What Information we collect
The types of personal information we collect depends on the products and services you use. It may include:
- Your contact information such as your name, address, phone, and email
- Information that we use to verify your identity, make decisions about your loan application, or manage risk such as your date of birth, social security number, your credit history, your credit scores, and your payment history
- Information about your education, such as your degree, SAT scores, your college, your major(s), and your grades including your college transcript, and your personal interests
- Information so we can process your payments such as your bank account numbers
- Information about your income and/or assets, including your employment, employment offers, tax returns, W-2, brokerage statements, and pay stubs
- Information about you when you visit the Site, including information submitted by you or our other customers when interacting with the Site’s features and using its online communication features
In addition, when you visit the Site or use the products and services available on the Site we automatically collect certain information from your computer, mobile phone or other access device. Log file information is automatically reported by your browser or mobile device each time you access the Site. When you use the Site, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, 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, and other such information. When you use the Site, we may also employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Site.
Information we receive from third parties
We may receive information about you from third parties. For example, if you access the Site through a third-party connection or log-in, such as LinkedIn or a referral partner, or otherwise link an account to the Site, that third party may pass certain information about you and your use of its service to us. This information could include the user ID associated with your account (for example, your LinkedIn UID), an access token necessary to access that service, 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 linking them to the Site. You may also unlink your third party account from the Site by adjusting your settings on the third party service. If you unlink your third party account, we will remove the information collected about you in connection with that service.
How we collect information
We collect information about you:
- From you when you register on the Site, use the Site, apply for a loan or to be a investor, and from your transactions, including your security purchases, repayments, account funding and withdrawals, and your communications with us;
- From third parties such as credit bureaus, identity verification services and other public records or websites; and
- From third parties who are participating in the Referral Program (see below)
Why we collect information
We collect this information from you in order to:
- provide you and other customers with access to the products and services offered through the Site,
- provide notices and other information to you about, or in connection with, these products and services,
- provide customer support,
- protect against fraud, fulfill legal requirements and enforce our agreements, and
- improve our services and your experience
What information we share on the Site, with other Upstart users and investors
If you submit a loan listing, it will automatically be allocated to one of two investment channels based on a random allocation methodology determined by us:
- The first allows investors on the Upstart site to purchase loans through Upstart Network Trust. We share some of your information with investors. This is limited to your loan terms, repayment history and loan status, information about your most recent degree, current income, what you intended to use your loan proceeds for, and your credit score within a 10 point range.
- The second allows investors to purchase 100% of 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 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 these investors, who become the creditor, or any subsequent purchaser of your loan.
If you have an income share agreement, we will share your name and information about your repayment history with investors in your income share agreement.
Our users can refer friends to the Site by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular loan listing, and the sender will not know whether you are a borrower, investor or simply a registered user. This information is stored for the sole purpose of sending emails to such referred customers and tracking the success of our referral program. In the case where a bonus is offered to a user in return for the referral we will only retain the information about the referred parties to properly credit the account of the user initiating the referral. The information is not used for any other purpose.
What information we share with third parties
All financial companies need to share customers’ personal information to run their everyday business. We may share your personal information with:
- Trustees overseeing Upstart Network Trust, including Bankers Trust Company, not in its individual capacity but solely as indenture trustee and Wilmington Savings Fund Society, FSB d/b/a Christiana Trust not in its individual capacity but solely as owner trustee.
- if you apply for a loan, the creditor, currently Cross River Bank, who originates all the loans on the Site and any investor who purchase 100% of your loan (but not an investor in Upstart Network Trust).
- Service providers who help with parts of our business operations such as fraud prevention, bill collection, marketing and technology services, and financial institutions that we partner with to offer a product and/or support our servicing activities. Our contracts dictate that these third parties only use your information in connection with the services they perform for us and not for their own benefit.
- Credit bureaus to report account information, as permitted by law.
- 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 Upstart Network Trust 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.
- Other third parties but only if you consent or direct us to do so.
Upstart will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described above.
Information that has been made anonymous 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, there is no need for you to opt-out from the information we share.
We 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. We authorize our employees to get your information only when they need it to do their work, and we require companies that work for us to protect your information.
When you access the Site or content or use the products or services available through the Site, we (or companies we work with) may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to recognize you as a customer; customize our services, content and advertising; collect information about your computer or other access device to mitigate risk and help prevent fraud. 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. We do not transmit any personal or sensitive information to advertising partners. However, certain partners may collect incoming IP addresses in connection with your visits to our Site, for example, to avoid double counting the number of new members who joined as a result of an advertising campaign.
In the event that any of your information that we control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify you and take other steps in accordance with any applicable laws and regulations.
Upon termination or deactivation of your Upstart account on the Site, we may retain your profile information and user content and information for backup, archival, or audit purposes.
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 logging into our website.
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 as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
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 email@example.com, by calling us at (650) 204-1000 during our operating hours 9:00 AM PST to 5:00 PM PST, Monday through Friday, or by writing to us via regular mail at Upstart Network, Inc., P.O. Box 61203, Palo Alto, CA 94306.