Privacy Policy

This privacy policy applies to Springstone Financial, LLC, a subsidiary of LendingClub Corporation ("Lending Club"), regarding the Your Tuition Solution Program. This privacy policy describes how Your Tuition Solution collects and uses the personal information you provide on our application interface housed on our website, on the phone or in writing, including information you provide on applications or other forms. It also describes the choices available to applicants for financing regarding our use of your personal information. Your privacy and the protection of your sensitive personal 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.

Employee Conduct

Lending Club expresses its absolute commitment to integrity, and our corporate values and ethical standards and the associated business conduct we expect from all our employees. The Lending Club Code of Conduct includes very specific guidelines concerning the safeguarding of confidential information, which includes customer information. In general, these guidelines limit employee access to confidential information, and limit the use and disclosure of such information to specifically authorized processes and transactions. If it is determined that employees have violated the Code of Conduct, corrective action may be taken, including immediate dismissal.

Verification of Practices

Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information. These reviews may be conducted by our own internal staff, external accounting, auditing firms, issuing banks and government regulators. Included in these self-assessments and examinations are reviews of the controls and safeguards related to consumer privacy.

Introduction

This policy discloses which information we collect and how we use it, as well as the choices applicants for financing can make about the way your information is collected and used. We also explain how any personal 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 information is protected both electronically and physically.

In general, and as described in detail below, we collect several types of information from you:

  • Personal information required to verify your identity
  • Personal and financial information necessary to assess the eligibility of an applicant for financing to borrow money through Your Tuition Solution’s issuing banks
  • Information from education providers such as confirming the amount of services
  • Information about your visits to and use of this website or the websites of third-party services to help us maintain the appropriate features, functionality and user experience

Information We Collect from an Applicant for Financing

We collect personal and financial information from you while you use the application interface on our website, on the phone or in writing. Most of this collection occurs during the application process. Additional information may be gathered during your subsequent use of the website, in phone calls or by written correspondence, whenever you choose to provide it.

Certain personal information must be supplied during the application process, as indicated below, in order to determine a borrower’s eligibility for financing through issuing banks, verify a borrower’s identity, establish a borrower’s ability to request financing by verifying that they are at least 18 years of age, and guard against potential fraud. This basic personal information includes your:

  • Name (application)
  • Email address (application)
  • Date of birth (application)
  • Home address and telephone number (application)
  • Social Security number (application)

When you apply for financing through our issuing banks, we will use this information to pull a credit report from a credit bureau to determine your creditworthiness. We will also use your required information to facilitate activities and transactions that need to occur during the lending process, such as:

  • Maintaining regular communications with you concerning an application you initiate, such as requesting additional information or assistance or submitting a request for financing
  • Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
  • Enabling our financial services partners to implement automatic payments

We (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website as discussed further below.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. For additional information about how we collect and use your personal information, please see Exhibit A below.

Information We Collect from Educators Requesting to be a Participating Education Provider

We collect personal information from you while you use the registration form on our website, on the phone or in writing. Most of this collection occurs during the registration process. Additional information may be gathered during your subsequent use of the website or your online education center, in phone calls or in written correspondence, whenever you choose to provide it.

Certain personal information must be supplied during the registration process, as indicated below, in order determine your eligibility to participate in the Your Tuition Solution Program. This basic personal information includes:

  • Legal business name and education provider’s company name (registration)
  • Education provider's fax, telephone number, website and physical address (registration)
  • Education provider’s federal tax identification or Social Security number (registration)
  • Email addresses of individuals involved in an applicant’s financing (registration)
  • Education provider’s bank account information (submitted with Provider Agreement)

When you submit registration information to request to participate in the Your Tuition Solution Program, we will use this information to verify the identity of the education provider(s). We will also use the required information to facilitate activities and transactions that need to occur during the applicant financing process, such as:

  • Maintaining regular communications with the education provider concerning an application for financing or a completed funding, such as requesting additional information or assistance
  • Contacting the education provider if there is a problem completing a transaction or to discuss a refund, or a problem with an applicant's application
  • Enabling our financial services partners to implement automatic payments

We (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website, as discussed further below.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Communications from Our Site

When you submit an application on the application interface on our website, on the phone or in writing, you will receive email notifications regarding your application. These are transactional notifications that you cannot opt out of receiving as they are in place to provide the status of your application or provide you with documents related to your application. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations, or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

Links to Third-Party Websites

Your Tuition Solution is not responsible for the information practices employed by sites linked to or from our website. In most cases, links to non-Your Tuition Solution websites are provided solely as an access point to obtain information on products and topics that may be useful to the users of the Your Tuition Solution website. Third-party websites may have different privacy policies and/or security standards governing their sites.

How and When Your Information Is Shared with Other Parties

Information is shared with other parties in the following ways:

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 personal information when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

Your Tuition Solution works with a number of trusted partners that perform vital functions as part of our operations, including credit bureaus, education providers and issuing banks. We may share information with an education provider's office concerning the status of an application, whether a signed approval document has been returned and other information about an applicant for financing's account only for the purpose of processing a transaction. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform. Our partners are legally required to keep your information private and secure.

Testimonials

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@yourtuitionsolution.com

Social Media Widgets

Our website includes social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.

Notifications

Your Tuition Solution will send you email notifications from time to time, and these are required elements of your transactions on our website, 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 an application for financing is approved or declined, or for legal or security purposes. For example, these notifications involve changes to various legal agreements or site policies. Generally, you may not opt out of these service-related emails.

Web-related Information Collection

Technologies such as: cookies, beacons, tags and scripts are used by Lending Club, our analytics providers, and our marketing partners. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users' settings and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Log Files - As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Links to Other Sites

We may offer links to partners' sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled or to facilitate our customers' more effective use of our platform, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy and may have different privacy policies or approaches to the handling of information. Further, Your Tuition Solution has no control over the content of these sites. Please consult the privacy policies on these sites before you provide them with any of your personal information.

Lending Club Security Policy

Industry-leading Standards and Controls

Lending Club takes strong steps to safeguard your personal information. We maintain a comprehensive security program based on industry standards and best practices.

We take a defense-in-depth approach to implementing rigorous physical, administrative, and technical safeguards to ensure your information is safe from unauthorized access or misuse. The safeguards include preventive, detective, and corrective controls. Physical safeguards like access badges and a video monitoring system protect Lending Club and Your Tuition Solution computing infrastructure from unauthorized access. Administrative safeguards like a security training program, employment background checks, and acknowledgement of our Acceptable Use Policy ensure that your information is only accessed by trained and trusted staff based on business needs to provide services to you. Technical safeguards like perimeter security, industry standard encryption, two-factor authentication, and continuous monitoring ensure that your information is adequately protected with layered and complementary controls. The security safeguards are reviewed and adjusted periodically based on ongoing risk assessment. However, despite our substantial investment in protecting your personal information, ultimately no institution can guarantee its absolute security.

If you have any questions about security on our website, you can contact us at privacy@yourtuitionsolution.com

Encryption and Website Certificates

Industry standard encryption protects the information you share with us from the moment it leaves your computer until it reaches our systems. Look for the secure locked padlock on your browser to confirm the identity of the Lending Club website and that your connection is secure. Consult your Web browser documentation for more information.

Session Time-outs

We employ session time-outs to protect your account. You will be logged out of the site automatically after a period of inactivity. This reduces the risk of others being able to access your account if you leave your computer unattended.

We May Make Changes to this Policy

As technologies, laws and user needs change, our site and its features will also change. This policy may be updated from time to time as such needs dictate, and we will always communicate these changes to you by posting them on this website and/or by notifying you via email prior to the change becoming effective in the event of any substantive or material changes.

You may contact us at:
Your Tuition Solution
Attn: Compliance Department
1700 West Part Drive, Suite 310
Westborough, MA 01581
Phone: (800) 920-9777
Email: privacy@yourtuitionsolution.com

Exhibit A

Privacy Notice

Facts

What does Your Tuition Solution 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 you apply for. This information can include:

  • Social Security number and income
  • Account balances and payment history
  • Credit history and credit scores

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 Your Tuition Solution chooses to share; and whether you can limit this sharing.

When you are no longer our customer, we continue to share your information as described in this notice.

Reasons we can share your personal information

Does Your Tuition Solution share?

Can you limit this sharing?

For our everyday business purposes - such as to process your applications, 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

Yes

Yes

For our affiliates to market to you

No

We don't share

For nonaffiliates to market to you

No

We don't share

To limit our sharing

Call (800) 920-9777 or contact us at privacy@yourtuitionsolution.com
Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.

What we do

How does Your Tuition Solution 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 Your Tuition Solution collect my personal information?

We collect your personal information, for example, when you

  • Place an application through Your Tuition Solution
  • Give us your contact information
  • Provide documentation during your application process, including for verification purposes
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 creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?

Your Tuition Solution currently does not offer joint applications.

For prior joint applications, your choices will apply to everyone on your application - unless you tell us otherwise.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include LendingClub Corporation and LC Advisors, LLC.

Nonaffilates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Nonaffiliates we share with can include other financial services companies, lenders, insurance companies, retailers, membership clubs, or other consumer service providers.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Our joint marketing partners include other financial services companies, lenders, insurance companies or other consumer service providers.

Other Important Information

Nevada Residents: We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by calling (800) 920-9777. Nevada law also requires us to provide you with the following contact information:

Office of the Nevada Attorney General
100 North Carson Street
Carson City, NV 89701
Phone: (775) 684-1100
Email: AgInfo@ag.state.nev.us

Your Tuition Solution
1700 West Part Drive, Suite 310
Westborough, MA 01581
Phone: (800) 920-9777
Email: info@yourtuitionsolution.com