2. SOURCES OF INFORMATION
The personal information we collect about you comes primarily from the information that you provide to us during the course of your relationship with us. We may also collect information about your transactions and experiences with us relating to your use of the Site and/or the Products. In addition, depending on the Products that we provide to you, we may obtain additional information about you from third parties (for example, we may obtain your credit history from consumer reporting agencies or demographic information maintained by third parties).
When you interact with the Site on a social media platform, we may collect the personal information that you make available to us relating to that platform, including your account ID or username and other information included in your posts.
Finally, in the provision of Products to you, information may be collected about you indirectly through monitoring or other means (for example, recording of telephone calls, monitoring emails and information collected through your use of the Site). By communicating with us, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Information That You Provide
When you visit the Site, apply for a Product, establish a customer relationship with us, use a Product or otherwise interact with us, the typical information we may collect about you includes:
• Your name, address, phone, email and other contact details and similar information;
• Your age and occupation;
• Your Social Security Number;
• Financial information (for example, information about your income and information about your assets);
• Documents to verify your identity, occupation and income, such as photographs or copies of government IDs, checks, tax documents and other similar materials; and
• Other personal information that you disclose as part of any Product enrollment, loan application or in other communications with us.
Of course, you are not required to supply any of the personal information that we request. However, your failure to do so may result in our being unable to open or maintain an account or to provide Products to you. You agree to promptly notify us if there are any changes to your personal information by updating your online account, calling us toll-free at 1-646-798-1800 or writing to us at STEM Lending, Inc. 143 Gates Avenue, Montclair, New Jersey 07042.
Automatically Collected Information
We may receive information about your location and your mobile device, including a unique identifier for your device. You can change whether you share specific geo-location information in your device settings; however, some Products or features may not function properly without this information.
3. OUR USE OF YOUR INFORMATION
We use your information to provide you with Products and information and to help us personalize and continually improve the Site, including fulfilling requests for information, processing applications, analyzing and compiling trends and statistics and communicating with you.
We may also use your information to:
• Contact you through various channels, including mail, telephone, text message and email, in connection with your account;
• Provide you with customized information and reports, tailored content and marketing messages;
• Authenticate your identity, including during account creation;
• Support our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements;
• Comply with contractual obligations, relevant industry standards and our policies;
• Mitigate fraud, enhance the security of your account and our online services and manage institutional risk;
• Operate, evaluate and improve our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);
• Improve Site performance and personalize your experience with the Site;
• Notify you about changes to the Site, Products and policies;
• Perform analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view;
• Respond to your requests and otherwise fulfill any purpose for which you provide it to us;
• For any other purpose that we disclose at the time you provide, or when we collect, your information; and
• Other purposes permitted by applicable law.
In addition to the above, we may use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.
We also may use or combine information that we collect offline or that we receive from third-party sources for many reasons, including to enhance, expand and check the accuracy of our records. Additionally, data collected from a particular browser, device or application may be used with another linked browser, device or application.
We provide you with certain communication choices relating to certain types of communications and information sharing. See the Do Not Call Policy below for more details on your telemarketing options. You may also receive a privacy notice in connection with certain Products that you receive from us describing certain communication choices associated with that Product. You can exercise your communications choices by following any instructions contained in our privacy notices or marketing materials, calling us toll-free at 1-646-798-1800 or writing to us at STEM Lending, Inc.
4. DISCLOSURES OF YOUR PERSONAL INFORMATION WITHIN STEM LENDING
In order to provide efficient and reliable Products and to improve product and service options available to you, more than one entity within STEM Lending may be given, or given access to, your personal information. For example, one STEM Lending entity might share your information with another in order to facilitate your transactions or the maintenance of your accounts. When we share your personal information in this way, we adhere to all applicable legal requirements regarding the sharing and protection of personal information. The privacy notice for an applicable Product may have information about your rights and choices regarding sharing your personal information within STEM Lending. Additional information on how your personal information is protected while within STEM Lending is provided below, under “Information Security: How We Protect Your Privacy.”
5. DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
We only share your personally identifiable information with third parties as described below. In addition, we may share information that does not specifically and personally identify you, such as aggregated information, device identifiers or other unique identifiers to third parties.
We will not sell information that personally identifies you to any third party for their own marketing purposes.
Third-Party Service Providers: We may share your personal information with non-affiliated companies that perform support services for us or in connection with any Product that you may receive from us (“Third-Party Service Providers”). Third-Party Service Providers that assist us are required to protect any non-public personally identifiable information that they receive from us and to use that information only for the purposes that we instruct or for other business purposes as permitted by law.
Law Enforcement, Legal Process and Emergency Situations: Your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations. Examples include responding to a subpoena or similar legal process, protecting against fraud and cooperating with law enforcement or regulatory authorities. We may also disclose your information if we believe it is necessary or appropriate to protect our rights, property or safety or the rights, property or safety of our employees, customers or others, or to enforce our contractual rights.
Sale, Assignment or Change of Control: In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets, some of the personal information that we hold may be among the assets transferred to a buyer or other successor. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control or financing transaction.
6. COOKIES AND OTHER TRACKING TECHNOLOGIES
Like many websites, we use tracking technologies such as cookies, web beacons and similar technologies. We may also use these technologies to record your preferences, track your use of the Site, measure exposure to our online advertisements, monitor traffic, improve the Site and make the Site easier to use.
You have choices to limit some tracking mechanisms that collect information when you use the Site. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. If you choose to decline cookies, certain features of the Site may not function properly or may not remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.
For more information about your choices, see Interest-Based Advertising, below.
Cookies are small text files that may be placed on your device when you visit the Site or when you view advertisements we have placed on other Web sites. Cookies allow your browser to remember some specific information which the Web server can later retrieve and use. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.
Tags, Pixels, Web Beacons, Clear GIFs
A “web beacon,” also known as an Internet tag, pixel tag or clear GIF is typically a one-pixel, transparent image located on a webpage or in an email. These may be used when you are served with advertisements, when you interact with advertisements outside of our online services or when you interact with our communications. They are generally used to transmit information back to a web server.
Interest-Based Advertising refers to collecting information about your online activities over time and across different websites and other online services to deliver advertisements to users of that device based on their web-viewing behavior. We use interest-based advertising to deliver advertisements and other targeted content to you. To facilitate interest-based advertising, we partner with third-party advertising companies that may use these technologies to collect information about you when you use the Site and your other online activities. They may also use persistent identifiers to track your Internet usage across other websites in their networks beyond the Site. They may use this information to provide you with interest-based advertising or other targeted content.
If you choose to opt-out, a cookie will be placed on your browser or device indicating your decision. This cookie is specific to a particular device and browser, so if you use different browsers or devices, you will need to opt-out on each. In addition, because the opt-out is facilitated via cookies, if you clear your cookies you will need to opt-out again.
In addition to Google Analytics, we use the Google Maps API to help pre-fill in address information. To learn more about Google’s privacy practices, click http://www.google.com/policies/privacy.
7. INFORMATION SECURITY: HOW WE PROTECT YOUR PRIVACY
We are committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized employees, agents, contractors or vendors. As described above in Disclosures of Your Personal Information to Third Parties, third parties receiving personal information are required to protect any personal information provided to them. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure while in our possession.
8. OTHER IMPORTANT INFORMATION
You must be an individual of at least eighteen (18) years of age and reside in the United States or on a United States military base in order to use the Site. If you do use the Site outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing and storage of your personal information in, the United States and elsewhere. The laws in the United States and these countries regarding personal information may be different than the laws of your state or country.
9. OTHER PRIVACY POLICIES OR STATEMENTS
10. DO NOT TRACK SIGNALS
11. DO NOT CALL POLICY
STEM Lending Inc. (“STEM Lending”) does not place marketing telephone calls to numbers appearing on a state or federal do not call list (unless permitted by applicable law) or to the number of a person who has requested not to receive telemarketing calls made by or on behalf of STEM Lending. If you ask not to receive telemarketing calls from us, you will be placed on our internally-maintained Do Not Call list and will not be called during any future telemarketing campaigns. Any request to be placed on our internally-maintained Do Not Call list will be processed within a reasonable amount of time, not to exceed 30 days.
STEM Lending employees involved in STEM Lending’s telemarketing campaigns receive training on how to use our internally-maintained Do Not Call list, and how to document, process and honor requests to be placed on our internally-maintained Do Not Call list. It is our policy to honor a Do Not Call request for five (5) years from the time the request is made. However, some states have Do Not Call Laws that require us to honor such a request for a longer period of time, and it is our policy to comply with those laws when applicable. Subject to applicable law, if you communicate with us by telephone, we may monitor or record the call. We reserve the right to revise this Do Not Call Policy.