal information at any time by calling us at 1-844-779-2253 business days that are Monday through Friday 9:00am EST to 4:00pm EST.
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as users. The Site and its content are not directed at children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will delete that information promptly. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
Some jurisdictions give consumers additional rights regarding their personal information.
- Access to your personal information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
- Changes to your personal information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information be modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
- Deletion of your personal information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purpose.
- Objection to certain processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Online tracking. We currently do not recognize the “Do Not Track” signal.
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
Consumers may make a rights request by emailing us at email@example.com or calling 1-844-779-2253.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, email address, or details about your last interaction with us. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
- A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
- If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal.”
Information for California consumers
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”).
The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than you.
|Categories of Personal Information We Collect
|To Whom We Disclose Personal Information for a Business Purpose
|Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.
|Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.
|Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.
|Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
|Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
|Inferences drawn from any of the information listed above
This policy is accessible through your browser’s audio reader. California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): a consumer’s social security number. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.
California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the How you can contact us section above.
We may amend this policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. The revised version will be effective at the time we post it. If we make a material change we will notify you of the changes by posting a Policy Update and update the ‘last modified’ date at the bottom of this page.
How you can contact us
If you have questions or concerns regarding this policy, you should contact us by emailing us at firstname.lastname@example.org, by calling us at 1-844-779-2253 during our operating hours 9:00 AM EST to 4:00 PM EST, Monday through Friday, or by writing to us via regular mail at Zendable, Spaces Suite 1511, 1740 Broadway, New York, NY 10019.