Privacy Policy

LendStrm, LLC ("LendStrm", "Company", "we", "us", or "our"), a limited liability company organized under the laws of the State of Florida, and the website at lendstrm.com (the "Website") are committed to respecting the privacy rights and concerns of all users ("Users", "you", or "your") of the Company's websites, applications, and financial services (collectively, the "Sites and Services").

We have established this Privacy Policy to inform you how we collect, use, protect, store, and disclose your personal information. By visiting, accessing, or using the Sites and Services, you consent to the data practices described in this Privacy Policy.

Changes to this Policy: We may update this Privacy Policy from time to time. We will post the updated policy on this page and revise the "Last Updated" date above. Where required by law, we will provide additional notice of material changes.

1. Information We Collect

To provide our Sites and Services, we may collect various categories of personal and financial information, including:

• Identifiers & Contact Information: Name, mailing address, email address, phone number, date of birth, Social Security Number (SSN), driver's license, or state identification number.
• Financial & Employment Data: Bank account details, billing addresses, employment history, and income information that you provide in connection with an application.
• Application & Decision Data: The status and outcome of your credit application, including whether the program lender approved or declined it and the terms offered. Consumer reports used to make that decision are obtained and stored by LendStrm, through our application platform, on the program lender's behalf.
• Transaction Data: Information about your transactions with LendStrm, our affiliates, and participating third-party merchants.
• Automated Device & Usage Data: Information about your browser, network, device, IP address, referring web pages, search engines used to locate us, pages viewed on our Sites and Services, and session duration.

2. Cookies and Web Analysis Tools

We use cookies, web beacons, and similar tracking technologies to collect anonymous session information, monitor site traffic, and personalize your experience.

• Cookies: These are small text files downloaded to your device. We use them to keep track of your login status, remember your preferences, and improve our Sites and Services. You may adjust your browser settings to refuse cookies, though some features of the Sites and Services may not function properly as a result.
• Web Analysis: We use web analytics tools to measure depersonalized user behavior. We also collect telemetry from our email communications to track open rates and link clicks, allowing us to improve our reporting and service delivery.

3. How We Use Your Information

We use your personal information strictly for legitimate business purposes, including to:

• Provide, operate, and maintain the Sites and Services.
• Process transactions, deliver requested products/services, and handle customer support inquiries.
• Verify your identity, support the program lender's underwriting of applications, and prevent fraud or unauthorized activity.
• Communicate with you regarding updates and security alerts and, if you are a website visitor or have subscribed to our communications, send you promotional offers (subject to your opt-out rights). We do not use information collected in connection with a credit application for promotional offers.
• Create Analytical Data: By submitting personal information, you grant LendStrm a royalty-free, worldwide, perpetual, and irrevocable right to use depersonalized and aggregated data for statistical analysis, commercial development, and sharing with prospective partners.

4. How We Share Your Information

We do not sell your personal information for monetary payment. Certain sharing practices described below may qualify as a "sale" under the California Consumer Privacy Act; see State Privacy Rights for how to opt out. We may share your data under the following circumstances:

The LendStrm Program involves several parties, each with a defined role. LendStrm, LLC is a financial technology company that manages the Program and provides origination and servicing support; it is not a lender and does not make credit decisions. Loans are made and held by the program lender and are serviced by a third-party servicer on the lender's behalf. The categories below describe how your information moves among those parties.

• Program Lender: Loans offered through the LendStrm Program are made by a federally insured, federal or state chartered financial institution acting as the lender of record. When you submit a credit application, we share the information you provide with the program lender so that it can verify your identity and make the credit decision. On the program lender's behalf, we obtain consumer reports about you from consumer reporting agencies through our application platform, and we store those reports and share them with the program lender for use in its credit decision. LendStrm is not a lender and does not make credit decisions. The program lender's own privacy notice governs its use of your information. A list of financial institutions currently providing loans through the LendStrm Program is available at lendstrm.com/bank-partners.
• Loan Servicer: The program lender's servicer services loans on the lender's behalf. If your loan is approved and funded, your information is shared with the servicer to administer your account, process payments, and provide customer support for the life of the loan.
• Other Service Providers: We also share information with third parties who perform services on our behalf, including the technology provider that operates our application platform, identity verification services, communications providers, and customer support platforms. These providers are required to maintain physical, managerial, and technical safeguards to protect your information and to obtain comparable data security protections from any subcontractor or sub-processor they engage, and are permitted to use your information only to perform services for us. Service providers may also create depersonalized and aggregated analytics, which do not identify you individually. Information processed in connection with a credit application is nonpublic personal information of the program lender; its use, reuse, and redisclosure by the Program's service providers is limited to the purposes permitted by the program lender's privacy notice and by applicable law, including the Gramm-Leach-Bliley Act.
• Asset Transfers: In the event of a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, User information may be transferred. We will use reasonable efforts to notify you of such an event via email or prominent notice on the Website.
• Legal Disclosures: We may disclose your information if required by law, subpoena, or court order, or if we believe disclosure is necessary to enforce our Terms of Service, protect our rights, or ensure the safety of LendStrm and its Users.
• Feedback: If you submit bug reports, comments, or ideas ("Feedback"), you grant LendStrm a perpetual, royalty-free license to use and disclose this Feedback for any purpose without obligation to you.

Note: Your Social Security Number and driver's license number are strictly protected and only shared with verified entities necessary for identity verification and financial underwriting. Text messaging (SMS) opt-in data and consent will never be shared with third parties for their own marketing purposes.

5. Payments and Third-Party Services

LendStrm does not receive or hold loan payments. Loan payments are administered by the program lender's servicer acting on the lender's behalf. If you elect automatic payments, the bank account information you provide is collected through our application platform and transmitted securely to the payment processor for the program lender's account, so that your payments can be collected for the lender. We do not currently accept debit or credit cards for loan payments, and we do not collect or store payment card numbers.

Third-Party Links & Policies: Our Sites and Services may contain links to third-party websites or utilize third-party integrations. Once you leave our Website or are redirected to a third-party application, you are governed by their privacy policies. LendStrm is not responsible for the privacy practices or data security of third-party platforms. If your transaction is processed in a different jurisdiction, your data may be subject to the laws of that jurisdiction.

6. Security and Data Retention

While LendStrm implements generally accepted industry standards to protect your sensitive information, no method of digital transmission or storage is 100% secure.

In the event of a suspected data breach compromising your personal information, we will investigate the situation, notify affected users, and take necessary steps to comply with applicable data breach notification laws, including the Florida Information Protection Act (FIPA), which generally requires notification to affected individuals no later than 30 days after the determination of a breach. We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy or to comply with legal and regulatory obligations.

7. Electronic Communication and SMS Consent

• Electronic Signatures: You may withdraw your consent to use electronic signatures or receive electronic communications by contacting us. Doing so may prevent us from processing pending applications or providing certain services.
• Text Messaging (SMS): If you provide a mobile number in connection with a credit application, it may be used to send you a one-time passcode to verify your identity. These messages are transactional and are sent by us or our service providers only as part of completing or securing an application. We do not use SMS for marketing or promotional messages. Message and data rates may apply. You may text HELP for assistance or STOP at any time to opt out. We do not sell or share SMS data or consent with any third party, except the SMS service provider used to deliver these messages.

8. Governing Law

This Privacy Policy and any disputes arising out of it shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of law principles.

9. State Privacy Rights

What this section covers. Much of the information we handle in connection with a credit application — including your Social Security Number, income, and financial account information — is nonpublic personal information collected pursuant to the federal Gramm-Leach-Bliley Act (GLBA). That information is governed by GLBA and by the privacy notice the program lender provides to you when your account is opened, rather than by the state privacy rights described in this section. The rights below apply to personal information we collect that is not subject to GLBA, such as information you submit through our website forms and information collected through cookies and analytics tools.

Depending on your state of residence — including California, Virginia, Colorado, Connecticut, Texas, Oregon, and other states with comprehensive privacy laws — you may have the following rights:

1. Right to Know or Access: You may request the categories of personal information we have collected, the sources of that information, the business purposes for collecting it, the categories of third parties with whom we share it, and the specific pieces of data we hold about you.
2. Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
3. Right to Delete: You may request the deletion of your personal information, subject to legal, regulatory, and business exceptions.
4. Right to Portability: You may request a copy of your personal information in a portable, readily usable format where technically feasible.
5. Right to Opt Out: While LendStrm does not sell personal information for monetary payment, certain sharing practices may qualify as a "sale" or "sharing" under the CCPA. You may opt out by using the "Do Not Sell or Share My Personal Information" link on our Website or by contacting us. We do not use personal information for targeted advertising or for profiling that produces legal or similarly significant effects.
6. Right to Non-Discrimination: You will not be penalized, denied services, or charged different rates for exercising these rights.

Sensitive Personal Information. Some information we collect — such as your Social Security Number, driver's license or state identification number, and financial account information — is treated as "sensitive personal information" under California law. We use this information only to verify your identity, process and service an application you have requested, prevent fraud, and meet legal obligations. We do not use or disclose sensitive personal information to infer characteristics about you, and we do not use it for purposes that would give rise to a right to limit its use under applicable law.

Retention. We retain personal information only as long as necessary for the purposes described in this Privacy Policy, or as required to satisfy legal, regulatory, tax, audit, and recordkeeping obligations. Records relating to credit applications and loans are retained for the periods required by applicable federal and state lending, anti-money-laundering, and consumer protection laws. Website and marketing records are retained only as long as needed for the purpose for which they were collected.

Exercising Your Rights. To submit a request, contact us at privacy@lendstrm.com with your name, email address, phone number, postal address, and state of residence. We must verify your identity before processing a request, and we will respond within the timeframe required by your state's law.

Appeals. If we decline your request, you may appeal that decision by contacting privacy@lendstrm.com with the subject line "Privacy Request Appeal." We will respond in writing within the period required by applicable law. If your appeal is denied, you may contact your state Attorney General to submit a complaint.

Authorized Agents. You may designate an authorized agent to make a request on your behalf. The agent must provide verifiable proof of your authorization, and you may still be required to verify your identity directly with us.

10. Minors

Our Sites and Services are not intended for individuals under the age of 18. We do not knowingly collect, request, or disclose the personal information of minors under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will promptly delete it.

11. Contact Us

If you have any questions, concerns, or requests regarding our privacy practices or this Privacy Policy, please contact us at:

LendStrm, LLC
Email: privacy@lendstrm.com
Mailing Address: 5055 SW 91st Terrace, Gainesville, FL 32608