Effective Date:
For information about how we collect, share, and protect information in connection with our consumer financial products and services, please see our U.S. Consumer Privacy Notice (GLBA) below.
At Live Oak Financial Funding LLC ("LOFF"), we take privacy and security seriously. LOFF provides an internet service/product branded "CrowdCash" ("CrowdCash"). In this Privacy Policy, "Live Oak Financial Funding LLC," "LOFF," "we," "our," and "us" refer to Live Oak Financial Funding LLC (and, where applicable, our affiliates). "CrowdCash" refers to the LOFF service and is not a separate legal entity or DBA.
We collect information you provide when you use, or apply to use, our Services or otherwise engage or communicate with us as described below.
Identity Data, such as your name, date of birth, marital status, social security number, photos of your face and government-issued identification documents, and other data on government-issued identification documents;
Contact Data, such as your email address, mailing address, and telephone number;
Financial Data, such as your bank account and payment card details, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores;
Profile Data, such as your username and password, your interests, preferences, feedback, and survey responses;
Additional Data You Provide, such as via focus groups, survey responses, contests/sweepstakes, customer support, data you provide in memos when using our Pay & Request Service, or other means.
As is true of many digital platforms, we also collect certain information about you automatically when you use our Services, as described below.
Usage Information. We collect information about your activity on our Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.
Transactional Information. When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.
Information Collected Through Tracking Technologies. We and our service providers also use technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information and other similar information. For information about how to disable cookies, please see the Your Controls section below.
We also obtain information about you from other sources as described below.
Vendors and Business Partners. We collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.
Plaid Services. We use Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Services, you grant CrowdCash and Plaid the right, power, and authority to access and transmit your personal and financial information from the relevant financial institution(s). The information gathered by Plaid may include account balances, transaction history, and other financial data. This data collection is governed byPlaid's Privacy Policy.
Connected Services. If you link, connect, or log in to your CrowdCash Account with a third-party service (e.g., Google, Apple, Plaid), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Publicly Available Data. This may include include contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
Advertising Data. We collect information in connection with our ad campaigns that surface on other platforms, such as the ads you click on and other interactions with our ads.
Credit Information. We may receive credit-related information about you from third parties, such as credit bureaus. For example, if you apply for a loan with CrowdCash, we may collect your credit history and credit scores from credit bureaus and other partners.
We use the information we collect for purposes described below or as otherwise described to you at the point of collection:
Maintain and provide the Services, including to process account applications, authenticate your identity and verify your financial information through Plaid, repair our Services, support, process and record transactional information, and handle billing and account management;
Send you transactional or relationship information, including confirmations, invoices, technical notices, customer support responses, software updates, security alerts, support and administrative messages, and information about your transactions;
Communicate with you about offers and other things we think you will be interested in, such as newsletters, product announcements, partner offerings, surveys, contests or sweepstakes, events or announcements;
Monitor and improve our Services, including analyzing usage, research and development;
Help protect the safety and security of our Services, business, and users, such as to investigate and help prevent fraud or other unlawful activity;
Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
Comply with applicable laws and legal obligations, such as compliance obligations associated with being a regulated broker-dealer and compliance obligations associated with being a money services business.
We maintain a written information security program overseen by a qualified individual and use administrative, technical, and physical safeguards—such as access controls, encryption where appropriate, multi-factor authentication, employee training, vendor oversight, and an incident response plan—to protect personal information, consistent with the FTC Safeguards Rule.
We are committed to maintaining your trust, and we want you to understand when and with whom we disclose information about you. We disclose information about you in the instances described below.
Authorized vendors. We disclose information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing services, tax and accounting services, contest fulfillment, web hosting, and analytics services. For example, we use an identification verification service provider, Plaid, to help determine whether a selfie you take matches the photo in your government-issued identification. The information collected from your photo by our vendors for these purposes may include biometric data.
When we or our vendors collect biometric identifiers (for example, face geometry) for identity verification, we obtain your informed consent, do not sell biometric data, limit disclosures as permitted by law, use reasonable security to protect it, and destroy biometric data within a reasonable period and no later than one year after the purpose for collection ends, consistent with Texas law.
For example, we use Plaid, an identification and financial data verification service provider, to retrieve and verify your financial information, such as account balances, transaction history, and other necessary financial data. The information collected by Plaid from your financial institution is governed by Plaid's Privacy Policy.
Banking and credit card partners. Where applicable to the product you use, we also disclose information about you to other entities, such as banking partners, credit card issuers that provide our credit cards, and credit card rewards partners (e.g., travel or shopping rewards partners) through which you can redeem rewards.
Substantial corporate transactions. We may disclose information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.
Legal purposes. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of CrowdCash, our users, or the public.
With your consent. We disclose information about you for any other purposes disclosed to you with your consent.
We may also disclose information with others in an aggregated or otherwise de-identified form that does not reasonably identify you.
We use analytics and measurement tools (for example, Google Analytics) to understand usage of our Services and improve performance. These partners collect information about your use of our Services over time through cookies and similar technologies, such as IP address, browser and device characteristics, pages viewed, time spent, and links clicked.
We do not sell personal data and we do not engage in targeted advertising as defined by Texas law. If our practices change, we will update this Policy and provide any required opt-out mechanisms before applying those changes.
You can control cookies through your browser settings. If you disable cookies, some features may not function properly.
Some browsers allow you to send global privacy signals. Because we do not sell personal data or engage in targeted advertising, these signals do not change how we process your information. If our practices change in the future, we will honor applicable browser- or device-based opt-out signals as required by Texas law.
How to control your communications preferences. You can stop receiving promotional emails from us by clicking the “unsubscribe” link in those emails. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages.
Cookie controls. Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.
For personal data that is not subject to the Gramm-Leach-Bliley Act (GLBA), Texas residents have the right to request: (i) access to and a portable copy of personal data; (ii) correction of inaccuracies; and (iii) deletion of personal data, subject to legal exceptions.
Opt-out rights: We do not sell personal data, we do not engage in targeted advertising as defined by Texas law, and we do not use non-GLBA personal data for profiling in furtherance of decisions that produce legal or similarly significant effects. If these practices change, we will provide a clear and conspicuous opt-out before applying those changes.
Submitting requests: You may submit a request by emailing [email protected]. We will respond within 45 days(we may extend once for an additional 45 days and will notify you of the extension and reason). If we deny your request, you may appeal by emailing[email protected] with “Appeal” in the subject line. If you remain unsatisfied, you may contact the Texas Attorney General.
Scope clarification: TDPSA does not apply to GLBA personal information or to our GLBA-regulated activities. Our credit underwriting and account servicing constitute GLBA activities and are outside TDPSA's scope.
We do not knowingly collect or solicit any information from anyone under the age of 13 through our Services. If we become aware that a child under 13 has provided us with personal information for any reason other than being added as an authorized user by their parent or guardian, we will take reasonable steps to delete that information. If you reasonably believe that we might have information from a child under 13, please contact us at [email protected].
Except for when you use our Services outside the United States (e.g., while traveling), our Services are currently designed for use only in the United States. If you are using our Services from another jurisdiction, or if third-party service providers like Plaid transfer data, your information may be processed in the United States or other countries that may not provide levels of data protection that are equivalent to those of your home jurisdiction.
This Privacy Policy will evolve with time, and when we update it, we will revise the “Effective Date” above and post the new Policy. In some cases, we provide additional notice (such as adding a statement to our website or sending you a notification), including when we add new third-party services like Plaid. To stay informed of our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.
If you have any questions about this Privacy Policy, please contact us at [email protected].
If we determine that a breach of system security involving Texans' sensitive personal information has occurred, we will notify affected individuals as quickly as possible and within 60 days, and we will notify the Texas Attorney General if the breach affects 250 or more Texas residents, consistent with Texas law.
Effective Date:
This notice explains how Live Oak Financial Funding LLC ("LOFF"), the legal entity that provides the internet service/product branded "CrowdCash" ("CrowdCash"), collects, shares, and protects your personal information when you obtain or apply for a financial product or service for personal, family, or household purposes. For purposes of this notice: "LOFF" means Live Oak Financial Funding LLC; "CrowdCash" refers to the online service provided by LOFF and is not a separate legal entity or DBA. Federal law gives you the right to limit some—but not all—sharing. Please read carefully.
The types of personal information we collect and share can include: Social Security number and income; account balances and payment history; transaction history; credit history and credit scores; contact details and identity information; and device/usage data related to your account access.
All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; whether CrowdCash shares; and whether you can limit this sharing.
| Reasons we can share your personal information | Do we share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes—such as to process your transactions, maintain your account, respond to court orders and legal investigations, detect and prevent fraud, or report to credit bureaus | Yes | No |
| For our marketing purposes—to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | No | We don't share |
| For our affiliates' everyday business purposes—information about your transactions and experiences | No | We don't share |
| For our affiliates' everyday business purposes—information about your creditworthiness | No | We don't share |
| For nonaffiliates to market to you | No | We don't share |
We do not share personal information in ways that you can limit under federal law (for example, we do not share with nonaffiliates for their marketing). If our practices change, we will update this notice and provide an opt-out as required. Some information is required by law or needed to open and service your account; if you do not provide it, we cannot open an account. For questions, contact us at [email protected].
Email us at [email protected].
Who is providing this notice? Live Oak Financial Funding LLC ("LOFF"), the provider/operator of the service branded "CrowdCash." "CrowdCash" is a service name of LOFF and is not a separate legal entity or DBA.
How does CrowdCash protect my personal information? We maintain a written information security program overseen by a qualified individual and use administrative, technical, and physical safeguards (including access controls, encryption where appropriate, and vendor oversight) to protect your information, consistent with the FTC Safeguards Rule.
How does CrowdCash collect my personal information? For example, when you open an account, apply for or receive a loan, make payments, give us your contact information, connect a bank account, or authorize us to obtain your credit report or credit score. We also collect information from others, such as credit bureaus, identity verification providers, and other companies.
Is any of my information optional? Certain information is required by law or necessary to open and service your account; without it, we are unable to provide our financial products or services.
Why can't I limit all sharing? Federal law gives you the right to limit only (i) sharing for affiliates' everyday business purposes—information about your creditworthiness; (ii) affiliates from using your information to market to you; and (iii) sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights.
Affiliates — Companies related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates — Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Joint marketing — A formal agreement between nonaffiliated financial companies that together market financial products or services to you.