Overview
This Privacy Policy (“Policy”) applies to data collected by GVC Inc. and AFG Lender, a provider of business loan products and related services (collectively “Services”). The Policy has two parts:
Part 1 provides our U.S. Privacy Policy, including our Privacy Policy for AFG Lender.com (“Website”), which is owned by GVC Inc. This Policy describes how AFG Lender collects and uses the personal information you provide (directly or through third parties), or which is automatically generated when you interact with our Website, and our mobile application (“Mobile App”).
Part 2 is our California Supplement, which provides our California Consumer Privacy Act of 2018 (“CCPA”) Privacy Policy. The CCPA provides various rights to consumers who reside in California with regard to personal information. A natural person, including a business owner or guarantor, is considered to be a consumer under the CCPA. Any terms defined in the CCPA have the same meaning when used in Part 2.
Part 1: AFG Lender US Privacy Policy
This Privacy Policy describes the choices available to you regarding our use of your personal information and how you can access and update such information. For purposes of this Privacy Policy, “Personal Information” means information that personally identifies you, including your contact information, IP address, and loan application information. A large portion of the Personal Information we collect, use, share, and store is sensitive in nature, including your social security number and financial account information (“Sensitive Personal Information”).
Information We Collect
We collect the following information from you:
Contact information such as name, business name, email address, mailing address, and phone number;
Financial information such as bank statements, credit card statements, your average bank balance, personal and business credit history, payment behavior, bank account information, and tax ID number;
Social security number;
Unique identifiers such as user name and password, and IP address;
Business information including company size, and business type, and
Beneficial ownership information*
In addition to collecting information via our Website and Mobile App, we may also conduct a site visit to collect information, and obtain information and external data used by lenders to process applications and complete and manage transactions, e.g., from credit reporting agencies and other vendors, as well as from social media. Once you are a AFG Lender customer, we may reach out to you for, or otherwise obtain, information if you decide to renew your loan or as otherwise needed to provide the Service.
* When required in the U.S., we will collect information on the beneficial owners of our business customers for purposes of verifying their identity only. The U.S. Government implemented the beneficial ownership regulation to help deter financial crimes. By complying, we are doing part in upholding the regulation to protect the financial system. Pursuant to our privacy policies and procedures, we will maintain beneficial ownership information in our system of record.
Use of Information
We use the information we collect to:
Compile, save, use and analyze your Personal Information in both a personally identifiable form and as part of aggregated data;
Operate, maintain, improve, and provide to you the Service and to conduct our business, including our own lending and referring you to third party small business lenders;
Verify your identity and conduct appropriate diligence;
Register you as a user and identify you when you sign into your account;
Process your business’ application and determine whether or not your business qualifies for one of our loan products;
Process your business loan product account, including deducting automatic payments;
Communicate with you to send order confirmations, respond to customer service requests, send marketing communications, and send account update notifications;
Post and review your comments on our blog;
Conduct research and analyses to better understand our customers; and
Produce data analytics and reports containing de-identified summaries of Personal Information and other information that is not Personal Information (such information, “General Information”) that we share with business partners. General Information may include Personal Information that has been aggregated and will not identify you.
Privacy and Sharing of Information
AFG Lender may share your information with its affiliated entities for business purposes, such as financial reporting. Should you apply to AFG Lender or its affiliated entities for a financial product or service, AFG Lender may share your application status, borrowing history, and loan performance.
AFG Lender will share your Personal Information with third parties only in the ways that are described in this Privacy Policy and as required by law. Neither AFG Lender or GVC Inc (or any of its affiliated entities) will sell your Personal Information to third parties.
We will provide your Personal Information, which may include application information, to our trusted business partners, third party lenders of AFG Lender products, service providers, and subsidiaries and affiliates to provide financing and/or to provide services to help us with our business activities, such as offering customer service, processing credit checks or secure data storage, and other similar services. These companies are authorized to use your Personal Information only as necessary to provide these types of services to us. In addition, we may share your basic information (name, company name, phone number, email address and requested loan amount) with one of our business partners to market their services to you, provided, however, if you do not want us to share your Personal Information in these circumstances with these business partners, please contact us to opt out by email at marketing@afglender.com or by postal mail at the contact information listed below. In addition, we may also share General Information for the same reasons as we provide Personal Information and for business partners and others to conduct analyses and research and track marketing performance or as otherwise provided in the Tracking Technologies part herein.
Some of our pages utilize framing or white-labeling techniques to serve content from our partners while preserving the look and feel of our Website. For example, our Careers page utilizes white-labeling techniques. Please be aware that in these instances you are providing your Personal Information to these third parties and not to AFG Lender.
We may also disclose your Personal Information:
As required by law, such as to comply with a subpoena, or similar legal process, including in a bankruptcy proceeding;
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a request from a governmental entity;
If AFG Lender is involved in a merger, acquisition, or sale of all or substantially all of its assets or equity, in which case, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information; and
To any other third party with your prior consent to do so.
User Access and Choice
If your Personal Information changes, or if you no longer desire our Service, you may correct, update, amend, delete/remove, ask to have it removed from a public forum or testimonial on our Website or deactivate it by emailing our Customer Support at marketing@afglender.com or by contacting us by phone at (833) 400-4311. We will respond to your request within 10 business days.
Security
We implement security measures designed to protect your Personal Information from unauthorized access. For example, we encrypt sensitive data transmitted online and protect your information offline. However, you should be aware that no data transmission over the internet can be 100% secure. While we strive to protect your information, we cannot guarantee the security of information transmitted to or from our Website.
Part 2: AFG Lender Privacy Policy
California Supplement
CCPA Policy
Information We Collect
We collect the following categories of information from you, which may include the following:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number/tax ID number, driver’s license number, passport number or other similar identifiers.
We use this information to identify you, process your application and access your personal credit bureau report, if you are a guarantor or business owner.
Personal Information such as your name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, employment history, bank account number or other financial information.
We use this information to identify you, process your application and access your personal credit bureau report, if you are a guarantor or business owner.
Protected classification characteristics under California or Federal Law such as age (date of birth).
We use this information to confirm your identity and that you are old enough to enter into a loan contract.
Commercial information, including records of personal property and personal credit information.
We may consider this information when processing your application.
Internet or other electronic network activity information, including, but not limited to, browsing history (AFG Lender pages visited), device ID, device type and information regarding a consumer’s interaction with AFG Lender’s Internet Web site, application or advertisement.
We use this information to analyze the use of our website and for fraud screening.
Geolocation Data
We collect this information for fraud prevention purposes.
Audio, or similar information
Interactions with AFG Lender sales staff, underwriters and customer service agents are recorded for monitoring and training purposes.
Professional or employment-related information
We may use this when underwriting our loans.
Inferences drawn from any of the information categorized above
This information may be used for credit and fraud analysis and to target future offers.
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated information.
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA).
Personal information covered by certain privacy laws, such as the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our applicants, clients, or their agents. For example, information provided as part of the loan application or related processes.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website (AFG Lender.com). For example, from submissions through our website portal or website usage details collected automatically.
From third parties that interact with us in connection with the services we perform. For example, from referral partners and brokers who provide us with loan applications or credit reporting agencies that provide us with information regarding a guarantor’s or business owner’s credit history.
Use of Information:
We use the information we collect to:
Compile, save, use and analyze your Personal Information in both a personally identifiable form and as part of aggregated data.
Operate, maintain, improve, and provide you with services.
Conduct our business, including our own lending, and refer your business to third party small business lenders.
Verify your identity and conduct appropriate diligence.
Review for potentially fraudulent activity.
Register you as a user and identify you when you sign in to your account.
Process your business’ application and determine whether or not your business qualifies for one of our loan products.
Process your business loan product account, including deducting automatic payments from your business bank account.
Communicate with you to send order confirmations, respond to customer service requests, send marketing communications, and send account update notifications related to your business.
Post and review your comments on our blog.
Conduct research and analyses to better understand our customers.
Produce data analytics and reports containing de-identified summaries of Personal Information and other information that is not Personal Information (such information, “General Information”) that we share with business partners. General Information may include Personal Information that has been aggregated and will not identify you.
Sharing Personal Information
AFG Lender may share your information with its affiliated entities for business purposes, such as financial reporting. Should you apply to AFG Lender or its affiliated entities for a financial product or service, AFG Lender may share your application status, borrowing history, and loan performance. AFG Lender will share your Personal Information with third parties only in the ways that are described in this Privacy Policy and as required by law. We do not sell your Personal Information to third parties.
We will provide your Personal Information, which may include application information, to our trusted business partners, third party lenders of AFG Lender products, service providers, and subsidiaries and affiliates to provide financing and/or to provide services to help us with our business activities, such as offering customer service, processing credit checks or secure data storage, and other similar services. These companies are authorized to use your Personal Information only as necessary to provide these types of services to us. In addition, we may share your basic information (name, company name, phone number, email address and requested loan amount) with one of our business partners to market their services to you, provided, however, if you do not want us to share your Personal Information in these circumstances with these business partners you can opt out at the email or mailing address provided in AFG Lender’s Privacy Policy Part 1, which precedes this policy. In addition, we may also share General Information for the same reasons as we provide Personal Information and for business partners and others to conduct analyses and research and track marketing performance or as otherwise provided in the Tracking Technologies part herein.
Some of our pages utilize framing or white-labeling techniques to serve content from our partners while preserving the look and feel of our Website. For example, our Careers page utilizes white-labeling techniques. Please be aware that in these instances you are providing your Personal Information to these third parties and not to AFG Lender.
We may also disclose your Personal Information:
As required by law, such as to comply with a subpoena, or similar legal process, including in a bankruptcy proceeding;
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a request from a governmental entity;
If AFG Lender is involved in a merger, acquisition, or sale of all or substantially all of its assets or equity, in which case, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Contact Information
Contact Information
General Queries: If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, please contact us by email at marketing@afglender.com, or with a letter by postal mail to:
AFG Lender
ATTN: Marketing
100 Craig Road. Suite 205
Manalapan, NJ 07726
USA
To opt-out of marketing communications: please use one of the communication methods below, and include your full name and business mailing, email addresses and account number. Once we locate your contact information based on the information you provide us, it will be removed from our databases and mailing lists.
Send an email to marketing@afglender.com
Send a letter to:
AFG Lender
ATTN: Marketing Opt-Out
100 Craig Road. Suite 205
Manalapan, NJ 07726
USA
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
We reserve the right to update this privacy policy at any time, in whole or in part, at our discretion. Changes may be made without prior notice, including via email or other forms of communication.