The GreenSky Online Privacy Policy

Last Updated:  11/18/2019

1. Introduction and Scope of Online 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 Online Privacy Policy (this “Online Privacy Policy”) outlines Our information collection practices at the GreenSky® Program websites that adopt this policy, including, but not limited to, www.greensky.com, www.greenskycredit.com, and www.greenskyonline.com (collectively, “Websites”), and any GreenSky® Program mobile application that links to this policy (collectively, “Mobile Applications”). This Online Privacy Policy applies to Personally Identifiable Information (defined in Section 2 below) collected through Websites or Mobile Applications but 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 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. 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.

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

 

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).

 

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 toy 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 Out 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. 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:
    • 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 Out 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 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 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 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 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 Online Privacy Policy

By accessing a Website or Mobile Application, you acknowledge that We have the right to revise and amend this Online Privacy Policy. We will post any changes to this Online Privacy Policy here so that you will always be aware of Our privacy practices. Please refer back to this Online 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. 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 service@greensky.com 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 service@greensky.com.