Kanmon, Inc.
This Privacy Policy has been updated effective August 31, 2021
Borrower Privacy Policy
This privacy policy (this "Privacy Policy") governs the collection, storage, and use of information and data collected by Kanmon Inc. or any of our U.S. affiliates (collectively, "Kanmon," "we", "us", or "our"), via our website at www.kanmon.com and its subdomains, by our mobile application, or by telephone, facsimile, email, or other means (collectively, and together with our website, "Kanmon Services").
We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use our website or any other Kanmon Services.
Please read this Privacy Policy carefully. By accessing and using this website or any other Kanmon Services, you confirm that you have read and understand this Privacy Policy in its entirety. You understand and acknowledge that we reserve the right to change or amend this Privacy Policy at any time, which will be reflected by the "effective" date above. Please check this webpage regularly to stay informed of updates to this Privacy Policy. If any material changes are made to this Privacy Policy, advance notice of the changes will be posted in the first section of this webpage as required by applicable law. You understand that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
Please also visit our Terms of Service which establish the rules, disclaimers, and limitations of liability governing your use of our website.
1. What information do we collect from you
A. Information provided by you directly or by your agent
Kanmon collects information when you use Kanmon Services and supplied by you or your designated agent during the application process, including but not limited to, the following information (as applicable):
- Borrowers
- Individual and business names
- Mailing address
- Business address
- Phone and e-mail details
- Bank account information
- Accounting account information
- Date of birth
- Social security number, drivers' license, or other government IDs
- Income, assets, debt, and other personal and business data
- Other information provided in correspondence with us, including by email, post facsimile, and telephone
B. Cookies and tracking technologies
When you use Kanmon Services, we and our third-party service providers may utilize cookies and other similar technologies (such as web beacons or pixel tags) to capture and remember certain information (collectively, "Technologies"). These Technologies help us to improve your website experience, provide you with better tools, and operate our business in other ways described under the heading "Why do we collect this information" below. You have the ability to disable cookies in your browser settings; however, doing so may affect the functionality of certain features of our website.
Analytics.We may also use Segment, Fullstory and other service providers to collect information regarding visitor behavior and visitor demographics on our Services, to provide tailored advertising, and to evaluate our marketing efforts. For more information about Segment Analytics, please visit www.segment.com. We do not process "do not track" (DNT) signals.
You may stop or restrict the placement of tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at networkadvertising.org, youronlinechoices.eu, youradchoices.ca/choices, and aboutads.info/choices. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings menu to exercise this choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners' use of this information for interest-based advertising purposes.
C. Device specific information and tracking technologies
When you use Kanmon Services, we and our third-party service providers may collect device specific information. This information, including but not limited to your internet protocol address, geographical location, browser type, operating system, MAC address, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, length of visit, and pages viewed, is saved automatically in log files. We use the information in these files to improve the functionality of our services and in other ways described under the heading "Why do we collect this information" below.
D. Information obtained from third parties
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
Information from financial partners to process your loan. In addition to collecting personal information supplied by you or your designated agent, we use unaffiliated third parties to gather data on borrowers and prospective borrowers, from financial institutions, consumer reporting agencies, and other information service providers for purposes described under the heading 'Why do we collect this information' below. This information includes the categories of information described above, and also includes:
- Government IDs
- Criminal records
- Household records
- Employment information, such as visa permit number
By using Kanmon Services and applying for a loan, you acknowledge that our unaffiliated, third-party providers will have the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution or consumer reporting agency, according to the terms of such third-party provider's privacy policy.
2. Why do we collect this information?
Kanmon may use information we collect about you to:
- determine your eligibility for a loan;
- obtain, upon your authorization, a credit report, references, and other information from credit bureaus or other third parties in connection with your loan application;
- verify your identity;
- detect and guard against potential fraud and identity theft;
- manage and monitor your Kanmon account and update your records;
- process your payments and other transactions;
- develop, maintain and improve our website, products, and services;
- detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity;
- improve customer acquisition through the use of advertising campaigns and other means, such as targeted marketing;
- enforce our agreements;
- carry out statistical analysis and market research and testing;
- comply with our legal and regulatory obligations, and carry out regulatory checks;
- make our website available to you and identify products and services you may be interested in; and/or
- send or facilitate communications with you.
Important Information About Procedures for Opening a New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
What this means for you:
When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.
3. How and when is your information shared with other parties?
We do not 'sell' your personal information as the term is defined under the California Consumer Privacy Act (CCPA), nor have we sold personal information in the preceding 12 months. Your information, as collected by or provided to us, may be shared by us (currently and in the preceding 12 months) with the following categories of third parties:
| Category | Examples | Category of Third Parties Information is Disclosed to |
|---|---|---|
| Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | Service Providers; Investors; Loan Partners |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, bank account information, | Service Providers; Investors; Loan Partners |
| Protected classification characteristics under California or federal law | Age (40 years or older). | Service Providers; Investors; Loan Partners |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Service Providers; Investors and Loan Partners (limited to records of personal property); Advertising Partners (limited to records of Kanmon products or services purchased, obtained, or considered) |
| Internet or other electronic network activity | Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement. | Service Providers; Advertising Providers |
| Professional or employment-related information | Current or past job history or performance evaluations. | Service Providers; Investors; Loan Partners |
| Inferences drawn from other personal information to create a profile about a consumer | Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Service Providers; Advertising Providers |
For more information on this sharing, see below:
Sharing with funding partners. We share information about your business and financial situation (as described in more detail in Section 4 below) in order to operate our lending platform, including:- To make available a loan application to prospective funding partners.
- To make available additional loan and/or borrower information to funding partners who fund the loan.
- To otherwise make information available to prospective funding partners who are contractually required to implement safeguards to protect and maintain the confidentiality of the information we share.
- Service providers may also include your representative(s), to the extent such a representative assists or assisted with the investor eligibility process. Information shared with your representative may include, among others, information about your loan performance.
- With credit bureaus, consumer reporting agencies, financial institutions, collections agencies, and fraud prevention agencies in order to, among other things, perform various checks, locate borrowers, or recover debts.
- With business credit bureaus to report loan performance.
- From time to time, we may provide data collected by the Services to trusted partners who work with Kanmon under confidentiality agreements. These partners have entered into partnership arrangements with us to market the Services to their customers. These partners may have a separate commercial relationship to you and may have indicated that the Services may be interesting, useful, or relevant to you. However, these companies do not have any independent right to share this information with any other party.
- We may allow third-party advertising partners to set cookies and other tracking tools described in 'Cookies and tracking technologies' above to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as 'interest-based advertising' or 'online behavioral advertising'.
- If you prefer not to share your personal information with third party advertising partners, you may follow the instructions in 'Cookies and tracking technologies' above to opt out.
- We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you.
In addition to the sharing outlined above, we may share any information we maintain about you with the following parties:
- With any third party who acquires some or all of our business and/or assets in connection with an acquisition or merger, as permitted under applicable law;
- When required by applicable law, including, but not limited to:
- With law enforcement or other government bodies, such as to comply with subpoenas, bankruptcy proceedings, or similar legal processes or for the purposes of limiting fraud.
- When we believe in good faith that sharing such information is necessary to enforce our site policies or any loan agreement, protect our or other's rights, property, or safety, and/or to comply with a judicial proceeding, court order, or legal process.; and
- We may continue to process your information as described in this Privacy Policy after your use of Kanmon Services has ended, for example to protect our rights as described above. For example, if you opt in to the 'Kanmon' program, we will share your name, email address, phone number, loan request information (including but not limited to loan amount requested and use of proceeds), and business information (including but not limited to company name and the number of years in business) with unaffiliated third parties who are in the business of arranging or providing financing. We may receive financial compensation from these third parties in connection with the sharing of this information.
4. Storage and security
While we take appropriate physical, technical and organizational measures to safeguard the personal information that you provide to us, unfortunately no system is 100% secure. To the fullest extent permitted by applicable law, we accept no liability if communications are unintentionally disclosed, intercepted by third parties, incorrectly delivered, or fail to deliver.
The personally identifiable information that you provide and that we collect will be stored and maintained by Kanmon for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) for which such information was collected, in accordance with this Privacy Policy, or (b) to comply with applicable laws, contracts or other rules or regulations.
5. Your rights
In accordance with applicable law, you may have the right, subject to verification of your identity:
- To update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and
- To opt out of any marketing communications that we or any service provider to whom we have disclosed your personal information may send you.
- To request deletion of your personal information, subject to certain exceptions prescribed by law.
- To request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you wish to exercise any of the above rights, please contact us using the details specified under the heading 'Contacting us' below. Note that we will require you to take steps to verify your identity before you may exercise the rights listed above, such as by requesting you provide us with your account information, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent's contact information to out customer support staff, as required by applicable law.
You may have a right not to receive discriminatory treatment as a result of your exercise of these rights.
Please note that the Fair Credit Report Act (FCRA) requires each of the nationwide credit reporting agencies — Equifax, Experian, and TransUnion — to provide you with a free copy of your credit report, at your request, once every 12 months. For more information, visit: https://www.ftc.gov.
6. Links to other sites
Our websites may offer links to sites of other companies and associations. While we monitor the quality of content provided on these sites, these external sites are not subject to this Privacy Policy and we have no control over their content. Please carefully review the policies of these sites before providing any personal information
7. Children's Online Privacy Protection Act
We comply with the requirements of the Children's Online Privacy Protection Act. We do not knowingly collect personal information from children under the age of the 13, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age, as the term 'sale' is defined under the CCPA. Our websites, products, and services are all directed to people who are at least 13 years of age or older.
If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child's account.
8. Contacting us
If you have any questions regarding this Investor Privacy Policy, you may contact us using the information below.
400 Concar Dr
San Mateo, CA 94402
USA
9. California Consumer Privacy Act Addendum
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), we provide this California Consumer Privacy Act Addendum (the “CCPA Addendum”) to California residents (“you”). This CCPA Addendum supplements the information contained in our Privacy Policy (“Privacy Policy”).
This CCPA Addendum does not apply to information we collect about individuals in their capacity as present or former job applicants, employees, contractors, shareholders, directors, or officers of Kanmon Inc.
Categories of Personal Information
Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular individual or household. “Personal Information” does not include publicly-available information, deidentified or aggregated information, or information covered by certain sector-specific privacy laws. “Sensitive Personal Information” refers to information that reveals social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless Kanmon Inc is the intended recipient of the communication; genetic data; and biometric information.
In the following charts, we identify (1) the categories of Personal Information and Sensitive Personal Information (as listed in the CCPA) that we plan to collect and use, and have collected and used within the preceding 12 months; (2) the categories of recipients to which we have disclosed each category of Personal Information or Sensitive Personal Information for our operational business purposes within the preceding 12 months; (3) the criteria we use to determine the retention period for each category of Personal Information or Sensitive Personal Information; and (4) the categories of Personal Information and Sensitive Personal Information we have sold or shared within the preceding 12 months, as “sale” and “sharing” are defined in the CCPA.
We do not sell Personal Information in the traditional sense of exchanging information for monetary payment. However, because the definitions of “Sale” and “Sharing” under the CCPA are defined broadly, and may include the disclosure of information to certain types of advertising and marketing partners and the disclosure of loan application information to investors and loan partners to facilitate our marketplace lending services, we provide California residents with the right to opt-out of any such Sale or Sharing of their Personal Information. For example, in an effort to provide you with additional business loan options, Kanmon Inc shares certain details of an application with Loan Partners to determine if the Loan Partner would be able to offer you a business loan. We do not knowingly Sell or Share the Personal Information of anyone under 16 years old.
Category | Examples | Category of Third Parties Information is Disclosed to for Operational Business Purposes | Retention Period Criteria | Sold or Shared? If so, to Which Categories of Third Parties? |
|---|---|---|---|---|
Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. |
| We use the following criteria to determine the period of time for which we retain each category of Personal Information:
| Yes
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, or bank account information. |
| See above | Yes
|
Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| See above | Yes
|
Internet or other electronic network activity | Browsing history, search history, information on interaction with an internet website, application, or advertisement. |
| See above | Yes
|
Professional or employment-related information | Current or past job history or performance evaluations. |
| See above | Yes
|
Inferences drawn from other personal information to create a profile | Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
| See above | Yes
|
Below, we provide this information related to Sensitive Personal Information:
Category | Examples | Category of Third Parties Information is Disclosed to for Operational Business Purposes | Retention Period Criteria | Sold or Shared? If so, to Which Categories of Third Parties? |
|---|---|---|---|---|
Identification numbers | Social security, driver’s license, state identification card, or passport number. |
| We use the following criteria to determine the period of time for which we retain each category of Personal Information:
| Yes
|
Login | Account log-in, financial account, debit card, or credit card number in combination with any required security or access codes, or credentials allowing access to an account. |
| See above | Yes
|
Precise geolocation | Data that is derived from a device and that is used or intended to be used to locate an individual within a geographic area of 1,850 feet. |
| See above | No |
Protected classification characteristics under California or federal law | Age (40 years or older), gender. |
| See above | Yes
|
Sources of Personal Information
We obtain the categories of Personal Information listed above (including Sensitive Personal Information) directly from you or from devices on which you use Kanmon Services, as well as from the following categories of sources: third-party services, publicly-available databases, third-party businesses, investors, financial partners, social networking sites, and other third-party sources.
Use of Personal Information
We use Personal Information (including Sensitive Personal Information) for a variety of business and commercial purposes, as described in our Privacy Policy above.
CCPA Rights and Requests
California residents may make the following types of requests under the CCPA:
- Requests to Know, Delete, or Correct
- Requests to Know
You may request that we disclose the following information to you about our collection and use of your Personal Information (including Sensitive Personal Information) over the past twelve (12) months or other CCPA-specified period: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which we collected this Personal Information; (3) the categories of Personal Information that we have sold, shared, or disclosed to third parties, (4) the categories of recipients to whom this information was sold, shared, or disclosed; (5) the business or commercial purpose for selling, sharing, or disclosing Personal Information; and (6) the specific pieces of information we collected about you. You may request information collected about you after January 1, 2022, beyond this twelve (12) month period, subject to applicable law. - Requests to Delete
You may request that we delete Personal Information that we have collected from you. We may limit or deny your deletion request in certain cases, in accordance with exceptions specified in the CCPA. - Requests to Correct
You may request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. - How to Submit Requests to Know, Delete, or Correct
You may submit a Request to Know, Request to Delete, and/or Request to Correct by emailing ccpa-request@kanmon.com.
We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as business name, business address, business tax identification, number, loan number, and phone number, and additional email addresses, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information. - Requests to Opt-Out of Sale or Sharing
You may opt-out of the Sale or Sharing of Personal Information.
To opt-out of Sale or Sharing, please contact us at ccpa-request@kanmon.com.
Authorized Agents
To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include proof of your registration with the California Secretary of State to conduct business in California; and/or a power of attorney from the California resident pursuant to Probate Code sections 4121-4130.
If you are making a Request to Know, Request to Delete, or Right to Correct on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the Request to Know or Request to Delete.
Nondiscrimination
You have the right to be free from unlawful discriminatory treatment for exercising any of your CCPA rights.
Contact us
If you have any questions or requests in connection with this CCPA Addendum or other privacy related-matters, please contact us using the information below.
Attn: Data Protection Officer
400 Concar Dr
San Mateo, CA 94402
USA
Kanmon is operated by Kanmon Inc. Kanmon Inc makes capital available to businesses through business loans, lines of credit, and advances. California loans are made pursuant to Kanmon’s California Department of Financial Protection and Innovation (DFPI) Finance Lenders Law License #60DBO-144925. Kanmon does not currently meet the applicability thresholds for the California Consumer Privacy Act. As set forth in our Privacy Policy and with respect of California residents, Kanmon will not share information we collect about you with affiliated or non-affiliated third parties, except in the limited circumstances disclosed in our Privacy Policy and permitted under California law, or if you give us permission. To learn more, please contact hello@kanmon.com.