Privacy Policy

1. Who We Are & Scope of This Policy

This Privacy Policy is provided by Prime Lendings Loans LLC (“PrimeLendings,” “we,” “our,” or “us”), the operator of the online loan marketplace platform at primelendingsloans.com(the “Platform”).

This policy applies to all personal information collected through the Platform, our mobile applications, email and telephone interactions, and any other services we operate. It does not apply to the privacy practices of third-party lenders, advertisers, or other companies whose links may appear on our Platform — those companies have their own independent privacy policies.

2. Information We Collect

We collect the following categories of personal information when you use our Platform:

2.1 Information You Provide Directly

• Identity & Contact: Full legal name, date of birth, mailing address, email address, phone number
• Government Identifiers: Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN); last 4 digits initially, full number transmitted to matched lenders upon consent
• Financial Information: Employment status, employer name, gross annual income, monthly housing cost, existing debt obligations, requested loan amount, loan purpose, self-reported credit score range
• Banking Information: Bank account type, financial institution name (full account/routing numbers shared with lenders only after your explicit consent)
• Identity Documents: Government-issued ID (e.g., driver’s license, passport) for identity verification, where required

2.2 Information Collected Automatically

• Device & Technical Data: IP address, browser type and version, operating system, device type and identifiers, screen resolution, time zone
• Usage Data: Pages visited, links clicked, time spent on pages, referral URL, search terms, session duration, navigation path
• Location Data: General geographic location derived from IP address (city/state level, not precise GPS)
• Cookies & Tracking: Cookie identifiers, pixel tags, and web beacons — see Section 7 for full details

2.3 Information From Third Parties

• Credit Reporting Agencies: Credit report data (Equifax, Experian, TransUnion) obtained with your authorization for matching purposes
• Identity Verification Providers: Identity confirmation data from KYC/AML service providers (e.g., Socure, Plaid)
• Marketing Partners: Contact and demographic information from lead generation partners if you were referred to us through a third-party campaign
• Public Records: Publicly available information for fraud prevention and compliance purposes

3. How We Collect Information

We collect information through the following methods:

• Loan request forms — when you submit a loan inquiry on the Platform
• Account registration — when you create an account
• Telephone & chat — when you contact our customer service team
• Email communications — when you interact with our emails
• Automated tracking technologies — cookies, pixels, and server logs (see Section 7)
• Third-party sources — as described in Section 2.3

4. How We Use Your Information

We use the personal information we collect for the following purposes:

4.1 Core Service Purposes

• To match your loan request with suitable Lenders in our network based on your financial profile
• To transmit your information to matched Lenders for their independent credit review
• To verify your identity, prevent fraud, and comply with anti-money laundering (AML) and Know Your Customer (KYC) obligations
• To communicate with you about your loan inquiry, application status, and any offers received

4.2 Legal & Compliance Purposes

• To comply with applicable federal and state laws, including GLBA, FCRA, TILA, ECOA, CAN-SPAM, and TCPA
• To respond to lawful requests from regulators, law enforcement, and courts
• To detect, investigate, and prevent fraudulent or illegal activity
• To enforce our Terms of Service and protect our legal rights

4.3 Business Operations Purposes

• To analyze Platform usage and improve the user experience
• To personalize content, offers, and financial product recommendations
• To conduct remarketing campaigns (showing you relevant ads on other websites and platforms), subject to your consent preferences
• To send you marketing communications about financial products and services that may interest you (with opt-out available)
• To conduct internal research, analytics, and reporting

We process your personal information only when we have a lawful basis to do so — including your consent, performance of a contract, compliance with legal obligations, or our legitimate business interests.

5. Information Sharing & Disclosure

We share your personal information with the following categories of recipients:

5.1 Lender Network Partners

When you submit a loan request, we transmit your personal and financial information to one or more Lenders in our network. Each Lender receives only the information necessary to evaluate your loan request and make a credit decision. Lender use of your information is governed by their own privacy policies and applicable federal and state law.

5.2 Service Providers (Processors)

We use trusted third-party service providers who process data only on our behalf and under strict confidentiality and data protection agreements:

• Identity verification: Socure, Experian Identity, LexisNexis
• Bank account verification: Plaid, Yodlee, or similar providers
• Cloud infrastructure: AWS, Google Cloud
• Analytics: Google Analytics 4, Mixpanel
• Email delivery: SendGrid, Mailchimp
• Customer support: Intercom, Zendesk
• Fraud prevention: Sardine, SEON, or similar providers

5.3 Credit Reporting Agencies

With your authorization (as described in our Terms of Service, Section 6), we or our Lender partners obtain your credit information from Equifax, Experian, TransUnion, and/or specialty consumer reporting agencies.

5.4 Legal & Regulatory Disclosures

We may disclose your information to:

• Law enforcement agencies, courts, or regulators when required by law, subpoena, or court order
• The Consumer Financial Protection Bureau (CFPB) or other financial regulators in response to examinations or investigations
• Government agencies in connection with fraud investigations or national security matters

5.5 Business Transfers

If PrimeLendings is involved in a merger, acquisition, asset sale, restructuring, or bankruptcy proceeding, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on the Platform at least 30 days before any such transfer becomes effective, and provide you with the opportunity to delete your account.

5.6 What We Do NOT Do

6. Lead Generation & Marketing Partners

In some cases, you may arrive at PrimeLendings through a referral from a third-party marketing partner. In these cases, we may share your information back with that partner to facilitate the referral and attribution. Marketing partners are contractually required to comply with applicable law and our data protection standards.

You may receive telephone calls, emails, or text messages from Lenders and marketing partners who have received your information through our matching process. Each communication will provide opt-out instructions. To opt out of all marketing communications from PrimeLendings, email privacy@primelendingsloans.com.

7. Cookies, Tracking & Analytics

We use the following types of cookies and tracking technologies:

You can manage your cookie preferences at any time using our consent banner (accessible via the cookie icon in the footer) or by adjusting your browser settings. Note that disabling certain cookies may affect your ability to use some features of the Platform.

We use Google Analytics 4 to analyze Platform traffic. Google’s use of this data is governed by Google’s Privacy Policy. You can opt out of Google Analytics using the Google Analytics Opt-Out Browser Add-on.

8. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption in transit: TLS 1.3 for all data transmitted between your browser and our servers
• Encryption at rest: AES-256 encryption for all stored personal and financial data
• Access controls: Role-based access control (RBAC) limiting data access to authorized personnel only
• Audit logging: All access to personally identifiable information is logged and monitored
• Penetration testing: Regular third-party security assessments and vulnerability scans
• Incident response: A documented data breach response plan in compliance with applicable state notification laws

Despite these measures, no system is completely secure. In the event of a data breach that affects your information, we will notify you as required by applicable law (typically within 72 hours of discovery for breaches affecting EU residents; as required by state law for US residents).

You can report security vulnerabilities to security@primelendingsloans.com. See our security disclosure policy.

9. Data Retention

We retain your personal information for the following periods:

• Active account data: Retained for the duration of your account relationship plus 7 years after account closure (to comply with federal lending recordkeeping requirements)
• Loan application data: Retained for 25 months from the date of application (per ECOA/Regulation B requirements) or longer if required by applicable law
• Credit inquiry records: Retained for 25 months (per FCRA Section 623)
• Marketing data: Retained until you opt out, or for up to 3 years from your last interaction
• Analytics & log data: Retained for up to 26 months (Google Analytics default)
• Security logs: Retained for 12 months for fraud prevention and incident investigation

When retention periods expire, we securely delete or anonymize your personal information in accordance with applicable law and our internal data disposal procedures.

10. Your Privacy Rights

Subject to applicable law and verification of your identity, you have the following rights regarding your personal information:

To exercise any of these rights, submit a request to:

• Email: privacy@primelendingsloans.com
• Phone: +1-800-774-6356 (Mon–Fri, 9AM–6PM PST)

We will respond to verified requests within 45 days. We may ask you to provide identity verification (e.g., email confirmation, last 4 digits of SSN on file) before processing your request. We will not charge a fee for standard requests.

11. California Residents (CCPA / CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), in addition to the rights described in Section 10.

11.1 Categories of Personal Information Collected (CCPA Categories)

• Identifiers (name, SSN, email, IP address, account ID)
• Personal records (financial account information, income, debt)
• Protected classification characteristics (age, where relevant to eligibility)
• Internet activity (browsing history on our Platform)
• Geolocation data (IP-based, general)
• Inferences drawn from personal information (credit risk profile)

11.2 Right to Opt Out of “Sale” or “Sharing”

Under CCPA, sharing personal information with Lenders for cross-context behavioral advertising may constitute a “sale” or “sharing.” You may opt out by emailing privacy@primelendingsloans.com with subject line: “CCPA Opt-Out Request.” Note: opting out of data sharing will prevent us from matching you with Lenders, which is our core service.

11.3 Authorized Agent

A California resident may designate an authorized agent to submit CCPA requests on their behalf. The agent must provide written proof of authorization (notarized power of attorney or signed permission letter) along with the request.

11.4 Sensitive Personal Information

Under CPRA, SSN, financial account information, and precise geolocation data are classified as “sensitive personal information.” We use this data only as necessary to provide our core loan matching service. You have the right to limit our use of sensitive personal information to that purpose.

12. Vermont & Nevada Residents

12.1 Vermont

Vermont law (9 V.S.A. § 2484) imposes additional restrictions on the sharing of financial information. We do not share personal financial information about Vermont residents with non-affiliated third parties for independent marketing purposes without your affirmative opt-in consent.

12.2 Nevada

Nevada residents have the right to opt out of the sale of their personal information under Nevada Revised Statutes § 603A. To exercise this right, email privacy@primelendingsloans.com with subject line: “Nevada Opt-Out Request.”

13. Your FCRA Rights

Because we facilitate credit-related services, some of your information may be considered a “consumer report” under the Fair Credit Reporting Act (FCRA). Under the FCRA, you have the right to:

• Know if information in your credit file has been used against you in any credit decision (adverse action notice — you will receive this from the applicable Lender)
• Request your credit report for free once every 12 months from each major bureau at annualcreditreport.com
• Dispute inaccurate or incomplete information directly with Equifax, Experian, or TransUnion
• Have outdated negative information removed (generally 7 years, 10 years for bankruptcy)
• File a complaint with the CFPB at consumerfinance.gov/complaint or the FTC at ftc.gov

14. Children’s Privacy (COPPA)

The PrimeLendings Platform is intended solely for users who are 18 years of age or older (19 in Alabama and Nebraska). We do not knowingly collect personal information from children under the age of 13 in compliance with the Children’s Online Privacy Protection Act (COPPA).

If we learn that we have inadvertently collected information from a child under 13, we will promptly delete that information. If you believe we may have collected information from a child under 13, please contact us at privacy@primelendingsloans.com.

15. Links to Third-Party Sites

The Platform may contain links to third-party websites, including Lender websites, financial tools, and resource pages. These links are provided for your convenience. PrimeLendings does not control and is not responsible for the privacy practices of any third-party website. We encourage you to review the privacy policy of any site you visit through our Platform.

16. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, applicable law, or business operations. When we make material changes, we will:

• Send an email notification to your registered email address at least 30 days before the change takes effect
• Post a prominent notice on the Platform
• Update the “Effective” and “Last Reviewed” dates at the top of this policy

Your continued use of the Platform after the effective date constitutes acceptance of the updated policy. If you do not agree with the changes, you must stop using the Platform and may request deletion of your account and data by contacting us at the address below.

17. Contact Us & Privacy Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact our Privacy Officer through any of the following channels:

You may also file a complaint with your state Attorney General’s office or the Consumer Financial Protection Bureau at consumerfinance.gov/complaint.