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TECHO FUNDING, LLC  

PRIVACY POLICY 

Policy last updated: June 1, 2024 

 

This Privacy Policy (the “Policy”) describes how Techo Funding, LLC and its affiliated companies (“Techo”, “we”, “our”, “us,” or the “Company”) uses Personal Information that we collect, receive, maintain, use, treat, and store about you (“you”, “your” or “consumers”) in connection with the use of our services and the websites, applications, and electronic communications where it appears, as well as all software, services, extensions, subdomains, and application programming interfaces related thereto (the “Platform”).  This Policy has been adopted, in part, to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended and by interacting with us through the Platform or by other means that identify this Policy, you consent to the terms and conditions of the Policy as described herein. 

 

1. INTRODUCTION 

We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Information that is shared with us as part of using our Platform. When used in this Policy, the term “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, and includes Sensitive Personal Information ( “Sensitive Personal Information”) “Sensitive personal information” means Personal Information that reveals (A) a consumer’s social security, driver’s license, state identification card, or passport number; (B) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer’s precise geolocation;  (D) a consumer’s racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mail, email, and text messages unless the Company is the intended recipient of the communication;  and (F) a consumer’s genetic data.  Sensitive Personal Information also includes the processing of biometric information for the purpose of uniquely identifying a consumer, Personal Information collected and analyzed concerning a consumer’s health, and Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation. Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information. 

We may collect Personal Information from you directly through a web-form, or indirectly through document(s) you upload to our Platform containing Personal Information, as discussed more fully in Section 3, below. When we combine Personal Information with other information (i.e., information that does not, on its own, identify you), we treat the combined information as Personal Information. 

You may choose whether or not to provide or disclose Personal Information in connection with your use of our Platform. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Platform but may be unable to access or use certain features, options, programs, products, and services. 

Our Platform may include third party content and links to third party websites and services that collect Personal Information. We do not control these third parties and this Policy does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use information you provide to them. Please read the third parties’ privacy policies carefully. 

 

2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT 

We and our service providers collect a range of Personal Information.  

We may collect contact information when you submit a loan application, when you register for services through the Platform, submit a job application, apply for employee benefits, or contact us through email or our website chat feature. For instance, we may collect information including your name, email address, phone number, and address. 

We may collect financial information if you apply for a loan, apply for membership in an investment fund, or become an employee, contractor, or vendor of Techo. Payment information includes your bank account information, credit reports, income, and information reported on state and federal income tax returns.  

We may also collect other background Personal Information such as your date of birth, Social Security number, driver’s license number, resume information, and a list of your assets and their value. 

We may also collect usage and device information when you visit our Platform. This may include information about the browser, operating system, and/or device identifier for the device you are using, your ISP and IP information, as well as the websites that you came from and the site you visit when you leave. 

 

3. METHOD OF INFORMATION COLLECTION 

We collect information in a variety of ways. We collect information directly from you; for instance, when you register an account, submit a loan application, submit a job application, apply for employee benefits, or communicate with us through our website chat function or via our SMS and phone line. Similarly, we collect information directly from you when you submit a job application or when you upload documents into our Platform.  

We also collect information from you passively. Our Platform uses tracking tools like cookies, pixels, and web beacons. We do this both on our Platform and in emails that we send to you. Through these tools we collect information about users over time when you use our Platform. This collection includes usage and browser information. We may also have third parties collect Personal Information this way. For more information about the trackers that we use, please see Section 5 of this Policy. 

We may also collect your Personal Information from third parties. For instance, we may obtain your credit report from credit reporting agencies. These providers may collect Personal Information about you in performing their services and/or functions on our Platform. For more information on who we employ as a service provider or vendor, their business purpose, and their privacy practices, please click here to submit a request. Additionally, we have worked with certain third-party social media providers to offer you their social networking services through our Platform. For example, you can use third-party social networking services to share information about your experience on our Platform with your friends and followers on those social networking services. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. You also may be able to link an account from a social networking service (e.g., Facebook) to an account through our Platform. This may allow you to use your credentials from the other site or service to sign into certain features on our Platforms. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Policy.  

 

4. COMBINING INFORMATION 

We may combine Personal Information we obtain. For example, we may combine information that we have collected online with information that we have collected offline, for instance during calls between you and our support team. We may also combine information that we have collected across other third-party sites or from other third parties with information we already have. Finally, we combine information across devices. 

 

5. INFORMATION COLLECTED AUTOMATICALLY  

We collect information about users over time on the Platform by using several common types of cookies and other tracking technologies including web beacons, pixels, and flash cookies. We also have third parties that collect information in this way on our behalf and for their own purposes. Cookies are small files that download when you access certain websites. We also utilize analytic services to assist with analyzing our website traffic.  

You can control cookies and tracking tools. Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings. Our Platform does not currently respond to these signals. If you choose to block cookies and other trackers, certain features of the Platform may not work. Blocking or rejecting cookies will not stop all of the tracking described in this Policy. These features and options are browser and device specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To find out more on how to manage and delete cookies, visit aboutcookies.org. On a mobile device, you may also be to adjust your settings to limit ad tracking. 

 

6. YOUR CHOICES 

You have certain choices about how we use your Personal Information. You can opt-out of certain marketing, and you can also limit the use of your Sensitive Personal Information to those uses specified in California Civil Code Sec. 1798.121. However, we may be allowed to use your Sensitive Personal Information for reasons not listed but allowed by law. To opt-out of marketing communication emails email us at compliance@techorec.com or by clicking “unsubscribe” at the bottom of our promotional communications. To limit the use of your Sensitive and Personal Information, submit your request to us via email at compliance@techorec.com. You will continue receiving transactional and relationship related communications, as permitted by law.  

 

7. THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION 

We use your Personal Information in a number of ways. If you are a loan applicant, borrower, or investor, we may use your Personal Information in order to process your loan application and to perform services you have requested. If you are a job applicant or employee, we may use your Personal Information to evaluate your job application or process your employee-benefits request. 

We also use your Personal Information to respond to your requests or questions, including questions about our Platform, our products and services, and your relationship with us. This includes communicating with you to review any loan or investment applications and to process and service them, as well as respond to your feedback.  

We may also use your information to improve our Platform and services, including customizing your experience with us. We may also use your information for marketing purposes. For example, we may send you information about new features on the Platform, new services we offer, and special offers. When legally permitted, this may also include using your information to serve you ads and to tell you about products or offers available through third parties we think you might find interesting.  

Additionally, we may user information for security purposes to protect our company, Platform, and customers. Finally, we may use your information for other purposes, as required and permitted by law, including fulfilling legal and regulatory requirements. 

 

8. HOW WE DISCLOSE PERSONAL INFORMATION 

We may share your Personal Information in the following ways and to the following third parties: 

  • Our Service Providers. We may share your Personal Information with third parties who perform services on our behalf. For example, we may share information with vendors that operate our Platform or send out our email communications. We also use third parties for technical and customer support, application development, tracking and reporting functions, quality assurance, administering employee benefits, and other services. 
  • Business Partners. We may also share Personal Information with our trusted third-party partners. For example, we may share information with partners when we co-sponsor a promotion. These partners may use your information to, among other things, send you information or contact you about services and products. We may also share your information with our business partners in order to obtain better loan rates and terms for your loan.  
  • Advertisers. From time-to-time, we engage advertising services to assist us in advertising our brand and Platform. Those services may target advertisements on third-party websites based on cookies or other information indicating previous interaction with our Platform. 
  • Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Platform, including Personal Information, may be among the items sold or transferred.  
  • Fraud and Other Investigations. We may share your information in the course of an investigation or to prevent a violation by you related to fraud, illegal or harmful activity, or contractual violation.  
  • Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person.  

We may also share information as described to you in other disclosures relating to additional services we provide. 

 

9. RETENTION OF PERSONAL INFORMATION 

We reserve the right to retain any Personal Information as long as the Personal Information is reasonably necessary to: (i) fulfill the purposes that are described in Section 7, and (ii) comply with applicable law.  

 

10. DATA SECURITY 

The privacy and security of Personal Information is very important to us. Taking into account the nature, scope, context and purposes of processing Personal Information as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, Techo has implemented appropriate technical and organizational measures to ensure and to be able to demonstrate that its processing of Personal Information is performed in accordance with applicable law. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security. 

  

11. CHILDREN’S PRIVACY 

The Platform is not intended for children. Our Platform is meant for adults, and we do not knowingly collect personally identifiable information from children under thirteen without permission from a parent or guardian, or from children between the ages of 13-16 without their consent. If you are a parent or legal guardian and think your child has given us information, or for children between the ages of 13-16 to opt-in , you can email us at compliance@techorec.com. You can also write to us at the address listed in the “Contact Us” section of this Policy. Please mark your inquiries “CCPA Inquiry.”  

 

12. CALIFORNIA RESIDENTS:  ADDITIONAL RIGHTS MAY BE AVAILABLE 

Pursuant to the CCPA, California residents have certain rights concerning their Personal Information, including Sensitive Personal Information. You can exercise those rights by contacting us at compliance@techorec.com or call us toll-free at [                 ]. Please find additional information below.  

(a) Rights afforded under CCPA.  

    • Access. You may learn the categories of information we collect and use, as well as the categories of collection sources and disclosure and the business purpose for the collection. You also may learn the categories of third parties to whom the business discloses personal information. 
    • Portability: You may be entitled to a copy of the specific pieces of information collected.  
    • Deletion: You may request we delete information collected from you.  
    • Correction: You may request we correct any information about you that is incorrect.  
    • Non-retaliation: You may not be discriminated against for exercising a privacy right.  

(b) How to Exercise Your Rights. 

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to compliance@techorec.com or call us toll-free at [              ]. We may use information provided in the request to confirm your identity through matching the information you provide to information we have about you. In some situations, we may not be able to process your request, such as when a legal exception applies. Techo will notify you of our decision and you have a right to request a reconsideration.  

 

13. CHANGES TO THIS PRIVACY POLICY 

As our organization changes over time, this Policy is expected to change as well. We reserve the right to amend the Policy at any time, for any reason, without notice to you, other than the posting of the amended Policy on our Platform. We may e-mail periodic reminders of our notices and terms and conditions, but you should check our Platform frequently to see the current Policy that is in effect and any changes that may have been made to it. 

  

14. CONTACTING US 

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to compliance@techorec.com