Last Modified: September 13, 2021
Please note, we do not provide financial advice or investment recommendations; any information or representations made on our Site do not constitute and should not be construed as financial advice or recommendations. Neither Steward Lending LLC nor Steward Technologies LLC is a registered broker-dealer or a financial adviser.
Personal data, sometimes called “personally identifiable information” in the United States (“Personal Data”) is information that can be used to identify you as an individual, such as a name, an identification number, location data, or an online identifier. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity which can assist someone in eventually identifying who you are. Steward Technologies collects Personal Data from you when you use our Site in various ways such as signing up for an account, completing forms or applications on our Site, sending us an email through our Site, or engaging in a transaction through our Site. Steward Technologies may also collect information which may be contained on server logs, such as your Internet protocol (“IP”) address. The types of Personal Data that we collect through our Site may include, but are not limited to, your: (1) personal name; (2) email address; (3) physical address; (4) date of birth; (5) Social Security Number; (6) information from an identity document such as a passport or driver’s license; (7) business name; (8) business address; (9) articles of incorporation;; (10) bank account information; and (11) any other Personal Data you may voluntarily provide. Bank account information is not stored on this Site. Bank account information is shared directly and securely with a third-party bank verification platform, Plaid Technologies, Inc. ("Plaid"), and a third-party payment facilitator, Dwolla, Inc. ("Dwolla"). Further, Steward Technologies contractually requires that all third-party vendors privy to personal information adhere to and implement a data protection program that is consistent with regulations enacted in all States in which Steward conducts business. Additional data that we collect and store in our log files may include, for example, frequency of visits to our Site, time spent viewing pages on our Site, date(s) and time(s) of visits to our Site, clickstream data, cookies existing on your computer, operating system, browser type, device type used to visit our Site (desktop or mobile), and sites visited before arriving at our Site. We collect this information through automated tracking technologies, some of which are discussed below, and we may combine this automatically collected information with other information we collect about you. We do this to improve services we offer you and to improve our Site. We obtain Personal Data from third party sources. Types and uses of such third party sources may include: (1) services used to verify identity and backgrounds; (2) services used for anti-money laundering screening; or (3) payment facilitation services.
We collect the above information about you when you voluntarily provide it through our Site. For example, we collect information you provide to us when you complete forms on our Site such as when you create your user account, submit a loan application, or complete a transaction. We also collect other information or content from you when you upload it voluntarily to our Site. We, our Affiliated Companies, and our service providers may also collect information about you using various automated technologies on our Site such as those described below:
Transfers Relating to Our Own Corporate Transactions. We may have to transfer your information to a buyer or other successor to our business in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Steward Technologies’ assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Data Information held by us about our Site users is among the assets transferred.
We or our affiliates may at times send you e-mail communications with general marketing information, even though none of your Personal Data is shared for marketing purposes beyond Steward Technologies’ affiliates. If you prefer not to receive such marketing or promotional e-mails, you may unsubscribe via your account dashboard or by emailing us at: email@example.com or you may choose to stop receiving our newsletter or marketing emails by following the “unsubscribe” instructions included in these emails. However, you cannot opt out of receiving certain types of email communications such as emails regarding specific transactions you have participated in on our Site, legal notices we may be required to give, or emails responding to specific inquiries from you. Please also note that at times we may need to send you e-mail communications which are transactional in nature and which you will not be able to opt-out of, such as service or termination announcements or payment confirmations.
We use reasonable efforts to secure access to Personal Data in our possession but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Information you provide to us is encrypted and stored securely on private cloud servers through third-party service providers that we use. We also take commercially reasonable efforts to store as little sensitive information as possible. We are required to notify you without undue delay in the event of a data breach on our part causing high risk to data subjects. The notification must include at least: the name and contact details of the Data Security Coordinator (or other relevant point of contact); the likely consequences of the data breach; and any measures taken by us to remedy or mitigate the breach. However, we may be exempt from this requirement if: the risk of harm is remote because the affected data are protected (e.g., through strong encryption); we have taken measures to protect against the harm (e.g., suspending affected accounts); or the notification requires disproportionate effort (in which case we must issue a public notice of the breach). Though we and our service providers, who have informed us that they also use reasonable efforts to secure Personal Data, take commercially reasonable efforts to keep secure any Personal Data, there is no guarantee that any communication over the public Internet is 100% secure at all times. Therefore, neither we nor our service providers shall be held liable for the failure to safeguard Personal Data, whether inadvertent or otherwise, except where you, as a data subject, prove that you have suffered material or non-material damage as a result of our infringement of the GDPR, in which event you shall have the right to receive compensation from us, in our capacity as data controller or processor, for the damage suffered. It is also important for you to protect against unauthorized access to your password and to your computer. Be sure to log off any computer or device you use to access your account on our Site after you have finished.
No one under eighteen (18) years of age is allowed to use our Site, provide any Personal Data, or receive our email distributions. We do not knowingly solicit or collect Personal Data from children under the age of thirteen (13) or anyone under eighteen (18) years of age. If you believe that anyone under these ages has disclosed Personal Data to us, please report this to us immediately by emailing us at firstname.lastname@example.org.