Introduction and Scope of Online Privacy Policy

We are committed to protecting the personal information we collect about individuals (e.g., applicants, borrowers, and merchants) participating in the FinMkt® Program and have adopted policies, procedures, and processes designed to protect personal information from misuse, theft, or other loss.

This FinMkt® Program website privacy policy (the “Online Privacy Policy”) outlines our information collection practices for our websites, including, but not limited to, www.FinMkt.io, and https://toro.mktplacegateway.com (collectively, our “Website”). This Online Privacy Policy applies to Personally Identifiable Information collected through our Website (defined in Section 2 below) 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 our Website, websites that link to or from our Website, or any other website.

Personally Identifiable Information, Definition

“Personally Identifiable Information” is any information collected through our Website that is reasonably likely to identify a specific, unique individual. Personally Identifiable Information collected through the site 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, telephone number, and date of birth.

Important Information Regarding Use of the Website

FinMkt and the federally-insured, federal or state chartered financial institutions and other lenders participating in the FinMkt® Programs (the “Funding Participants”) (collectively, “we” or “us”) own the information we collect on the Website.

The Website contains links to other websites. We do not control and are not responsible for the content, security, and privacy practices of such websites.

This Website is intended for visitors located in the United States. This Website is 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. Information submitted to this Website is housed on servers located in the United States.

By using the Website, 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 Website. Furthermore, by using this Website, you agree to the application of United States law and consent to the use and disclosure of your information consistent with this Online Privacy Policy.

Information Collected on the Website

We collect Personally Identifiable Information at various times when you use our Website. Some of the places where we collect such information includes, but is not limited to, the following:

• Emails, contact forms, questionnaires, and other forms you submit to us;

• Your applications and transactions with the FinMkt® Programs, including those involving the Funding Participants;

• Requests for pre-qualification for credit; and

• Requests regarding qualified merchants.

Additionally, each time you visit the Website, the web server may automatically collect certain types of non-Personally Identifiable Information. Some examples of the non-Personally Identifiable Information we may automatically collect include:

• Information about your Internet service provider, browser, operating system, and device;

• Cookie information to recognize when you are visiting the Website;

• Data related to your location at the time of accessing our Website, and

• Beacons to know if a certain page was visited or an email was opened.

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 the 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 our website. Google’s Adwords technology may recognize a cookie that our website has sent to your browser during a past visit by you to our 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.

Third parties use tracking technologies with the Site. This may include the collection of information about your online activities. We may not control those tracking technologies. We are not responsible for those tracking technologies. You consent to encountering third-party tracking technologies when using the Site. You accept that this Privacy Policy does not apply to the tracking technologies or practices of such third parties.

Third parties that have content embedded on the Site may set Cookies on a user’s browser. They may also get information that a web browser visited a FinMkt website from a certain IP address.

Other third parties are making or have made signals or other mechanisms for consumer choices about the collection of information about a consumer’s online activities. We do not track or take any action on these signals or other mechanisms. We do not allow third parties to collect Personal Information about a user’s online activities when that user uses the Site, service or applications.

Use of Information Collected on the Website

We may use your Personally Identifiable Information for the following purposes:

• To process transactions you request;

• To assess your creditworthiness when you apply for credit or to pre-qualify you for credit;

• To manage loans or other accounts you have with us;

• To communicate with you about your FinMkt® Program loans or credit accounts and the use of our Website;

• To advise you of promotions, sales, or other special opportunities;

• To market goods or services offered by:

  • FinMkt or its affiliates and subsidiaries;
  • Funding Participants, or their affiliates and subsidiaries;
  • merchants participating in the FinMkt® Programs; or
  • other unaffiliated third-parties;

• To comply with the law, regulatory requirements, legal subpoena or other litigation process, or to enforce our Terms of Use;

• 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.

Disclosure of Personally Identifiable Information to Third-Parties

By accessing our Website, you authorize us to disclose your Personally Identifiable Information to affiliated and unaffiliated third-parties as follows:

• To companies in our corporate group;

• To third parties, including Funding Participants, loan servicers, 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;

• 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 our Terms of Use;

• 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.

Personally Identifiable Information of children

We do not knowingly solicit or collect Personally Identifiable Information about children under the age of 18. Our Website is 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 privacy@finmkt.io.

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.

Reviewing information we have collected on 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 privacy@finmkt.io.

Opting out from our solicitations. If you receive a marketing e-mail from the FinMkt® Program 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 lenders. If you need help accessing your information related to a service provided by one of our service providers or information held by your lender, 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 programsupport@finmkt.io.

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)-988-3708 or write to us at FinMkt, Inc. Attn: Information Sharing Opt-Out, 1178 Broadway, 4th Floor, Suite 402, New York, New York, 10001. 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.

Changes and revisions to this Online Privacy Policy

By accessing our Website, 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 our Website following our posting of any such changes will mean that you accept such changes.

Your California Privacy Rights

Special Notice to California Residents. If you are a resident of California, in addition to the rights set forth in this Privacy Policy:

You have the right to control whether we share some of your personal information and you may opt out of any sharing of your information with any party.

You also have the right to request that we disclose to you the categories and specific pieces of information that we have collected about you by sending us an inquiry at https://www.finmkt.io/contact-us or by sending a written request to:

FinMkt, Inc.
Attn: Privacy Administrator
1178 Broadway, 4^thFloor,
Suite 402, New York, New York, 10001

We will respond within thirty (30) calendar days of receiving your request by providing a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding twelve months along with the names and addresses of these third parties.

You also have the right to request that we delete your personal information that we have collected from you by sending a written request to the address listed above. We will respond to any such requests by mail free of charge to you.

Please read the following information carefully before you make your choices below.

We are required by the California Financial Information Privacy Act to provide this notice to you annually.

This Privacy Notice applies to FinMkt and its subsidiaries.

YOUR RIGHTS

You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies with which we do business. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.

YOUR CHOICES

Restrict Information Sharing With Companies We Own or Control (Affiliates): Unless you say "No," we may share personal and financial information about you with our affiliated companies or subsidiaries.

[ ] NO, please do not share personal and financial information with your affiliated companies or subsidiaries.

Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you say "No," we may share personal and financial information about you with outside companies we contract with to provide financial products and services.

[ ] NO, please do not share personal and financial information with outside companies you contract with to provide financial products and services.

TIME SENSITIVE REPLY

You may make your privacy choice(s) at any time. Your choice(s) will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services.

To exercise your choices do one of the following:

Please note that in order for us to process your request, the address you provide below must be a California address you've given to us in relation to your account.

Last name (please print):___________________________

First name:_____________________________________

Street address:_________________________________

City:___________________State:____________ZIP:_________

Mailing Address (if different than the street address):

City:__________________State:_____________ZIP:_________

Signature:_______________________________Date:_________

We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is privacy@finmkt.io.