Privacy Policy and Notices


Last Updated: December 8, 2017

This privacy policy (the “Bread Privacy Policy”) describes how Lon Operations LLC (d/b/a Bread and Bread Operations) and its affiliates, subsidiaries, agents and assigns (collectively, “Bread”, “we”, or “us”) collect and use the personal information you provide when “you” (any user of our Site or the Bread Services (as defined below)) use any Bread online product or services, including use of Bread’s technology and interface to determine potential eligibility for a loan or to request a loan from Cross River Bank, a New Jersey state-charted bank, Member FDIC, as well as to manage your account (the “Bread Services”) and when you access or use the Bread website at www.getbread.com, including derivatives of the Site such as the member’s portal where you can access information on your account (collectively, the “Site”).

To see how we use and share your information, see “Information Shared With Other Parties” below.

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 and Bread Privacy Notice carefully. The privacy and the protection of your personal information are important to us and this policy and privacy notice describe how we collect and store your information, how we share that information, and your choices regarding how the information is used or shared.

Bread loans are made by Cross River Bank, a New Jersey state-charted bank, Member FDIC (the “Bank”). For information about how the Bank collects, uses, and discloses your personal information obtained in connection with your loan, see the Cross River Bank Privacy Notice.

Changes to Bread Privacy Policy

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 or if we deem any of the change to be material, we will 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 “Consumers” (users of Bread Services who have at any time been prequalified for financing), as well “Customers” (users of Bread Services with an outstanding loan) at least annually, by December 1, 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.

We may change this Privacy Policy or the Privacy Notice. If you continue to use the Bread Services or the Site, you are agreeing to the new Bread Privacy Policy and Privacy Notice. The dates on the top shows when the Bread Privacy Policy was last updated. Customers and consumers of Bread Services will receive a copy of the Bread Privacy Policy and Bread Privacy Notice annually by e-mail.

Information We Collect About You

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
  • A debit card and/or number and its associated account information (your debt 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 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 and as required by law.

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

We ask for and collect personal information about you. This information is used for many purposes, including verifying your identity.

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.

We may obtain information about you from third party vendors or use third party vendors to verify the information you provide to us.

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 email address
  • 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 Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on the Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site’s activity and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. The Site does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s 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 may collect 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 as long as necessary to provide the Bread Services to you. We may retain information for longer periods of time and even after you have ceased to be a Bread Customer, in order to prevent fraud, if this is 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 We May Use Your Information

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 to you;
  • Contact you by mail, telephone, text message and 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 me think may interest you);
  • Develop new products and services and 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, preventing or detecting 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 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 browsers, device or application may be used with another linked browser, device or application.

We will use your information for our everyday business purposes, to facilitate the use of the Bread Service, and to market to you.

Information Shared With Other Parties

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, visiting us online at www.getbread.com, 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”) 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;
  • 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;
  • Affiliates of Lon Operations LLC who have a need to know such information for everyday business purposes;
  • 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 entity or its affiliates, advisors or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control or financing transaction.

    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 de-identified data.

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

    Prospective Partners

    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 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.

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, visiting us online at www.getbread.com, or emailing us at support@getbread.com. We may also share your information with non-affiliate vendors and partners for everyday business purposes and for marketing purposes, our affiliates for everyday business purposes, in response to a legal inquiry.

Safeguarding Your Information

We take reasonable precautions to protect your information, protect against unauthorized access to your information, and to dispose of your personal information. We have adopted a security policy intended to reflect industry standards. Our security policy requires us to monitor the risk of any threats to administrative, technical, and physical safeguards we have put in place to protect your information. The safeguards may include, at a minimum, firewalls and 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 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.

We have security safeguards intended to ensure the privacy of your information and a security policy to monitor risks.

Other Sites

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. 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.

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 https://members.getbread.com. You can update your password, cellular phone number, email address, physical address, phone number, bank account information and other personal 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 agree to notify us promptly of any changes to your personal information.

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

Other Limitations

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).

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 18 may have provided us personal information, please contact us immediately at legal@getbread.com.

Your use of the Site and/or Bread Services is intended for use only in the United States and the 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).We do not knowingly collect or solicit personal information from anyone under the age of 13. 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/

Bread Privacy Notice

Rev. November 2017

What does Lon Operations LLC (“Lon”) 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

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 customers’ personal information; the reasons Lon chooses to share; and whether you can limit this sharing.
Reasons We Can Share Your Personal Information Does Lon 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 We don’t share.
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 nonaffiliates to market to you Yes Yes
To limit our sharing
  • Call (844) 992-7323 – our menu will prompt you through your choice(s)
  • Visit us online at www.getbread.com
  • Contact us at support@getbread.com.

Please note:

If you are a new customer, we can begin sharing your information 45 days from the date we sent this notice; however we may immediately share your information with merchants and nonaffiliated marketing companies pursuant to the authorization and consent you provide in the “How and When Your Information Is Shared With Other Parties” section of our Privacy Policy. 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
What we do  
How does Lon 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 Lon collect my personal information?

We collect your personal information, for example, when you

  • Apply for a loan or open an account;
  • Give us your contact information or provide account information; or
  • Use your debit card

We also collect your personal information from others, such as credit reporting agencies, identity verification service providers, 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 additional information on your rights under state law.

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 can include merchants with which you use our services, nonaffiliated marketing companies, and Lon’s service providers.
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
Other Important Information  
California Customers In accordance with California law, we will not share information we collect about California residents with nonaffiliates, unless the law allows. For example, we may share information with your consent or to service your accounts. We will limit sharing among our companies to the extent required by California law.
Vermont Customers We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be obtained by calling (844) 992-7323.

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 Residents. For 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.