Last Updated: November 2015
Peerform, Inc. also known as Peerform, has received TRUSTe's Privacy Seal signifying that this privacy statement and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe program covers only the information collected through this Web site, https://www.peerform.com and does not cover information that may be collected through our [mobile applications] [social networking applications]. If you have questions or concerns regarding this Statement, you should first contact email@example.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request.
This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any sensitive and/or personal information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal and sensitive information is protected both electronically and physically.
In general, and as described in detail below, we collect several types of information from you:
· Personal information required to verify your identity
· Personal and financial information necessary to assess your eligibility to borrow or lend money through Peerform
· Optional personal information (such as details about your loan) you may wish to share in the furtherance of your goals in using our site
· Information about your visits to and use of this web site to help us maintain the appropriate features, functionality and user experience
Peerform works with a number of trusted partners that perform vital functions as part of our operations, including credit bureaus, collection agencies, and electronic payment service providers. In addition, since all loans originated through Peerform are made to borrowers by Cross River Bank, if you request a loan, your information will be shared with Cross River Bank. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
You accept this policy when you sign up for or use our products, services or any other features, technologies or functionalities offered by us on our website or through any other means (via the phone directly) (collectively the “Peerform Services").
Information We Collect From You and About You
We collect personal and financial information from you while you use the site, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the site, whenever you choose to provide it.
Certain personal information must be supplied during the member, investor and borrower registration processes, as indicated below, in order to (a) enable registered users to login to the site, (b) determine borrowers' eligibility for loans through our proprietary credit scoring process, (c) verify borrowers' and investors' identities, (d) establish borrowers' and investors' ability to make and request loans by verifying that they are at least 18 years of age (or 19 to request a loan from Alabama and Nebraska), and (e) guard against potential fraud. This basic personal information includes:
· Your name (member registration)
· Your E-mail address (member registration)
· Your date of birth (borrower/investor registration)
· Your home address and telephone number (borrower/investor registration)
· Your Social Security number (borrower/investor registration)
· Your Bank Account Information-such as account and routing number (borrower/investor)
· Your Driver’s License Number (investor)
When you register as a borrower, we will use this information to pull a credit report from a credit bureau to determine your creditworthiness as well as to help investors assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during online person-to-person lending, such as:
· Generating borrower profiles on the site
· Assigning you a borrower credit grade based on your credit history and financial circumstances
· Enabling our financial services partners to implement automatic payments and fund transfers
· Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
· Implementing collection activities as needed
· Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
· Allowing you to add new bank account information and save to your online profile
When you register as an investor, we will request some required and optional data in order to facilitate such activities as:
· Generating an investor profile on the site
· Enabling our financial services partners to implement fund transfers and the receipt of borrower payments
· Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
· Maintaining regular communications with you as may be necessary to execute transactions you request, such as submitting loan portfolios and transferring funds, etc.
In addition, we gather names and E-mail addresses of people who contact us through our web site with questions about our company or lending/borrowing operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information.
Communications from Our Site
When you register on our site you will receive E-mails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of E-mail addresses and bank accounts, and confirmation of successful submissions of loan requests and portfolios. You will also receive progress updates on the status of loan requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any E-mails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and site operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback E-mails, you may opt out by writing to firstname.lastname@example.org or by following the unsubscribe instructions located at the bottom of each E-mail communication.
Peerform will send you E-mail notifications from time to time, and these are required elements of your transactions on our web site, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or investor, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new E-mail address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally you may not opt out of these service related E-mails.
When you register to our site, we will ask you for your employer’s name and phone number. Peerform stores this information for the sole purpose of verifying your employment.
Your employer may contact us at email@example.com to request that we remove this information from our database.
How Long Will My Information Be Stored?
Federal and state agencies require that Peerform provide aggregated demographic and loan funding information about our loan applicants. We maintain electronic loan application information for funded/declined/withdrawn loans for a period of at least 7 years in accordance with federal and state laws.
How and When Your Information is Shared With Other Parties
We do not sell, share, rent, or trade your personal information with third parties other than as disclosed herein.
Information is shared with other parties in the following ways:
· Required information (such as name, address and E-mail address) and optional information about borrowers and investors is displayed on profiles that members can update at any time; certain information is optional (such as additional phone number) and you can choose not to supply it and/or can remove the optional information at any time.
· Information (such as gross income, length of employment) but not personal information about borrowers is contained in loan listings that can be viewed by all users.
· Financial and credit information about borrowers is displayed to qualified investors on loan listing pages.
· Information is shared directly between users and other or potential users (who are only able to view loan postings but do not have access to the full loan listings). Information shared directly by users might contain personal information (such as name and E-mail address).
· Information may be shared with collection agencies or service providers but only if they are contractually obligated to keep such information confidential.
For privacy purposes, borrowers and investors remain anonymous on the site and are identified only by their screen names. Peerform will assign a unique screen name to each member. This automatic screen name is composed with the concatenation of the letters “PF” and a random and unique combination of numbers and letters. Borrowers will be able to see the screen names of their investors and vice versa. The loan listing pages include borrowers' credit grades and other financial information that is shown to qualified investors so that they can effectively evaluate loan requests. Loan listings also contain certain personal information (such as name and E-mail address) and, in some cases, answers to questions posed by investors that are incorporated into loan listings.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personal information when we believe that disclosure is reasonably necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site.
Peerform works with a number of trusted partners that perform vital functions as part of our operations, including without limitation credit bureaus, collection agencies, electronic payment service providers, and customer support call centers. Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We also may disclose information about you to companies that service, maintain, or process for us your transactions and accounts. For example, we provide information to companies that prepare and mail account statements and transaction confirmations.
These third parties are prohibited from using your personal information for promotional purposes but are authorized to use your personal information only as necessary to provide these services to us.
We may also disclose your personal information if Peerform is involved in a merger, acquisition, or sale of all or portion of its assets, you will be notified via E-mail and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
To What Other Types of Entities Might We Disclose Nonpublic Personal Information?
In addition, we disclose nonpublic personal information (such as name, address and social security number) to nonaffiliated third parties as permitted by or required by law, or to cooperate with regulators or law enforcement authorities; These parties include government/regulatory organizations, such as the Internal Revenue Service (IRS) and the Securities and Exchange Commission (SEC), as well as any of the securities exchanges, self-regulatory organizations and states we are registered with and to parties under court order or subpoena that request this information. We may also disclose nonpublic personal information to nonaffiliated third parties for which you have provided your consent or you have directed us to make.
How Your Credit History and Peerform Loan Data Are Shared
When you create a loan listing, you will be posting personal information on the site. This information includes details about your loan request (such as your name, E-mail address and amount you wish to borrow), as well as your screen name, geographic location, Peerform credit grade and a description of the loan request.
Qualified Peerform investors will also see certain credit data (such as a range of your credit score) collected from or calculated based on your credit bureau file. It is necessary to allow prospective investors to see this information as they evaluate your loan request. The information displayed to investors includes a credit profile section and a credit history section.
The credit profile section includes your:
· FICO score range
· Debt-to-income ratio (DTI)
· Gross income
· Home ownership status
· Current employer and tenure in your current position
· Existing debt payments (monthly snapshot of your current outstanding debt)
· Monthly payment amount for the loan being requested.
The credit history section includes the following information:
· The date your earliest reported credit line was opened (e.g., revolving credit)
· The total number of credit lines currently in your credit file
· The number of open credit lines currently in your credit file
· Your total balance for all open revolving credit lines
· Revolving line utilization rate, or the amount of credit you are using relative to all of your available credit
· The number of accounts on which you are now delinquent, and the past-due amount you owe
· The number of months since your last delinquency
· The number of 30+ days past-due incidences of delinquency in your credit file for the past 2 years
· The number of negative public records (e.g., bankruptcies and judgments, etc.) placed in your file and the number of months since the last record
· The number of inquiries by creditors during the past 6 months
If you successfully receive a loan through Peerform, we will also display status information about your loan to your investors. You should not include your name or personal information in your loan request. Your payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to your investors. Loan status information is also aggregated and displayed on the statistics page.
Where You Can Find and/or Correct Your Information
You can access all of your personal information that we collect online and maintain by visiting your profile at www.peerform.com. This section of the site is password-protected to better safeguard your information. As a registered user, you can correct, update, amend your password, E-mail address, physical address, phone number and bank account information at any time on the website, you may also ask to have your personal information deleted/removed from a public forum on our site or deactivate it and if you need to change any other information in your profile you can contact us at firstname.lastname@example.org. To protect your privacy and security, please contact us at email@example.com to make changes to your sensitive account information. We will respond to your access request within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Web-Related Information Collection
Technologies such as: cookies, beacons, tags and scripts are used by Peerform and our marketing, affiliates, or analytics partners. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and particularly to prevent you from identity theft.
We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information.
Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash cookies, please click here.
Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to www.peerform.com.
Compliance with State and Federal Law
Links to Other Sites
Peerform Security Policy
Industry-leading Standards and Controls
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at email@example.com.
Peerform takes strong steps to safeguard your personal information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.
Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our web site you are actually on our site. SSL also ensures that all sensitive (such as bank account information) and personal data entered into the web site is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For further encryption protection, we use a 128-bit secure browser for logins and transactions. Our site also makes use of "CAPTCHA" technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering in the text shown in the image. Finally, we subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.
We also employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.
Protection of Account Numbers
When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Further, we employ strict access standards ensuring that only the senior-most employees or partner representatives have access to your account numbers and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account.
At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an E-mail purporting to come from Peerform that asks for your password, you should immediately report this development.
ID Theft Policy
Peerform utilizes state of the art authentication technology to verify identities. However, if an investor suspects that one of their loans belongs to a person who has committed ID theft, please contact us at firstname.lastname@example.org. Peerform will work with law enforcement authorities to track down and prosecute anyone who has committed identity theft. Peerform will reimburse the investor for the unpaid principal balance of loans where the borrower has committed identity theft.
What You Can Do
In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member's name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.
To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your E-mail account. Therefore, you might consider restricting access to the E-mail account you registered with on this site and/or changing your password on that E-mail account frequently.
If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our site, you should log out completely, then close the browser window and clear the browser's cache files.
You should also be aware of fraudulent attempts to gain access to your account information known as "phishing." Phishing is a tactic used by scammers in which unsuspecting people are brought to a web site by a genuine-looking E-mail purporting to be from a legitimate company. The phony or "spoof" E-mail takes the person to a web site that looks legitimate but in fact is not. Either in the E-mail itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money. Peerform will never ask you for your login information in the context of any E-mail. In general, you can protect yourself against phishing by never providing personal or login information via an E-mail—instead, go the web site directly. You might also make it a habit to check the URL of a web site to be sure that it begins with the correct domain. In the case of Peerform, you should always ensure the URL begins with http://www.peerform.com, https://www.peerform.com.
If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name and E-mail address. We will automatically send your friend a one-time E-mail inviting him or her to visit the site. Peerform stores this information for the sole purpose of sending this one-time E-mail and tracking the success of our referral program.
Your friend may contact us at email@example.com to request that we remove this information from our database.
Social Media Widgets
We May Make Changes to This Policy
You may contact us at:
Attention: Compliance Department
711 3rd Avenue, 6th Floor
New York, NY 10017
For purposes of federal privacy regulations, we identify our consumers as any individual that visits the Peerform website. We identify our customers as any individual that has applied for a loan (which includes completing a loan application and Borrower Membership Agreement) and any individual that has applied to become an investor (which includes a Questionnaire and a Subscription Agreement). We may change the designation of any customer to that of a consumer at any time, at our sole discretion, based on factors that may include suspected fraud.