Privacy Policy & Notices

We may update the Bread Privacy Policy and Bread Privacy Notice from time to time. If we do this, we will post the changed Bread Privacy Policy or the Bread Privacy Notice on the Site and will indicate at the top of the page when this policy or notice was last revised. If any such changes impose additional obligations on you and if we deem any such change to be material, we may send you a notification regarding such changes (e.g. by sending you an email). In some cases, we may notify you in advance of the changes taking effect. 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 or Bread Privacy Notice, as applicable.

In any event, we will provide “Customers” (users of Bread Services with an outstanding loan) at least annually, a copy of the Bread Privacy Policy and Bread Privacy Notice, which will be provided electronically to the e-mail address provided at the time of application.

Information That You Provide

When you use the Bread Services on a merchant website, we may collect some information about you, which may include the following:

• Your name
• Your email address
• Your phone number
• Your date of birth
• Your identification number (Social Security Number or other taxpayer identification number)
• Your home street address
• Your personal financial information, including income information
• A debit card and/or f account number and its associated account information (your debit card information is processed by a third party; we do not have access to your payment card information or other information you provide to us to facilitate a payment by debit card); and
• Other identity information, such as photographs, government identification, and other similar information to protect against fraud and identity theft.

In the course of communicating with us, you may also provide information in writing, through our website, including through our “Contact Us” feature or any other customer service tools, or over the phone which will be recorded and maintained in order to provide the Bread Services to you, to improve Bread Services for other Customers, or as required by law.

You agree to promptly notify us if there are any changes to your personal information by calling us at (844) 992- 7323 or writing to us at Bread at P.O. Box 1264, New York, NY 10276.

Information We Collect from Third Parties

We may also obtain information about you from third party vendors or use third party vendors to verify the information you have provided to us. For example, we work with identity verification companies that will help us identify you and other vendors that help us gather information to prevent potential fraudulent transactions.

Third Party Vendor Information:

One of the third parties we use to collect and track user statistics and trends related to our Site and services is Upland Software, Inc. through its LeadLander product offering (“LeadLander”). LeadLander’s privacy policy and how the LeadLander services operate and use data from our sites and services is available at: http://www.leadlander.com/privacy.html. As part of our use of our Site we will install cookies onto your computer on behalf of LeadLander. You acknowledge and accept the placement of such cookies which will collect data about your use of our Site and the Bread Services and other sites and services which utilize LeadLander’s services. In addition, if you provide us with personal information (including name, e-mail address, company affiliation and similar personally identifying data) we may provide this information to LeadLander so they can associate it with the cookie we have installed on your computer which will allow them to identify you on other sites which utilize the LeadLander service and share your information with the third parties who operate those sites.

We may also use a service called Crazy Egg which collects anonymous data about visitors to our website. Crazy Egg’s current privacy policy can be found at https://www.crazyegg.com/privacy and its opt-out feature at https://www.crazyegg.com/opt-out.

Information We Collect Automatically

In order to help us further identify you to protect against fraud and identity theft, and for other purposes (including, for example, to improve our product or services or to market to you), our technology may gather further information about you, which information may include the following:

• The type of device you are using to access the Bread Services or the Site;
• Your device’s IP address;
• Your device’s location information and any other information sent to us by the device; and
• Other information about your interaction with the Bread Services on any merchant website or the Site.

Like many online services, we use cookies or other anonymous identifiers to collect information about you. We may also gather and store “clickstream information,” including information regarding your use of our Site directly or through service providers, including web beacons, page tags, pixels or similar tools and information about your computer, the type of browser you are using, your internet service provider, your page views, pathways to and from the Site, referral URL, data from third party analytics or marketing companies regarding the interaction with any web-based advertising, and your operating system. You can control the use of cookies at the individual browser level. If you reject cookies, you may not be able to use the Bread Services or access the Site.

We use various analytics services, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), as well as Heap and FullStory on the Site and through the Bread Services. These analytics services use cookies or other tracking technologies to help us analyze how users interact with and use the Site or use the Bread services, compile reports on activity and provide other services related to activity and usage. These technologies may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. The Site and Bread Services do not use analytics services to gather information that personally identifies you. The information generated by analytics services will be transmitted to and stored by the individual analytics service provider and will be subject to the providers’ privacy policies.

You can control the information provided to Google and opt out of certain ads provided by Google by using of the of the methods set forth in http://www.google.com/policies/privacy/partners/ or use the Google Analytics opt out browser add-on at http://tools.google.com/dlpage/gaoptout?hl=en

We will retain your information in accordance with our data retention policies even after you have ceased to be a Bread Customer.

We may use your information for everyday business purposes and marketing purposes, including to:

• Process transactions with you and otherwise to maintain your online account with us;
• Market the Bread Services or our Merchant partners’ products to you;
• Contact you by mail, telephone, text message or email, in connection with your Bread account or to deliver updates to our services (for example, we may use email to send you information about Bread products or services and new offers which we think may interest you);
• Develop new products and services or improve them and your experience with them;
• Support internal business operations, including assessing and managing risk and meeting legal and regulatory requirements;
• Provide technical support for using the Bread Services;
• Monitor and analyze trends and usage;
• Comply with contractual obligations, relevant industry standards and our policies;
• Verify your identity, prevent or detect fraud or other unauthorized or illegal activity;
• Operate, evaluate and improve our business (including developing new products and services, performing data analytics, and performing accounting, auditing and other internal functions);
• Respond to your requests;
• Resolve disputes; and
• Enforce this Privacy Policy, the Terms of Use, and any other terms that you have agreed to, including to protect the rights, property, or safety of us, our users, or any other person or the copyright-protected content of the Bread Services.

We may use or combine information that we collect through other sources or from service providers to enhance, expand or verify the accuracy of our records, or for other reasons. Data collected from a particular browser, device or application may be used with another linked browser, device or application.

By using Bread Services, you authorize us to share with the non-affiliate merchant on whose website you are using the Bread Services (the “merchant”) for their marketing purposes and other nonaffiliated third parties (for example, marketing companies) to market the Bread Service or the merchant’s products and services to you, certain information that is a part of or related to your application for Bread Services, including, but not limited to, your name, e-mail address and whether or not you were pre-qualified to use the Bread Service, as permitted by law. You may opt out of this sharing at any time by calling us at (844) 992-7323 or emailing us at support@getbread.com.

We may share your information with other third parties, including the following:

• Nonaffiliated vendors and partners (our “service providers”), including vendors who assist in underwriting, documents storage, fraud prevention, and collections, to allow them to perform the services they have agreed to provide us;
• Subject to your consent and right to opt-out as described above, the non-affiliate merchant on whose website you are using the Bread Services (the “merchant”) for their marketing purposes and other nonaffiliated third parties (for example, marketing companies) to market the Bread Service or the merchant’s products and services to you;
• With regulators, auditors, or our partner bank, Cross River Bank, in connection with an audit, routine inquiry, or to fulfill our contractual or legal obligations;
• Financing partners to Lon Operations LLC, its parent company, or its affiliates to fulfill certain contractual obligations;
• Third parties who may purchase your loan (or an interest in the loan), or the rights to service such loan;
• Nonaffiliated third parties, including regulatory bodies, law enforcement officials, governmental agencies, and courts, in response to a judicial proceeding, court order, or legal process or for the purposes of preventing fraud or criminal activity, or as required by law or to protect our legal rights;
• Third parties with whom we may work in conjunction with or to whom we may license our technology;
• Affiliates of Lon Operations LLC who have a need to know such information for everyday business purpose; and
• With any third party in response to a legal or regulatory inquiry.

In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets, some of the personal information that we hold may be among the assets transferred to a buyer or other successor. We may transfer to another business or non-affiliated entity or its affiliates, advisors or service providers some or all information about you in connection with, or during negotiations of, any joint marketing relationship, merger, acquisition, sale of assets or any line of business, change in ownership control or financing transaction. If we do, we may not limit how such other party may use or further transfer your information.

We may also share with third parties – such as advertisers – aggregated or de-identified information and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing such aggregated or de-identified data.

We may share information in other ways if you give us consent or direct us to do so.

If you are a resident of California, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Bread or its subsidiaries to a third party for the third party’s direct marketing purposes. The right granted to California residents applies only to their direct activities within the State of California. To make such a request please sent an email to support@getbread.com or write to us as:

Bread
P.O. Box 1264
New York, NY 10276

We have adopted a security policy and certain safeguards intended to protect your information against unauthorized access, which may include firewalls, data encryption and restricting access to your personal information only to those employees or contractors who have a need to know such information to carry on our operations. These safeguards are reviewed and adjusted periodically based on ongoing risk assessments.

Some of our employees, contractors and representatives may have access to your information. Wherever possible, our policies and procedures may limit access to your information to those employees, contractors, and representatives who have a need for such information to perform their job functions.

Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that the information collected about you will always remain private when using the Bread Services.

The Bread Privacy Policy and Bread Privacy Notice only cover your use of the Bread Services or access to the Site. Merchants through which you purchase products or services using Bread Services may have different privacy policies with respect to the handling of your information. In addition, merchants which sell products that are health related may have other requirements with respect to the collection and use of your information. The Bread Services are not, and are not intended to be, a part of merchants’ privacy policies. Before providing them with your personal information, 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.

You can access your personal information by logging into your account at https://members.getbread.com. You can update your bank account information through the account portal and if you need to change any other information you can contact us at support@getbread.com or (844) 992- 7323. You agree to notify us promptly of any changes to your personal information.

Your use of the Site and/or Bread Services is intended for use only in the United States and states where Bread Services are available. The Bread Services are intended only for persons aged eighteen (18) years or older (nineteen (19) years of age in Alabama or Nebraska). While certain merchant’s products may be sold outside the United States, including in the European Union, the Bread Services and the Site are not marketed to or intended to be used by any non-United States resident.

We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to use Bread Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us immediately at legal@getbread.com.

Do Not Track Signals

Our Site does not support Do Not Track (“DNT”) at this time. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit http://www.donottrack.us/