Willow Lake Lending Privacy Policy

1. Information We Collect

1.1 Information You Provide Directly

When you apply for a loan or contact us, we may collect:

Identity information: Full legal name, date of birth, Social Security number, government-issued ID number.

Contact information: Mailing address, email address, telephone number.

Financial information: Annual income, employment status, employer name, bank account information (for funding and repayment), existing debts and monthly obligations.

Loan application data: Requested loan amount, loan purpose, desired loan term.

Communication records: Records of your communications with our customer service team, including calls (which may be recorded with notice), emails, and online chats.

1.2 Information We Collect Automatically

When you visit our website, we automatically collect:

Device and technical information: IP address, browser type and version, operating system, device identifiers.

Usage data: Pages visited, links clicked, time spent on pages, referring URL, search terms used to find our site.

Location data: Approximate geographic location derived from your IP address (state and city level — not precise location).

1.3 Information from Third Parties

We may receive information about you from:

Credit reporting agencies: We obtain credit reports from Equifax, Experian, and TransUnion when you apply for a loan. Initial rate checks use a soft inquiry that does not affect your credit score. A hard inquiry is made only upon your acceptance of a loan offer.

Identity verification services: We use third-party services to verify your identity and prevent fraud.

Income and employment verification: With your consent, we may verify income and employment through third-party verification services.

2. How We Use Your Information

We use the information we collect to:

Process your application: Evaluate your creditworthiness, verify your identity and income, determine your loan eligibility, and fund your loan if approved.

Service your loan: Process payments, send statements and notices, respond to your inquiries, and administer your loan account.

Comply with legal obligations: Meet requirements under federal and state lending laws, anti-money laundering regulations, and tax reporting requirements.

Prevent fraud and ensure security: Detect and prevent fraudulent activity, unauthorized access, and other illegal activity.

Improve our services: Analyze usage patterns to improve our website, application process, and customer service.

Marketing communications: With your consent or as permitted by law, send you information about products and services that may interest you. You can opt out at any time.

3. Information Sharing

We do not sell your personal information to third parties. We do not share your information with advertisers for their own marketing purposes. We share your information only in the following circumstances:

Service providers: We share information with companies that help us operate our business (payment processors, identity verification providers, cloud hosting services) under strict confidentiality agreements.

Credit bureaus: We report your loan account information to Equifax, Experian, and TransUnion as required by the Fair Credit Reporting Act.

Legal requirements: We may disclose information when required by law, court order, or valid government request, or to protect our legal rights.

Business transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, with appropriate notice to you.

With your consent: We may share information in other circumstances with your explicit consent.

4. Data Security

We implement industry-standard technical, administrative, and physical safeguards to protect your information, including:

256-bit SSL/TLS encryption for all data in transit. AES-256 encryption for sensitive data at rest. Multi-factor authentication for all internal system access. Regular third-party security audits and penetration testing. SOC 2 Type II compliance for our data handling practices.

While we maintain robust security measures, no security system is impenetrable. In the event of a data breach affecting your sensitive information, we will notify you as required by applicable law. For questions about our security practices, contact us at [email protected].

5. Your Rights & Choices

Access your information: You may request a copy of the personal information we hold about you.

Correct inaccuracies: You may request correction of inaccurate or incomplete information in your records.

Opt out of marketing: You may opt out of marketing communications at any time by clicking "unsubscribe" in any email or contacting us directly. Opting out of marketing does not affect required service communications about your loan account.

Credit report disputes: If you believe information we reported to a credit bureau is inaccurate, you may dispute it directly with the bureau or through us. We will investigate and respond as required by the Fair Credit Reporting Act.

To exercise any of these rights, contact us at [email protected] or at our mailing address: 1 Willow Lake Plaza, Suite 400, Charlotte, NC 28202.

6. Cookies & Tracking Technologies

We use cookies and similar technologies to:

Essential cookies: Operate core website functions, maintain your session state during an application, and prevent fraud. These cannot be disabled without impairing site functionality.

Analytics cookies: Understand how visitors interact with our website (pages viewed, time on site, referring sources). We use this data in aggregate to improve our services. We use Google Analytics with IP anonymization enabled.

Preference cookies: Remember your preferences (such as form data you've entered).

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may impair your ability to use portions of our site. We do not use cross-site tracking cookies to build advertising profiles about you.

7. Third-Party Links

Our website contains links to third-party websites, including government agencies such as the CFPB and FTC. These links are provided for your information only. We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party site you visit.

8. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected information from a child under 18, we will delete it promptly. If you believe we may have collected information from a minor, please contact us immediately at [email protected].

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information. These include the right to know what personal information we collect and how it's used, the right to delete your personal information (subject to certain exceptions), the right to opt out of the sale or sharing of your personal information (note: we do not sell personal information), and the right to non-discrimination for exercising your privacy rights.

To submit a California privacy rights request, contact us at [email protected] or call 1-800-555-4823. We will respond within 45 days as required by law.

Note: Certain financial data collected in connection with lending products is regulated under the GLBA and is subject to its specific provisions rather than CCPA/CPRA. We will identify which exemption applies when responding to your request.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last Updated" date at the top of this policy and, where required by law or where changes are significant, notify you by email or prominent website notice. Your continued use of our services after the effective date of an updated policy constitutes acceptance of the changes.

11. Contact Us About Privacy

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will respond to all privacy inquiries within 30 days. For complaints about our privacy practices that we have not resolved to your satisfaction, you may file a complaint with the CFPB Consumer Complaint Database or the FTC Complaint Center.