Last Updated: October 14, 2010
Your privacy and the protection of your personal and sensitive information are important to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information.
This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any sensitive and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal and sensitive information is protected both electronically and physically.
In general, and as described in detail below, we collect several types of information from you:
- Personal data required to verify your identity
- Personal and financial data necessary to assess your eligibility to borrow or lend money through Blackhawk Investments
- Optional personal information (such as details about your loan) you may wish to share in the furtherance of your goals in using our site
- Information about your visits to and use of this web site to help us maintain the appropriate features, functionality and user experience
You accept this policy when you sign up for or use our products, services or any other features, technologies or functionalities offered by us on our website or through any other means (via the phone directly) (collectively the “Blackhawk Investments Services”).
Information We Collect From You and About You
We collect personal and financial information from you while you use the site, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the site, whenever you choose to provide it.
Certain personal information must be supplied during the member, investor and borrower registration processes, as indicated below, in order to (a) enable registered users to login to the site, (b) determine borrowers’ eligibility for loans through our proprietary credit scoring process, (c) verify borrowers’ and investors’ identities, (d) establish borrowers’ and investors’ ability to make and request loans by verifying that they are at least 18 years of age, and (e) guard against potential fraud. This basic personal information includes:
- Your name (member registration)
- Your email address (member registration)
- Your date of birth (borrower/investor registration)
- Your home address and telephone number (borrower/investor registration)
- Your Social Security number (borrower/investor registration)
- Your Bank Account Information-such as account and routing number (borrower)
When you register as a borrower, we will use this information to pull a credit report from a credit bureau to determine your creditworthiness as well as to help investors assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during online person-to-person lending, such as:
- Generating borrower profiles on the site
- Assigning you a borrower credit grade based on your credit history and financial circumstances
- Enabling our financial services partners to implement automatic payments and fund transfers
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
- Implementing collection activities as needed
- Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
- Allow you to add new bank account information and save to your online profile
When you register as an investor, we will request some required and optional data in order to facilitate such activities as:
- Generating a investor profile on the site
- Enabling our financial services partners to implement fund transfers and the receipt of borrower payments
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
- Maintaining regular communications with you as may be necessary to execute transactions you request, such as submitting loan portfolios and transferring funds, etc.
In addition, we gather names and email addresses of people who contact us through our web site with questions about our company or lending/borrowing operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information.
Finally, we may collect information about your computer and your visits to our web site, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We use this aggregated information in the administration of our web site to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We use non-identifying and aggregated information to help optimize our web site based on the needs of our users. No personally identifiable information about any individual will ever be distributed to third party organizations without disclosure to you.
Communication from Our Site
When you register on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and confirmation of successful submissions of loan requests and portfolios. You will also receive progress updates on the status of loan requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any emails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and site operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback emails, you may opt out by writing to info@blackhawk inv.com or by following the unsubscribe instructions located at the bottom of each email communication.
Blackhawk Investments will send you email notifications from time to time, and these are required elements of your transactions on our web site, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or investor, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally you may not opt out of these service related emails.
How long will my information be stored?
Federal and state agencies require that Blackhawk Investments provide aggregated demographic and loan funding information about our loan applicants. We maintain electronic loan application information for funded/declined/withdrawn loans for a period of at least 7 years in accordance with federal and state laws.
How and When Your Information Is Shared With Other Parties
We do not sell, share, rent, or trade your personally identifiable information with third parties other than as disclosed herein.
Information is shared with other parties in the following ways:
- Required (such as name, address and email address) and optional information about borrowers and investors is displayed on profiles that members can update at any time; certain information is optional (such as load description and additional address or phone number) and you can choose not to supply it and/or can remove the optional information at any time
- Personal (such as gross income, length of employment) but not personally identifiable information about borrowers is contained in loan listings that can be viewed by all users
- Financial and credit information about borrowers is displayed to qualified investors on loan listing pages
- Information is shared directly between users and other or potential users (who are only able to view loan postings but do not have access to the full loan listings). Information shared directly by users might contain personally identifiable information (such as name and email address).
- Information may be shared with collection agencies or service providers but only if they are contractually obligated to keep such information confidential.
For privacy purposes, borrowers and investors remain anonymous on the site and are identified only by their screen names. Blackhawk Investments will assign a unique screen name to the each member. This automatic screen name is composed with the concatenation of the letters “PF” and a random and unique 5 digit-number. Borrowers will be able to see the screen names of their investors and vice versa. The loan listing pages include borrowers’ credit grades and other financial information that is shown to qualified investors so that they can effectively evaluate loan requests. Loan listings also contain certain personal information (such as name and email address) and, in some cases, answers to questions posed by investors that are incorporated into loan listings.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is reasonably necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site.
Blackhawk Investments works with a number of trusted partners that perform vital functions as part of our operations, including without limitation credit bureaus, collection agencies, electronic payment service providers, and customer support call centers. Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We also may disclose information about you to companies that service, maintain, or process for us your transactions and accounts. For example, we provide information to companies that prepare and mail account statements and transaction confirmations.
These third parties are prohibited from using your personal information for promotional purposes.
Other types of entities might we disclose nonpublic personal information
In addition, we disclose nonpublic personal information (such as name, address and social security number) to nonaffiliated third parties as permitted by or required by law, or to cooperate with regulators or law enforcement authorities. These parties include government/regulatory organizations, such as the Internal Revenue Service (IRS) and the Securities and Exchange Commission (SEC), as well as any of the securities exchanges, self-regulatory organizations and states we are registered with and to parties under court order or subpoena that request this information. We may also disclose nonpublic personal information to nonaffiliated third parties for which you have provided your consent or you have directed us to make.
How Your Credit History and Blackhawk Investments Loan Data Are Shared
When you create a loan listing, you will be posting personal information on the site. This information includes details about your loan request (such as your name, email address and amount you wish to borrow), as well as your screen name, geographic location, Blackhawk Investments credit grade and a description of the loan request.
Qualified Blackhawk Investments investors will also see certain credit data (such as a range of your credit score) collected from or calculated based on your credit bureau file. It is necessary to allow prospective investors to see this information as they evaluate your loan request. The information displayed to investors includes a credit profile section and a credit history section.
The credit profile section includes your:
- FICO score range
- Debt-to-Income ratio (DTI)
- Gross income
- Property ownership status
- Current employer and tenure in your current position
- Existing debt payments (monthly snapshot of your current outstanding debt)
- Monthly payment amount for the loan being requested The credit history section includes the following information:
- The date your earliest reported credit line was opened (e.g., revolving credit)
- The total number of credit lines currently in your credit file
- The number of open credit lines currently in your credit file
- Your total balance for all open revolving credit lines
- Revolving line utilization rate, or the amount of credit you are using relative to all of your available credit
- The number of accounts on which you are now delinquent, and the past-due amount you owe
- The number of months since your last delinquency
- The number of 30+ days past-due incidences of delinquency in your credit file for the past 2 years
- The number of negative public records (e.g., bankruptcies and judgments, etc.) placed in your file and the number of months since the last record
- The number of inquiries by creditors during the past 6 months
If you successfully receive a loan through Blackhawk Investments, we will also display status information about your loan to your investors. You should not include your name or personally identifiable information in your loan request. Your payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to your investors. Loan status information is also aggregated and displayed on the statistics page.
Where You Can Find and/or Correct Your Information
You can access all of your personally identifiable information that we collect online and maintain by visiting your profile at www.Blackhawk Investments.com. This section of the site is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone number and bank account information at any time on the website, and if you need to change any other information in your profile you can contact us at info@Blackhawkinv.com. To protect your privacy and security, please contact us at info@Blackhawkinv.com to make changes to your sensitive account information.
Web-related Information Collection
Compliance with State and Federal Laws
Links to Other Sites
We May Make Changes to This Policy
You may contact us at:
Blackhawk Investments Corp
1793 Union Street
San Francisco, CA 94123
For purposes of federal privacy regulations, we identify our consumers as any individual that visits the Blackhawk Investments website. We identify our customers as any individual that has applied for a loan (which includes completing a loan application and Borrower Membership Agreement) and any individual that has applied to become an investor (which includes a Questionnaire and a Subscription Agreement). We may change the designation of any customer to that of a consumer at any time, at our sole discretion, based on factors that may include suspected fraud.