The GreenSky® Program Privacy Policy

Last Updated:  December 31, 2019

  1. Introduction and Scope of Privacy Policy

    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.

    This GreenSky® Program Privacy Policy (this “Privacy Policy”) applies to information collected online through the GreenSky® Program websites, including, but not limited to, www.greensky.com, www.greenskycredit.com, and www.greenskyonline.com (collectively, “Websites”), online through the GreenSky® Program mobile applications that link to this Privacy Policy (collectively, “Mobile Applications”), and offline via mail, telephone, and in person. This Privacy Policy does not apply to information, including personally identifiable information, collected from third-party sources (such as consumer reporting agencies) or that you reveal or post in any public forum on (a) Websites or Mobile Applications, (b) websites that link to or from Our Websites or Mobile Applications, or (c) any other website or mobile application. If you are approved for a loan through the GreenSky® Program, your information may also be subject to a privacy policy specific to your lender under the GreenSky® Program.

  2. Definition of Personally Identifiable Information

    “Personally Identifiable Information” is any information that is reasonably likely to identify a specific, unique individual. Personally Identifiable Information 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 Our 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. Users from the 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.

    By using a Website or Mobile Application, you agree to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, do not use the Websites or Mobile Applications. Furthermore, by using a Website or Mobile Application, you agree to the application of United States law and consent to the use and disclosure of your information consistent with this Privacy Policy.

  4. Information Collection

    We collect Personally Identifiable Information at various times when you use a Website or Mobile Application, or communicate with Us offline. This may include information you enter into Website or Mobile Application forms or fields regardless of whether you click “submit” or otherwise complete the form or field. We collect Personally Identifiable Information from 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 non-Personally Identifiable 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 geolocation 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).

  5. Cookies

    An HTTP cookie (also called web cookie, Internet cookie, browser cookie or simply cookie) is a small piece of data sent from a website and stored on your computer by the web browser you use while browsing the Internet). We use cookies to collect certain types of non-Personally Identifiable Information to recognize you when you are visiting a Website. You can control the placement of cookies on your device through the use of your web browser’s cookie settings. Rejecting cookies may affect your ability to use some of the features offered by a Website.

    In addition, We use cookies in connection with Google Ads so that Google can show ads for Our products to you before you visit or after you leave a Website. Google’s Adwords technology may recognize a cookie that a Website has sent to your browser during a past visit by you to a Website and use the cookie information to show you ads for Our products or similar products. You can opt out of this use of cookies by visiting Google’s Ads Settings.

    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. Information Use

    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:
      • GreenSky;
      • 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 Our other products or services;
    • To comply with the law, regulatory requirements, legal subpoena or other litigation process, or to enforce any other agreements between you and Us, including, but not limited to, the GreenSky® Program Terms of Use and your loan agreement with your lender under the GreenSky® Program;
    • 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 the 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 marking agreements, merchants and retailers, companies that help market Our 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 necessary to comply with the law, regulatory requirements legal subpoena or other litigation process, or to enforce any other agreements between you and Us, including, but not limited to, the GreenSky® Program Terms of Use and your loan agreement with your lender under the GreenSky® Program;
    • 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 service@greensky.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 about you and opting out of information sharing and use

    Information retained in Our active databases. If you would like to review or correct any Personally Identifiable Information We have retained about you in Our active databases, please send an e-mail request to service@greensky.com.

    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 service@greensky.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.

  11. Changes and Revisions to this Privacy Policy

    By accessing a Website or Mobile Application, you acknowledge that We have the right to revise and amend this Privacy Policy. We will post any changes to this Privacy Policy here so that you will always be aware of Our privacy practices. Please refer back to this Privacy Policy regularly. Your continued use of a Website or Mobile Application following Our posting of any such changes will mean that you accept such changes.

  12. 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. 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 service@greensky.com

California Residents: Your Rights

California residents have specific rights regarding their personal information (“personal information” or “PI”) under the California Consumer Privacy Act (CCPA). This section describes your CCPA rights and explains how to exercise them. This policy only pertains to personal information that is subject to the CCPA. Much of the personal information GreenSky processes— including loan information—is subject to the Gramm-Leach Bliley Act and is not subject to the CCPA. Our handling of information not subject to the CCPA may not be fully described below.

Categories of Personal Information Collected, Disclosed, or Sold in the Last Twelve (12) Months

You have the right to know the categories of personal information GreenSky has collected, disclosed, or sold about its consumers within the last twelve (12) months. The chart below offers a comprehensive overview of the types of personal information We collect, with whom it is shared, and for what purpose.

Category Examples Collected [YES/NO] Source of Collection Purpose for Collection Third Parties to Whom Disclosed
Personal identifiers A real name, alias, postal address, online identifier, application ID, Internet Protocol address, email address, Social Security number, driver’s license number, and passport number. YES Directly from consumer or consumer’s representative. Directly from merchant. From credit reports received from credit bureaus. To make decisions about and provide services related to loans.
To respond to consumer requests for leads for home improvement contractors.
To underwrite merchants and facilitate their involvement in the GreenSky merchant program.
To run credit reports and criminal background checks to validate merchants.
To advise consumers of promotions and sales.
To merchants with whom We have connected customers seeking home improvement contractors. To Our bank partners. To lending and leasing platform providers. To law enforcement to comply with a court order or governmental regulations. To third parties for fraud prevention and data security purposes.
Personal information categories listed in the California Customer Records statute A name, postal address, date of birth, signature, Social Security number, telephone number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, and GreenSky account number. YES Directly from consumer or consumer’s representative. Directly from merchant. From credit reports received from credit bureaus. To make decisions about and provide services related to loans. To respond to consumer requests for leads for home improvement contractors. To underwrite merchants and facilitate their involvement in the GreenSky merchant program. To run credit reports and criminal background checks to validate merchants. To advise consumers of promotions and sales. To merchants with whom We have connected customers seeking home improvement contractors. To Our bank partners. To lending and leasing platform providers. To law enforcement to comply with a court order or governmental regulations. To third parties for fraud prevention and data security purposes.
Protected classification characteristics under California or federal law Age (40 years or older), national origin, citizenship, marital status, medical condition, physical or mental disability, sex veteran or military status. YES Directly from consumer or consumer’s representative. Directly from merchant. From credit reports received from credit bureaus. To make decisions about and provide services related to loans. To respond to consumer requests for leads for home improvement contractors. To underwrite merchants and facilitate their involvement in the GreenSky merchant program. To run credit reports and criminal background checks to validate merchants. To merchants with whom We have connected customers seeking home improvement contractors. To Our bank partners. To lending and leasing platform providers. To law enforcement to comply with a court order or governmental regulations. To third parties for fraud prevention and data security purposes.
Commercial information property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES Directly from consumer or consumer’s representative. Directly from merchant. From credit reports received from credit bureaus. To make decisions about and provide services related to loans. To respond to consumer requests for leads for home improvement contractors. To run credit reports and criminal background checks to validate merchants. To Our bank partners.
Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES Indirectly from consumer and merchant by monitoring behavior. To make decisions about and provide services related to loans. To law enforcement to comply with a court order or governmental regulations. To third parties for fraud prevention and data security purposes.
Geolocation data Physical location or movements. YES Indirectly from consumer and merchant by monitoring behavior. To make decisions about and provide services related to loans. To respond to consumer requests for leads for home improvement contractors. To underwrite merchants and facilitate their involvement in the GreenSky merchant program. To third parties for fraud prevention and data security purposes. To merchants
Sensory data Audio recordings of phone calls. YES Directly from consumer. To make decisions about and provide services related to loans. To respond to consumer requests for leads for home improvement contractors. To address consumer complaints. To provide proof of consumer authorization. To Our bank partners. To government agencies. To merchants.
Professional or employment- related information Current or past job history. YES Directly from merchant. To underwrite merchants and facilitate their involvement in the GreenSky merchant program. None
Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that GreenSky disclose certain information to you about Our collection, use, disclosure and sale of your personal information over the past twelve (12) months. Once We receive and confirm your request, to the extent you have requested them, We will disclose to you:

  • The categories of personal information We collected about you;
  • The categories of sources for the personal information We collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom We share that personal information;
  • The specific pieces of personal information We have collected about you (also called a data portability request);
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and
    • Sales, identifying the personal information categories that each category of recipient purchased.
Sale of Personal Information

GreenSky do not sell personal information within the meaning of the CCPA. We do, however, make certain identifiers and contact information available about consumers that participate in our home improvement referral program to potential home improvement contractors. A consumer that no longer wishes to participate in this program may opt-out by contacting us at: privacyservice@greensky.com

Right to Request Deletion of Personal Information

You have the right to request that GreenSky delete any of your personal information that We have collected from you and maintain, subject to certain exceptions. Once We receive and confirm your request, We will delete, de-identify, or aggregate your personal information, unless retaining the information is necessary for Us or Our service provider(s) to:

  • Complete the transaction for which We collected the personal information, take actions reasonably anticipated within the context of Our business relationship with you, or otherwise perform Our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights to Know and Deletion

To exercise your rights please submit a request to privacyservice@greensky.com, complete the following webform or call 1-833-215-6869 toll-free.

In order to submit a consumer request, a consumer need only provide GreenSky with his or her name and email. We will then remit any requested information to the mailing address or email address we have on file for that customer as those addresses are already verified. If a consumer would like to receive a response to his or her request at a different mailing or email address, the consumer will need to provide Us two to three pieces of personal information, depending on the sensitivity of the information requested, in order to verify the identity of the consumer.

Only you, or someone legally authorized to act on your behalf (i.e., your authorized agent), may make a request related to your personal information. An authorized agent is someone acting on your behalf and GreenSky may ask that an agent provide verification that he or she is acting on behalf of a customer.

Non-Discrimination

GreenSky will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:

  • Deny you services.
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of services.
Contact Information

If you have any questions or comments about this privacy policy, the ways in which GreenSky collects and uses your information, your rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Phone: 1-833-215-6869

Website: www.greensky.com

Email: privacyservice@greensky.com

Postal Address: P.O. Box 29429, Atlanta, GA 30359