Legal

Security On Our Website

Visitors to our web site remain anonymous. We may use standard software to collect non-identifying information about our visitors, such as:

• Date and time our site was accessed

• IP address (A numeric address given to servers)

• Web browser used

• City, State, and County

LendingClub Bank N. A. may use this information to create summary statistics, to determine the level of interest in information available on our site or to further market our products and services across the Internet. Some areas of our website require information, such as your email address or name, to enable you to correspond with us. In these cases, we collect your information necessary to interact with you.

How We Protect You

LendingClub Bank N. A. is committed to keeping your information safe.

LendingClub Bank N. A. utilizes advanced security technologies and processes to safeguard your information when you choose to bank with us online or by mobile device. We use a variety of methods to secure our network, servers and all of our web and mobile applications, including:

• Top-rated anti-virus protection to help us detect and prevent viruses.

• Advanced firewalls help block unauthorized access by individuals or networks.

• Our information security team performs regular software updates to remain up-to-date on software security enhancements.

• Login ID, password and security questions are used for authentication when accessing your accounts online or via mobile device and should never be shared with anyone.

• We automatically log you out of your secure online and mobile banking session(s) after a period of inactivity to help protect against others accessing or using your online accounts.

• We never store personal or account information on your mobile device.

• We monitor online and mobile banking activities for potential fraud.

If you have any questions or concerns about the security of your information when banking with LendingClub Bank N. A. online or by mobile device, please contact our Customer Service team at 800.242.0272 or via email at bankhelp@lendingclub.com* Monday – Friday, 8:30AM – 1:00AM ET and Saturday – Sunday, 8:00AM – 8:00PM ET.

How We Handle Email

If you send us email, we may retain the content of the email and your email address in order to respond to questions or concerns that you might have. Email is not necessarily secure against interception. That is why we use MessageLabs to send confidential information back to you. MessageLabs is a secure messaging network that uses industrial-strength encryption and a secure web interface to deliver email messages and attachments.

Identity Theft

If you suspect your identity has been stolen, please do the following two things:

1. Contact us immediately at 800.242.0272 or send a secure message through your Online Banking account.

2. Contact the Federal Trade Commission

    and follow the instructions on their website for recovering your identity.

Phishing Scams

Please be aware of any LendingClub Bank N. A. “phishing” emails, email communications that appear to be from LendingClub Bank N. A. and indicates that your attention is required regarding your LendingClub Bank N. A. account. Such emails direct you to a website via an embedded hyperlink, which also appears to be a LendingClub Bank N. A. website. This type of email is designed to look legitimate, but is actually a fraudulent attempt to obtain your personal information. Please do not respond to this email or enter any personal information in response.

• Asking for personal information should raise a flag since LendingClub Bank N. A. emails will never ask you to reply in an email with any personal information, such as your Social Security number, ATM or Debit Card PIN.

• Urgent appeals claim that your account may be closed if you fail to confirm, verify or authenticate your personal information. LendingClub Bank N. A. will not ask you to verify information in this way.

• Messages about system and security updates claim that the bank needs to confirm important information due to upgrades and state that you must update your financial information online. LendingClub Bank N. A. will not ask you to verify information in this way.

To protect against phishing and spoofing:

• Make sure you are at LendingClub Bank N. A.’s website when you sign in to Online Banking. You can confirm that you have been directed to the correct LendingClub Bank N. A. Online Banking website by matching the web address to “https://online.lendingclub.com.” You can type https://bank.lendingclub.com in your browser to be sure you are using the correct website.

• If you receive a suspicious email, do not click on any links or reply to it. Simply delete it.

• To report a suspicious email that uses LendingClub Bank N. A.’s name, you can forward it to bankhelp@lendingclub.com*.

Please note that LendingClub Bank N. A. will never ask for your Username, Password or ATM PIN over the telephone, by text message or by email.

SMShing

SMShing is phishing that happens via SMS text message. A criminal sends a text messages tricking you into providing financial or personal information or clicking on links that will sneak viruses onto your mobile device. To guard against these scams:

• Don’t respond to a text message that requests personal or financial information. LendingClub Bank N. A. will never ask you to respond in this way.

• Verify the phone numbers that appear in a text message. Store LendingClub Bank N. A. phone numbers in your mobile contacts for a quick cross-check. Or, you can go to the Contact Us  page.

Vishing

Vishing uses Voice over Internet Protocol (VoIP) to call, leaving an automated recording. It alerts the consumer that their account has experienced unusual activity. The message instructs the consumer to call the same phone number shown in the spoofed caller ID with the same name as the financial company they are pretending to represent. And sometimes, criminals who try to get consumers to turn over personal data send emails and text messages containing fraudulent phone numbers. Rather than provide any information, you should contact LendingClub Bank N. A. at the customer service number you normally use to verify the validity of the message.

Malware

Malware, short for “malicious software,” includes viruses, spyware and trojans that are designed to infiltrate or damage a computer system. Malware is often used to steal personal information and commit fraud. There are several easy ways to minimize the risk of malware:

• Downloads from file sharing and social networking sites can be distributions points for malware

• Attachments and free software from unknown sources shouldn’t be opened or installed

• Pop-up advertisements asking for personal or financial information are likely fraudulent, so it’s better to close them

• Updated security and system software can protect your computer from malware threats

Money Mules

Money mules are unsuspecting victims who become middlemen for criminals trying to launder stolen funds. Victims are lured by the promise of a new career opportunity making large sums of money for minimal work. Criminals recruit money mules, send them stolen money and then ask the money mules to wire or transfer the money unwittingly to the criminals. Using the money mule masks the criminal’s identity.

The money mule may keep a commission for performing the transfer or wire. The victims of these scams may not only have their bank accounts closed and financial reputation ruined, but are often left financially responsible for returning the stolen funds.

Common signs of a money mule scam:

• Overseas companies requesting money transfer agents in the US

• Opening new bank accounts to receive money from someone you don’t know

• Accepting large sums of money into your personal bank account for a new job

• Transferring or wiring funds out of your personal bank account to people you do not know

Online surveys and sweepstakes

From time to time, you may be asked to participate in online surveys or sweepstakes. You are not required to complete online surveys, sweepstakes or promotions, however, online surveys are used so that we can gather information to better serve you. Based on the information you provide to us, we may inform you of accounts and services from LendingClub Bank N. A.

Social Media

LendingClub Bank N. A. provides experiences on social media platforms, such as Facebook, Twitter, LinkedIn, YouTube and Google+, that enable online sharing and collaboration among users who have registered to use them. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Linking to other sites

We may provide links to non-LendingClub Bank N. A. websites, such as credit bureaus or merchants. If you follow links to websites not controlled by LendingClub Bank N. A., you should review their privacy policies and other terms, as they may be different from those of our sites. LendingClub Bank N. A. does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness, reliability or suitability of their information.

Making sure information is accurate

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our website, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative at a banking center, or to your financial advisor or account representative.

About “Cookies”

A “cookie” is a small text file that is sent from our web server and stored with your web browser on your computer. Cookies are commonly used on websites and do not harm your system.

Using “COOKIES” For Online Banking

When you log in to LendingClub Bank N.A. Online Banking, we use a “cookie” as part of our interaction with your browser. We use cookies to establish and maintain your LendingClub Bank N.A. Online Banking session. These cookies do not collect personally identifiable or confidential information. The cookies expire or are deleted after you log off and end your LendingClub Online Banking session.

You may be prompted to retrieve and enter a Security Access Code to verify your identity when logging in to LendingClub Bank N.A. Online Banking. This is an additional layer of security we provide on top of your standard Login ID & Password combination. During this process, you may be prompted to register your device. If you choose “Register Device,” a “cookie” will be stored with your browser on that device so you can bypass this procedure the next time you attempt to log in (using that browser on that device). If after you go through this process the device or browser is reset in a way which clears the stored cookies, you will be prompted to go through the process again the next time you attempt to log in.

USING “COOKIES” FOR ONLINE Advertising

In our online advertising, LendingClub Bank N. A. may use Google Analytics, Google AdWords Conversion tracker, other Google services, Facebook, and other third party sites which place cookies on a browser across the LendingClub Bank N. A. website(s). This cookie placement helps us increase the website’s general effectiveness for visitors. Cookies are set and read by Google, Facebook and other third party sites. You can opt out of Google tracking at any time by visiting the Google Ad Settings page. You can opt out of Facebook tracking at any time by visiting https://www.facebook.com/ads/website_custom_audiences/.

LendingClub Bank N. A. may also use AdWords, Facebook or other third party remarketing, sometimes called retargeting, to market our website(s) across the Internet. Google, Facebook or other third party sites place a cookie on a browser. Google, Facebook or third party sites read cookies and may present a LendingClub Bank N. A. ad on a 3rd party site. You may opt out of Google’s remarketing here. You may opt out of Facebook remarketing by visiting https://www.facebook.com/ads/website_custom_audiences/.

This agreement may be changed from time to time by posting the new Terms of Use on LendingClub Bank N. A.’s website. All LendingClub Bank N. A. website users agree to be subject to this agreement as it changes from time to time.

Looking out for children

Protecting children’s identities and information online is important. LendingClub Bank N. A. does not knowingly solicit data from children online, nor do we market our online products and services to children.

Questions About Privacy

To view LendingClub Bank N. A.’s Privacy Policy, click here. If you have any questions about LendingClub Bank N. A.’s Privacy Policy or practices, or if you have any concerns about the protection of your information, please call us toll-free at 1-800-242-0272, email us at bankhelp@lendingclub.com* or write to us at:

ATTN: Privacy
LendingClub Bank N. A.
P.O. Box 55063
Boston, MA 02205-8031