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Privacy Policy

Last Updated: July 16, 2020

Your privacy is critically important to us.

It is Challenger Finance Inc.'s (hereinafter, "us", "we", “our”, or “Challenger”) policy to respect your privacy regarding any information we may collect while operating our Website and Services. This Privacy Policy applies to (i) our Websites (“getchallenger.com”, “challengercash.com”, etc.)  (ii) the Challenger mobile and web applications and related services ((i) and (ii), collectively the “Services”). We respect your privacy and are committed to protecting personally identifiable information you may provide us. 

We have adopted this privacy policy ("Privacy Policy") to explain what information may be collected on our Website and Services, how we use this information, under what circumstances we may disclose the information to third parties, and what rights you have regarding this information. This Privacy Policy covers how we treat Personal Information when you access or use our Services. “Personal Information” means any information or data that identifies or relates to a specific individual including personal and financial data. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.

This Privacy Policy, together with the Terms of Service posted on our Website, set forth the general rules and policies governing your use of our Services. Depending on your activities when interacting with our Services, you may be required to agree to additional terms and conditions.

‍By using, interacting, or accessing our Website or Services, you acknowledge and accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use and share your information as described herein.

Financial Services

Challenger requires Personal Information to provide financial services made available in partnership with Lending Club Bank and others. If you have a financial product or service with Challenger, you have certain choices regarding the collection, use, sharing, and processing of your Personal Information by Challenger and our partners. Please refer to the Consumer Privacy Notice below as well as Challenger’s Terms of Service, Lending Club Bank’s Privacy Policy and Terms & Conditions.

Employers

Challenger works with employers and other third parties to deliver Services to consumers. Challenger does not share personal financial data with employers unless you explicitly opt-in to do so to access additional features. Challenger does share anonymous or aggregated data with employers to communicate high-level insights and users cannot limit this type of sharing.

Website Visitors

Like most website operators, Challenger collects non-personally identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Challenger's purpose in collecting non-personally identifying information is to better understand how Challenger Finance Inc.'s visitors use its website. From time to time, Challenger may release non-personally identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.

Personal Information We Collect

Certain visitors to our Services choose to interact with Challenger in ways that require Challenger to gather personally identifiable information (PII). The amount and type of information that Challenger gathers depends on the nature of the interaction. For example, we may use the information you provide when you complete an online application for a product or service in order to process and evaluate your application. If you request product information, we may use the information you provide to mail you information you request.

This information may include, but is not limited to:

  • Legal Name
  • Address
  • Social Security or Taxpayer Identification number in whole or in part
  • Phone numbers (including mobile)
  • Account number
  • Account number at a bank or other financial institution, type of bank account and the name of bank or other financial institution
  • Email address
  • Email referral information
  • Date of birth
  • Employment information
  • Income information
  • Internet Protocol (IP) Address and/or domain
  • Geo-location of your computer or mobile device
  • Mobile carrier and/or Internet Service Provider

We use personal information collected online for various functions, which may include:

  • processing your request for services, products or information
  • improving our customer service and products
  • servicing your account
  • facilitating your participation in online activities

We may also use the information you provide to contact you regarding your account. In addition, we may collect and use information for analytic purposes, market research or for marketing purposes, as allowed by law. When you are no longer our customer, we may continue to share your information as described in this notice. For more information on the Personal Information we collect and how we use it, please refer to “Categories of Sources of Personal Data”, “How Personal Information is Protected and Shared”, and the “Consumer Privacy Notice” below.

Regulated Data

Some of the data listed above, such as name, date of birth, taxpayer identification or social security number, and other personal/financial information, may be regulated by federal and state laws and regulations, such as the Gramm-Leach-Bliley Act (the “GLBA Act”). To the extent such data is subject to the GLBA Act, please refer to our consumer privacy notice below.

Geo-location Data 

Challenger may collect information from your device about your location while you are accessing or using our Services and while you are not accessing or using Services. We may use this information to enhance your security while using our Services or to provide targeted offers to you. You may opt out of the collection of location data at any time by changing your settings on your mobile device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

Biometric Data

Challenger’s mobile Application supports FaceID and TouchID. If you enabled such settings on your mobile device, you may be asked to scan your face or provide your fingerprints to verify your identity. Challenger and its service providers may collect such information (including the biometric data contained therein) in order to verify your identity and provide our Services.

Security

We seek to protect your Personal Information from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures. You can help protect your data by selecting, using, and protecting a unique password and/or other sign on mechanism and limiting access to your devices. The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is completely secure.

Ads appearing on our website may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by Challenger Finance Inc. and does not cover the use of cookies by any advertisers.

Data Retention

We will retain your account and Personal Information for as long as your account is active or as needed to provide you our Services. We will retain and use your information as necessary to comply with our legal obligations and regulation, to resolve disputes, and to enforce our agreements.

Links To External Sites

Our Services may contain links to external sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy and terms and conditions of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites, products or services.

Aggregated Statistics

Challenger may collect statistics about the behavior of visitors to its website and users of our Services. Challenger may display this information publicly or provide it to others.

Cookies

To enrich and perfect your online experience, Challenger Finance Inc. uses "cookies" and similar technologies and services provided by others to display personalized content, appropriate advertising and store your preferences on your computer.

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Challenger uses cookies to help identify and track visitors, their usage of our Websites, and their website access preferences. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Challenger Finance Inc.'s websites, with the drawback that certain features of Challenger's websites may not function properly without the aid of cookies.

By continuing to navigate our website without changing your cookie settings, you hereby acknowledge and agree to Challenger's use of cookies.

Business Transfers

If Challenger, or substantially all of its assets, were acquired, or in the unlikely event that Challenger Finance Inc. goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Challenger Finance Inc. may continue to use your personal information as set forth in this policy. We will make reasonable efforts to notify you if your information becomes subject to different privacy policies.

Privacy Policy Changes

Although most changes are likely to be minor, Challenger may change its Privacy Policy to reflect changes to our information practices, at Challenger's sole discretion. Challenger encourages visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

If we make any changes to how we use Personal Information, we will notify you prior to the change becoming effective.

Contact

If you are a registered user of Challenger’s Services and have supplied your Personal Information, Challenger may occasionally send you an email, SMS, or push notification to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with Challenger and our products. We primarily use our blog to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Challenger takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

US Persons

Challenger’s Services are intended for US-based businesses and consumers. If you are located outside of the United States, your information may be recorded and processed in the United States. We currently do not offer products or services to non-U.S. users.

Categories of Sources of Personal Data

We collect personal information from the following sources:

  1. You.
  1. By Providing Information Directly to Us. By signing up, opening an account, or accessing our Services in other ways, you are required to share personal information to help Challenger and our partners verify your identity and fulfill your requests. Some information is required depending on the Service you wish to access, while some may be voluntary. You may be required to share Personal Information to our customer support team through email, SMS, in-app chat, or phone to verify your identity.
  2. By Use of our Services. Challenger collects information automatically as you use our Services to help us deliver a better experience to our users. Please refer to the sections “Cookies”, “Personal Information We Collect”, and “How Personal Information is Protected and Shared” in this Privacy Policy for more information on how we use cookies and the geo-location of your device.
  1. Third Parties
  1. Employers. Challenger works with employers to distribute our Services to their current and prospective workforce including employees and contractors. Our employer partners may share nonpublic personal information with Challenger including name, email address, phone number, address, date of birth, and tax-identification information to offer you access to our Services.
  2. Bank Partner. When you use certain services offered by Challenger, we may collect personal and account information from our bank partner.
  3. Financial Vendors. By performing certain actions, such as connecting an existing bank account, we collect financial and personal information to help deliver our Services and complete your requests. We may collect usernames, passwords, account numbers, and other information. By using Challenger’s Services, you authorize Challenger, Plaid, and other third party financial ventors to act on your behalf to access and transmit nonpublic personal information in accordance with our partners’ privacy policies.
  4. Vendors. We may work with third party partners that help us generate leads, understand our user base, and complete your requests.
  5. Plaid Inc. (“Plaid”) Challenger uses Plaid to gather your data from financial other institutions. By using the Service, you grant Challenger 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. https://plaid.com/legal/#end-user-privacy-policy

How Personal Information is Protected and Shared

Challenger discloses Personal Information only to those of its employees, contractors, service providers, and affiliated organizations that (i) need to know that information in order to process it on Challenger's behalf or to provide Services, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors, service providers, and affiliated organizations may be located outside of your home country; by using Challenger’s Services, you consent to the transfer of such information to them. 

We do disclose your Personal Information to the categories of service providers, partners, and other parties listed in this section. Depending on state law that may be applicable to you, some of these disclosures may constitute a “sale” of your nonpublic personal data.

  1. Service Providers. Service providers are third-parties that help us provide our Services or perform business functions on our behalf. They include payments processors and networks, financial institutions such as Lending Club Bank, financial infrastructure services, identity verification services, card fulfillment vendors, credit reporting and scoring agencies, authentication vendors, customer service and support software and providers, risk and fraud monitoring tools, web hosting partners, analytics providers, mobile check deposit software, and employer partners on distribution and fulfillment of Services.
  2. Marketing Partners. We work with various third parties to market our Services including employers, marketing partners, and ad networks.
  3. Parties you Authorize or Authenticate. In order to process your requests, we may ask you to authenticate a third party to access and share information on your behalf, including identity services, financial institutions through Plaid, and employers.
  4. As Required By Law. We may preserve and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours', ours' or others' rights, property, or safety.

Our Commercial or Business Purposes for Collecting Personal Data

  1. Service Providers described above help us deliver complete Services to you.
  2. Marketing Partners help us market and sell the Challenger Services.
  3. Parties you Authorize or Authenticate help us process your requests and provide important information to keep our services safe, compliant, and reduce fraud.
  4. Our Legal Requirements help us fulfill our legal obligations under applicable law, regulation, court order or other legal process. Challenger and our financial partners may be required to collect and maintain information records relating to anti-money laundering, know your customer, Bank Secrecy Act, GLBA and other legal and regulatory oversight. 
  5. Correspondence With You is important for our business. To process and respond to your requests, we collect and store Personal Information.

Challenger’s Contact Information

getchallenger.com

support@getchallenger.com

Challenger Finance Inc.

Denver, Colorado

Consumer Privacy Notice