1. The information we collect and how we collect it.
How we collect and store information depends on the pages of this website you visit, the activities in which you participate and the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.
1.1 Information you provide
We may collect information about you during your use of the Services, including your first name, last name, email address, loan amount, phone number(s), zip code, employment status, annual income, credit score/FICO range, and information you provide or post on our Services or allow us to access when you do certain things, such as:
Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via a SNS, on message boards, chat areas or in advertising or notices you post, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties.
1.2 Automatically-collected information
1.2.1 Device/usage information
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.
1.2.2 Location information
We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Chicago, the Services may be customized with Chicago-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
1.2.3 Cookies and other electronic technologies
When you use the Services, we use persistent and session cookies and other similar tracking technologies to: (a) analyze the usage of our sites and Services by collecting the information discussed in section 1.2.1 above; (b) customize the Services to your preferences; and (c) control the advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications. The cookies may reflect de-identified data linked to or derived from data you voluntarily have submitted to us, e.g., a hashed version of your email address that we may share with service providers, solely in non-human readable form. We and our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, as well as serve you ads when you are using our Services and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. As we adopt additional technologies, we may also gather additional information through other methods.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browsers toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
1.3 Information from third parties
We may obtain additional information about you from third parties such as service providers, credit bureaus, marketers, partners, researchers, and others. We may also receive information from lenders regarding the status of your application including, but not limited to, the amount or disposition of your loan. This information may include your Social Security number, FICO score, credit report, transaction history, payment history, name, phone number, email address, ZIP code, whether you have received loan offers, and which loan offers you have received. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.
1.4 Aggregate or de-identified data
2. What we do with the information we collect.
We use the information that we collect for the following purposes:
We may send you commercial emails regarding products you may be interested in. Each such email we send you will have an opt-out that you can use to stop receiving such communications. If you opt out of receiving commercial emails about products we think you may be interested in, we may still send you emails about any services you have requested or received from us.
3. How we share and disclose user information with third parties.
We will make your information available to other companies, websites, applications or people in the circumstances described below:
We may share your information with any agent or company that is part of Shogun in order to provide the Services or advertising or to communicate with you on our behalf.
When you express interest in other products, services, promotions that we offer (by, for example, completing an inquiry for such services), we will share your request or expression of interest with the businesses with which we partner to offer you those products, services and promotions, and, as applicable, with their affiliates and third party finder or marketing companies (collectively, “Business Providers”). When you choose to participate in a particular offer or program, you authorize us to provide information and other personally identifiable information to those Business Providers. Be aware the Business Providers with whom we share your information and other personally identifiable information may retain or use your information whether or not you use their services and you should contact these parties directly concerning their privacy and information sharing practices which may differ from ours.
When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers, operators, or sponsors privacy policies or practices.
We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.
We may share your personal information with our authorized service providers that perform certain services on our behalf including, but not limited to service providers that perform services on our behalf in connection with your request for a loan or the funding, sale and/or servicing of your loan. These third parties include, without limitation credit bureaus, marketing and customer services firms, or entities that provide business analysis or website support. These third parties may have access to information and other personally identifiable information needed to perform their functions. We may also share your information with other third-parties with whom we have a contractual relationship for their own direct marketing or advertising purposes.
We may disclose your information in connection with reporting required in connection with state and/or federal licensing requirements. You authorize Shogun to obtain any and all necessary information required from the Lender or Provider you choose to report back any and all required information relating to the disposition of your request. For example, if the loan closed, if you withdrew the request, and/or if you were not approved. In addition, under current reporting requirements the lender may provide to Shogun the loan you selected, the terms of the same, fees, rate, APR etc. in order to comply with current laws and regulations.
We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all Shogun assets, or a financing or acquisition of all or a portion of our business by another company.
We may employ third-party software provided by FullStory, Inc. to improve the quality of the Services. This allows Shogun to review a video-playback of your use of Services and any other activity on Shogun’s website. By using this site, you expressly consent to Shogun’s use of FullStory Inc.’s service. If you would like to opt-out, please email email@example.com.
We may share your information with your contractor or potential contractor, including but not limited to the fact that you have begun an information request on our site, that you have submitted an information request on our site, that you have clicked on a result on our results page that would direct you to begin a loan application with one of our lending partners, that you have completed a loan application with one of our lending partners, that you have been approved for a loan by one of our lending partners, and that your loan has been funded. We may also share with your contractor or potential contractor information related to the prequalified offers that you may have received from one or more of Shogun’s lending partners.
If you are a contractor and were referred to us by a third-party partner, we may share information about you, including but not limited to your subscription status, usage data, and information about any loans obtained or loan requests made by customers using your co-branded page.
4. Shogun’s use of online analytics and tailored advertising.
4.1 Online analytics
We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.2 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
4.2 Tailored advertising
When you use the Service, Shogun may serve you with ads based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
Also, third parties, including without limitation those whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that tailored ads may be delivered to you when you are using other websites. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g., user-generated content) for purposes of delivering tailored advertising on the Services and/or other websites.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
When using a mobile application, you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.
5. California Do-Not-Track disclosure requirements.
We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiative’s Consumer Opt-out link, Digital Advertising Alliance’s Consumer Opt-Out Link, TRUSTe’s Advertising Choices page, and the Google opt-out link in Sections 4.1 and 4.2. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.
6. How you can access and update your information.
To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at firstname.lastname@example.org.
7. How we protect information.
8. Linked sites and advertisements.
The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.
9. Use of the Services by users from outside the United States.
10. Use of the Services by children.
The Services are not intended for persons under the age of 18. We require that only persons 18 years of age or older use the Services. By using the Services, you hereby represent that you are at least 18 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.
11. How to contact us.
12. Your California privacy rights.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to email@example.com.
13. No rights of third parties.
15. Assistance to Victims of Identity Theft
If you suspect that someone has had unauthorized access to your Information or access to your personally identifiable information, you should report this crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free 1-877-IDTheft (1-877-438-4338). Or, to enter information about your complaint into a secure FTC online database, visit www.consumer.gov/idtheft. The site also provides links to consumer education materials.
Last updated: Nov. 27, 2018.