This Privacy Policy describes how Orchard Key ("we," "us," or "our") collects, uses, protects, and shares your personal information when you use our website and services.
1. Information We Collect
To connect you with prospective lenders and provide our services, we collect various categories of information from and about you. This collection is necessary to verify your identity, assess your eligibility for financial products, and prevent fraud.
A. Information You Provide Directly
- Identifiers: Name, physical address, email address, telephone number, Social Security Number (SSN), driver's license number, and date of birth.
- Financial Information: Bank account details, routing numbers, income details, employment status, employer name, and pay frequency.
- Other Personal Data: Information regarding your loan request (e.g., loan purpose, desired amount).
B. Information Collected Automatically
- Device and Usage Information: IP address, browser type, operating system, access times, pages viewed, and the referring link through which you accessed our website.
- Cookies and Tracking Technologies: We use cookies, web beacons, and similar tracking technologies to analyze trends, administer the site, track user movements, and gather demographic information.
2. How We Use Your Information
We use the information we collect for various business and commercial purposes, including:
- Service Delivery: To process your loan request and connect you with our network of third-party lenders, lending partners, and financial service providers.
- Communication: To send you confirmations, updates, security alerts, and support messages, as well as to contact you via telephone or email regarding your inquiry.
- Verification & Security: To verify your identity, protect against fraudulent or illegal activity, and comply with state and federal legal obligations (including the USA PATRIOT Act and GLBA).
- Marketing: To deliver targeted advertising, promotional offers, and communications regarding products or services that may be of interest to you.
3. How We Share Your Information
To facilitate your request for financial products, we must share your information with trusted third parties. By submitting your information on our site, you direct us to share your data with our lending network.
- Network Partners & Lenders: We share your personal and financial information with third-party lenders and lending partners who use this data to evaluate your eligibility for a loan and provide you with conditional offers.
- Service Providers: We may share data with vendors, consultants, and other service providers who need access to such information to carry out work on our behalf (e.g., fraud prevention, credit bureaus, hosting services).
- Legal and Regulatory Authorities: We may disclose your information if required by law, subpoena, or other legal processes, or to protect the rights, property, and safety of Orchard Key, our users, or the public.
- Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the transaction.
4. Gramm-Leach-Bliley Act (GLBA) Notice
As a provider of financial services, we adhere to the Title V of the Gramm-Leach-Bliley Act (GLBA). The GLBA strictly limits how we can share your non-public personal information (NPI). The sharing of your data with our lending partners to fulfill your loan request is permitted under GLBA exceptions for processing and servicing a transaction requested by the consumer.
5. Your Privacy Rights
Depending on your state of residence (such as California under the CCPA/CPRA, Virginia, Colorado, Connecticut, or Utah), you may have specific rights regarding your personal information.
A. Your Rights
- Right to Know: You may request disclosure of the specific pieces and categories of personal information we have collected about you, the sources, the business purpose, and the categories of third parties with whom we share it.
- Right to Delete: You may request the deletion of your personal information, subject to certain legal exceptions (e.g., retaining data to complete a transaction, detect security incidents, or comply with legal obligations).
- Right to Correct: You have the right to request the correction of inaccurate personal information we hold about you.
- Right to Opt-Out (Do Not Sell or Share): You have the right to direct us not to "sell" or "share" your personal information to third parties for targeted advertising or cross-context behavioral advertising.
- Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights.
6. Data Security
We implement robust, industry-standard physical, electronic, and procedural safeguards designed to protect your personal information from unauthorized access, loss, misuse, alteration, and destruction. This includes the use of 256-bit Secure Socket Layer (SSL) technology to encrypt data during transmission. However, no data transmission over the Internet or storage system can be guaranteed to be 100% secure.
7. Children's Privacy
Our website and services are not intended for individuals under the age of 18. We do not knowingly collect, sell, or share personal information from children under 18. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete such information from our records.
8. Third-Party Links
Our website may contain links to third-party websites (including our lending partners). This Privacy Policy does not apply to the practices of those third parties. We strongly encourage you to review the privacy policies of any third-party sites you visit, as their data collection and usage practices may differ materially from ours.
9. Changes to this Privacy Policy
We reserve the right to modify or update this Privacy Policy at any time to reflect changes in our legal or regulatory obligations, or changes in how we process data. We will notify you of any material changes by updating the "Effective Date" at the top of this page. Your continued use of our services following any updates constitutes your acceptance of the revised policy.
10. Contact Us
If you have any questions, concerns, or comments regarding this Privacy Policy, our data practices, or wish to exercise your privacy rights by mail, please contact our Compliance Department at:
Orchard Key Legal & Compliance
Email: privacy@orchardkey.com