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Your privacy and the protection of your sensitive personal information are of utmost importance to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information.

This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.

In general, and as described in detail below, we collect several types of information from you:

• Personal data required to verify your identity
• Personal, academic and financial data necessary to assess your eligibility to borrow or lend money through Fynanz
• Optional personal information you may wish to share in the furtherance of your goals in using our site
• Information about your visits to and use of this web site to help us maintain the appropriate features, functionality and user experience

We collect personal and financial information from you while you use the site, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the site, whenever you choose to provide it.

Certain personal information must be supplied during the member, lender and borrower registration processes, as indicated below, in order to (a) enable registered users to login to the site, (b) determine borrowers' eligibility for loans through our proprietary credit scoring process, (c) verify borrowers' and lenders' identities, (d) establish borrowers' and lenders' ability to make and request loans by verifying that they are at least 18 years of age, and (e) guard against potential fraud. This basic personal information includes:

• Your name (member registration)
• Your email address (member registration)
• Your date of birth (borrower/lender registration)
• Your home address and telephone number (borrower/lender registration)
• Your Social Security number (borrower/lender registration)

When you register as a borrower, we will use this information to pull a credit report from a credit bureau to determine your creditworthiness as well as to help lenders assess your loan request in the context of your overall academic and financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during online people-to-people lending, such as:

• Generating public borrower profiles on the site
• Assigning you a borrower credit grade based on your academic characteristics and financial information
• Enabling our financial services partners to implement automatic payments and fund transfers
• Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
• Implementing collection activities as needed
• Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.

When you register as a lender, we will request some required and optional data in order to facilitate such activities as:

• Generating a public lender profile on the site
• Enabling our financial services partners to implement fund transfers and the receipt of borrower payments
• Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
• Maintaining regular communications with you as may be necessary to execute transactions you request, such as submitting loan portfolios and transferring funds, etc.

In addition, we gather names and email addresses of people who contact us through our web site with questions about our company or lending/borrowing operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people, such as in the case of job applicants who submit resumes, etc.

Finally, we collect information about your computer and your visits to our web site, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We use this aggregated information in the administration of our web site to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We use non-identifying and aggregated information to help optimize our web site based on the needs of our users. Except as specifically described below in the section entitled "How and When Your Information Is Shared With Other Parties," no personal or personally identifiable information about any individual user will ever be distributed to third party organizations for any purpose, including marketing.

If you choose to use our referral service to share something within our website http://www.fynanz.com, such as a listing or a member profile, with a friend, we will ask you for your friend's name and email address to process your request to share the information. We will automatically send your friend a one-time email inviting him or her to visit the site. Fynanz stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your friend may contact us at compliance@fynanz.com to request that we remove this information from our database.

Users may choose to refer friends to the site or directly to their loan listings via email. If this referral occurs independently of our site or a partner's site, we do not track the referral other than as a unique page view. Since we do not collect any information from the referring party or the recipient of the external email referencing our site, we do not capture or store any information about either party. If friends refer each other to our site or to their loan listings via a partner's site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities which contributed to the referral.

Users may choose to electronically forward a link or page to a friend by clicking the “email” or “share” link. The users must provide their own names and email addresses as well as those of the intended recipients in order for the email to be sent. This information is used only in the case of transmission errors as well as to let the recipient know who sent the email so that it is not mistaken for spam. The information is not used for any other purpose and we do not store the names or email addresses of your friends. These are one-time-only emails initiated by friends of the recipients, and the recipients are not added to any mailing list or contacted by Fynanz apart from this specific email.

Our users can also refer friends to the site by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular loan request, and the sender will not know whether you are a borrower, lender or simply a member. The information collected in this process is only kept long enough to monitor whether the referral program is achieving the desired results in terms of attracting new visitors to the site and converting them into members. Again, these are one-time-only messages initiated by friends of the recipients, and the recipients will not be added to any mailing list or contacted by Fynanz apart from this specific email. In the case where a bonus is offered to a member in return for the referral, Fynanz will only retain the information about the referred parties to properly credit the account of the member initiating the referral. The information is not used for any other purpose.

When you register on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and confirmation of successful submissions of loan requests and portfolios. You will also receive progress updates on the status of loan requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any emails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and site operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback emails, you may opt out by writing to customer.care@fynanz.com.

Information is shared with other parties in the following ways:

• Required and optional information about borrowers and lenders is displayed on public profiles that members can update at any time; certain information is optional and you can choose not to supply it and/or can remove the optional information at any time
• Personal but not personally identifiable information about borrowers is contained in loan listings that can be viewed by all users
• Financial and credit information about borrowers is displayed only to qualified lenders
• Information is shared directly between users and other or potential users through referrals initiated by borrowers, either manually or through a "share my loan with a friend" feature which makes the loan data available through other channels

For privacy purposes, borrowers and lenders remain anonymous on the site and are identified only by their chosen screen names. Borrowers will be able to see the screen names of their lenders and vice versa. However, borrowers have public profiles and loan listings on the site that display their information to any users who view these pages. The loan listing pages include borrowers' FACS grades, school information and other financial information that is shown to qualified lenders so that they can effectively evaluate loan requests. Loan listings also contain certain personal information and, in some cases, answers to questions posed by lenders that are incorporated into loan listings. Lenders also have public profiles on the site containing personal information that they have opted to include. Finally, members creating blog/forum posts are also identified by their screen names.

To protect borrowers' and lenders' privacy, however, the blog/forum posts do not track back to loan listings or loan funding decisions, respectively. Fynanz is not responsible for any personal information that borrowers or lenders may choose to reveal about themselves in their screen names, loan requests, blogs, or public profiles or blog/forum posts. Given the community nature of any people-to-people transaction site, however, it may be in the best interests of borrowers and lenders to share some level of personal information in order to achieve a satisfactory outcome (i.e., it may be necessary for you to share a certain amount of personal information in order for your loan to receive full funding).

If you choose to disclose your affiliations with networking sites, online communities and professional or educational organizations, we will ask you to provide us with your affiliation credentials (such as an alumni email address for your college) so that such an affiliation can be verified. In other cases, this verification may involve our contacting a list administrator or other information owner who is in the position to verify your association with the organization you specify. Supplying this type of affiliation information benefits you as both a borrower and a lender in that it helps our automatic matching system pair you with suitable transaction partners and thereby helps bring about successful borrowing and lending endeavors.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site.

Fynanz works with a number of trusted partners that perform vital functions as part of our operations, including credit bureaus, collection agencies, electronic payment service providers, and customer support call centers. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.

When you create a loan listing, you will be posting personal information on the site that will be visible to all users. This information includes details about your loan request, as well as your screen name, geographic location, Fynanz credit grade and a description of the loan request.

Qualified Fynanz lenders will also see certain credit data collected from or calculated based on your credit bureau file. It is necessary to allow prospective lenders to see this information as they evaluate your loan request. The information displayed to lenders includes a credit profile section and a credit history section.

The academic information section includes your:

• Class status / Year in school
• Major or course of study
• Enrollment status
• Expected graduation date
• Debt-to-income ratio (DTI)

The financial infomation section includes the following information:

• Expected loan repayment start date
• Employment status
• Occupation, job title and tenure in your current position, if provided by you
• Income range
• Existing monthly debt payments
• Relationship to borrower (for cosigners)
• Home ownership status, if available

If you successfully receive a loan through Fynanz, we will also display status information about your loan to your lenders. Your loan tracks back to you by your screen name, so it is important that you choose a screen name that will protect your anonymity. You should not choose a screen name that resembles your actual name or that of any other person. Further, you should not include your name or personally identifiable information in your loan request. Your payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to your lenders.

Fynanz will send you email notifications from time to time, and these are required elements of your transactions on our web site, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or lender, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally you may not opt out of these service related emails.

You can access all of your personal and personally identifiable information that we collect online and maintain by visiting your profile in the My Account section of our site. This section of the site is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone number, bank account information and affiliations data at any time on the website, and if you need to change any other information in your profile you can contact us at customer.care@fynanz.com. To protect your privacy and security, please contact us at customer.care@fynanz.com to make changes to your sensitive account information.
As noted above, much of the optional personal information we collect will help increase the likelihood that you, as a borrower or a lender, will have a successful experience on the site. We accomplish this objective with an automatic matching system that uses a complex algorithm to identify connections between borrowers and lenders based on the optional personal information provided on our site. This optional information includes:

• Details about your loan request that you may decide to share in an extended loan description
• Schools attended
• Past and present employers
• Affiliations with clubs, associations, social networks and online communities

This information, along with all of your other personal data, is maintained in your member profile.

We use cookies on our web site, including session ID cookies and persistent cookies. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser and load the pages according to a user's preferences for that particular site, including the personalization of content. Cookies are not tied to personally identifiable information.

More importantly, using cookies also helps us protect the security of your account. Session ID cookies follow your activities on our site so that we can ensure that no one is making changes to your profile, applying for loans or making loans on your behalf. This information is encrypted and no personal data about you is stored on our servers.

We may send a cookie that can be stored by your browser on your computer's hard drive. We may use the information we obtain from the cookie in the administration of our web site, to improve its usability and for evaluating our marketing effectiveness as described above. We may also use that information to recognize your computer when you visit our web site (if you select the "remember me on this computer" option, and to personalize our web site for you. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector). Blocking cookies, however, can also have a negative impact on the usability of many web sites.

Cookies may have long-term expiration dates and thus can stay in your hard drive for months at a time. While you can remove them as instructed by the help content in your chosen browser, disabling cookies will prevent you from using our site. As with many transactional web sites, cookies must be enabled in order to use our site.

We use a third-party tracking service that uses cookies to track non-personally identifiable information about visitors to our site in the aggregate (such as page views and referral page information to track the success of our marketing efforts to bring people to our site as well as overall site performance). We use a web beacon on one page of the basic member registration form to track the number of new users who join our site in response to certain advertising efforts. No personal or sensitive information is transmitted to advertising partners (but one such partner uses incoming IP addresses to avoid double-counting the number of new members who joined as a result of the advertising campaign).

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

We may offer links to partners' sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy. Further, Fynanz has no control over the content of these sites. Please consult the privacy policies on these sites before you provide them with any of your personal information.

Fynanz has instituted industry-leading procedures to safeguard your personal and personally identifiable information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that you when you connect to our web site you are actually on our site. SSL also ensures that all data entered into the web site is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For further encryption protection, we use a 128-bit secure browser for logins and transactions. Our site also makes use of "CAPTCHA" technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering in the text shown in the image. Finally, we subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.

We store all sensitive financial data such as Social Security numbers and bank accounts in a highly secure environment hosted by our partner, Engine Yard, a SAS 70 Type 1 compliant provider. We also maintain physical, electronic, and procedural safeguards that meet or exceed industry standards for financial institutions.

We also employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Further, we employ strict access standards ensuring that only the senior-most employees or partner representatives have access to your account numbers and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account.

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an email purporting to come from Fynanz that asks for your password, you should immediately report this development.

Fynanz utilizes state of the art authentication technology to verify identities. However, if a lender suspects that one of their loans belongs to a person who has committed ID theft, please contact us at security@fynanz.com. Fynanz will work with law enforcement authorities to track down and prosecute anyone who has committed identity theft. Fynanz will reimburse the lender for the unpaid principal balance of loans where the borrower has committed identity theft.

In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member's name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this site and/or changing your password on that email account frequently.

If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our site, you should log out completely, then close the browser window and clear the browser's cache files.

You should also be aware of fraudulent attempts to gain access to your account information known as "phishing." Phishing is a tactic used by scammers in which unsuspecting people are brought to a web site by a genuine-looking email purporting to be from a legitimate company. The phony or "spoof" email takes the person to a web site that looks legitimate but in fact is not. Either in the email itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money. Fynanz will never ask you for your login information in the context of any email. In general, you can protect yourself against phishing by never providing personal or login information via an email—instead, go the web site directly. You might also make it a habit to check the URL of a web site to be sure that it begins with the correct domain. In the case of Fynanz, you should always ensure the URL begins with http://www.fynanz.com, https://www.fynanz.com, or http://blog.fynanz.com

As technologies, laws and user needs change, our site and its features will also change. This policy may be updated from time to time as such needs dictate, and we will always communicate these changes to you by posting them on this web site and/or by notifying you via email in the event of any substantive or material changes.

You may contact us at:
Fynanz, Inc.
Attn: Compliance Department
224 West 30th Street, Suite 604
New York, NY  10001

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