At Pigeon Loans, Inc., (“Pigeon Loans”, “Company”, “we”, “our” or “us”), we value your trust. We are committed to acting responsibly when we collect, use and protect your non-personal and personal information.
We believe in being clear and open about how we collect data related to you when you visit our websites at www.usepigeon.io or app.usepigeon.io (the “Websites”), download, access, and/or use Pigeon Loan’s mobile application named Pigeon Loans (“App”), subscribe to our services that provide individuals with resources to create and manage loans between friends, family, and other relations, subscribe to our newsletter, interact with us, participate in our rewards program (“Pigeon Points”), surveys, online advertisements or marketing emails, apply for a job with us, refer a friend, or engage with any other websites that Pigeon Loans has now or acquires in the future, pages, podcasts, blogs, features, or content we own, operate and/or provide, mobile and/or web-based applications, products and/or services (collectively with the Websites and App, the foregoing shall hereinafter be referred to as the “Services”).
Federal and state laws say that we must tell you how we collect, share and protect your personal information. This Privacy Notice (“Privacy Notice”) is designed to help you understand how we collect, use, share and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. Please read this Privacy Notice very carefully.
In this Privacy Notice, you will find information about:
- Types Of Data We Collect
- Children’s Online Privacy Protection Act (“COPPA”)
- Information you Provide to Us
- Collected via Technology
- Use of Your Personal Information
- Use of Non-Personal Information
- How We Share Your Personal Information
- Third-Party Service Providers
- Process Payments
- Business Transfers
- Other Disclosures
- Links to Third Party Websites and Third Party Providers
- Your Rights Regarding the Use of Personal Information
- Security of Your Personal Information and Personal Data
- How We Retain Your Personal Information
- Changes to This Privacy Notice
- Other Jurisdictions
- Notice to California Residents
- Contact Information
1. Types of Data We Collect
We collect “Non-Personal Information” and “Personal Information” and the information we collect from you depends on how you use the Services. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit, and preferences that are generated based on the data you submit and number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, and email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. This includes:
2. Children’s Online Privacy Protection Act (“COPPA”)
Our Services are not designed for children under 13, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information.
3. Information You Provide to Us
When you choose to set up an account through the Services, we collect Personal Information from you such as your first and last name, email address, password and IP address. If you choose to share additional details with us, we will also collect Personal Information from you such as your birth year, gender, income range, ethnicity and estimated credit range.
When you choose to create a loan or add an existing loan with us, we collect your:
- first and last name
- email address
- mailing address
- phone number
- bank account; credit or debit card information
- social security number
- the industry that you work in and website if applicable
- IP address
- reason for loan and description that you choose to add
- repayment details and schedule
- the borrower’s or lender’s email address as the case may be
When you engage us to provide Services, our payment processor, Stripe, Inc. (“Stripe”) will collect all information necessary to complete the transaction, including your name, credit card information, billing information, and direct deposit/ ACH information. When you engage us to provide Services, our e-signing processor, HelloSign, will collect all information necessary to complete the setting up a new or existing loan with us.
When you choose to post a review and share your own information on a publicly accessible area of the Websites or App, that information will be available to anyone who is able to access that content, including other Website and App users.
We may also collect your name and email address in connection with referral programs we may provide.
If you provide us feedback or contact us via email, we may collect your name, if stated, and email address, as well as any other content included in the email, in order to send you a reply.
When you participate in one of our surveys, we may collect additional information that you knowingly provide.
We will maintain the information you send via email in accordance with applicable federal law.
In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
4. Collected via Technology
We reserve the right to use technological equivalents of Cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. We reserve the right to use these pixels in compliance with the policies of the various social media sites.
5. Use of Your Personal Information
In general, Personal Information you submit to us is used either to respond to requests that you make or to aid us in serving you better. We use your Personal Information in the following ways:
- to facilitate the creation of and secure your account;
- to identify you as a user in our system;
- to establish an account on the Websites and/or App;
- to manage your registration as a user of Services. The Personal Information you provide can give you access to different functionalities of the Services that are available to you as a registered user.
- to set up a new loan or add an existing one;
- to send you Services as you requested;
- to send you rewards if you participate in our referral program;
- draft promotional or educational content;
- to post your review if you share your own information on a publicly accessible area of the Websites or App;
- for the performance of a contract. The development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Services;
- to provide and maintain our Services, including monitoring the usage of our Services;
- to provide improved administration of the Services;
- to improve the quality of experience when you interact with the Services;
- to send you administrative email notifications, such as security or support and maintenance advisories;
- to communicate with users and respond to your inquiries related to employment opportunities or other requests;
- to share with other users when you share Personal and/or Non-Personal Information or otherwise interact in public areas with other users. Such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you, and view your profile.
- we may share your Personal Information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- to periodically send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes including those of third parties;
- to perform marketing or data analysis;
- to comply with legal obligations, as part of our general business operations, and for other business administration purposes;
- in very limited circumstances where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of this Privacy Notice.
6. Use of Non-Personal Information
In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Services. This Privacy Notice does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers, and other third parties at our discretion.
7. How We Share Your Personal Information
As a general rule, we do not sell, rent, lease or otherwise transfer any information collected either automatically or through your voluntary action. We may disclose your Personal Information as described below and as described elsewhere in this Privacy Notice.
8. Third Party Service Providers
We may share your Personal Information with third-party service providers to provide you with the Services that we offer you; to conduct quality assurance testing; to perform marketing; to process your payment through our Websites or App; to run data analysis; to facilitate the creation of accounts; to provide technical support; and/or to provide future services to you. Prior to engaging a third-party service provider, Pigeon Loans performs due diligence to evaluate their defensive posture and executes an agreement requiring each third-party service provider to maintain minimum acceptable security practices. The third-party service providers we are engaged with and/or third-party products and/or services we use to provide the Services include without limitation:
9. Process Payments
10. Business Transfers
If (i) Pigeon Loans is acquired by, merges with, or receives investment from another company or (ii) if any of the Pigeon Loans’ assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, attorneys, and consultants.
11. Other Disclosures
Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property, or the rights or property of users of the Services; (d) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or any agreements you may have with us, as applicable.
12. Links to Third Party Websites and Third Party Providers
13. Your Rights Regarding the Use of Your Personal Information
We may send periodic promotional emails to you. You have the right at any time to prevent us from contacting you for marketing purposes. When we send promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. If applicable, you can also indicate that you do not wish to receive marketing communications from us in the “Settings” section of your Account. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Settings section of your Account, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Notice. You may unsubscribe to promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process unsubscribe requests. If you unsubscribe from receiving promotional emails, we may still send you emails about the Services.
Your Rights and Choices
If applicable privacy laws allow, you may have rights over your Personal Information. This includes, but is not limited to:
- Right to Know. You have the right to request disclosure about our Personal Information collection practices during the prior 12 months, including the categories of Personal Information we collected, the sources of the information, our business purposes for collecting or sharing the information, and the categories of third parties with whom we shared such information. You may request a copy of the specific pieces of Personal Information we may have collected about you in the last 12 months.
- Right to Delete. You may request that we delete (and direct our service providers to delete) your Personal Information, subject to certain exceptions.
- Right to Opt-Out. You have the right to opt out of any ‘sales’ of your Personal Information if a business is selling your information. For clarity, we do not sell your Personal Information.
- Non-Discrimination. You have the right to not be discriminated against for exercising these rights.
You can make the following choices regarding your Personal Information:
- Access To Your Personal Information. You may request access to your Personal Information by contacting us at the email or address below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you. We will provide this information in a portable format, if required. Note that California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing.
- Changes To Your Personal Information. We rely on you to update and correct your Personal Information. Please contact us at the address below immediately if there are any changes to your Personal Information. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, or as otherwise described in this Privacy Notice. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
If you decide to delete your in-App account, you may do so by selecting “Delete My Account” on your profile page. Deleting your Pigeon Loans account in-App will:
Sign you out immediately
Remove or anonymize any identifiable user information
Remove your email from our mailing lists.
After deletion of your account is completed, we will only retain your email address for aggregated, cumulative analytics over time. However, if you instruct us to delete your email address, we will comply with your instructions unless there is a legal obligation that would prevent us from doing so.
- Objection to Certain Processing. You may object to our use or disclosure of your Personal Information by contacting us at the address below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you communications related to your use of the Services and administrative purposes for reasons such as providing you with updates to this Privacy Notice.
- Revocation Of Consent. If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address below.
14. Security of Your Personal Information and Personal Data
We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Any account you have on our Websites or App is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure.
15. How We Retain Your Personal Information
We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use and/or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your Personal Information (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice. We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with the requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your Personal Information by contacting us.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.
If you are visually impaired, you may access this Privacy Notice through your browser’s audio reader.
17. Changes to This Privacy Notice
We reserve the right to change this Privacy Notice or any agreement you entered into with Pigeon Loans from time to time. We may notify you of significant changes to this Privacy Notice by sending a notice to the primary email address specified by you or by placing a prominent notice on the Websites and App. Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Websites and App and this Privacy Notice for updates.
18. Other Jurisdictions
Personal information that you submit through the Services may be transferred outside of the jurisdiction in which you live. We also store Personal Information locally on the devices you use to access the Services. Your Personal Information may be transferred to other jurisdictions that do not have the same data protection laws as the jurisdiction in which you initially provided the information. The following provisions may apply to you depending on where you are located.
This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing users, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at email@example.com or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov. We do not make marketing calls to existing users.
In accordance with Vermont law, we will not share information we collect about you with companies outside of Pigeon Loans except as described herein, or otherwise required or permitted by law.
This Section is only applicable to you if you are a resident of the state of Virginia (“Virginia Residents”). If you have a complaint, first contact us at firstname.lastname@example.org. We will respond within 45 days after receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary. We will notify you of any extension within the initial 45-day period. If you are not satisfied with our responses, you have the right to appeal. We will respond within 60 days of receipt of your appeal. If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at email@example.com or call (804)-786-2071.
To the extent the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA” effective January 1, 2023) are applicable, this Section is only applicable to you if you are a resident of the state of California (“California Residents”) and only applies to Personal Information for which Company is a “Business” (as defined in the CCPA & CPRA), but does not apply to Personal Information we collect from you where you are a, non-profit or government agency. It applies to Personal Information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person).
Rights and Choices
Exercising Your Rights
If you’re a California resident and desire to exercise your data protection rights, please contact us at firstname.lastname@example.org. You may be required to provide additional information necessary to confirm your identity before we can respond to your request, and we will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days from receipt of such request and will endeavor to respond within 45 days after receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days after receipt of such request. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you. You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell or share your information or for deletion of your information at any time. For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your e-mail account on file, if you have an email address on file with us. For requests for deletion of your information, please understand that CPRA does not extend the request for deletion to household data and applies only to consumers as defined by the CPRA. California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if (1) the information is necessary for us to (a) complete a transaction for you or otherwise perform a contract; or (b) detect, protect against, or prosecute security incidents, fraud or illegal activity; (2) we use the information only internally in ways reasonably aligned with your expectations as our customer, and (3) we are required to retain the information to comply with legal obligations. The foregoing list of examples is non-exhaustive. If we receive such a request from you, we will notify any service providers we have engaged and provided your information to delete your information as well.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
The California Business and Professions Code §22581 allows California residents under the age of 18, who are registered users of online sites, services or applications to request and obtain the removal of content or information they have publicly posted.
If you are a California resident under the age of 18, and wish to request removal of such data, you can contact us at email@example.com, and include a detailed description of the content to be removed and the email address associated with your account. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
We do not sell, share or disclose your information for monetary or other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a ‘sale’ or ‘share’ under the CPRA, we will update this Privacy Notice.
Using an Authorized Agent
You may submit a request through someone holding a formal ‘Power of Attorney’. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Categories of Information Collected
We collect information that identifies, relates to, describes, references is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information” as defined by the CPRA).
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CPRA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We collect personal information for the business purposes described in this Privacy Notice. The CPRA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.
During the past 12 months, we may have collected the following categories of information about California residents from the listed sources, used it for the listed business purposes, and shared it with the listed categories of third parties. Please see more information below:
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and Services you inquire about or purchase.
- Indirectly from you. For example, from observing your actions and interactions with the Services
- Other sources. For example, friend referrals, data analytics providers, advertising networks, internet service providers, operating systems and platforms, or social networks.
20. Contact Information
If you have any questions, comments, or complaints concerning our privacy practices, please contact us by sending an email to firstname.lastname@example.org or send correspondence via mail to:
Pigeon Loans, Inc.
1000 Brickell Ave
Suite 715 #5044
Miami, FL 33131
We will attempt to respond to your request and to provide you with additional privacy-related information.