Conduct of GROUNDFLOOR Employee
GROUNDFLOOR is committed to the highest ethical standards. Our corporate values are founded on integrity and we expect our employees to act with your best interests in mind when it comes to your privacy. Our corporate Code of Conduct includes very specific guidelines concerning the safeguarding of confidential information, which includes customer information. In general, these guidelines limit employee access to confidential information, and limit the use and disclosure of such information to specifically authorized processes and transactions. If it is determined that employees have violated the Code of Conduct, corrective action may be taken, including immediate dismissal.
Review and Control of Privacy Practices
GROUNDFLOOR periodically reviews its operations and business practices for compliance with corporate policies and procedures governing the confidentiality of information. These reviews may be conducted by our own internal staff, external accounting and auditing firms, and government regulators. Included in these self-assessments and examinations are reviews of the controls and safeguards related to consumer privacy.
In general, and as described in detail below, we collect several types of information from you:
- Personal information required to verify your identity
- Personal and financial information necessary to assess your eligibility to borrow money or invest through GROUNDFLOOR
- Optional personal information you may wish to share in the furtherance of your goals in using our site
- Information about your visits to and use of this web site or the web sites of third party servicers to help us maintain the appropriate features, functionality and user experience
Customer Information that GROUNDFLOOR Collects
GROUNDFLOOR collects personal and financial information from you while you use the GROUNDFLOOR site, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. You will be told which information is private and which information is displayed to other users. Additional information may be gathered during your subsequent use of the site, whenever you choose to provide it.
Certain personal information must be supplied during the investor and borrower registration processes, as indicated below, in order to (a) enable registered users to login to the site, (b) determine borrowers’ eligibility for loans through our underwriting process, (c) verify borrowers’ and investors’ identities, (d) establish borrowers’ ability to request loans and investors’ ability to invest by verifying that they are at least 18 years of age, and (e) guard against potential fraud. This basic personal information includes:
- Your name (member registration)
- Your email address (member registration)
- Your date of birth (borrower/investor registration)
- Your home address and telephone number (borrower/investor registration)
- Your Social Security number (borrower/investor registration)
A borrower can be a company or the entity which you control that seeks financing. When you register as a borrower, we will use this information to underwrite your loan. This will include your financial information and circumstances. This may also include pulling a credit report from a credit bureau to determine your creditworthiness as well as to help investors assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during the lending process, such as:
- Generating public borrower profiles on the site
- Marketing specific borrower requests
- Communicating to investors your financial circumstances and relative creditworthiness
- Enabling our financial services partners to implement automatic payments and fund transfers
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
- Implementing collection activities as needed
- Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
When you register as an investor, we will request some required and optional data in order to facilitate such activities as:
- Generating an investor profile on the site
- Enabling our financial services partners to verify identity, implement fund transfers and the receipt of borrower payments
- Enabling our financial services partners to implement automatic payments and fund transfers
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
- Maintaining regular communications with you as may be necessary to execute transactions you request, such as submitting loan portfolios and transferring funds, etc
In addition, we gather names and email addresses of people who contact us through our web site with questions about our company or lending/borrowing operations. We collect this information for the sole purpose of responding to such inquiries.
Finally, we (and/or our service providers) collect information about your computer and your visits to our web site, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our web site to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our web site based on the needs of our users.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Referrals and other User to User Communications
Users may choose to refer friends to the site or directly to their borrower requests via email. If this referral occurs independently of our site or a partner’s site, we do not track the referral other than as a unique page view. Because we do not collect any information from the referring party or the recipient of the external email referencing our site, we do not capture or store any information about either party. If friends refer each other to our site or to their borrower requests via a partner’s site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities which contributed to the referral.
Our users can also refer friends to the site by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular loan request, and the sender will not know whether you are a borrower, investor or simply a member. The information collected in this process is only kept long enough to monitor whether the referral program is achieving the desired results in terms of attracting new visitors to the site and converting them into members. Again, these are messages initiated by friends of the recipients, and the recipients will not be added to any mailing list or contacted by GROUNDFLOOR apart from this referral process, which may include invitation reminders. In the case where a bonus is offered to a member in return for the referral, GROUNDFLOOR will only retain the information about the referred parties to properly credit the account of the member initiating the referral. The information is not used for any other purpose.
Communications from the GROUNDFLOOR Site
When you register on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and confirmation of successful submissions of loan requests and portfolios. You will also receive progress updates on the status of loan requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.
Third Party Websites Links
GROUNDFLOOR is not responsible for the information practices employed by sites linked to or from our website. In most cases, links to non-GROUNDFLOOR websites are provided solely as an access point to obtain information on products and topics that may be useful to the users of the GROUNDFLOOR website. Third party websites may have different privacy policies and/or security standards governing their sites.
Information Sharing with Third Parties
Information is shared with other parties in the following ways:
- Required and optional information about borrowers and investors is displayed on public profiles that members can update at any time; certain information is optional and you can choose not to supply it and/or can remove the optional information at any time. GROUNDFLOOR may, but is not obligated to, monitor any entered optional information to assist in the protection of your identity.
- Personal but not sensitive information about borrowers is contained in loan listings that can be viewed by all users and is filed with the various securities regulators and as such is made publicly available.
- Financial and credit information about borrowers is displayed to qualified investors on loan listing pages, is filed with the various securities regulators, and as such is made publicly available, and is contained anonymously in loan data files.
- Information is shared directly between users and other or potential users. Information shared directly by users might contain personal information
- GROUNDFLOOR may, with your consent, share required and optional information about you.
Borrowers will be able to see the screen names of their investors and vice versa. Borrowers have public profiles and loan listings on the site that display their information to any users who view these pages. The loan listing pages include borrowers’ underwriting score and other financial information that is shown to qualified investors so that they can effectively evaluate loan requests. As noted above, this information is also contained anonymously in loan data files which GROUNDFLOOR may make available in statistical form. Loan listings also contain certain personal information and, in some cases, answers to questions posed by investors, borrower created loan titles and loan descriptions that are incorporated into loan listings. Investors also have public profiles on the site containing personal information that they have opted to include. Finally, members creating blog/forum posts are also identified by their screen names.
GROUNDFLOOR is not responsible for any personal information that borrowers or investors may choose to reveal about themselves in their screen names, loan requests, blogs, or public profiles or blog/forum posts. Given the community nature of any person-to-person transaction site, however, it may be in the best interests of borrowers and investors to share some level of personal information in order to achieve a satisfactory outcome (i.e., it may be necessary for you to share a certain amount of personal information in order for your loan to receive full funding).
If you use our blog on this site, you should be aware that any personal information you submit there can be read, collected, or used by other users of this forum, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in this forum.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personal information when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site.
GROUNDFLOOR uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant GROUNDFLOOR and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the
GROUNDFLOOR works with a number of trusted partners that perform vital functions as part of our operations, including credit bureaus, collection agencies, electronic payment service providers, and customer support call centers. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
Reviews and Testimonials
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.
How Credit Information is Used
When you create a loan listing, you will be posting personal information on the site that will be visible to all users. This information includes details about your loan request, as well as your screen name, geographic location, and project details. It may even include a GROUNDFLOOR assessment as to your creditworthiness.
Qualified GROUNDFLOOR investors will also see certain credit data based on information we collect about you, which may include your credit history. It is necessary to allow prospective investors to see this information as they evaluate your loan request. Because we underwrite each borrower individually, the information we request will differ from borrower to borrower. Before you decide to list your loan request with GROUNDFLOOR, you will receive a description of the information we will need from you in order to complete our underwriting.
If you successfully receive a loan through GROUNDFLOOR, we will also display status information about your loan to your investors. Your loan tracks back to you by your project page. Your payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to your investors. Loan status information is also aggregated and displayed on the statistics page.
GROUNDFLOOR will send you email notifications from time to time, and these are required elements of your transactions on our web site, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or investor, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally you may not opt out of these service related emails.
Editing Your Information
You can access all of your personal information that we collect online and maintain by visiting your profile on our site. This section of the site is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone number and bank account information at any time on the website.
Cookies and Web-related User Information
We use web beacons or pixel tags, which are tiny graphics, in conjunction with cookies on our web site, including session ID cookies, non-persistent cookies and persistent cookies. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser and load the pages according to a user’s preferences for that particular site, including the personalization of content. Cookies are also used to gather statistical data, such as which pages are visited, what is downloaded, the ISP’s domain name and country of origin, and the addresses of sites visited before and after coming to our site, as well as your "click stream" activity (meaning, the paths taken by visitors to our site as they navigate from page to page) and transactional attributes in accordance with information you voluntarily submit in the course of using our site. This data is aggregated for analysis to ensure proper functioning of our site, in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing efforts. At no time do any of our cookies capture any personal information. More importantly, using cookies also helps us protect the security of your account. Session ID cookies follow your activities on our site so that we can ensure that no one is making changes to your profile, applying for loans or making loans on your behalf. This information is encrypted and no personal data about you is stored on our servers.
We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our web site, to improve its usability and for evaluating our marketing effectiveness as described above. We may also use that information to recognize your computer when you visit our web site (if you select the "remember me on this computer" option, and to personalize our web site for you. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookie by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector). Blocking cookies, however, can also have a negative impact on the usability of many web sites.
Cookies may have long-term expiration dates, or none, and thus can stay in your hard drive for months at a time. While you can remove them as instructed by the help content in your chosen browser, disabling cookies will prevent you from using our site. As with many transactional web sites, cookies must be enabled in order to use our site.
Compliance with State and Federal Laws
Links to Other Sites
GROUNDFLOOR Security Policy
Industry-leading standards and controls
GROUNDFLOOR takes strong steps to safeguard your personal and sensitive information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.
Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that you when you connect to our web site you are actually on our site. SSL also ensures that all data entered into the web site is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For further encryption protection, we use a 128-bit secure browser for logins and transactions. Finally, we subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.
Protection of account numbers
You should never share your password with anyone, and if you ever receive an email purporting to come from GROUNDFLOOR that asks for your password, you should immediately report this development.
What you can do
In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.
To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this site and/or changing your password on that email account frequently.
If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our site, you should log out completely, then close the browser window and clear the browser’s cache files.
You should also be aware of fraudulent attempts to gain access to your account information known as "phishing." Phishing is a tactic used by scammers in which unsuspecting people are brought to a web site by a genuine-looking email purporting to be from a legitimate company. The phony or "spoof" email takes the person to a web site that looks legitimate but in fact is not. Either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. GROUNDFLOOR will never ask you for your login information in the context of any email. In general, you can protect yourself against phishing by never providing personal or login information via an email. Instead, go to the web site directly.
We May Make Changes to This Policy
GROUNDFLOOR will always strive to meet our customers’ needs best. Therefore our site and its features will also change. Laws, regulations, and circumstances may also change. This policy may be updated from time to time as such needs dictate, and we will always communicate these changes to you by posting them on this web site and/or by notifying you via email in the event of any substantive or material changes.
GROUNDFLOOR Finance Inc.