Privacy
policy

Sunfish Solutions, LLC (“Sunfish,” “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website or use our services and describe our practices for collecting, using, maintaining, protecting and disclosing that information. For clarity, we will refer to our website and our services throughout this Privacy Policy as the “Services.”

This Privacy Policy applies to any person who uses our Services and how we collect and use their personal information except for consumers of our financial services, whose personal information is subject to our Financial Privacy Notice.

This Privacy Policy is meant to help you understand how we and our affiliates collect, secure, use, and disclose your personal information in connection with our Services. This Privacy Policy applies to personal information we collect from you and from third parties, both online and offline.
By using Sunfish’s services, or otherwise providing us with personal information, you agree that your personal information is subject to this Privacy Policy and any updates we make to it. Our Terms of Use take precedent over any provision conflicting with our privacy policy.

Changes to Our Privacy Policy

We update our Privacy Policy regularly at our sole discretion —this version is effective as of the date indicated above. We will notify you of material changes to the Privacy Policy by email or by other means  or by posting the updated Privacy Policy  on our Services. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
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1. HOW AND WHY WE COLLECT INFORMATION ABOUT YOU
1.1. Information you provide us
1.1.1. Personal Information
We collect personal information from you to help you use our Services. When we say “personal information,” we mean information that specifically identifies you.

We collect this information in a number of ways. You are asked to provide personal information to us while submitting loan applications, registering to use our Services, discussing your application or product with us, or providing feedback to us. Examples of personal information include:
Your Name
Your Address
Telephone Number
Email Address
Social Security Number
Employment Information
Salary Information

We may supplement the personal information you submit to us with information from third-party sources.

Finally, we never intend to collect personal information from children under 18 years of age. If we learn or are notified that we have collected this information from a child under the age of 18, we will promptly remove the data from our system.

1.2. Information we Collect About You
1.2.1 Aggregate and de-identified Information
Aggregate and de-identified information, which is data we collect about your use of our Services, from which personal information has been removed. Aggregate and de-identified information is used to help us understand consumer trends, needs, interests, and preferences so we can improve our products and services.

Sunfish may also collect demographic information, which is anonymous, and may include:
Age
Date of Birth
Income
Geographic Area

1.2.2. Consumer Reports
As a company engaged in lending, Sunfish both receives and transmits data to consumer reporting agencies. We partner with these agencies to assess your creditworthiness and to prevent fraud and identity theft. This is done as part of our regular underwriting, fraud prevention and loan servicing processes.

Information we collect in these reports includes, but is not limited to:
Information about open and closed credit accounts, including the date opened, the date closed (if applicable), the latest reported monthly balance and monthly payment
Information about credit inquiries
Information about late payments and collection actions occurring on open and closed credit accounts
Information regarding public records of bankruptcy, judgements, tax liens, and other payment statuses
The credit score produced by the credit bureau providing the report
Information about your transaction history, assets, and account balances
Correcting information maintained by the credit bureaus

Information related to your creditworthiness is maintained by the credit bureaus. If you find that there is an error or you want to dispute the information found in your credit report, please contact the credit reporting bureaus.

Experian – https://www.experian.com/
Transunion – https://dispute.transunion.com/
Equifax – https://www.equifax.com/personal/

1.2.3 Services Use Data Sunfish also collects information about your computer or mobile device to improve and evaluate your use of our Services. We may gather data such as your browser type, operating system, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device.

1.2.4 Information We Get from Others
We may contract with third parties to place advertisements for our Services on websites that are not our own. We may place these ads where we think they are likely to be most relevant. These advertisements on third-party websites allow us to track responses to our ads. We and our affiliates use this information to track the performance of our advertising and marketing campaigns by using tools like cookies, web beacons and similar technologies. We use these tools to collect and store information about your visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site.

1.2.5 Cookies
Sunfish may use “cookies” and similar tools to track your use of our website when you use our Services. We collect information such as the types of service used, and number of users we receive daily. Our web servers may automatically log information about your computer, but we don’t use this information to identify you personally.

We and our vendors use cookies to improve our Services and to provide more convenient and relevant experiences to you. Cookies are designed to transfer a small amount of data to your browser by servers within a domain. That data is only read by designated servers within that domain. It functions as your computer’s identification card and enables Sunfish to improve your experience by securely maintaining your authenticated session and preferences.

A web beacon embeds a small transparent gif image in a web page or email used to track when the page or email has been viewed. A similar device may be used where a product, service or functionality sends data to a server when a set of user-initiated events occur such as clicking a button on the website or in an email. This is similar to a cookie – it tracks your visit and the data is only read by the server that receives the data. However, it differs because it is not browser-based, may not function as an ID card and doesn’t store any data on your computer.

Most Internet browsers are set up to accept cookies automatically. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. For some web pages requiring an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages or their products and services.

We may use tracking technologies and other third-party tools to process analytics information on our Services. These tracking technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics providers include:

Google Analytics. To assist Sunfish in maintaining and improving our service, and our site, Sunfish uses Google Analytics to gather information about usage of our site. The information helps Sunfish improve the performance of our service and site for you. For more information on Google’s use of the data, please see the website “How Google uses data when you use our partners’ sites or apps” located at https://policies.google.com/technologies/partner-sites.

Hotjar. Sunfish uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Services with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. By using our Services, you agree that Hotjar may record your interactions with our website and other Services. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.For further details about Hotjar’s data collection and use practices, please see the Hotjar Privacy Policy available here and the ‘about Hotjar’ section of Hotjar’s support site.

1.2.6 Contacting us by Telephone
If you communicate with us by telephone, we may monitor or record the call. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of Sunfish’s products.

1.2.7 Telephone Consumer Protection Act Communication Consent
Consent for Communications: You consent to use of an automatic telephone dialing system (“ATDS”) and/or artificial or prerecorded messages by Sunfish and its affiliates, agents and service providers (“we,” “us,” “our”) for any lawful purpose, including marketing messages, to any telephone number you provide to us, now and in the future, including cellular telephone numbers. You understand and agree these communications may include your personal information. You consent to the monitoring and recording of your telephone calls with us to assure service quality and for other legitimate business reasons. We will not charge you for any communication we make or attempt, but your service provider may. If you wish to withdraw your consent to receive ATDS calls and texts or artificial or prerecorded messages for non-emergency purposes, you agree to do so by calling us at (510) 775-0064 or by sending an email to us at info@joinsunfish.com. You understand and agree that we may always communicate with you in any manner allowed by law that does not require your consent. You agree to notify us if any telephone number you have provided us changes or is reassigned to a new subscriber. You certify you are authorized to provide this consent because you are either the subscriber of the telephone number or a non-subscriber customary user with authority to provide this consent.

2. USE AND SHARING OF YOUR PERSONAL INFORMATION
2.1 How we use your personal information

We use your personal information to provide you with information or services you request, to inform you about other information and services we think will be of interest to you, to facilitate your use and our operation of our website, and to improve our products and services. We don’t forget about you once you’ve signed—Sunfish provides Services to help you build your family and manage costs.

Here are some examples of ways in which we use your personal information:
Creating and maintaining your login information on our site
Contacting you regarding issues with your account
Allowing our servicing partners to process your payments
Invitations to Sunfish events
Sending you information about new product offerings
Sharing your personal information

2.2 How we share your personal information
Sunfish  may share your personal information with the following categories of third parties: 

Please note that, if you are a current borrower, you may not control certain information associated with your loan that you have already agreed to provide to certain investors as described in your loan agreement.

Finally, we may disclose or transfer your personal information as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance involving Sunfish or in any other situation where personal information may be transferred or disclosed as one of the business assets of Sunfish.

2.3 Sharing of Aggregated/De-Identified Information
Personal information that we have collected may be aggregated or de-identified in a manner that no longer identifies you personally. We may share this aggregated or de-identified information with third parties for various business purposes, where permitted by applicable law.

3. PROTECTING YOUR PERSONAL INFORMATION
3.1. What we do to protect your personal information
Sunfish takes the privacy and security of its members’ personal information seriously. We maintain administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity.

Whenever we save your personal information, it’s stored in locations that only selected Sunfish personnel and our contractors have access to. Remember – all information you submit to us by email is not secure, so please do not send sensitive information in any email to Sunfish.

3.2. Steps you can take to help us keep your information safe
Sunfish urges your caution when using public computers or networks, like at a coffee shop or library. To best protect your personal information, don’t use such computers to access your sensitive accounts, and if you must, ensure that you logout of your account entirely. We would not ask for sensitive information over email or text.

4. YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION
We want you to be aware of the choices you have in limiting the sharing of your personal information.

4.1. Changing and Updating Your Personal Information
We want to provide you with the resources you need to keep your information with us correct and up-to-date. You can make changes to, or request to know more about, your personal information at any time by emailing us at info@joinsunfish.com. If you need to change any information related to your application or that you may have submitted to us, please contact us at info@joinsunfish.com.

Our website contains links to other sites that may collect your personal information. For example, Sunfish has relationships with various service providers whose services are available to you from our Services, from other websites or services that are linked to our Services, or in connection with our Services. These partners offer services we think our customers may find useful or will improve our Services. Those providers may require you to provide personal information to use their services. Personal information collected on other websites is not covered by this Privacy Policy. Unless stated otherwise, the policies of those partners will govern the collection, use, disclosure and security of your personal information. We encourage our users to read the privacy policies of each website and service with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or services. Providing personal information to third-party websites or applications is at your own risk.

Do Not Track Signals. We don’t respond to “do not track” signals or similar mechanisms – where a visitor to Sunfish’s website requests that we disable the collection of personal information about the visitor’s online activities, including navigation around our website and the Services. We may also permit third parties to collect aggregate usage information on our Services, and they may also not respond to “do not track” signals.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Use or this Privacy Policy).Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

5. COMPLAINTS & CONCERNS
Sunfish takes your privacy seriously, and maintains a process to respond to your concerns regarding violations of this Privacy Policy. If you believe that we haven’t complied with this Privacy Policy in regards to your personal information or have questions regarding your privacy with us, please contact us at info@joinsunfish.com. If you are reporting non-compliance with this Privacy Policy, please describe the issue in as much detail as possible without disclosing any sensitive information about you or third parties.

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

6. RETENTION OF YOUR PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. INTERNATIONAL DATA TRANSFERS

Privacy laws and expectations vary from country to country. If you are visiting our ServicesWebsite from locations outside the United States, please note that by providing your personal information to us, you are agreeing to the transfer of your personal information to, and the collection and processing of such personal information in, the United States. U.S. laws regarding the collection, use, disclosure, and processing of personal information may vary from those in other countries and may be less stringent than the applicable laws in your jurisdiction. By providing us with your personal information, you consent to any transfer and processing in accordance with this Privacy Policy.

8. NEVADA RESIDENTS

Nevada residents have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that personal information. We do not “sell” personal information of Nevada residents as sales are defined under the Nevada privacy laws, but, if you are a Nevada resident who has questions or who wants to make this type of request, please send your email to info@joinsunfish.com.

9. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at info@joinsunfish.com.

Sunfish Solutions, LLC
Financial Privacy Notice

rev. 02/21

FACTS	WHAT DOES SUNFISH SOLUTIONS, LLC (“SUNFISH”) DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include:Social Security number and credit scores Credit history and credit card or other debt Employment information and assets When you are no longer our customer, we continue to share your information as described in this notice.
How?	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; the reasons Sunfish chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Sunfish share?	Can you limit this sharing?
For our everyday business purposes –such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, 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	Yes	No
For our affiliates’ everyday business purposes –information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes –information about your creditworthiness	No	We don’t share
For our affiliates to market to you	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

Questions?

Call (501) 775-0064, email us at support@joinsunfish.com or write to us at 2219 Main St, Suite 660, Santa Monica, CA 90405.

What we do
How does Sunfish protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Sunfish collect my personal information?	We collect your personal information, for example, when youApply for financing or open an account give us your income information or show us your government-issued IDgive us your contact information.We also collect your personal information from others, such as credit bureaus, affiliates or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only:sharing for affiliates’ everyday business purposes – information about your creditworthinessaffiliates from using your information to market to yousharing for nonaffiliates to market to youState laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
Definitions
Affiliates	Companies related by common ownership or control.Our affiliate is Sunfish Technologies, Inc
Nonaffiliates	Companies not related by common ownership or control.Sunfish does not share with nonaffiliates so they can market to you.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you.Our joint marketing partners include depository institutions and consumer lenders.
Other important information
California residents: We will not share personal information with nonaffiliates to market to you, except with your express consent. We will not share your personal and financial information with affiliates, or with other companies we do business with to provide financial products or services if you instruct us not to do so. To limit our sharing with affiliates and other companies we do business with to provide financial products or services, complete and return the enclosed Notice of Important Privacy Choices for Consumers. Vermont residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at www.joinsunfish.com or by calling our customer support number at (501) 775-0064.

Texas Residents: For questions or complaints about this loan, contact Sunfish at (501) 775-0064, email us at support@joinsunfish.com or write to us at 2219 Main St, Suite 660, Santa Monica, CA 90405. The lender is licensed and examined under Texas law by the Office of Consumer Credit Commissioner (OCCC), a state agency. If a complaint or question cannot be resolved by contacting the lender, consumers can contact the OCCC to file a complaint or ask a general credit related question. OCCC address: 2601 N. Lamar Blvd., Austin, Texas 78705. Phone: (800) 538-1579. Fax: (512) 936-7610. Website: occc.texas.gov. E-mail: consumer.complaints@occc.texas.gov.

Important Privacy Choices for California Consumers

You have the right to control whether we share some of your personal information.

Please read the following information carefully before you make your choices below.

Your Rights

You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.

Your Choices
Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you notify Sunfish, we may share personal and financial information about you with outside companies we contract with to provide financial products and services to you.

To notify Sunfish not to share personal and financial information with outside companies they contract with to provide financial products and services email support@joinsunfish.com with the subject line “Do not share my personal and financial information” and provide your full name and the email address used to create the account.