Flex Privacy Notice
| Facts | What does Flex 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:
When you are no longer our customer, we continue to share your information as described in this notice. |
| 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 Flex chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does Flex 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, report to credit bureaus, or as otherwise permitted by law | 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 creditworthiness | No | We don’t share |
| For our affiliates to market to you | No | We don’t share |
| For nonaffiliates to market to you | No | We don’t share |
| Question? | Call 888-205-9407 or go to https://help.getflex.com/hc/en-us. |
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| Who we are | |
|---|---|
| Who is providing this notice? | This privacy notice is provided by Flexible Finance, Inc. and its affiliates and subsidiaries (collectively, “Flex”), 228 Park Ave S #75995, New York, NY 10003-1502. |
| What we do | ||
|---|---|---|
| How does Flex 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. We restrict our employees’ access to your information so that it is only accessible when they need it to do their work, and we require companies that work for us to protect your information. | |
| How does Flex collect my personal information? | We collect your personal information, for example, when you:
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:
State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law. | |
| Definitions | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial service providers. Our affiliates include others, such as:
|
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial service providers. Nonaffiliates that we share personal information include vendors that perform services or functions on our behalf, and include credit bureaus, banks, security vendors, and data management vendors. |
| Joint Marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial and property companies. |
| Other important information |
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California Residents: We will not share your information with nonaffiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. North Dakota Residents: We will not share your information with nonaffiliated third parties, except for our everyday business purposes, for marketing our products and services to you or for joint marketing, with your consent (as required), or as otherwise permitted by law. Vermont Residents: We will not share your information with nonaffiliated third parties, except for our everyday business purposes, for marketing our products and services to you, with your consent (as required), or as otherwise permitted by law. We will not disclose creditworthiness information about you within or outside the Flex group except as permitted by law, unless we otherwise obtain your consent. |
Your Privacy Rights
Rev. August 1, 2024
Introduction
Welcome to Lead Bank!
We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Lead Bank (“Lead Bank”) collects through our websites and services. It also explains why we collect your information and how we use it.
Privacy is important to Lead Bank. We will never rent or sell your information to anyone. If you have any questions or if you believe that Lead Bank has not adhered to this privacy policy, please send us a note at [email protected]. We reserve the right to amend this privacy policy at our discretion and at any time.
Table of Contents
- What does Lead Bank do with your personal information?
- How does Lead Bank use and share your personal information?
- Who we are
- What we do
- Definitions
- Other important information
- Your Privacy Choices and Rights
- Exercising Your Privacy Choices and Rights
- Non-Discrimination
- California Specific Notices
- Changes to Our U.S. State Mandated Privacy Notice at Collection
- Contact Information
U.S. Consumer Privacy Notice
| Facts | What does Lead Bank 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:
When you are no longer our customer, we continue to retain and share your information as described in this notice. |
| 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 Lead Bank chooses to share; and whether you can limit this sharing. |
How does Lead Bank use and share your personal information?
Reasons we can share your personal information | Does Lead Bank 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 | No | We don’t share |
| For our affiliates’ everyday business purposes— information about your creditworthiness | No | We don’t share |
| For affiliates to market to you | No | We don’t share |
| For nonaffiliates to market to you | No | We don’t share |
| Questions? |
|
|---|
| Who we are | |
|---|---|
| Who is providing this notice? | Lead Bank |
| What we do | ||
|---|---|---|
| How does Lead Bank 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. We authorize our employees to get your information only when they need it to do their work, and we require companies that work for us to protect your information. | |
| How does Lead Bank collect my personal information? | We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. See below for more information on your rights under state law. | |
| Why can’t I limit all sharing? | Federal law gives you the right to limit only:
You should be aware that Lead Bank does not collect or share information for these purposes. State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law. | |
| Definitions | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies.
|
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies.
|
| Joint Marketing | A formal agreement between non-affiliated financial companies that together market financial products or services to you.
|
| Other important information |
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Lead Bank is chartered under the laws of the State of Missouri and is subject to regulatory oversight by the FDIC. Any consumer wishing to file a complaint against Lead Bank should contact the FDIC though one of the following means: In person, by U.S. Mail: 1100 Walnut Street; Suite 2100; Kansas City, MO 64106, by Telephone (800) 209-7459, or Online at: https://ask.fdic.gov/FDICCustomerAssistanceForm Several U.S. states, including California, have enacted or will soon enact consumer privacy laws that grant their residents certain rights and require additional disclosures. If you are a resident of California or one of these states, you may have rights granted under the applicable state law. Learn more about your privacy rights. VT: Accounts with a Vermont mailing address are automatically treated as if they have limited the sharing as described above. For joint marketing, we will only disclose your name, contact information and information about your transactions. NV: We are providing you this notice pursuant to Nevada law. For more information, contact us at 866-845-9545, or email [email protected], with “Nevada Annual Notice” in the subject line. You may also contact the Nevada Attorney General’s office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: 1–702–486–3132; email [email protected]. CA: Accounts with a California mailing address are automatically treated as if they have limited the sharing with nonaffiliates as described above. If you are a California resident and would like to exercise additional choices over your data, please click here. |
U.S. State Mandated Privacy Notice at Collection
Several U.S. states, including California, have enacted or will soon enact consumer privacy laws that grant their residents certain rights and require additional disclosures (collectively, “State Privacy Laws”). If you are a resident of one of these states, this section applies to you and supplements the information contained in Lead Bank’s Privacy Policy.
As explained in our Privacy Policy, both federal and state laws require us to tell you how we collect, use, share, and protect your personal information. As a result, our data collection practices are generally governed by federal law, including the Gramm-Leach-Bliley Act (“GLBA”). However, certain information collected may be out of scope of federal laws and instead covered by State Privacy Laws. Under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) of 2020 and other California laws (collectively, the “CCPA”), this may also include information about employees and employee applicants as well as enterprise data (such as business-to-business).
This notice is intended to provide information required under State Privacy Laws, including the CCPA. This notice applies to the data collection and processing practices of Lead Bank (collectively, “Lead Bank” or “we”).
We do not and will not sell consumer personal information in the traditional and colloquial sense of the word sale. We do not use advertising technology on our website, which under some State Privacy Laws may be considered a “sale” or “share” of your information. In the preceding twelve (12) months, we have not “sold” or “shared” consumers’ personal information, as defined under State Privacy Laws. We do not engage in targeted advertising.
We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data.
Your Privacy Choices and Rights
Under the State Privacy Laws, you may have the following rights, including the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose and access your personal information, including receive the information in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, (4) request to limit the use and disclosure of sensitive personal information, and (5) not be discriminated against for exercising these rights (“Data Subject Requests”).
This section describes consumers’ rights under the State Privacy Laws and explains how you can exercise those rights with Lead Bank.
Right to Delete
Under certain State Privacy Laws, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your Data Subject Requests, we will delete your personal information from our records (and direct our service providers to delete your personal information from their records), unless an exception applies.
Certain personal information that we collect and use to provide you with financial services, and which Lead Bank is obligated by federal law and/or regulations to retain, cannot be deleted upon request.
We also may deny your Data Subject Requests to delete if retaining the information is necessary for us or our service providers to:
- Detect security incidents;
- Protect against malicious, deceptive, fraudulent, or illegal activity;
- Assist law enforcement in prosecuting those responsible for such activities; or
- Comply with a legal obligation.
Right to Correction
Under certain State Privacy Laws, you have the right to request that we correct any inaccuracies about your personal information. If we provide you with financial services, you can do so through our application.
Right to Know/Right to Access and Data Portability Rights
Under certain State Privacy Laws, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we confirm your Data Subject Request, we will disclose to you, upon specific request:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, disclosing, or sharing that personal information.
- The categories of third parties with whom we disclose that personal information.
- The categories of personal information we disclosed or sold to each category of third party.
- The specific pieces of personal information we collected about you.
Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to request that we limit the use and disclosure of sensitive personal information to the services we provide to you. Lead Bank’s current practice is to use the sensitive personal information it collects only for the purpose of providing you with the financial services we offer.
Exercising Your Privacy Choices and Rights
If you are a resident of a state that provides the above rights under State Privacy Laws, you may exercise the rights above by:
- By email: [email protected]
- By phone: (800) 209-7459
Each Data Subject Request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We will make every effort to verify your identity using your email address, but we may request additional information. If an authorized representative is making the request on your behalf, we require documentation showing that the representative has such authority.
- Describe your Data Subject Request with sufficient detail that allows us to properly evaluate and respond to it.
We cannot respond to your Data Subject Request or provide you with personal information if we are unable to verify your identity, or unable to verify the authority for the person making the request as your agent. We will use personal information provided in a verifiable consumer Data Subject Request to verify your identity or authority to make the Data Subject Request, and not for any other purpose.
You may only make a verifiable Data Subject Request for access or data portability twice within a 12-month period.
Response Timing and Format
We will acknowledge your Data Subject Request within 10 days. We attempt to respond to every Data Subject Request within 45 days. If we require more time, we will inform you of the reason and how much additional time we require (up to 90 days in total). Any disclosures we provide may only cover the 12-month period preceding the Data Subject Request’s receipt. If we are unable to satisfy your Data Subject Request, or a part of your Data Subject Request, we will explain why.
We do not charge a fee to process or respond to Data Subject Requests.
Authorized Agent
Only you, or a person you have designated in writing as your authorized agent, or who is registered with the applicable Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to applicable laws, (“Authorized Agent”), may make a verifiable consumer request to access, port, correct, or delete your personal information. You may also make a verifiable consumer request on behalf of your minor child.
If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
Non-Discrimination
We will not discriminate against you for exercising any of your rights. Unless permitted by the State Privacy Laws, we will not:
- Deny you services.
- Charge you different prices for our services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of service.
California Specific Notices
If you are a California resident, California Civil Code Section 1798.83 permits you to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personally identifiable information for direct marketing purposes. In the preceding calendar year, we have not disclosed personally identifiable information for direct marketing purposes.
We are only required to respond to a customer request for this list once during any calendar year. To make such a request, please see above under the section “Exercising Your Privacy Choices and Rights.” Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
During the last twelve (12) months, we have collected personal information in the following categories from consumers and disclosed personal information with the following categories of recipients. Although the list contains examples of information collected, we do not collect every specific piece of personal information for every consumer:
| Category of Personal Information | Examples of Personal Information Collected | Categories of Recipients |
|---|---|---|
| Identifiers | Name, address, email address, phone number, account identifiers, online identifiers, IP address, Social Security number, or other similar identifiers. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| California customer records or similar information in states with applicable privacy laws | Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, employment, employment history, bank account number, and other financial information. This category may overlap with other categories. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| Characteristics of protected classifications under state or federal law | Age, marital status, or gender. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| Commercial information | Purchasing or consuming histories or tendencies. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| Internet or other similar network activity | Information on a consumer’s interaction with our website, applications, or advertisements. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| Professional or employment-related information | Current occupation. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| Inferences | Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
| Sensitive Personal Information | Government-issued identifiers (such as Social Security number and driver’s license), financial account numbers in combination with login credentials, and facial images used for identification. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
We collect personal information for the business and commercial purposes and uses described in the Privacy Policy section titled “What does Lead Bank do with your personal information?”
In addition to the sources described above, we collect personal information from the following categories of sources:
Directly from our clients or their agents,
Indirectly from our clients or their agents, in the course of the services that we provide,
Directly and indirectly from activity on our website, and
Other third-party sources, including government sources.
From third parties that interact with us in connection with the services we perform.
The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, for legal defense purposes and to comply with legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services.
Changes to Our U.S. State Mandated Privacy Notice at Collection
We reserve the right to amend this privacy notice at our discretion and at any time. When we make material changes to this privacy notice, we will notify you by email, by notice on this site, or by other acceptable means.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under State Privacy Laws, please do not hesitate to contact us.
By email: [email protected]
By phone: 866-845-9545
