A smarter way to invest and borrow.

Privacy Policy

Last updated: October 25 , 2012

TRUSTe Click to Verify seal

Lending Club has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Web site, www.lendingclub.com.

TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@lendingclub.com. If you are not satisfied with our response you can contact TRUSTe here.

Your privacy and the protection of your sensitive personal information are important to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information.

Employee Conduct

Lending Club expresses its absolute commitment to integrity, and our corporate values and ethical standards and the associated business conduct we expect from all our employees. The Lending Club 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.

Verification of Practices

Periodically, our operations and business practices are reviewed 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.

Introduction

This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.

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 Lending Club or one of its marketing partners.
  • 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 services to help us maintain the appropriate features, functionality and user experience

Information We Collect From You and About You

We collect personal and financial information from you while you use the 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. We always let you know which is which. 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 member, 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 proprietary credit scoring 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)

When you register as a borrower, we will use this information to pull 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
  • Assigning you a borrower credit grade based on your credit history and financial circumstances
  • 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 a public 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 and do not store the contact information unless requested by these people, such as in the case of job applicants who submit resumes, etc.

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. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our web site, as discussed further below.

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.

Tell-a-Friend and Other User Referral Activities

Users may choose to refer friends to the site or directly to their loan listings 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. Since 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 loan listings 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 Lending Club 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, Lending Club 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 Our 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.

Links to Third Party Websites

Lending Club is not responsible for the information practices employed by sites linked to or from our website. In most cases, links to non-Lending Club websites are provided solely as an access point to obtain information on products and topics that may be useful to the users of the Lending Club website. Third party websites may have different privacy policies and/or security standards governing their sites.

How and When Your Information Is Shared With Other 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. Lending Club 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 Securities and Exchange Commission 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 Securities and Exchange Commission, and as such is made publicly available, and is contained anonymously in loan data files available on the statistics page.
  • Information is shared directly between users and other or potential users. Information shared directly by users might contain personal information.
  • Lending Club may, with your consent, share required and optional information about you.

For privacy purposes, borrowers and investors remain anonymous on the site and are identified only by their chosen screen names. Borrowers will be able to see the screen names of their investors and vice versa. However, 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’ credit grades 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 available on the statistics page. Loan listings also contain certain personal information and purposes for which the loan will be used, as designated by borrowers. 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.

To protect borrowers’ and investors’ privacy, however, the blog/forum posts do not track back to loan listings or loan funding decisions, respectively. Lending Club 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. To request removal of your personal information from our blog, contact us at privacy@lendingclub.com.

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.

Lending Club 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.

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. If you wish to update or delete your testimonial, you can contact us at privacy@lendingclub.com.

How Your Credit History and Lending Club Loan Data Are Shared

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, Lending Club credit grade, and the purpose for which the loan will be used.

Qualified Lending Club investors will also see certain credit data collected from or calculated based on your credit bureau file. It is necessary to allow prospective investors to see this information as they evaluate your loan request. The information displayed to investors includes a credit profile section and a credit history section. As noted above, this information is also contained anonymously in loan data files available on the statistics page.

The credit profile section includes your:

  • FICO score range
  • Debt-to-income ratio (DTI)
  • Gross income
  • Home ownership status
  • Current employer and tenure in your current position
  • Existing debt payments (monthly snapshot of your current outstanding debt)
  • Monthly payment amount for the loan being requested

The credit history section includes the following information:

  • The date your earliest reported credit line was opened (e.g., revolving credit)
  • The total number of credit lines currently in your credit file
  • The number of open credit lines currently in your credit file
  • Your total balance for all open revolving credit lines
  • Revolving line utilization rate, or the amount of credit you are using relative to all of your available credit
  • The number of accounts on which you are now delinquent, and the past-due amount you owe
  • The number of months since your last delinquency
  • The number of 30+ days past-due incidences of delinquency in your credit file for the past 2 years
  • The number of negative public records (e.g., bankruptcies and judgments, etc.) placed in your file and the number of months since the last record
  • The number of inquiries by creditors during the past 6 months

If you successfully receive a loan through Lending Club, we will also display status information about your loan to your investors. Your loan tracks back to you by your screen name, so it is important that you choose a screen name that will protect your anonymity. You should not choose a screen name that resembles your actual name or that of any other person. Further, you should not include your name or personally identifiable information in your loan request. 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.

Notifications

Lending Club 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.

Where You Can Find and/or Correct Your Information

You can access all of your personal information that we collect online and maintain by visiting your profile in the My Account section of 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, and if you need to change any other information in your profile you can contact us at support@lendingclub.com. To protect your privacy and security, please contact us at support@lendingclub.com to make changes to your sensitive account information.

Web-related Information Collection

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. Additionally, Lending Club currently does not process, acknowledge or otherwise respond to any web browser’s "do not track" signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our website.

We use third-party tracking services that use cookies or other tracking technology to track non-personal information about visitors to our site in the aggregate (such as web page views, other sites visited and referral page information to track the success of our marketing efforts to bring people to our site as well as overall site performance). We use respective web beacons to gather information that lets us tune and improve our users' browsing experience, as well as track user responsiveness to various advertising campaigns and user activities. Lending Club utilizes information such as "click stream" and transactional data, and uses all information collected in the aggregate, for anonymous purposes; in other words, Lending Club does not associate any collected data with any users as individuals. Additionally, no personal or sensitive information is transmitted to advertising partners. However, certain partners may collect incoming IP addresses in connection with your visits to our site (for example, to avoid double-counting the number of new members who joined as a result of an advertising campaign) and may also track the other websites visited by users of these IP addresses.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Links to Other Sites

We may offer links to partners’ sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled or to facilitate our customers' more effective use of our platform, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy and may have different privacy policies or approaches to the handling of information. Further, Lending Club has no control over the content of these sites. Please consult the privacy policies on these sites before you provide them with any of your personal information.

Lending Club Security Policy

Industry-leading standards and controls

Lending Club 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. Portions of our site also make use of "CAPTCHA" technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering in the text shown in the image. Finally, we subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.

Secure, off-site hosting

We store all sensitive financial data such as Social Security numbers and bank accounts in a highly secure, SAS 70 environment.

Session time-outs

We also employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

Protection of account numbers

When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Further, we employ strict access standards ensuring that only the senior-most employees or partner representatives have access to your account numbers and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account.

Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an email purporting to come from Lending Club that asks for your password, you should immediately report this development.

ID theft policy

Lending Club utilizes state of the art authentication technology to verify identities. However, if an investor suspects that one of their loans belongs to a person who has committed ID theft, please contact us at security@lendingclub.com. Lending Club will work with law enforcement authorities to track down and prosecute anyone who has committed identity theft. Lending Club will reimburse the investor for the unpaid principal balance of loans where the borrower has committed identity theft.

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. Lending Club 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 the web site directly. You might also make it a habit to check the URL of a web site to be sure that it begins with the correct domain. In the case of Lending Club, you should always ensure the URL begins with http://www.lendingclub.com, https://www.lendingclub.com, http://blog.lendingclub.com or https://www.lendingclub.com.

We May Make Changes to This Policy

As technologies, laws and user needs change, our site and its features will 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.

You may contact us at:

Lending Club Corporation
Attn: Compliance Department
71 Stevenson St. Suite 300
San Francisco, CA 94105

Via email at: privacy@lendingclub.com

If Lending Club is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information..


Exhibit A

Privacy Notice

Facts

What does Lending Club do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.

Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number and income
  • Account balances and payment history
  • Credit history and credit scores

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Lending Club chooses to share; and whether you can limit this sharing.



When you are no longer our customer, we continue to share your information as described in this notice.

To limit our sharing


Call (888) 596-3157 - our menu will prompt you through your choice(s) or visit us online: www.lendingclub.com or contact us at privacy@lendingclub.com

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

Questions

Call (888) 596-3157 or go to www.lendingclub.com

What we do

How does Lending
Club protect my
personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Lending
Club collect my
personal information?

We collect your personal information, for example, when you

  • Open an account or pay us by check
  • Provide account information or give us your contact information
  • Show your driver's license

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can't I limit
all sharing?

Federal law gives you the right to limit only

  • Sharing for affiliates' everyday business purposes-information about
    your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for non-affiliates companies to market to you

State laws and individual companies may give you additional rights to
limit sharing.

What happens when I
limit sharing for an
account I hold jointly
with someone else?

Your choices will apply to everyone on your account - unless you tell us otherwise. Joint accounts are offered only for investors, not borrowers.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include LC Advisors, LLC.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Nonaffiliates we share with can include other financial services companies,
    lenders, insurance companies, retailers, membership clubs, or other consumer
    service providers.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Our joint marketing partners include other financial services companies,
    lenders, insurance companies or other consumer service providers.

Financial Innovation

Companies like Lending Club are cutting out the middle man − banks − to offer consumers the opportunity to lend money directly to others and obtain a higher return.

Market Watch

Featured Borrower

Dan

"My loan was 100% funded within 12 hours, and I had funds in my account within 4 days. It was ridiculously fast..."