Privacy Policy

                                                                                Effective date: March 1st, 2020


This Privacy Policy (“Policy”) applies to the products, services, and platform (referred to collectively as the “elphi Platform” or “Platform”) owned and operated by elphi, Inc. (“elphi” or “us” or “our” or “we”). For purposes of this Policy, “you” and “your” mean the Platform account creator, authorized signer, authorized representative, delegate, and/or other authorized Platform user, including a co-applicant. This Policy describes and governs the personal information collection, use, and sharing practices of elphi with respect to the Platform. Personal Information, sometimes also known as Personally Identifiable Information or ‘PII’, is information that can be used on its own or with other information to identify, contact, or locate a person or household, or to identify a person or household in context. 
 

Before you use or submit any information on or through the Platform, please carefully review this Policy. By using any part of the Platform, you consent to the collection, use, and disclosure of the information you provide as further outlined in this Policy. We will continue to evaluate this Policy as we update and expand the Platform and our offerings, and we may make changes to the Policy accordingly. Any changes will be incorporated into this Policy and posted on the Platform. Your continued use of the Platform will signify acceptance of the terms of the updated Policy.
 

Joint Applicants. If you are using the Platform with another person to apply jointly for a loan, you and your co-applicant may choose to provide information for your application using a single joint Platform account or multiple individual Platform account(s). If joint applicants choose to utilize a single Platform account, they will have access to all information supplied by Platform account users to complete that application. Such joint applicants will have the ability to view, print, transmit, save, and/or edit the information. Access may continue for as long as the joint applicants utilize the single Platform account in connection with the application process.
 

What Type of Information Do We Collect?
 

We collect information in multiple ways, including when you provide information directly to us and when we passively collect information from you, such as from your browser or device.
 

Information You Provide Directly to Us
 

We may collect information from you during your use of or access to the Platform, such as when you:

  • Register for an elphi Platform account;

  • Enter information in the elphi Platform;

  • Communicate with us; or

  • Connect with your third-party accounts to retrieve your information.
     

For example, we may collect identifying information such as your name, email address, account password, and phone number for creating and authenticating an elphi Platform account. We may also collect third-party account credentials (e.g., your log-in credentials for accessing your bank account or tax return information) , as well as contact, financial, and other information that may be used for the purpose of retrieving information from third-parties. All such information we collect from you through or in connection with the Platform is covered by this Policy.

 

Information Collected Passively
 

  • Device/Usage Information
     

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Platform. As described further below, we may collect and analyze information such as (a) IP addresses (including city and state information), unique device identifiers, IMEI and TCP/IP addresses, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, and the state or country from which you accessed the Platform; and (b) information related to the ways in which you interact with the Platform, such as referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Platform, amount of time spent on particular pages, date and time you used the Platform, frequency of your use of the Platform, 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 this information.
 

  • Cookies and Other Electronic Technologies
     

Cookies are small text files stored locally by your browser when you visit a elphi website. We use cookies to improve a elphi website and make it easier to use, allowing us to recognize users and avoid repetitive requests for the same information.
 

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser (e.g., Internet Explorer ; Google Chrome ; Mozilla Firefox; or Apple Safari)for more information. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Platform.

 

Information from Third Parties
 

We may also obtain information about you from third parties such as third parties that provide products or services related to the Platform.
 

How Will elphi Use My Information?
 

We may use the personal information we collect:

  • To process and fulfill a transaction or to provide products or services through or in connection with the Platform

  • To administer an elphi website, including troubleshooting, data analysis, testing, and for statistical and survey purposes;

  • To send you information about your Platform-related activities;

  • To contact you with information or surveys regarding our Platform;

  • To process and respond to your inquiries or to request your feedback;

  • For internal research and reporting;

  • To improve the content and features of the Platform or develop or deliver new products or services;

  • To enforce the legal terms that govern your use of the Platform; and

  • To monitor trends, marketing and advertising;
     

We may also use information that we collect on an aggregate or anonymous basis (such that it does not identify any individual or household) for various business purposes, where permissible under applicable laws and regulations.


How Will elphi Share My Information?
 

We do not sell or lease your Personal Information to third parties for marketing purposes. We may share the Personal Information we collect from and about you with third parties in a variety of ways, as described in this section.
 

  • Financial Services Providers. We collect information for Financial Services Providers that are evaluating, processing, or funding loan applications or other financial services applications. We may share the information you provide with, and/or make that information available to Financial Services Providers, their successors-in-interest, and other relevant third parties that the Financial Services Provider has authorized to access the information in order to facilitate the loan process or other financial services transaction, and provide related services and products to you. If you are a customer of such a Financial Services Provider and have questions about its privacy practices or you no longer want to be contacted by the Financial Services Provider, please contact the Financial Services Provider directly. The Financial Services Provider’s privacy policy, and not this Policy will apply to the Financial Services Provider’s use of your information, and to the sharing and use of your information to/by others authorized by the Financial Services Provider to obtain your information. elphi is not responsible for the privacy practices of the Financial Services Providers.

  • Third party service providers who act on our behalf.

  • Data Access Providers and Other Third Parties. If you choose to provide your Third-Party Account Credentials to link with your third-party financial accounts, you grant us and our data access providers the right to retrieve information from the relevant third party on your behalf and transmit such information to the Financial Services Providers. The collection, use, transmission, and storage of this information by our data access providers is governed by the privacy policy of the applicable data access provider. If following the initial retrieval of information from your third-party financial account, you no longer want us or our data access providers to obtain information from such accounts in connection with continued provision of services to you, please see the “What Choices Do I Have” section below. elphi may also share your information with partners of elphi or the Financial Services Provider (e.g., pricing engines, document generation providers).

  • Consent. With your consent, we may also share your information with other third parties.

  • Other third parties to meet obligations for legal or regulatory compliance; to verify or enforce our terms of use and other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers, employees, or third parties.
     

How Does elphi Secure My Data?
 

Safeguarding your Personal Information is our top priority. We have implemented security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, we store usernames, passwords, PINs, and other log-in information in encrypted form. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because despite our efforts, no internet and/or other electronic transmissions can be completely secure.
 

We recommend that you change your password periodically. You are responsible for maintaining the security of your Platform account username and password. If you believe that your Platform account username and/or password have been stolen or been made known to others, it is your responsibility to immediately contact us at privacy@elphi.io and change your password. We are not responsible if someone else accesses your Platform account through information they have obtained from you.
 

What Choices Do I Have?
 

  1. Updating and Deleting Your Information. You may be able to add, update, or delete certain information through the Platform. When you update information, however, we may maintain a copy of the unrevised information in our records for legal compliance purposes. Any information that cannot be updated or deleted through the Platform will require you to contact the Financial Services Provider for further assistance. Additionally, to the extent applicable law affords you rights to your personal information, such as access and deletion rights, please reach out to your Financial Services Provider to inquire about your data rights.

  2. Account Access for Providing Financial Services. If you no longer want us or our data access providers to obtain information from your financial accounts on behalf of your Financial Service Provider, please email us at privacy@elphi.io

  3. California Residents. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask for a notice (a) identifying the categories of personal information (as defined by California law) that are shared with third parties for their own marketing purposes and (b) providing contact information for such third parties. As discussed above, elphi does not share such personal information for these purposes.


What Is elphi’s Policy on Children?
 

We do not knowingly collect or solicit personal information (as defined by the “Children’s Online Privacy Protection Act”) from anyone under the age of 13. If you are under 13, please do not attempt to register for the Platform or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact privacy@elphi.io.

For more information about the Children's Online Privacy Protection Act (COPPA), visit the FTC website: http://www.ftc.gov/.

 

Retention of Your Information
 

We keep your information in identifiable form for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
 

Will elphi Change This Policy?
 

We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of the Platform, or advances in technology. Please check this page periodically for changes. Your continued use of the Platform following the posting of changes to this Policy will mean you accept those changes.
 

How to contact us?
 

If you have any questions or concerns regarding our Privacy Policy, please send us a detailed message to privacy@elphi.io and we will try to resolve your concerns.
 

elphi , Inc.

24 School St 2nd floor

Boston, MA 02108