Effective Date: February 22, 2019
As described in greater detail in this policy, we collect several types of information from you, your business and/or third-parties you refer to us:
If you submit an investor application, we collect:
If you submit a loan application on behalf of a business, we collect:
Regardless of where our servers are located, your data will be stored by us in the United States, where data protection and privacy regulations may not be to the same level of protection as in other parts of the world. BY VISITING THIS WEBSITE OR USING THE SERVICES, YOU UNEQUIVOCALLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH YOUR USE OF THE WEBSITE OR SERVICES, AND YOU ALSO AGREE THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.
INFORMATION RELATED TO DATA COLLECTED THROUGH QUARTERSPOT SERVICES
QuarterSpot may collect and process personal information of both investors and individual owners of business borrowers, under the direction of a Third-Party Agent working on behalf of the investor or borrower. QuarterSpot acknowledges that you have the right to access your personal information. If QuarterSpot is acting on behalf of a Third-Party Agent, we have no ownership of the information and may not have a direct relationship with those individuals whose personal information may be processed as part of providing our Services. If you are a customer of a Third-Party Agents and would no longer like to be contacted by one of our Third-Party Agents that use our service, please contact the Third-Party Agents that you interact with directly. We may transfer personal information to companies that help us provide our service ("Partners"). For example, we may notify Partners if we are unable to collect the balance due on your business' loan with us. Transfers to Partners are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Partners.
An individual who seeks access to their data, seeks to correct, amend or delete inaccurate data or wishes to opt-out of communications from QuarterSpot should direct his/her query to the Third-Party Agent he/she interacts with directly. If a QuarterSpot Third-Party Agent requests that we remove or access personally identifiable information on your behalf, we will respond to their request within 30 days.
QuarterSpot will retain personally identifiable information we process for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
INFORMATION WE COLLECT FROM YOU AND ABOUT YOU
The first step in using our Website and Services as an investor or a borrower is application submission. New users must first submit an application to QuarterSpot. Certain personal information must be supplied within the application, as indicated below. This information is needed to (1) allow applicants to be contacted about our Services, and (2) guard against potential misuse of the Website and Service.
This basic personal information we collect includes:
To become an investor on our platform, we will request some required and optional data such as your bank account in order to:
To become a borrower on our platform, we will request some required and optional data in order to:
INFORMATION WE COLLECT ABOUT OTHER PARTIES
We collect the names and email addresses of people who contact us through the Website and Service.
If you use our Website or Services to share our content with others, we may collect the contact information of the party with whom you wish to share such information. We may send that contact a message inviting them to visit our Website or use our Services. You or your contact may email us at firstname.lastname@example.org to opt-out of this use.
Users of the Website and Services may refer contacts via e-mail to the Website and Services. If this referral occurs through our Website or Service or those of our associates, we may track and store information about such referral sources and referrals. We may use this information to send the communication, for internal operations, to effectuate bonuses or incentives, if any, and to assess our efforts.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. We may post your testimonial along with your name with your consent. If you wish to update or delete your testimonial, you can contact us at email@example.com.
COMMUNICATIONS FROM QUARTERSPOT
By participating in the Website or Services, you may be contacted by QuarterSpot from time to time. Such communications may include emails regarding confirmation of actions, progress updates, loan eligibility and other administrative communications from us. You cannot opt out of these communications.
We may contact you with surveys, requests for feedback or offers from us or our Partners. Out of respect for your privacy, you may choose to stop receiving the communications by following the unsubscribe instructions included in these emails, or you may opt out from such communications by emailing us at firstname.lastname@example.org.
HOW AND WHEN YOUR INFORMATION IS SHARED
Information about investors is shared with other parties in the following ways:
Information about applicants and borrowers is shared with investors and Partners in the following ways:
Business Name and EIN;
Names of individual business owners;
Business owners' dates of birth;
Business owners' Social Security numbers;
Phone and fax numbers; and
Applicant's Credit History and Background
Average bank account balance
Number of bank account deposits
Annual revenue estimated from bank account deposited dollars
Occurrences of non-sufficient funds
Years in business;
Third party loans;
Secretary of State standing;
Outstanding QuarterSpot loan balance.
Owner of Applicant's Credit History and Background
Consumer credit score of any individual business owner who may be a guarantor;
Length of credit history;
Association with existing QuarterSpot borrowers.
In certain situations, QuarterSpot may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose collected information to the extent we believe it necessary to comply with the law, to limit fraud or to defend a legal claim, such as in response to a subpoena or court order or similar legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others. Additionally, we may transfer your information to a successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, merger or bankruptcy. In these cases, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
QuarterSpot works with trusted providers who perform vital operational functions for QuarterSpot, including web hosting services, analytics providers, collection agencies, banks, credit bureaus, accountants, consultants, commercial loan brokers, independent sales organizations, attorneys and payment service providers. Collected information may be shared with these third parties to the extent required for them to facilitate the offering of the Website and Services by QuarterSpot.
PSEUDONYMIZATION OF PARTIES
Investors and borrowers will be identified on the Website and Service, which may be viewable to investors who are users of the Website and Services. In addition, borrowers may have public profiles on the Website and Services that display loan listings along with non-personally identifiable information about them, including credit ratings and other financial information to permit the evaluation of the borrower's loan requests. This data may also be included in pseudonymized form on statistical pages.
WHERE YOU CAN FIND AND/OR CORRECT YOUR INFORMATION
Upon request QuarterSpot will provide you with information about whether we hold any of your personal information. If your personal or business information changes, please contact us at email@example.com. If you no longer desire our Services, please contact us directly using the email listed above. We will respond to your request within 30 days. We will retain your information for as long as your account is active or as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
WEB-RELATED INFORMATION COLLECTION
We also may collect information automatically about your visits to our Website and use of our Services, such as your IP address, Internet Service Provider (ISP), information about your computer and peripherals, referring website, geographical location, length of visit, browser type and page views (e.g. HTML pages, graphics, etc.), date/timestamp and/or clickstream data and store it in log files. We use this analytical information, in the operations, marketing and enhancement of our Website and Services.
COMPLIANCE WITH LAWS
This policy may not discuss all of your privacy rights, as such rights vary depending on state law. Consult with your local agencies for more information.
Federal and State regulations may require us to maintain and report information regarding our users, investors or borrowers. We may be required to maintain your information for seven years or more in order to comply with applicable laws.
Some of our pages utilize framing techniques to serve content 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 QuarterSpot.
Security is important at QuarterSpot. We therefore take steps to secure the information you provide through the Website or Service. Information we collect is protected internally by passwords and defined access points. Our systems are housed in secure facilities. Both physical and electronic access to our system is controlled by high-ranking managers. We store sensitive financial data such as Social Security numbers and bank accounts in a SAS 70 environment.
We utilize strong encryption technology, including Transport Layer Security (TLS), when you connect to our Website and Service and to encrypt data transfers. This technology uses encryption to secure logins and transactions and is designed to protect your data at all times. Our Website and Service may make use of "CAPTCHA" technology. We may also use session time-outs for inactivity to protect your account.
When we communicate with you, we will verify your identity using a number of methods which may include the last four digits of your account numbers or social security number. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
We may employ password standards to assist investors in selecting a secure password. This may require the use of both numbers and letters. We may also provide steps by which investors can regain access to investor accounts should you forget your password, including the use of a security question. We will never ask for your password as a means of identifying yourself. You should not share your password with anyone, and if you ever receive an email purporting to come from us that asks for your password, you should immediately contact us at email@example.com.
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*Subject to the completion of all applicable application requirements prior to 3:30 p.m. ET, Monday through Friday, excluding designated Federal Reserve holidays.
Loans made in California are issued by QuarterSpot, Inc. pursuant to California Lenders License No. 603K646