Effective date: January 1, 2020
1.1.1. Personal Information
We collect personal information from you to help you use our services. When we say “personal information,” we mean information that specifically identifies you. We collect this information in a number of ways. You are asked to provide personal information to us while submitting ISA applications / questionnaires, registering on our Website, verifying information you have provided, discussing your application or product with us, providing feedback to us, or transferring funds when using our services. Examples of personal information may include: Your Name, Your Address, Telephone Number, Email Address, School / University Information, Your Educational Program InformationYour Graduation YearYour Immigration StatusYour Credit Score / Credit Report, Your Loan Balance, Student Loan Account Numbers, Social Security Number, Employment Information, Salary Information
We may supplement the personal information you submit to us with information from third-party sources. For example, in an effort to protect the integrity of your account and if permitted under applicable law, we may supplement your registration information with address standardization data to verify the address you have entered is valid and to protect you against identity theft.
Finally, we never intend to collect personal information from children under 13 years of age. If we learn or are notified that we have collected this information from a child under the age of 13, we will promptly remove the data from our system.
1.2.1 Aggregate Information
Aggregate information, which is data we collect about your use of our or third-party websites or services, from which personal information has been removed. Aggregate data is used to help us understand consumer trends, needs, interests, and preferences so we can improve our products and services. Florian may also collect demographic information, which is anonymous, and may include: Age, Date of Birth, Income, Geographic Area.
1.2.2. Consumer Reports
As a company engaged in funding, Florian may receive data from consumer reporting agencies. We may receive reports from these agencies to assess your creditworthiness and to prevent fraud and identity theft. This may be done as part of our regular underwriting, fraud prevention and ISA servicing processes.
Information we collect in these reports may include, but is not limited to: Information about open and closed credit accounts, including the date opened, the date closed (if applicable), the latest reported monthly balance and monthly payment; Information about credit inquiries, Information about late payments and collection actions occurring on open and closed credit accounts, Information regarding public records of bankruptcy, judgements, tax liens, and other payment statuses; The credit score produced by the credit bureau providing the reportInformation about your transaction history, assets, and account balances.
Correcting information maintained by the credit bureausInformation related to your creditworthiness is maintained by the credit bureaus. If you find that there is an error or you want to dispute the information found in your credit report, please contact the credit reporting bureaus.
1.2.3. Website Use and Logging Data
Florian also collects information about your computer or mobile device to improve and evaluate your use of our website and our services. We may gather data such as your browser type, operating system, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device.
1.2.4. Information We Get from Others
Like other advertisers, we contract with third parties to place advertisements for our products and services on websites that are not our own. We place these ads where we think they are likely to be most relevant. These advertisements on third-party websites allow us to track responses to our ads. We and our affiliates use this information to track the performance of our advertising and marketing campaigns by using tools like cookies, web beacons and similar technologies. We use these tools to collect and store information about your visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site.
Florian uses “cookies” and similar tools to track your use of the Website when you use our services. We collect information such as the types of service used, and number of users we receive daily. Our web servers automatically log information about your computer, but we don’t use this information to identify you personally.
A web beacon embeds a small transparent gif image in a web page or email used to track when the page or email has been viewed. A similar device may be used where a product, service or functionality sends data to a server when a set of user-initiated events occur such as clicking a button on the website or in an email. This is similar to a cookie – it tracks your visit and the data is only read by the server that receives the data. However, it differs because it is not browser-based, may not function as an ID card and doesn’t store any data on your computer.
Most Internet browsers are set up to accept cookies automatically. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. For some web pages requiring an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages or their products and services.
1.2.6 Contacting us by Telephone
If you communicate with us by telephone, we may monitor or record the call. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of Florian’s products.
We use your personal information to provide you with information or services you request, to inform you about other information and services we think will be of interest to you, to facilitate your use and our operation of our website, and to improve our products and services.
Here are some examples of ways in which we may use your personal information: Creating and maintaining your login information on our site or your details in our systems, Contacting you regarding issues with your account, Allowing us or servicing partners we may use to process your payments, Invitations to Florian events, Providing Florian services, such as mentorship and networking, Sending you information about new product offerings.
Sharing your personal information
We don’t sell or rent your personal information to anyone. Florian only shares your personal information with unaffiliated third parties as permitted or required by law. We may share your personal information with our affiliate companies and as part of joint marketing campaigns with other financial companies. If Florian shares your personal information with vendors and service providers who perform functions on our behalf, we require the security and confidentiality of your information, as well as limiting their use of the information to reasonably and necessarily to carry out their work with us and comply with applicable laws and regulations.
Third parties we may share your information with may include, but are not limited to: Any servicing partners we may work with who provide your statements, process your payments, and service your account or ISA; Direct marketing service providers; Auditors and examiners; Law enforcement, regulators and other government bodies; Our regulators and other relevant government agencies.
Please note that, if you are a current borrower, you may not control certain information associated with your ISA, that you may have already agreed to provide to certain investors as described in your ISA agreement.
Finally, personal information may be disclosed or transferred as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Florian.
3.1. How we store your information
We use Google Drive infrastructure, Webflow infrastructure, Zapier infrastructure, and computers owned by Florian or employee/managers of Florian to store, process, and transfer all information collected. While we are not responsible for the privacy practices of third parties, we only partner with third parties that maintain commercial reasonable privacy and security practices.
3.2. What we do to protect your personal information
We maintain commercially reasonable physical, administrative and technological safeguards to preserve the integrity and security of all information collected. We use authentication and encryption code and protocols to encrypt your information in transit and storage. Despite these safeguards, no website, database, or system is completely secure, so we recommend that you take additional measures to protect yourself and your information, including by ensuring that you have enabled the latest security features on your devices, closing browsers after use, and installing up-to-date anti-virus software. In the event that any information under our control is compromised, and we become aware of such a compromise, we will take commercially reasonable steps to investigate. If appropriate, we will also take commercially reasonable steps to notify those individuals whose information may have been compromised in accordance with applicable laws and regulations.
If you would like to update information that you have provided us, you may contact us at firstname.lastname@example.org. Note that certain information is required to respond and process requests/orders/inquiries; requests to delete required information may result in our inability to respond and process requests/orders/inquiries.
Your Rights As a California Resident
Residents of the state of California have the right to request certain information from us with respect to the types of personal information we may share with third parties for their direct marketing purposes, as well as the identities of the third parties we have shared such information with during the immediately preceding calendar year.
To limit our sharing, please contact email@example.com.
We don’t respond to “do not track” signals or similar mechanisms – where a visitor to Florian’s website requests that we disable the collection of information about the visitor’s online activities, including navigation around our website and the service. We may also permit third parties to collect aggregate usage information on our website, and they may also not respond to “do not track” signals.
Under the California Consumer Privacy Act, you have a right to request: The specific personal information we have collected about you, The categories of sources from which we’ve gathered your information, The business purpose for which we have collected your information, The categories of third parties with whom we’ve shared your information.
We cannot discriminate against you in any way for exercising your rights under the California Consumer Privacy Act, including: Denying you goods or servicesCharging you different prices or ratesProviding you with a lesser quality of goods or servicesSuggesting any of the foregoing
Please note, we collect and share your personal information in order to service you and the products you hold with us. If you apply for an ISA or hold a product with us, we cannot support requests to delete your personal information due to business purpose. If you register with us, but do not apply for an ISA or hold a product, we are happy to honor your deletion request.
We also do not sell your information. Therefore, no request to opt-out of sale is necessary.
You may submit a request at firstname.lastname@example.org.
4.1. Changing and Updating Your Personal Information
We want to provide you with the resources you need to keep your information with us correct and up-to-date. If you need to update any information, please contact us at email@example.com.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org.