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Privacy Policy

Effective Date: June 20, 2016

This Privacy Policy explains the practices of Social Finance, Inc., Varam Capital Private Limited, and their affiliates (together, “Social Finance”, “Varam”, “we”, or “us”) with respect to how we collect, use, disclose and secure your personal information in connection with the Varam website at –————-, –—————– (together “Website”) and Social Finance’s lending and social networking service or related services (“Service”). This Privacy Policy applies to personal information we collect from you and from third parties both online and offline, but does not apply to any personal information collected by third parties from you. If you are a current Varam customer, please see our Privacy Notice for a comprehensive explanation of how we collect, use and share your personal information and what you can do to limit the use and sharing of your information.

Changes in Privacy Policy

This notice describes our Privacy Policy effective as of the date indicated above. Social Finance reserves the right to change this Privacy Policy at any time so please review it frequently. We will provide notice of changes by indicating on the Privacy Policy the date it was last updated and making such updated Privacy Policy available on the Website. We may also choose to notify you of material changes to the Privacy Policy by email or by means of a notice on our home page.

Collecting personal information

We may collect personal information about you from you and from third parties, including personal, demographic and aggregate data. As used in this Privacy Policy, “personal information” means information that specifically identifies you, including, but not limited to, your name, address, telephone number, email address, social security number, driver’s license number, bank account numbers, student loan account numbers, employment info, credit card number, and student identification number. Demographic information is anonymous information, which may include your age, date of birth, income, gender, geographic area, hobbies or interests. Demographic information is not considered personal information unless it is linked with your other personal information, which we may do for a variety of reasons such as customizing content or services according to your interests and preferences or verifying your identity. Personal information does not include aggregate information, which is data we collect about the use of the Website or Service (or categories of the Website or Service), from which personal information has been removed. Aggregate data are used for a number of purposes such as helping us understand trends and user needs so we can improve our products and services.

Personal information may be collected in a number of ways, such as when you visit the Website with your Internet browser or use the Service. In addition, Social Finance may ask you to provide certain personal information when filling out and submitting loan applications, registration forms or providing feedback to Social Finance. When submitting loan applications, registering to view your loan account history, or applying to receive or provide a transfer of funds pursuant to the Service, you may be asked to provide your social security number, a bank routing number, a bank account number, contact information, your name and other personal information (“Registration Information”). Also, you may post to the Website or transmit to Social Finance personal information, photographs, videos, and other content, such as to your social networking profile, through messaging functionality on the Website, or to a public bulletin board, blog, chat room or other forum on the Website. You may control with whom you share your profile information on the Website and you understand that if you choose to share your information, your profile may be generally available on the Website. However, if you are a current borrower, you may not control certain information that you have already agreed to provide to certain investors as described in your promissory note. All such content that you post to the Website is done at your own risk and Social Finance bears no responsibility for any such content or any liability for any claims arising out of such content. You should also be aware that any personal information you use on our blog can be used, read, or collected by other users of the blog and could be used to send you unsolicited messages. We are not responsible for personal information you choose to submit in the blog or any other area of the website.

When you use the Website, Social Finance may also collect certain information about your computer to facilitate and evaluate your use of the Website and the Service. For example, we may log environmental variables, such as browser type, operating system, referring or exit web pages, and the Internet Protocol (IP) address of your computer. We may on occasion supplement the personal information you submit to us with information from third-party sources. For example, if permitted under applicable law, we may supplement your Registration Information with address standardization data to verify the address you have entered is actually your address.

We do not intend to collect personal information from children under 13 years of age. If we learn that we have collected this information from a child under the age of 13, we will promptly take all reasonable steps to delete the data from our system.

Use of personal information

In general, we use personal information to provide you with information or services you request, to inform you about other information and services we think will be of interest to you, to facilitate your use and our administration and operation of the Website and the Service, to learn more about and improve the Website and the Service, and for the purpose for which the information was provided.

Sharing your personal information

We only share your personal information with unaffiliated third parties as permitted or required by law. When we share your personal information with vendors and service providers who perform functions on our behalf, we require that they keep your information confidential and secure, and that they use it only as is reasonably necessary to carry out their work or comply with applicable law. We may share your personal information with affiliates and as part of joint marketing campaigns with other financial companies. In addition, personal information may be disclosed or transferred to our affiliates and as part of, or during negotiations of, a merger, consolidation, sale of company assets or equity, financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Social Finance.

Protecting your personal information

We maintain administrative, technical and physical safeguards designed to protect the security, confidentiality and integrity of your personal information. We also protect personal information that you provide online in connection with registering yourself as a user of the Website or of the Service or use the Service in several ways. Access by you to such personal information is available through a password and unique customer ID selected by you. This password is encrypted. To protect the confidentiality of such personal information, you should not divulge your password to anyone. You are responsible for all uses of the Website and Service by any person using your customer ID and password. Please advise us immediately if you believe your password has been compromised. In addition, your personal information resides on servers or in areas of facilities that only selected Social Finance personnel and contractors have access to. Social Finance encrypts all data that you submit to Social Finance through the Website, and thereby attempts to prevent unauthorized parties from viewing such information during transmission to Social Finance. Please note that any information you submit by email may not be secure, so please do not send any sensitive information or materials in or attached to any email to Social Finance. Social Finance will never request that you submit sensitive information over email; please report any such requests purporting to originate from Social Finance to us.

Please note that any information, photos, contact information, email addresses, videos, and other content you post to your social networking profile or to any public bulletin board, blog, chat room or other forum is available to all persons accessing that location. The information you share would then be available to all persons accessing these venues, and such information may be read, collected or used by others for any purpose, including sending you unsolicited messages. Social Finance is not responsible for any information you elect to submit in these venues or the use of such information.

Your choices regarding your personal information

Personal information that is not collected on the Website or in connection with the Service is not generally subject to this Privacy Policy. The Website may contain links to other websites which may collect personal information. For example, Social Finance may have relationships with various service providers whose services are available to you from the Website, from websites that are linked to the Website, or in connection with the Service. Typically, these providers offer services that Social Finance customers might find useful, such as those you may use in conjunction with Service. Those providers’ may require you to provide personal information to use their services. Unless expressly provided to the contrary, the privacy policy applicable to that website, and not this Privacy Policy, will govern the collection, use, disclosure and security of your personal information.

You can access all of your personal and personally identifiable information that we collect online and maintain by logging in to your account and going to “My Profile”. This section of the site is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone numbers, education and employment information at any time on the website, and if you need to change any other information in your profile or request that we delete/remove your information, you can contact us at (855) 456 – 7634.

Tracking, use of cookies, web beacons and similar tracking devices

In order to improve our Service and the Website and provide more convenient, relevant experiences to our customers, we and our vendors may use “cookies” and similar devices to track your activities. A cookie transfers a small amount of data to your browser by servers within the domain and is only read by the server that gave it to you. It functions as your identification card and enables Social Finance to record your passwords, purchases and preferences. A web beacon embeds a small transparent gif image in an HTML page or email used to track when the page or email has been viewed. A similar device may be used by which a product, service or functionality may send data to a server when a set of user-initiated events occur (such as after clicking a button on the Website or in an email). This device is similar to a cookie because it tracks your visit and the data is only read by the server that receives the data. It is different than a cookie because it is not browser-based, may not function as an identification card and does not store any data on your computer. While Social Finance uses cookies and similar devices to track your use of the Website and the Service, such as the number of downloads, types of Service used, and how many users we receive daily, and while our web servers automatically log the IP/Internet address of your computer, Social Finance does not generally use this information to identify you personally. However, if you expressly provide consent for the Website or the Service to “remember” you when you log into your account, we will store that unique identifier on a cookie on your computer and link that unique identifier to your Registration Information. As a result, we will track your navigation path around the Website and the Service.

Most browsers are initially set to accept cookies and similar devices. You can set your browser to notify you when you receive a cookie or similar device, giving you the chance to decide whether or not to accept it. (For some web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages or the related products and services.)

How We Respond to Do Not Track Signals

We do not respond to “do not track” signals or similar mechanisms where a visitor to Varam’s websites requests that we disable the collection of information about the visitor’s online activities, including navigation around the Website and the Service. We may also permit third parties to collect information on the Website, and they may also not respond to “do not track” signals.

Information from Advertisements on Other Websites

We place and track advertisements on third-party websites. Like many advertisers, we advertise our products and services, and we contract with third parties to place advertisements, on websites not affiliated with us where we think the advertisements are likely to be most relevant. These advertisements may contain cookies or other mechanisms that allow tracking of your response to our ads. We and our contracted third parties track and report performance of our advertising and marketing campaigns by using cookies, web beacons, and other similar technology, which may be used to collect and store information about user visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site. No personally identifiable information is stored during this process.

Contacting Social Finance

If you have questions regarding our Privacy Policy or if you believe that Social Finance has not complied with this Privacy Policy with respect to your personal information, please contact us at————–. If you are reporting non compliance with this Privacy Policy, in your e-mail or letter, please describe in as much detail as possible (but without disclosing any sensitive information about you or third parties) the ways in which you believe that the Privacy Policy has not been complied with.