Privacy Policy

Effective Date: 08/15/2017

Ethos Lending LLC is dedicated to maintaining your trust when handling personal and financial information about you. In doing so, we are committed to protecting the privacy and security of those who access and use our website, www.ethoslending.com, and any of its subdomains or mobile applications.

This Online & Mobile Privacy Practices Statement (“Statement”) describes Ethos Lending’s online and mobile privacy practices and applies to anyone who visits our websites, including without limitation our consumer borrower and mortgage broker portal sites, or Ethos Lending-branded social media sites or pages, or uses our mobile applications (collectively, “Sites”).

The term “Ethos Lending” or “we” or “us” or “our” in this Statement means affiliates or subsidiaries of Ethos Lending linking to this Statement.

This Statement pertains only to information collected through your use of our Sites. Information that you provide to Ethos Lending when you apply for or obtain a product or service from us to be used primarily for personal, family or household purposes is also governed by a separate notice entitled Ethos Lending Privacy and Opt-Out Notice. If you are such an applicant or customer, please refer to that notice for additional information about our privacy practices.

By registering and/or using Ethos Lending’s products and services, including our Sites, you expressly authorize and consent to Ethos Lending’s collection, aggregation, transfer, and other uses of your information as set forth in this Statement. This includes Ethos Lending’s aggregation and use of your personal information for future marketing purposes, such as determining your current and future eligibility for products and services and continued verification of your eligibility for participation in any program offered by Ethos Lending or one of its marketing partners, now or in the future.

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Information We Obtain

When you use our Sites or our mobile applications, we may collect data from you that generally fall into one of two categories:

Personal Information: Personally identifiable information you provide to us such as your name, mailing address, email address, telephone or wirelessphone number or other information that identifies you. You may provide certain financial information to us through our Sites for the purpose of consideringan extension of credit to you and extending credit to you which is personally identifiable information.

Online/Mobile Activity Data: Data such as your IP address, your browser type and language, and your display/screen settings; data about how you useour Sites and how you interact with our Sites; data about your mobile device; geolocation data; social media preferences and other social media data; and other data that may be aggregated and/or de-identified (information that doesn’t identify individual consumers/customers).


How We Collect Information

When You Use or Visit Our Sites

Ethos Lending may collect information about you when you browse our website or use our online services. We may collect Personal Information when you voluntarily provide it to us through forms on our website or in our mobile applications, mortgage loan applications and login pages for access to our Sites.

Ethos Lending may also use cookies and other online tracking devices such as pixel tags and clear GIFs (also known as web beacons) to collect Online/Mobile Activity Data from you depending on your browser settings. Cookies are small text files that a website’s server places on your computer. Cookies provide a means for websites that you visit to track browsing activities conducted with your computer. A Web beacon is a small string of software code that represents a graphic image on a website or email.

Ethos Lending may also partner with certain third parties to deliver advertisements and monitor activities on our Sites and other websites. Our partners may use cookies, web beacons, and/or other monitoring technologies to compile statistics about website visitors.

When You Use Our Mobile Apps

Additionally, Ethos Lending may collect Online/Mobile Activity Data when you access our mobile applications or use the browser on your mobile device to access our Sites. For example, if you have enabled location services on your mobile device, we may collect geolocation data from your device.

When You Use Our Social Media Pages

Ethos Lending has official pages on social media websites such as Twitter® and LinkedIn that enable consumers and customers to discuss their experiences with Ethos Lending products and services. We may also partner with companies that operate social media websites through which you may engage with Ethos Lending. When you interact with us on social media websites we may collect information such as your likes, interests, feedback and preferences. When you interact with our partners, you are subject to their terms of use and privacy policies. We may collect information from our social media partners, but only if you choose to share with them and they, in turn, share such information with us. Never include sensitive personal, financial or other confidential information such as your Social Security number, account number, phone number, mailing address or email address when posting or commenting online. Any posts you make on our official social media pages, including posts that contain pictures, comments, suggestions, opinions, complaints or Personal Information, are available to others who use those pages and are subject to the terms of use and privacy policies of the companies that operate the websites on which they appear. Please refer to the policies of those companies to better understand your rights and obligations with regard to such posts. You are also subject to this Statement and our social media guidelines when you visit our official social media pages.


How We Use Information

We may use Personal Information and Online/Mobile Activity Data we have collected for a variety of reasons. For example, we may use this type of data:

  • to enable you to apply for Ethos Lending products or services
  • to enable you to use online tools or perform certain online transactions
  • to verify your identity and/or location to allow access to your accounts, conduct online transactions and assist us in taking data security precautions and to engage in fraud prevention/detection
  • for business purposes, including data analysis, to improve, personalize, optimize your website browsing and mobile application experiences by examining which parts of our website you visit or which aspect of our mobile applications you find most useful, and to improve existing or develop new products and services
  • to comply with federal, state or local laws; civil, criminal or regulatory investigations; or other legal requirements
  • to share with companies within the Ethos Lending family, and with trusted third parties who are contractually obligated to keep such information confidential and to use it only to provide the services we have asked them to perform (For a description of how Ethos Lending may share information collected from consumers who have applied for or obtained a consumer product or service from us, please refer to the Ethos Lending Privacy and Opt-Out Notice).

Managing Your Online and Mobile Preferences

You provide Personal Information to us on a voluntary basis and are not required to provide it in order to browse our Sites. If you provide us with Personal Information to obtain a consumer product or service from us, our Ethos Lending Privacy and Opt Out Notice will govern how we share your Personal Information with our affiliates and third parties and will enable you to opt out of certain types of sharing.

Online Tracking & Advertising on our Sites or Apps

As you access our online services over time, cookies and similar technologies such as web beacons allow us to collect information such as browser type, pages visited, preferences, and your relationship with us. Ethos Lending may customize content for our products and services on the Sites or mobile apps we own. In order to make the content as informative and useful as possible, we may use information about your relationship with us. Currently, for online advertising purposes, our website does not respond to browser “do not track” signals, but these signals may be used for fraud prevention. However, if you choose, you can set your website browser to inform you when cookies are sent or you may choose not to accept cookies. Your decision not to accept cookies could limit access to some of the services and offers that are available on our Sites. For example, your device may not be recognized when you visit our website and, if you are an existing customer, you may need to answer challenge questions each time you log on.

Email

If we send you an email advertisement, it will include instructions on how to opt out of receiving such emails in the future. If you are a customer and you elect to opt out of receiving email advertisements, we may still send you emails about your account relationships with us. To opt out of receiving email advertisements, you may submit your request at [TO BE COMPLETED]. If your name was previously selected for any of our upcoming email offers, it is possible for you to receive information from Ethos Lending up to 10 business days after your request has been submitted.

If you receive an email that claims to be from us but you are not sure, or if you think it is suspicious, do not click on any of the links in the e-mail. Instead forward it to us at [abuse@Ethoslending.com] then delete it.


Updating Your Information

Keeping your account information up-to-date is very important. You may review, or update certain account information by logging into your account online. If you cannot change the incorrect information online, or you prefer to request changes offline, please use the Contact Us option on our site, or call or write to us using the contact information listed on your account statements, records, or other account materials.


Links To Other Websites

Our websites may include links to third-party websites. These third parties are not subject to this Statement or to the Ethos Lending Privacy and Opt Out Notice. Whenever you visit a third-party website, you should review its privacy notice.


Protecting Children's Online Privacy

Ethos Lending encourages protection of children’s information on the internet. We do not intentionally collect personal information from children under 13 on our Sites without first obtaining consent from their parents or legal guardians. For more information about the Children’s Online Privacy Protection Act (COPPA) please refer to the FTC’s website at http://www.business.ftc.gov/privacy-and-security/children%27s-privacy.


Your California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to prevent disclosure of their personal information and request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.


Information Security

At Ethos Lending, we make your safety and security a top priority and are committed to protecting your personal and financial information. If we collect identifying information from you, we will protect that information with controls based upon recognized security standards, regulations, and industry-based best practices.

Ethos Lending maintains customer authentication procedures to protect your personal information and account from identity theft. These procedures are for your protection. If you suspect a website is pretending to be an Ethos Lending website (also known as “spoofing”) do not enter personal information but instead contact us in a branch or through a phone number you know is associated with your account at Ethos Lending, or by emailing [abuse@Ethoslending.com].


Changes to this Statement

This Statement describes Ethos Lending’s current online privacy practices. Ethos Lending may change its online privacy practices in the future and we may revise this Statement to reflect material changes.


How to Contact Us

If you have any questions or concerns about this Policy, please contact us by e-mail at info@ethoslending.com, by calling our toll free telephone number (855) 384-6753 during our operating hours from 8:00 AM to 5:00 PM PST, or write to us at:

Ethos Lending
180 Montgomery Street, Suite 1000
San Francisco, CA 94104


Rev. 07/17
FACTS WHAT DOES ETHOS LENDING 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 Account Balances
  • Payment History and Credit History
  • Credit Scores and Income
How? All financial companies need to share customer personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer’s personal information; the reasons Ethos Lending LLC (“Ethos Lending”) chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information Does Ethos Lending Share? Can you limit this sharing?
For our everyday business purposes -
such as to process your transactions, maintain
your account(s), respond to court orders and legal
investigations, or report to credit bureaus
Yes No
For our marketing purposes -
to offer our products and services to you
Yes No
For joint marketing with other financial companies Yes No
For our affiliates' everyday business purposes -
information about your transactions and experiences
Yes No
For our affiliates' everyday business purposes -
information about your credit worthiness
Yes Yes
For our affiliates to market to you Yes Yes
For nonaffiliates to market to you Yes Yes
To limit our sharing 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 toll-free 855-384-6753 or go to www.ethoslending.com

Who we are
Who is providing this notice? Ethos Lending LLC and its affiliated entities, such as Fenway Summer LLC and FS Card Inc.

What we do
How does Ethos Lending 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 Ethos Lending collect my personal information?

We collect your personal information, for example, when you

  • Apply for a loan or
  • Give us your contact information or
  • Give us your employment history or
  • Give us your income information or
  • Provide your mortgage information

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 nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account.

Definitions
Affiliates

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

  • Companies operating under the Ethos Lending, Fenway Summer, or FS names.
Nonaffiliates

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

  • Nonaffiliates we share with can include financial service companies such as mortgage lenders, brokers, investors, servicers, insurance companies, credit card and unsecured lenders, as well as retailers and nonprofit groups.
Joint Marketing

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

  • Our joint marketing partners include financial service companies.

Other important information
Do Not Call Policy: This notice is the Ethos Lending Do Not Call Policy under the Telephone Consumer Protection Act. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless the law requires or allows. Ethos Lending employees receive training on how to document and process telephone marketing choices. Consumers who ask not to receive telephone solicitations from Ethos Lending will be placed on our Do Not Call list and will not be called in any future campaigns, including those of our affiliates.

Nevada Residents: We are providing you this notice under state law. You may be placed on our internal Do Not Call List by calling toll-free 855-384-6753. For more information on this Nevada law, contact: Bureau of Consumer Protection,Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702.486.3132; email: BCPINFO@ag.state.nv.us. Ethos Lending, 180 Montgomery Street. Suite 1000, San Francisco, CA 94104, or calling us toll-free at 855-384-6753.

Vermont Residents: We will not share information we collect about Vermont residents with companies outside of our family of companies, unless the law requires or allows. For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our family of companies, except with your consent, but we may share information about our transactions or experiences with you within our family of companies without your consent.

California Residents: We will not share information we collect about you with nonaffiliated third parties except as permitted by California law, such as to process your transactions or to maintain your account. We will limit sharing among our family of companies to the extent required by California law.

Telephone Communications: All telephone communications with us or our authorized agents may be monitored or recorded.