Madison Funding Partners Privacy Policy
This Privacy Policy has been updated effective August 9, 2023.
This privacy policy (this “Privacy Policy”) governs the collection, storage, and use of information and data collected by Madison Funding Partners, Inc. or any of our affiliates (collectively, “Madison Funding Partners,” “we”, “us”, or “our”), via our website at www.madisonfundingpartners.com and its subdomains, by our mobile application, or by telephone, facsimile, email, or other means (collectively, and together with our website, “Madison Funding Partners Services”).
We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use our website or any other of our services.
Please read this Privacy Policy carefully. By accessing and using this website, you confirm that you have read and understand this Privacy Policy in its entirety. You understand and acknowledge that we reserve the right to change or amend this Privacy Policy at any time, which will be reflected by the “effective” date above. Please check this webpage regularly to stay informed of updates to this Privacy Policy. If any material changes are made to this Privacy Policy, advance notice of the changes will be posted in the first section of this webpage as required by applicable law. You understand that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
1. What information do we collect from you?
A. Information provided by you or by your agent
Madison Funding Partners collects information supplied by you or your designated agent during the application process, including but not limited to, the following information (as applicable):
Individual and Business names
Mailing and physical address
Business address
Phone and e-mail details, including passwords
Bank account information
Date of birth
Social security number, drivers’ license, or other government IDs
Income, assets, debt, and other personal and business data
Other information provided in correspondence with us, including by email, post facsimile, and telephone
B. Cookies and tracking technologies
When you use Madison Funding Partners Services, we may utilize cookies and other similar technologies (such as web beacons or pixel tags) to capture and remember certain information (collectively, “Technologies”). You have the ability to disable cookies in your browser settings; however, doing so may affect the functionality of certain features of our website.
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services, to provide tailored advertising, and to evaluate our marketing efforts. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. We do not process “do not track” (DNT) signals.
You may stop or restrict the placement of tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings menu to exercise this choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
C. Device specific information and tracking technologies
When you use Madison Funding Partners Services, we may collect device specific information. This information, including but not limited to your internet protocol address, geographical location, browser type, operating system, MAC address, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, length of visit, and pages viewed, is saved automatically in log files. We use the information in these files to improve the functionality of our services and in other ways described under the heading “Why do we collect this information” below.
D. Information obtained from third parties
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
Information from financial partners to process your loan. In addition to collecting personal information supplied by you or your designated agent, we use unaffiliated third parties to gather data on borrowers and prospective borrowers, from financial institutions, consumer reporting agencies, and other information service providers for purposes described under the heading “Why do we collect this information” below. This information includes the categories of information described above, and also includes:
Government IDs
Criminal records
Household records
Employment information, such as visa permit number
By using Madison Funding Partners Services and applying for a loan, you acknowledge that our unaffiliated, third-party providers will have the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution or consumer reporting agency, according to the terms of such third-party provider’s privacy policy.
2.Why do we collect this information?
Madison Funding Partners may use information we collect about you to:
determine your eligibility for a loan;
obtain, upon your authorization, a credit report, references, and other information from credit bureaus or other third parties in connection with your loan application;
verify your identity;
detect and guard against potential fraud and identity theft;
manage and monitor your Madison Funding Partners account and update your records;
develop, maintain and improve our website, products, and services;
detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity;
improve customer acquisition through the use of advertising campaigns and other means, such as targeted marketing;
enforce our agreements;
carry out statistical analysis and market research and testing;
comply with our legal and regulatory obligations, and carry out regulatory checks;
make our website available to you and identify products and services you may be interested in; and/or
send or facilitate communications with you.
3.How and when is your information shared with other parties?
We do not “sell” your personal information as the term is defined under the California Consumer Privacy Act (CCPA), nor have we ever sold personal information. Your information, as collected by or provided to us, may be shared by us (currently and in the preceding 12 months) with the following categories of third parties:
Category of Third Parties Information is Disclosed to -
1.Identifiers (A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.)
Service Providers
Loan Partners
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) -A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account information,
Service Providers
Loan Partners
3.Commercial information -Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Service Providers
Loan Partners (limited to records of personal property)
Advertising Partners (limited to records of Madison Funding Partners products or services purchased, obtained, or considered)
4.Internet or other electronic network activity -Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
Service Providers
Advertising Providers
5.Professional or employment-related information -Current or past job history or performance evaluations.
Service Providers
Loan Partners
6.Inferences drawn from other personal information to create a profile about a consumer -Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Service Providers
Advertising Providers
For more information on this sharing, see below:
Sharing with Service Providers. In order to provide, operate, and improve Madison Funding Partners Services, we may share your information with service providers who assist us in operating our website, providing market research and marketing our products and services, so long as the service provider contractually agrees to only use the data on our behalf.
Service providers may also include your representative(s), to the extent such a representative assists or assisted with the investor eligibility process. Information shared with your representative may include, among others, information about your loan performance.
Sharing with Loan partners. In order to enable Madison Funding Partners to carry out our services and conduct our businesses, including, but not limited to:
With credit bureaus, consumer reporting agencies, financial institutions, collections agencies, and fraud prevention agencies
With business credit bureaus to report loan performance.
In addition to the sharing outlined above, we may share any information we maintain about you with the following parties:
With our company affiliates;
With any third party who acquires some or all of our business and/or assets in connection with an acquisition or merger, as permitted under applicable law;
When required by applicable law, including, but not limited to:
With law enforcement or other government bodies, such as to comply with subpoenas, bankruptcy proceedings, or similar legal processes or for the purposes of limiting fraud.
When we believe in good faith that sharing such information is necessary to enforce our site policies or any loan agreement, protect our or other’s rights, property, or safety, and/or to comply with a judicial proceeding, court order, or legal process.; and
With other third parties in de-identified or aggregated form, for marketing, advertising, research, or other business purposes.
4.Storage and security
While we take appropriate physical, technical and organizational measures to safeguard the personal information that you provide to us, unfortunately no system is 100% secure. To the fullest extent permitted by applicable law, we accept no liability if communications are unintentionally disclosed, intercepted by third parties, incorrectly delivered, or fail to deliver.
The personally identifiable information that you provide and that we collect will be stored and maintained by Madison Funding Partners for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) for which such information was collected, in accordance with this Investor Privacy Policy, or (b) to comply with applicable laws, contracts or other rules or regulations.
5.Your rights
In accordance with applicable law, you may have the right, subject to verification of your identity:
To update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and
To opt out of any marketing communications that we or any service provider to whom we have disclosed your personal information may send you.
To request deletion of your personal information, subject to certain exceptions prescribed by law.
To request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you wish to exercise any of the above rights, please contact us using the details specified under the heading “Contacting us” below. Note that we will require you to take steps to verify your identity before you may exercise the rights listed above, such as by requesting you provide us with your account information, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to out customer support staff, as required by applicable law.
You may have a right not to receive discriminatory treatment as a result of your exercise of these rights.
Please note that the Fair Credit Report Act (FCRA) requires each of the nationwide credit reporting agencies — Equifax, Experian, and TransUnion — to provide you with a free copy of your credit report, at your request, once every 12 months. For more information, visit: https://www.ftc.gov
6.Links to other sites
Our websites may offer links to sites of other companies and associations. While we monitor the quality of content provided on these sites, these external sites are not subject to this Privacy Policy and we have no control over their content. Please carefully review the policies of these sites before providing any personal information
7.Contacting us
If you have any questions regarding this Privacy Policy, you may contact us using the information below.
Madison Funding Partners, Inc.
c/o Legal Dept.
48 Wall St., 11th floor
NY, NY 10005
(212)380-8182
info@madisonfundingpartners.com
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 mailings lists.
1. Send an email to info@Madison Funding Partners.com
2. Send a letter to:
Madison Funding Partners
ATTN: Marketing Opt-Out
48 Wall St, 11th floor
New York, NY 10005
USA
Madison Funding Partners Privacy Policy Part 2: 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 (Madison Funding Partners pages visited), device ID, device type and information regarding a consumer’s interaction with Madison Funding Partners’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 Madison Funding Partners 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 (Madison Funding Partners.com). For example, from submissions though 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
Madison Funding Partners may share your information with its affiliated entities for business purposes, such as financial reporting. Should you apply Madison Funding Partners may share your application status, borrowing history, and loan performance. Madison Funding Partners 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 Madison Funding Partners 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 Madison Funding Partners’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 Madison Funding Partners.
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 Madison Funding Partners 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.
In the preceding 12 months, we may have disclosed personal information for a business purpose from each of the categories listed previously where we collect information.
Sale of Personal Information
We do not sell personal information.
Your Rights and Choices
The CCPA provides consumers, including owners/guarantors of small business loans (California residents), with specific rights regarding their personal information. Madison Funding Partners is providing these rights to California consumer residents who have provided their personal information as part of an Madison Funding Partners application or loan. This section describes the CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights:
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (“Request”), we will disclose to you:
The categories of information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exceptions
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Section 1546 seq.).
Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to other applicable ethics and privacy laws, when the deletion of the information may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with expectations based on your relationship with us.
Comply with a legal obligation, such as retaining personal information collected to verify/identify under federal anti-money laundering laws (“AML”).
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Only you or a person registered with the California Secretary of State or other state agency that you authorize to act on your behalf, may make a Request related to your personal information.
You may only make a Request for access or data portability twice within a 12-month period. The Request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We can’t respond to your request or provide you with personal information if we are unable to verify your identity or authority to make the request and confirm the personal information relates to you. Making a Request does not require you to create an account with us. We will only use personal information provided in a Request to verify your identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a Request in writing within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will cover the 12-month period preceding the receipt of the Request. The response we provide will also explain the reasons we can’t comply with a request, if applicable. For data portability requests, we will select a format to provide the information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or response to your Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of these rights. Unless permitted by the CCPA, we will not, because you have exercised rights under the CCPA:
Deny you goods or services.
Charge you different prices for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our CCPA Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.