Updated on Sep 26, 2019.
The Sima Company, a Georgia corporation, ("Sima" or "we") respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:
This policy applies only to information we collect:
Sima works with a number of business partners that perform essential functions as part of our operations, including electronic payment service providers and loan servicing companies. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services. Our business partners are legally required to keep your information private and secure. In addition, since all loans facilitated through Sima are made directly to borrowers by lender participants on the Platform, if you request a loan, certain information will be shared with potential lenders on the Platform.
This policy does not apply to information that:
These third parties have their own privacy policies, which we encourage you to read before providing information on or through them. While we do our best to ensure your privacy, we cannot be responsible for the privacy practices of third parties.
Information We Collect and How We Collect It
We collect information from and about users of the Platform:
Information You Provide to Us
When you create an account, or use the Platform, we may ask you to provide information by which you may be personally identified, including:
In addition, other types of information you may provide to us include:
Automatic Information Collection and Tracking
When you download, access, and use the Platform, it may use technology to automatically collect:
If you do not want us to collect this information you may opt out at any time through your device's privacy settings. For more information, see "Your Choices About Our Collection, Use, and Disclosure of Your Information" below.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
Information we Receive from Third Parties; Third Party Information Collection
We may receive information about you from third parties, including information we request on your behalf, in the case of borrowers, from credit reporting agencies such as TransUnion, Equifax, and/or Experian and, in the case of lenders, from third parties to verify your status as an "accredited investor." We may also work with different third-party data partners to supplement the information we collect directly from you for fraud or identity verification purposes. We may also receive information about you if you access the Platform through a third-party connection or log-in, such as Facebook or a referral partner, or otherwise link an account to the Platform, that third party may pass certain information about you and your use of its service to us which you have permitted the third party to share with us, and any information you have made public in connection with that service. For example, if you access the Platform through your Facebook account, Facebook will provide the data regarding who your "friends" on Facebook are, and the Platform will identify other users on the Platform that are your friends. Similarly, your friends that access the Platform via Facebook will see that your user account on the Platform is designated as one of their friends on Facebook. You should always review and, if necessary, adjust your privacy settings on third-party websites, applications and services before linking them to the Platform. You may also unlink your third-party account from the Platform by adjusting your settings on the third-party service. If you unlink your third-party account, we will remove the information collected about you in connection with that service.
When you use the Platform or access its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
Our Platform may include social media features, such as the Facebook Like button, Google Plus, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Platform, and they may set a cookie or employ other tracking technologies.
In addition, we display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Platform while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
We do not control these third parties' tracking technologies or how they may be used. Information collected by third parties is governed by their privacy practices. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see "Your Choices About Our Collection, Use, and Disclosure of Your Information" below.
Children Under the Age of 13
The Platform is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please immediately contact us at [email protected]
How We Use Your Information
Generally, we use information that we collect about you or that you provide to us, including Your Personal Information, to:
More specifically, when you register as a borrower participant on the Platform, we will use Your Personal Information to:
Any part of your credit report (other than your identity) including, but not limited to, your VantageScore 4.0 credit score, your debt-to-income ratio, your annual income and account history, as well as your Sima Platform Score, will be shared with lender participants on the Platform to help such potential lenders to assess your loan request in the context of your overall financial situation. For privacy purposes, borrower participants and lender participants remain anonymous on the Platform and are identified only by the initials of their names. However, we may disclose information related to the identity of borrower participants who are in default under the terms of any loan they receive, either to third-party collection agencies or to the lender participant who funded the loan.
In addition, when you register as a lender participant on the Platform, we may request additional information or documentation in order to verify you meet certain eligibility requirements under applicable law including, but not limited to, your status as an "accredited investor."
The usage information we collect helps us to improve the Platform and to deliver a better and more personalized experience by enabling us to:
We may use location information we collect to identify areas to advertise or ways promote the Platform, to verify the identity of Platform participants, and for other business reasons.
We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see "Your Choices About Our Collection, Use, and Disclosure of Your Information" below.
We may use the information we collect to display advertisements to our advertisers' or business partners' target audiences. Even though we do not disclose Your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose Your Personal Information that we collect or that you provide:
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding Your Personal Information. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
Accessing and Correcting Your Personal Information
You can review Your Personal Information by logging into the Platform and visiting your account profile page.
You may also send us an email at [email protected] to request access, or a change, to Your Personal Information. We cannot delete Your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We reserve the right to verify your identity in connection with any request regarding Your Personal Information to help ensure that we provide the information we maintain to the individual to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
Your Privacy Rights
California Residents: California Civil Code Section 1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of Your Personal Information to our affiliates or third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: Attn: Legal Department, The Sima Co. [Address]
Vermont Residents: We will not share information we collect about you with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account.
Nevada Residents: We provide you this notice under Nevada state law. You may be placed on our internal Do-Not-Call List by emailing us at [email protected], or writing us at: Attn: Legal Department, The Sima Co., [ADDRESS].
Nevada law also requires us to provide you the following to obtain additional information:
Office of the Attorney General
100 North Carson Street
Carson City, NV 89701
Email: [email protected]
We have implemented measures designed to secure Your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and credit report information will be encrypted using SSL technology. In addition, we employ session time-outs that will log you out of the Platform automatically after a period of inactivity. This reduces the risk of others being able to access your account if you leave your computer unattended.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to any part of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect Your Personal Information, we cannot guarantee the security of Your Personal Information transmitted through the Platform. Any transmission of Your Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Our retention periods for Your Personal Information are based on business needs and legal requirements. We retain Your Personal Information for as long as is necessary for the purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. When we no longer need Your Personal Information or aren't otherwise required by law to retain such information, we either irreversibly anonymize the information (in which case, we may further retain and use the anonymized information) or securely destroy the information. In addition, Federal and state agencies may require that we provide aggregated demographic and loan funding information about the borrower participants on our Platform.
Communications from Us
When you register on our Platform, you will receive emails that confirm specific actions you requested. For example, you will receive notifications confirming (i) your registration, (ii) the successful verification of email addresses and bank accounts, (iii) the confirmation of successful submissions of loan requests and loan closings, and (iv) for other legal or security purposes. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any emails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and Platform operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback e-mails, you may opt out by writing to [email protected] or by following the unsubscribe instructions located at the bottom of each email communication.
Attn: Legal Department
Or email us at: