Privacy Policy and Notices


Last Updated: October 1, 2015

This privacy policy (the “Bread Privacy Policy”) describes how Lon Operations LLC (d/b/a Bread and Bread Operations) and its affiliates or subsidiaries (collectively, “Bread”, “we”, or “us”) collect and use the personal information you provide when you use the Bread Services (as defined in our Terms of Use) and when you access or use the Bread website at www.getbread.com (the “Site”).

The “In a nutshell…” summaries next to each section are for reference purposes only, may not summarize all of the rights and obligations contained in that section and are not contract terms. As such, please read the Bread Privacy Policy carefully. The privacy and the protection of your personal information are important to us and this policy describes how we collect and store your information and your choices regarding how we may use that information.

Loans available through Bread are provided by Cross River Bank (the “Bank”). Personal information is provided to the Bank in connection with each application. For information about how the Bank collects, uses, and discloses your personal information in connection with your loan, see the Cross River Bank Privacy Notice below.

Changes to Bread Privacy Policy

We may update the Bread Privacy Policy from time to time. If we do this, we will post the changed Bread Privacy Policy on the Site and will indicate at the top of the page when this policy was last revised. If any such changes impose additional obligations on you or if we deem any of the change to be material, we will inform you of these changes. Your continued use of the Bread Services or the Site after we have made any such changes will constitute your acceptance of the new Bread Privacy Policy.

We may change this Privacy Policy. If you continue to use the Bread Services or the Site, you are agreeing to the new Bread Privacy Policy. The date on the top shows when the Bread Privacy Policy was last updated.

Information We Collect About You

When you register to use the Bread Services by applying for a loan (including pre-qualification for a loan) on a merchant website or registering on the Site, we collect your name, your email address, your phone number, date of birth, an identification number, and home or business street address. We may collect additional information from you in order to enable us to verify your identity. As part of your continued use of the Bread Services, we may also collect financial information about your bank account or your debit card information.

In order to help us further identify you, we may also gather information about the device you are using to access the Bread Services or the Site, including any information about the device, its location, the device’s IP address and any other information sent to us by the device. We may also gather information about your use of our Site or any merchant website, including your interaction with the loan application, your past use of the Bread Service, any past purchases that you’ve made using the Bread Service and any actions you have taken relating to your application.

We may also obtain information about you from third party sources. For example, we work with identity verification companies that will help us identify you. As part of the credit underwriting process, we will obtain information about you, including your personal information and credit report, from credit reporting agencies.

We ask for and collect information about you. This information is used for many purposes, including verifying who you say you are and assessing your creditworthiness. We may also verify the information you provide with third party sources. These parties may also give us additional information about you.

Web Information Collection

We use cookies or other anonymous identifiers to collect information about you. We may also gather and store information about the type of browser you are using, your internet service provider, or your operating system. We may use this information to remember your settings when you use the Bread Service or access the Site, to analyze trends, to help with our marketing efforts and to otherwise improve our services. We may share this information with our partners and vendors. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Bread Services or access the Site.

We may collection information about how you use the Bread Services or the Site and share this with our partners and vendors.

Retaining Your Information

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

For legal and other reasons, we need to retain the information we collect about you. We will only use this information for limited purposes.

How and When Your Information Is Shared With Other Parties

We work with many vendors and partners that help us with our operations generally and help us perform services on behalf of the Bank. These vendors and partners include identity verification services, credit reporting agencies and other data providers, servicing companies and electronic payment service providers. We may share your information with any one of these vendors and partners to allow them to perform the services they have agreed to provide us. In each case, we have an agreement with the vendor or partner that will require them not to disclose or sell you information to a third party (unless required for them to provide services to us or if required by law).

We may share your information with the merchant on whose website you are using the Bread Services.

We may also share your information in response to a judicial proceeding, court order, or legal process or for the purposes of preventing fraud or criminal activity, as required by law or to protect our legal rights.

Cross River Bank will have access to any information you provide to us. Please see Cross River Bank’s privacy notice below.

We may share your information with vendors and partners or our affiliates who help us provide our services. We may share your information with the merchant on whose website you are using the Bread Services. We may also share your information in response to a legal inquiry, if needed. Cross River Bank will have access to the information you provide to us.

How We May Use Your Information

Some of our employees and representatives may have access to your information. We have in place policies and strong safeguards to ensure that your information is protected and kept confidential.

We will use your information for our everyday business purposes, including working with the Bank to assess your eligibility and creditworthiness for obtaining a loan, processing transactions with you, collecting repayment amounts on your loan, resolving disputes, and otherwise maintaining your account with us. We may also use your information to reduce the risk of fraudulent transactions and to better assess credit risk. For these reasons, some of our employees and representatives and agents working on our behalf may have access to your personal information. In each case, any employee, representative, or agent with access to your information will be required to comply with our policies on safeguarding your information and keeping your information confidential.

We will use your information for our everyday business purposes. As discussed above, we may share your information with vendors and partners and affiliates. We may also share your information with the merchant partner where you used the Bread Services.

How We Safeguard Your Information

We maintain strong security safeguards to ensure the security and confidentiality of your personal information, protect against any anticipated threats to the security of your personal information, protect against unauthorized access to your information, and ensure the proper disposal of your personal information. We have adopted a comprehensive security policy that complies with law and regulations and reflects industry standards.

Our security policy requires us to consistently monitor the risk of any threats to the administrative, technical, and physical safeguards we have put in place to protect your information. The safeguards include, at a minimum, firewalls and data encryption and restricting access to your personal information only to those employees who have a need to know such information to carry on our operations. Further, access to our physical office is restricted only to our employees and representatives. These safeguards are reviewed and adjusted periodically based on ongoing risk assessments.

We have strong security safeguards to ensure the privacy of your information and a security policy to consistently monitor risks. We take safeguarding your information very seriously.

Other Sites

The Bread Privacy Policy only covers your use of the Bread Services or access to the Site. Our merchant partners may have different privacy policies with respect to the handling of your information when you interact with the merchant’s website. You should consult their privacy policies to understand how any information you may have provided to merchants, or that the merchant may have accessed, will be handled.

This policy only covers the Bread Services and this Site. The merchant with whom you use the Bread Services will likely have their own privacy policies.

How You Can Correct Your Information

You can access all of your personal information by logging into your account at www.getbread.com/borrowerportal. You can update your password, cellular phone number, email address, physical address, phone number and bank account information at any time, and if you need to change any other information in your profile you can contact us at support@getbread.com.

You can, and should, update your information by logging into your account.

Compliance with State and Federal Laws

The Bread 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.

This policy may not contain your entire set of privacy rights, which may vary from state to state. We may need to retain and use your information for certain purposes to comply with federal and state laws.

Confidentiality, Security, and Integrity of Customer Information

Employees of Bread are very educated about the importance of confidentiality and privacy. Management will take steps necessary to ensure only employees with a legitimate business reason for knowing personally identifiable customer information shall have access to such information. To the extent practicable, access will be limited by computer access codes and granting limited access to areas in which sensitive customer information is retained. Employees will be informed at the time of their initial employment of these standards. Violation of this policy through misuse of sensitive information will result in disciplinary action against the offending individual.

Bread Privacy Notice

(Rev. 10/2015)

WHAT DOES BREAD 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 or service you have with us. This information can include:

  • Social Security number and Account balances
  • Payment history and Transaction history
  • Credit history and Credit scores

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

How? All financial companies need to share personal information to run their everyday business. In the section below, we list the reasons financial companies can share their personal information; the reasons Bread chooses to share; and whether you can limit this sharing.
Reasons We Can Share Your Personal Information Does Bread share? Can you limit this sharing?
For our everyday business purposes—such as to process your transactions, maintain your account(s), 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 No N/A
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 N/A
For nonaffiliates to market to you Yes Yes
To limit our sharing Call (844) 992-7323 – our menu will prompt you through your choice(s) or visit us online at www.getbread.com or contact us at support@getbread.com.Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice, unless applicable law permits us to share the information immediately. 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.
Questions? Call (844) 992-7323 or go to www.getbread.com
Who we are  
Who is providing this notice? Lon Operations LLC (d/b/a Bread)
What we do
How does Bread protect my personal information? We restrict access to your information to those employees who need to know it to provide products or services to you.
How does Bread collect my personal information?

We collect your personal information, for example, when you

  • Apply for a pre-qualification rate or loan or
  • Provide your bank account information for repayment or
  • Give us your contact information

We also collect your personal information from others, such as credit reporting agencies, identity verification service providers, 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 nonaffilliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions  
Affiliates

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

  • Our affiliates include Lon Holdings LLC and Lon Administration LLC.
Nonaffiliates

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

  • Nonaffiliates we may share with include merchant partners that use the Bread Services
Joint marketing

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

  • We do not share your information for joint marketing with nonaffiliated financial companies

Cross River Bank Privacy Notice

(Rev. 11/2015)

WHAT DOES CROSS RIVER BANK 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 or service you have with us. This information can include:

  • Social Security number and Account balances
  • Payment history and Transaction history
  • Account transactions and Wire transfer instructions
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 Cross River Bank chooses to share; and whether you can limit this sharing.
Reasons We Can Share Your Personal Information Does Cross River Bank share? Can you limit this sharing?
For our everyday business purposes—such as to process your transactions, maintain your account(s), 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 No We don’t share
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes—information about your transactions and experiences No We don’t share
For our affiliates’ everyday business purposes—information about your creditworthiness No We don’t share
For nonaffiliates to market to you Yes Yes
To limit our sharing

Call toll-free 1-877-55CRB55 – our menu will prompt you through your choice(s).

Please note: If you are a new customer, we can begin sharing your information 30 days from the date we provided or 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.

Questions? Call toll-free 1-877-55CRB55 or go to www.crossriverbank.com
What we do
How does Cross River Bank 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. We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.
How does Cross River Bank collect my personal information?

We collect your personal information, for example, when you

  • Open an account or Apply for a loan
  • Make deposits or withdrawals from your account or Provide employment information
  • Give us your contact information

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 nonaffilliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account
Definitions  
Affiliates

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

  • Cross River Bank does not share with our affiliates. Our affiliates include CRB Group, Inc., CRB Investment Company, Inc., CRB RET Inc.
Nonaffiliates

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

  • Nonaffiliates we share with can include loan finance companies
Joint marketing

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

  • Our joint marketing partner(s) include loan finance companies.
Other important information

Special Notice For State ResidentsFor Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing-without your authorization.

For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing -without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing-without your authorization.

For Vermont Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization, and we will not share personal information with affiliates about your creditworthiness without your authorization.