1. Information We Collect.

We collect personally identifiable information that can identify you such as your name, address, telephone number, mobile number, e-mail address and Social Security Number (“Personally Identifiable Information” or “PII”). We also collect information such as demographic data and data about your online activity on our website that does not identify you (“Non-Personally Identifiable Information” or “Non-PII”). PII and Non-PII are known together as “Information.” We may also collect and store Information that you provide to us about other people (such as co-borrowers), including their name, address, telephone number, mobile devices, email address and Social Security Number.

2. How We Collect Information You Provide.

a. From You. We collect Information you provide to us in connection with inquiring about or obtaining our services. The Information we collect from you will vary depending on the product or service requested.

b. Other Sources. We may obtain Information about you from third parties such as: credit reports, information about your home and demographic information. None of the information obtained is shared with any matched service provider relating to your inquiry, rather the information may only be accessed by and disclosed to our employees with a legitimate business need to know in accordance with applicable laws and regulations. Information such as Social Security Number (SSN), date of birth (DOB), address and phone number may be verified by third parties to assist in the prevention of identity theft, consumer identification and verification. Fresh Funding takes your privacy seriously and performs these checks using best practices according to industry standards and does not alter or change the information you provide in your inquiry form.

c. Automatic Collection, Cookies and Other Internet Technologies. We use cookies, web beacons and other standard internet technologies to collect information from your computer and about your activities on our website. We automatically collect Non-PII from your browser when you visit our website. This information includes, but is not necessarily limited to, your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us and the referring website address. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. When you visit our website, we may assign your computer one or more cookies to facilitate access to our website, personalize your online experience and record information about your visit. Through the use of a cookie, we also may automatically collect information about your online activity on our website, such as the web pages you visit, the links or advertisements you click on and other actions you take while on our website. The cookies do not store any PII about you. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that some of the features and services of our website may not function properly. We also use cookies for purposes such as maintaining continuity during an online session; gathering data about the use of our site; monitoring online promotions; and anti-fraud and information security purposes.

We may allow third-parties, advertising companies and ad networks (“Advertisers”) to display advertisements on our website. Advertisers may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our website does not provide any PII to these Advertisers, but they may collect information about where you, or others who are using your computer, saw and/or clicked on the advertisements they delivered, and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personal information they collect directly from you. The collection and use of that personal information is subject to the particular Advertiser’s privacy policy. Some of these Advertisers may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. For a list of Advertisers we typically use, click the link above.

Other Technologies. We may use web beacons and other standard Internet technologies to track your use on our websites. Web beacons (also known as clear gifs, pixel tags, targeting and re-targeting pixels, third party pixels or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon.

3. How We Use Information.

a. In General. We may use Information to:

– Deliver the products and services you requested;

– Manage your customer relationship and provide you with customer support;

– Research and analyze your use of, or interest in, our products, services and content and the products, services and content offered by others;

– Communicate with you via e-mail, telephone, postal mail and/or mobile devices about products or services that may be of interest to you;

– Develop and display content and services tailored to your interests on our website and other websites;

– Develop and deliver targeted advertisements;

– Measure the overall effectiveness of our online advertising, content, programming and other activities;

– Verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;

– Manage our business; and

– Perform functions as described to you at the time of collection of the information.

b. Financial Information. Depending on the service requested, we may use financial information to: (i) match you with agents, brokers, financing providers, including merchant cash advance providers, or lenders; (ii) provide you with conditional offers from financing providers, including lenders’ or merchant cash advance providers’ conditional offers; (iii) as well as to verify your identity, protect against or identify possible fraudulent transactions; or (iv) otherwise as needed to manage our business.

c. Job Applicants. If your PII is submitted when applying for a position with us, the information will be used solely in connection with considering and acting upon your application. We may retain your PII for a period of time, but only for the purpose of considering your application for current or future available positions or as required by law.

4. With Whom do we Share Your Information

a. Fresh Funding Affiliates. We may share your Information with our affiliate businesses. All Fresh Funding affiliate businesses adhere to this Privacy Policy. Except as otherwise described in this policy, we will not disclose your PII to others outside of Fresh Funding.

b. Services Providers. We may share your personal information with our authorized service providers that perform certain services on our behalf including, but not limited to service providers that perform services on our behalf in connection with your request for a loan or other financing, and/or the servicing of your loan. These third parties include, without limitation, credit bureaus, title companies, flood or other insurance companies, appraisal companies, escrow companies, closing agents, marketing and customer services firms, credit card processors, or entities that provide business analysis or website support. These third parties may have access to PII needed to perform their functions.

5. Other Situations. We also may disclose your information at our sole discretion:

– In response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right available to us.

– When we believe disclosure is appropriate in connection with efforts to investigate, prevent or take other action regarding actual or suspected illegal activity or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees or others; or to enforce our websites’ terms and conditions or other agreements or policies.

– In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy.

– In connection with state and/or federal licensing requirements, if any, wherein reporting of information regarding your inquiry to the closing of your transaction. You authorize Fresh Funding to obtain any and all necessary information required from the “Lender” or “Provider” you choose to report back any and all required information relating to the disposition of your request. For example, if the transaction closed, if you withdrew the request, if you were not approved. In addition, under current reporting requirements the provider may provide to Fresh Funding, the loan or similar product that you selected, the terms of the same, fees, rate, etc., in order to comply with current laws and regulations.

6. Subscriptions/Unsubscribe.

When you “submit” information, register for a service, or create an account through Fresh Funding and its website or otherwise, Fresh Funding and/or its’ affiliate companies may send your information to associated third parties consistent with the Terms of Use. If at any time you do not wish to continue to receive communications from Fresh Funding and/or its affiliate companies, lenders or its associated third parties’ communications, you may modify your preferences by through your My Fresh Funding Credit Account.

7. Considerations.

For certain products and services available through Fresh Funding’s Website, we will not share your email address or phone number with the Provider or Lender with whom you are matched. Where this feature is available for a product or service, it will be noted on the web page for that product or service. Nevertheless these Providers and Lenders will still receive other PII about you and they may retain or use your PII whether or not you use their services and you should contact these Providers or Lenders directly concerning their privacy and information sharing practices, which may differ from ours.

8. Non-Personally Identifiable Information.

We may share Non-PII with third parties, in our discretion.

9. Third Party Services.

Our website contains links to other websites owned and operated by third parties. These third parties and their servers may be located in the United States or in other countries. We do not control, and are not responsible for, the privacy and security practices of these third parties. We recommend that you review the privacy and security policies of these third parties to determine how they handle Information they may collect about you.

Fresh Funding uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using our services you grant Fresh Funding and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

10. Updating and Accessing Your Information.

The appropriate method(s) for accessing your Information, if any, will depend on which sites or services you have used. Depending on the respective service, you may have the ability to view or edit some of your information online. If you have submitted a loan (or other) request with us, you can update your personal information by contacting our Customer Care Department at contact@gofreshfunding.com. Our address is 95 Morton St., New York, NY 10014.

11. Choices about Collection and Use of Your Information. 

a. You can choose not to provide us with certain information, but that may result in the inability to use certain features of our websites or receive certain products or services. Public forums are not intended for the disclosure of PII. To the extent you provide PII in any public forum, it is at your own risk.

b. Federal and state regulations may require that we store completed loan or other requests for various periods of time. In order to comply with these requirements, we may be unable to delete your information from our database until the expiration of the applicable period.

11. How we Protect your PII.

We take industry standard security measures (including physical, electronic and procedural measures) to help safeguard your PII from unauthorized access and disclosure. In addition to the restrictions outlined above, we require employees to comply with information security safeguards, we use encryption in the transmission of your PII between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your PII.

No system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications will always remain secure. Users should also take care with how they handle and disclose their PII. Please refer to the Federal Trade Commission’s website for information about how to protect yourself against identity theft.

13. Changes to this Privacy Policy.

We may update or modify this Privacy Policy to reflect changes to how we will collect, use and/or share Information. Our Privacy Policy will reflect the date it was last updated. If we make material changes to this Privacy Policy, we will notify you either by prominently posting a notice of such changes before implementing them or by sending you electronic notification of the changes. Please check this Privacy Policy each time you use our websites to ensure you are aware of any changes in our practices. Your continued use of our websites will signify your acceptance of the changes to the Privacy Policy.

14. Visiting our Websites From Outside the United States.

This Privacy Policy is intended to cover collection of information on our websites from residents of the United States. If you are visiting our websites from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

15. No Rights of Third Parties.

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any PII relating to users of our websites.

16.  How to Contact Us.

If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by e-mail or postal mail as follows: contact@gofreshfunding.com.