Last Updated: 11/18/2019
GreenSky, LLC (together with its affiliates and subsidiaries) (collectively, “GreenSky”) and the federally insured, federal or state chartered financial institutions participating in the GreenSky® Program and other persons holding title and/or economic rights to loans originated through the GreenSky® Program (the “Funding Participants” and, collectively with GreenSky, “We”, “Us”, or “Our”) are committed to protecting the personally identifiable information We collect about individuals (e.g., applicants, borrowers, and merchants) participating in the GreenSky® Program and have adopted policies, procedures, and processes designed to protect personally identifiable information from misuse, theft, or other loss.
2. Personally Identifiable Information, Definition
“Personally Identifiable Information” is any information collected through a Website or Mobile Application that is reasonably likely to identify a specific, unique individual. Personally Identifiable Information collected through a Website or Mobile Application may include, but not be limited to, an individual’s name, address, e-mail address, income, financial and banking information (including banking account information and payment card data), Social Security number, Driver’s License number, telephone number, or date of birth.
3. Important Information Regarding Use of the Websites and Mobile Applications
We own the information We collect on a Website or Mobile Application.
The Websites and Mobile Applications may contain links to other websites. We do not control and are not responsible for the content, security, and privacy practices of such websites.
The Websites and Mobile Applications are intended for visitors located in the United States. The Websites and Mobile Applications are governed solely by the federal and state laws in the United States. User from European Union are advised not to disclose any Personally Identifiable Information to Us through the Websites or Mobile Applications. Information submitted to the Websites and Mobile Applications may be housed on servers located in the United States.
4. Information Collected through a Website or a Mobile Application
We collect Personally Identifiable Information at various times when you use a Website or Mobile Application. This may include collecting information you enter into a Website or Mobile Application forms or fields regardless of whether you click “submit” or otherwise complete the form or field. Some of the places where We collect such information include, but are not limited to, the following:
- Emails, contact forms, questionnaires, and other forms into which you enter or submit to Us information;
- Your applications and transactions with the GreenSky® Program, including those involving the Funding Participants;
- Requests for pre-qualification for credit; and
- Requests regarding qualified merchants.
Additionally, each time you visit a Website or Mobile Application, the web server may automatically collect certain types of information. Some examples of information We may automatically collect include:
- Information about your Internet service provider, browser, operating system, and device including device identification number;
- Cookie information to recognize when you are visiting a Website and as further described below;
- Data related to your location at the time of accessing a Website or Mobile Application; and
- Beacons to know if a certain page was visited, your activity on particular pages, how long you spend on a particular page or portion of a page, or whether an email was opened.
When using a Mobile Application, We may collect geo-location data, with your consent. The Mobile Application also may ask you to use your device’s camera to take pictures of identification or other documentation in connection with your participation in the GreenSky® Program (e.g., for an application for a loan).
We may use third party providers of analytics tools or similar third-party services to analyze information about visits to a Website or Mobile Application.
6. Use of Information Collected through a Website or a Mobile Application
We may use your Personally Identifiable Information for the following purposes:
- To process transactions at your request;
- To assess your creditworthiness when you apply for credit or to pre-qualify you for credit;
- To manage and service loans or other accounts or applications you have with Us;
- To communicate with you about your GreenSky® Program loans or credit accounts and the use of a Website or Mobile Application;
- To advise you of promotions, sales, or other special opportunities;
- To market goods or services offered by:
- Funding Participants or their affiliates or subsidiaries;
- Merchants or sponsors participating in the GreenSky® Program or their affiliates or subsidiaries; or
- Other affiliated or unaffiliated third-parties;
- For fraud prevention and data security purposes;
- To improve the Websites, Mobile Applications or Out other products or services;
- As directed or authorized by you; or
- As permitted by law.
We may use non-Personally Identifiable Information, including, but not limited to, aggregate or anonymized information for any purpose consistent with law.
7. Disclosure of Personally Identifiable Information to Third-Parties
By accessing a Website or Mobile Application, you authorize Us to disclose your Personally Identifiable Information to affiliated and unaffiliated third-parties as follows:
- To companies in GreenSky’s corporate group;
- To third parties, including, but not limited to, Funding Participants, financial services providers (such as credit bureaus, securities broker-dealers, and insurance companies), companies with which We have joint marketing agreements, merchants and retailers, companies that help market Out products, and non-profit organizations, and any affiliates of any such third parties;
- To selected businesses, such as online and offline advertisers, so they can market products and services to you;
- As directed or authorized by you; or
- As permitted by law.
California Residents: Other than as required or permitted by law, We will not disclose Personally Identifiable Information about you to other financial service providers with which We have joint marketing agreements, unless you authorize Us to do so.
8. Personally Identifiable Information of Children
We do not knowingly solicit or collect Personally Identifiable Information about children under the age of 18. The Websites and Mobile Applications are not designed for or directed to children under the age of 18. If We become aware that a child under the age of 18 has provided Personally Identifiable Information to Us, We will delete the information from Our records. If you become aware of any Personally Identifiable Information We collected from children under 18, please contact Us at email@example.com.
9. Our Security Safeguards
We and Our third-party service providers use reasonable technical, administrative, and physical safeguards to secure your Personally Identifiable Information.
We take steps to protect the confidentiality of Personally Identifiable Information, including, but not limited to, Social Security numbers, and prohibit the unlawful disclosure of such information. We limit access to such Personally Identifiable Information.
Although We work to protect your Personally Identifiable Information, you should be aware that no technology is perfect and that there is always some risk involved in transferring data over the Internet, particularly if you send information to Us through an unsecured means, such as email.
10. Reviewing Information We have Collected on You and Opting Out of Information Sharing and Use
Information retained in Our databases: If you would like to review or correct any Personally Identifiable Information We have retained about you in Out databases, please send an e-mail request to firstname.lastname@example.org.
Opting out from Our solicitations: If you receive a marketing e-mail from Us relating to any offer or promotion and wish to be removed from future email solicitations, you will have the option to do so. If you opt out, the only future email communication you will receive from Us will be (a) transactional or relationship messages, such as activity alerts and payment reminder messages; (b) in response to questions from you; or (c) to resolve any customer service issues you may have reported.
Information relating to services provided by Our service providers and your Funding Participant: If you need help accessing your information related to a service provided by one of Our service providers or information held by your Funding Participant, We will assist you by referring you to the appropriate third party. Please contact Us for that information by submitting an e-mail request to email@example.com.
Limiting Information Sharing: You may limit when We may share information about you. You may exercise one or more of your opt-out choices described. Call Us toll free at 866-223-7098 or write to Us at GreenSky® Attn: Information Sharing Opt-Out, P.O. Box 29429, Atlanta, GA 30359. If you write to Us, please include your account number, contact phone number, and full name on the account. If you have a joint account, your opt-out applies to every person on the account. If you have multiple accounts with Us, you must opt-out separately for each account.
12. California and Delaware Do Not Track Policy
Some browsers have a “do not track” feature that may transmit “do not track” signals to websites and other online services with which the browser communicates. At this time, We do not currently participate in any “Do Not Track” (DNT) systems that would allow Us to respond to such browser “do not track” signals.
13. Your California Privacy Rights
If you are a California resident, you have the right to request and receive information regarding the disclosure of your Personally Identifiable Information by Us or any of Our affiliates to a third party for its direct marketing purposes. Any such requests for information can be made by sending an email to firstname.lastname@example.org or calling Us toll free at 855-809-1889.
14. Access and Correction
If you would like to request access to and/or correction of Personally Identifiable Information that you provided through a Website or Mobile Application, please contact Us at email@example.com.