SnapRent Privacy Policy

Date Last Updated
May, 2024

1. Scope

This Privacy Policy is meant to help you understand how we and our affiliates collect, use, protect, and share your personal information. This Privacy Policy applies to SnapRent’s online and offline collection, use, sharing, and retention of your personal information.

If you are a SnapRent consumer or customer and applied for or obtained a financial product or service with SnapRenti, read our U.S. Consumer Privacy Notice to learn how we collect, use, protect and share your personal information and the privacy options available to you.

2. Changes to Our Privacy Policy

We may change or update this Privacy Policy periodically. When we do, we will let you know by appropriate means such as by posting the revised Privacy Policy on our website with a new “Last Updated” date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise.

3. Personal Information We Collect and How We Collect It

a. Information you provide to us.Personal information you may provide to us includes:
b. Identity information – including name, date of birth, marital status, social security number, and other data on government-issued identification documents (e.g., passport and driver’s license).

We collect this information, in part, to meet federal requirements and to combat money laundering activities. Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens a financial account.

When you open a financial account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

• Profile Data – such as your username and password, your interests, age, preferences, feedback, and survey responses.
• Contact information – including home address, telephone, email address, and emergency contact details.
• Employment information – including job title/position and annual income.
• Geolocation data – which may include, city, state, and country and location associated with your I.P. address.
• Characteristics of protected classifications under California or federal law, such as age, citizenship, and marital status.
• Preferences – such as your preferences for receiving our marketing communications and privacy choices.
• User-generated content – such as questions, messages, reviews, blog posts, and other content or information that you generate, transmit, or otherwise make available, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Promotional information – including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest, or giveaway, we may ask you for your contact data to notify you if you win or not, to verify your identity and/or to send you prizes. We may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
• Financial information – such as student loan, personal, credit card, and mortgage account number(s); banking details; tax information, expenses, stock, equity details, including financial account details of linked financial accounts via Plaid.
• Information Technology (IT) information – information required to provide access to SnapRent’s lending systems such as IP addresses, log files, and login information.
• Audio, electronic, visual, or similar information, including recordings of calls and online user sessions. We collect and use this information to measure and improve our member relationship protocols, to train and educate employees, and for compliance purposes.
• Other – not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at time of collection.

c. Sensitive Personal Information We Collect
d. Unique Identifiers – Your social security, driver’s license, state identification card, or passport number.

• Financial accounts – We collect account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
• Biometric data – As part of the verification process, we collect biometric information from government IDs and images to verify your identity.

Third-party sources. We collect information about you from third parties. We may also combine personal information we receive from you with personal information we obtain from other sources. We receive information from the following categories of sources.

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources (e.g., public record sources and collection agencies).
• Consumer Reporting Agencies
• As a company engaged in lending, SnapRent both receives and transmits data to consumer reporting agencies. We obtain information from 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 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 past due payments and collection actions occurring on open and closed credit accounts.
  • ○ Information regarding public records of bankruptcy, judgements, tax liens, and other payment statuses.
• If you connect an external financial account to SnapRent, SnapRent will obtain information from that account such as account balance and transaction information, or loan details. SnapRent facilitates our customers to use Plaid to retrieve information from external accounts, and we keep and use that information.

e. Agencies to whom complaints have been submitted regarding Our services/products
Financial regulators, consumer protection agencies, and other businesses may share information, typically with your consent and knowledge, regarding complaints you submitted related to SnapRent and its products or services.

f. Automatic data collection. We may automatically collect, use, and retain information about you, your computer or mobile device, and your interaction over time, our communications, and other online services, such as:

g. Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the previous website visited before navigating to our website(s), navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Location data, such as city, state, country, and location associated with your I.P. address.

4. Cookies and similar technologies

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that we place on our websites and app for social media, advertising, analytics companies, and other service providers.
• Logical storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Pixels or web beacons, also known as pixel tags or clear GIFs, enable collection, storage, and sometimes sharing of your information and/or your actions taken, such as whether you accessed or opened a webpage or email or that you viewed or clicked certain content. Certain pixels include computer-code snippets that enable the collection and sharing of information back to web servers of third parties.
• Session Replay Technologies. SnapRent may capture your use of the Site and may record your use with third-party services. These services employ software code to record users’ interactions with the Website in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. We may use the Cookies and similar technologies for the following purposes:
• Technical operation. To allow the technical operation of our Services, such as by remembering your selections and preferences as you navigate our websites and app.
• Functionality. To enhance the performance and functionality of our Services. Analytics. To help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions with our emails.
  • For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
• Cookie Opt-outs. You can disable cookies via most browsers. This may affect site functionality. To opt out of cookies on our site, click the “Your Privacy Options” link in the footer of our website, click “cookie choices” and select your preference.

5. Retention of Personal Information

We retain information we collect about you, and use the following factors to determine the retention period of personal information:

• to maintain an ongoing relationship with you as a customer, member, or business contact (for example, when you are a recipient of any of our financial services/products).
• to perform under applicable terms and services to which you agreed.
• as necessary in connection with the lawful purposes set out in this Privacy Policy. ● to comply with applicable laws
• to establish, exercise or defend our legal rights.

6. How We Use Your Personal Information

We use your personal information for the following purposes, or as otherwise described at the time of collection:

Provide Financial Services and Products. We use your personal information to provide you with financial services and products and

• review your application and determine eligibility for financial products and services.
• process transactions and payments, fulfill orders, and verify your customer information.
• provide, operate, and maintain your SnapRent financial accounts
• communicate with you about our products and services, your financial accounts, including by sending announcements, updates, security alerts, and support and administrative messages.
• provide support for the Website, our financial services, and products, and respond to your requests, questions, and feedback.

Website and application delivery. We may use your personal information to:

• provide, operate, and improve the Website, application, our services, and our business.
• establish and maintain your user profile on the website or application.
• enable online security features, such as by remembering devices from which you have previously logged in.
• understand your needs and interests and personalize your experience with the Website and our communications.
• provide support for the Website, our financial services, and products, and respond to your requests, questions, and feedback.

Research and development and business promotion. We may use your personal information for research and development purposes, including to analyze and improve the Website and our business, and for business promotion purposes.

Marketing and advertising. We may collect and use your personal information for internal marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Meet compliance and legal obligations. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
• audit our internal processes for compliance with legal and contractual requirements or our internal policies.
• enforce the terms and conditions that govern our Services.

Fraud Detection and prevention. We may use your personal information to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks, and identity theft.

With your consent. In certain cases, we ask for your consent to collect, use, and share your personal information, such as when obtaining a credit report.

7. Our Disclosure of Your Personal Information for Business Purposes

We share your personal information with the following parties and as otherwise described in this Privacy Policy, or at the time of collection.

Service providers. Third parties that provide services to SnapRent, or to you on our behalf, or help us operate our business (such as data cloud providers), information technology, customer support, email delivery, marketing, consumer research and website analytics.

Consumer reporting agencies.

Social Media Platforms. If you interact with us or our SnapRent Services on or through social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our sites, both the social media platform and your connections on the platform may be able to view that activity. To control the sharing of information, please review the privacy policy of the relevant social media platform.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. We will share personal information these other companies need to provide the services that you requested.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Legal authorities. Law enforcement, government authorities, regulatory agencies, and third parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above, and in compliance with applicable law.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, SnapRent or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Other users and the public Your user-generated content may be visible to other users of our Services and the public. For example, other users or the public may have access to your information if you provide comments, reviews, blog posts, messages or share other content. This information can be viewed, collected, and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

8. The Categories of Third Parties with Whom We Disclose Your Personal Information for Business Purposes

9. Security

SnapRent 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.

10. Connections with external bank accounts

As part of SnapRent’s underwriting procedures, we require you to connect at least one account from an external financial institution. By doing so, you authorize SnapRent to obtain information from the external account and use it as described below.

SnapRent will obtain your account information. If you elect to connect an external account to SnapRent, SnapRent will obtain information from those Connected Accounts. The specific information SnapRent obtains may vary by institution and account type. SnapRent may obtain from the account any transactional and balance information from the linked accounts. For example, once you connect a bank account, SnapRent can collect information from the account, including balance and transaction information, such as payments made and their amounts, debits, and deposits.

Use of Plaid Services. To connect an account, SnapRent requires you to use a service offered by Plaid Inc. (“Plaid”). Review Plaid’s Privacy Policy to learn more.

Use of information from Connected Accounts. If you connect an account through SnapRent with your consent, SnapRent will use this information to determine your eligibility for a loan.

15. Links to Other Services or Applications

This Privacy Policy applies only to SnapRent’s Services. SnapRent Services may contain links to other websites or apps or may forward users to other websites or apps that we may not own or operate and to which this Privacy Policy does not apply. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest reading the privacy notices of these websites or app providers or contacting them directly for information on their privacy practices. Nonetheless, we seek to protect the integrity of our Services and welcome any feedback about these linked websites and mobile applications.

16. Information of Children

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from an individual under age 18. If you are under the age of 18, please do not submit any personal information through the Website, app, or service. If you have reason to believe that we may have accidentally received personal information from an individual under age 18, please contact us immediately at help@snaprent.com

We do not knowingly collect, sell, or share the personal information of children under the age of 16.

17. Your Personal Information Choices

We want you to be aware of the choices you have in limiting the sharing of your personal information.

Direct Mail Opt-Out

To opt out of SnapRents’s marketing and advertising campaigns conducted via direct/postal mail, please make your request to help@snaprent.com

Access or Update Your Information (Registered Users)

If you have registered for an account with us through the snaprent.com Website, you may review and update certain account information by logging into your account. To update your profile, visit “My Profile” after logging into your account. This section of the site is password protected to safeguard your information. As a registered user, you can update your password, physical address, phone numbers, education, and employment information at any time on the Website. If you need to change any other information in your profile, please contact help@snaprent.com

Correcting Information Maintained by the National Credit Reporting Agencies

Credit reporting agencies maintain Information related to your creditworthiness. If you find that there is an error or want to dispute the information found in your credit report, please contact the national credit reporting agencies.

Advertising choices You can limit use of your information for interest-based advertising by:

• Browser settings. Blocking third-party cookies in your browser settings. ● Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies. Read our treatment of the Global Privacy Control.
• Platform settings. Google, Bing, Facebook, and TikTok offer opt-out features that let you opt-out of use of your information for interest-based advertising:
  • ○ Google: https://adssettings.google.com/
  • ○ Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ad
  • ○ Facebook: https://www.facebook.com/about/ads
  • ○ TikTok: https://www.tiktok.com/legal/privacy-policy-us?lang=en

Unlinking or disconnecting connected accounts.

Mobile settings.

Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. You will need to apply these opt-out settings on each device from which you wish to opt-out.

Do Not Track

Certain Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. If your browser is set to “Do Not Track” or “Send a Do Not Track Request,” we interpret this as a valid request to not sell or share the personal information for that browser or device.

Communication Preferences

SnapRent registered users can manage their communication preferences via the “My Profile” section of the site after logging into their account.

Declining to provide information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

18. Complaints and Concerns

SnapRent maintains a process to respond to your concerns regarding violations of this Privacy Policy. If you believe that we have not complied with this policy or have questions regarding your privacy with us, please email us at help@snaprent.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.

19. California Privacy Rights

This section applies solely to residents of California and their personal information that is subject to the California Consumer Privacy Act (CCPA). The CCPA allows exceptions for, therefore, does not apply to the following:

• Publicly available information made lawfully available from government records.
• Information that is deidentified, meaning that the information is rendered so that it cannot reasonably be used to infer information about or link to a specific person.
• Information subject to other laws, such as the following:
  • ○ Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
California residents have the right to
• know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you
• request the deletion of certain personal information collected by us
• correct inaccurate personal information
• know/access or receive a disclosure of your personal information
• know what personal information is sold or shared and to whom
• opt-out of the sale or sharing of your personal information
• in certain cases, limit the use and disclosure of sensitive personal information
• no retaliation for opting out or exercising any other rights, including an employee’s right not to be retaliated against for the exercise of their CCPA rights

How to Exercise Your Rights to Know (Access), Delete, or Correct Your Personal Information

We must verify your identity before processing most requests, which may require you to provide additional information. You may submit a request by emailing help@snaprent.com and including “CA Privacy Request” in the subject line

We strive to honor requests within forty-five (45) days of receipt. In certain instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity. We will notify you if we are unable to process your request within that time or at all and provide you an explanation.

How to Exercise Your Right to Opt Out of the Selling/Sharing of Personal Information Registered users
Browse to the “Cookie preferences” link at the bottom of all SnapRent webpages to choose your preferences.

Unregistered visitors or Logged out help@snaprent.com Users
Browse to the “Cookie preferences” link at the bottom of all SnapRent webpages to choose your preferences.

How to Exercise Your Right to Limit the Use of Sensitive Personal Information at snaprent.com
Browse to the “Cookie preferences” link at the bottom of all SnapRent webpages to choose your preference.

Submitting Requests on Another’s Behalf/Authorized Agents>
You can designate an authorized agent to submit a request on your behalf by emailing us at help@snaprent.com. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us.

Opt-Out preference signal (Valid request to not sell/share personal information)
SnapRent processes browser opt out/do not track signals in a frictionless manner. If your browser is set to “Do Not Track” or “Send a Do Not Track Request,” we interpret this as a valid request to not sell or share the personal information for that browser or device in compliance with applicable laws.

Global Privacy Control SnapRent recognizes the Global Privacy Control (GPC), which is a setting that allows you to communicate your privacy preferences to websites and online services that you visit. When we detect a GPC signal from a browser, we interpret this as a valid request to not sell or share the personal information for that browser or device in compliance with applicable laws. Please visit the Global Privacy Control website to learn more about the setting and how to enable it on your browser.

20. Your Nevada Privacy Rights

Senate Bill No. 220 (May 29, 2019) amends Chapter 603A of the Nevada Revised Statutes to permit a Nevada consumer to direct an operator of an Internet Website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by emailing help@snaprent.com We will provide further information about how we verify the authenticity of the request and your identity.

21. How to Contact Us

Email - If you have any questions about SnapRent’s privacy practices, please contact us via email at help@snaprent.com