Privacy Policy

1. Who we are and what this policy covers

Lead Harbor is a personal loan lead generation network operated by [Lead Harbor legal entity name] ("Lead Harbor", "we", "us"). We connect people looking for a loan with lenders and lending marketplaces ("Advertisers") through forms operated by us and by our approved marketing partners ("Publishers").

This Privacy Policy explains what personal information we collect, how we use and share it, and the choices and rights you have. It applies to:

• our website at [leadharbor.com] and our publisher portal (together, the "Sites");
• loan-request forms that we host or that Publishers connect to us (the "Forms");
• our communications with Publishers, Advertisers, and consumers.

Lead Harbor is not a lender and does not make credit decisions. When we pass your loan request to an Advertiser, that Advertiser's privacy policy governs what it does with your information from that point on.

By using the Sites or submitting a Form, you agree to this Privacy Policy. If you do not agree, please do not use them.

2. Information we collect

2.1 Information consumers give us through a Form

To match you with lenders, a Form may ask for:

• Identity: name, date of birth, Social Security number, driver's license or state ID details, citizenship or residency status;
• Contact: street address, email address, mobile and home telephone numbers;
• Loan request: amount requested, purpose, and how soon you need funds;
• Employment and income: income source, employer name and phone, job title, time employed, monthly income, pay frequency, and next pay dates;
• Banking: bank name, account type, routing and account numbers, time with the bank, and whether you receive direct deposit;
• Financial profile: self-reported credit rating, home ownership, military status, and existing debts;
• Consent records: the disclosures shown to you, your agreement to them, the date and time, and a third-party consent certificate where used.

Social Security numbers, financial account numbers, income, and government ID details are sensitive information. We collect them only when needed to obtain a loan offer for you and treat them with additional safeguards.

2.2 Information Publishers and Advertisers give us

When you apply for or manage a Publisher or Advertiser account we collect your name, company name, business address, country, email, phone, messenger handle (for example Teams or Telegram), website URLs, traffic types, tax identification and tax forms, payment details such as bank or PayPal information, and the content of your communications with us.

2.3 Information collected automatically

When you use the Sites or a Form we and our service providers automatically collect device and usage information: IP address, approximate location derived from it, browser and operating system, device identifiers, referring URL, the pages and offers you view, the fields you complete, timestamps, and click and session identifiers such as a Publisher's sub-IDs. We collect this using cookies, pixels, scripts, and server logs, as described in Section 5.

2.4 Information from other sources

We may receive information about you from Publishers who direct you to a Form, from Advertisers (for example whether a lead was accepted, contacted, or funded), from identity, fraud, and consent verification services, and from public or commercial databases used to validate contact details.

3. How we use information

We use personal information to:

• match loan requests with lenders, which is the core purpose of the Forms, including sending your request to Advertisers whose criteria you appear to meet and redirecting you to an Advertiser's site when one accepts it;
• validate and protect: check that information is accurate and complete, detect and prevent fraud, duplicate submissions, bots, and abuse, and enforce our agreements;
• operate the Program: create and manage accounts, track clicks and leads to the responsible Publisher, calculate and pay Publisher earnings, bill Advertisers, and provide reporting;
• communicate: respond to enquiries, send service messages about your request or account, and, where permitted, send marketing about loan offers and related financial products (see Section 7 for how to opt out);
• improve and analyze: understand how the Sites and Forms are used, test and improve their performance, and develop new features;
• comply with law: keep records required by lending, tax, anti-fraud, and consumer protection laws, respond to lawful requests, and document consent under the TCPA and similar rules;
• other purposes that we describe when we collect the information or that you consent to.

We may combine information from different sources for these purposes. We may also create aggregated or de-identified data that no longer identifies you and use it for any lawful purpose.

4. How we share information

4.1 Advertisers

When you submit a Form, we share your loan request, including sensitive information, with one or more Advertisers so they can evaluate it and, if they accept, contact you and make you an offer. Depending on the offer, the Advertiser may be a lender, a lending marketplace that in turn shares your request with its own network of lenders, or a licensed loan broker. Advertisers may perform credit checks or verify your information with third parties under their own policies.

In most cases your request is first offered to Advertisers in a limited form that does not include your name, contact details, Social Security number, or account numbers. Full details are sent only to the Advertiser that accepts your request. Under some state privacy laws, this sharing for value is treated as a "sale" of personal information. See Section 8 for how to opt out.

4.2 Publishers

We report to the Publisher that referred you whether a lead was generated and accepted and the amount earned, tied to the click and sub-ID identifiers the Publisher supplied. We do not give Publishers your loan request details unless you submitted them on a form the Publisher operates.

4.3 Service providers

We use vendors that host our infrastructure, deliver email and SMS, verify identity and consent, screen for fraud, process payments, provide analytics, and support customers. They may access personal information only to perform services for us and must protect it.

4.4 Legal, safety, and corporate

We may disclose information to comply with law, subpoenas, or regulatory requests; to enforce our terms and protect the rights, property, and safety of Lead Harbor, our users, or others; to investigate fraud; and in connection with a merger, financing, acquisition, bankruptcy, or sale of all or part of our business, in which case the recipient will be bound by this Policy for the transferred information.

4.5 With your direction or consent

We share information with other parties when you ask us to or agree to it.

5. Cookies and tracking technologies

We and our partners use cookies, local storage, pixels, and similar technologies to keep the Sites working, remember your session and preferences, attribute traffic and leads to Publishers and their campaigns, measure performance, and detect fraud. Some are session-based and expire when you close your browser; others persist for up to [e.g. 24 months].

You can control cookies through your browser settings. Blocking essential cookies may prevent the Sites or Forms from working. Our Sites do not currently respond to browser "Do Not Track" signals, but we do honor opt-out preference signals as described in Section 8 where the law requires it.

6. Consent to be contacted

When you submit a Form you will be asked to consent to receive calls, texts, and emails about your loan request from Lead Harbor and the Advertisers who receive it, including through automated dialing systems and prerecorded or artificial-voice messages. Consent is not a condition of obtaining a loan and you may withdraw it at any time. Message and data rates may apply.

We record the exact consent language shown to you, the date and time, your IP address and device, and where used, a certificate from a third-party consent verification service. We keep these records to demonstrate compliance with the Telephone Consumer Protection Act and similar laws and share them with the Advertisers that receive your request.

To stop text messages, reply STOP to any message. To stop calls, tell the caller or email [[email protected]]. Each Advertiser manages its own contact preferences, so you may need to tell them separately.

7. Your choices

• Marketing email: use the unsubscribe link in any marketing email from us. We will still send service messages about an active request or account.
• Text messages: reply STOP to opt out, or HELP for assistance.
• Cookies: adjust your browser settings as described in Section 5.
• Account information: Publishers and Advertisers can review and update most account details in the portal or by contacting their account manager.
• Loan requests: you can ask us to stop sharing a submitted request with additional Advertisers by emailing [[email protected]]. Requests already delivered to an Advertiser are governed by that Advertiser's policy.

8. Your privacy rights

Depending on where you live, you may have rights under state privacy laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and similar laws in Colorado, Connecticut, Oregon, Texas, Virginia, and other states. Subject to legal limits and verification, these may include the right to:

• know the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties we shared it with;
• access a portable copy of the personal information we hold about you;
• correct inaccurate personal information;
• delete personal information we collected from you, subject to exceptions such as completing a transaction you requested, security and fraud prevention, and legal record-keeping;
• opt out of the sale or sharing of your personal information and of targeted advertising;
• limit the use of sensitive personal information to purposes necessary to provide the service you requested;
• not be discriminated against for exercising these rights.

8.1 California notice at collection

In the preceding 12 months we collected the categories of personal information described in Section 2: identifiers, personal records described in California Civil Code §1798.80(e) (including financial information), protected classification characteristics such as age and military status, commercial information, internet activity, geolocation derived from IP address, professional and employment information, sensitive personal information (Social Security number, government ID, financial account details), and inferences drawn from the above. We use them for the purposes in Section 3 and disclose them to the categories of recipients in Section 4. We sell or share identifiers, personal records, commercial information, employment information, and sensitive personal information with Advertisers as described in Section 4.1. We do not knowingly sell or share the personal information of consumers under 16.

8.2 How to exercise your rights

Submit a request by emailing [[email protected]] with the subject "Privacy request", or by calling [toll-free number]. To opt out of sale or sharing you can also use the "Do Not Sell or Share My Personal Information" link in the footer of our Sites. We will verify your identity by matching the information you provide against the information we hold, and may ask for additional details. An authorized agent may submit a request on your behalf with written permission; we may still verify your identity directly.

We aim to respond within 45 days and will tell you if we need more time. If we decline a request, we will explain why and, where the law provides it, how to appeal by replying to our response.

8.3 Opt-out preference signals

Where required by law, we treat a Global Privacy Control signal from your browser as a request to opt out of sale and sharing for that browser.

9. International visitors

The Sites and Forms are intended for consumers located in the United States and we do not knowingly accept loan requests from elsewhere. Publisher and Advertiser accounts may be held outside the United States. Information we collect is stored and processed in the United States, where privacy laws may differ from those of your country. If you are in the European Economic Area, the United Kingdom, or another jurisdiction with data protection laws, you may have additional rights, including to object to processing and to lodge a complaint with a supervisory authority. Our legal bases for processing account information are performance of our contract with you and our legitimate interests in operating and protecting the Program. Contact [[email protected]] to exercise these rights.

10. How long we keep information

We keep personal information for as long as needed for the purposes described in this Policy and as required by law. In general:

• loan requests and related consent records are kept for [e.g. five years] to meet TCPA, lending, and dispute-resolution requirements;
• Publisher and Advertiser account, payment, and tax records are kept for the life of the account plus [e.g. seven years];
• server logs and analytics data are kept for [e.g. 24 months];
• information subject to a legal hold or investigation is kept until the matter is resolved.

When information is no longer needed we delete it or de-identify it so it can no longer be associated with you.

11. Security

We protect personal information with administrative, technical, and physical safeguards appropriate to its sensitivity, including encryption in transit and at rest, access controls and logging, network segmentation, vendor due diligence, and staff training. Sensitive fields such as Social Security and account numbers are transmitted to Advertisers only over encrypted connections.

No system is completely secure. If we learn of a breach affecting your personal information we will notify you and the relevant authorities as required by law. You can help by using a strong, unique password for the portal, enabling any additional authentication we offer, and contacting us immediately if you suspect misuse of your account.

12. Children

The Sites and Forms are not directed to anyone under 18 and we do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, contact [[email protected]] and we will delete it.

13. Third-party sites and services

The Sites and Forms may link to or redirect you to websites operated by Advertisers, Publishers, and other third parties. We are not responsible for their content or privacy practices. We encourage you to read the privacy policy of every site that asks for your information.

14. Changes to this policy

We may update this Policy from time to time. When we do we will post the new version here and update the effective date. If a change materially affects how we use information already collected, we will provide additional notice, such as by email or a prominent notice on the Sites, and obtain consent where the law requires it. Your continued use after a change takes effect means you accept the updated Policy.

15. Contact us

Questions, requests, or complaints about privacy can be sent to:

California residents may also contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.