Privacy Policy
Effective date: ____________________ | Last updated: ____________________ | Version: 1.0
DRAFT — PENDING COUNSEL REVIEWBorrowExperts is operated by WeLead LLC, a Wyoming limited liability company doing business as BorrowExperts, registered at 30 N Gould St, Ste N, Sheridan, WY 82801 ("BorrowExperts", "we", "us", "our"). This policy explains how we collect, use, disclose, sell and share personal information through borrowexperts.com and any BorrowExperts-branded page or form (the "Services").
BorrowExperts is not a lender, bank, or credit union. We are an advertising and matching service. We connect consumers who request information about personal loans with third-party lenders and lead purchasers (including lead aggregators and networks that may pass your information to lenders in their own networks) ("Marketing Partners"). We do not make credit decisions, do not set rates or terms, and do not fund loans. Marketing Partners pay us when they accept an inquiry. What a Marketing Partner pays us may affect which Marketing Partners receive your inquiry and the order in which they contact you. We do not recommend or endorse any Marketing Partner or loan.
This is the single most important thing to understand about this policy: when you submit our form, we sell or share your information with Marketing Partners, and they will contact you. That is the purpose of the Services.
When you complete our loan inquiry form we collect:
| Category | Examples |
|---|---|
| Identifiers | Name, email address, mobile telephone number, postal address, date of birth, Social Security number |
| Financial information | Requested loan amount, loan purpose, self-reported credit score range, gross income, employment status, employer name, pay frequency, residence status. Bank routing and account number, only after a lender has accepted your inquiry and only if that lender requires them (see section 2.4) |
| Commercial information | Products you inquired about, submission history |
| Consent records | The consent language version displayed, the Marketing Partner list as displayed, the version of our Terms of Service displayed, timestamp, IP address, browser user agent, and page URL at the time of submission, the version of our Credit Authorization and Consumer Report Consent displayed |
Why we ask for your Social Security number. Lenders need it to confirm your identity and to review your inquiry. We do not use it to check your credit, and we do not obtain a credit report — see our Credit Authorization and Consumer Report Consent. We pass it only to Marketing Partner that is a lender, or to a Marketing Partner that is contractually required to pass it only to a lender and not to keep or use it for any other purpose. How we protect it is set out in our Social Security Number Protection Policy.
IP address, device and browser type, operating system, referring URL, pages viewed, time spent, and interaction data. We collect this through cookies, pixels, session-replay and consent-certification technologies. See our Cookie and Tracking Notice.
We use third-party consent certification services (currently TrustedForm and Jornaya LeadiD) which record your interaction with our form in order to evidence the consent you provided. These services create a record of your form session, including what you type into the form, from the time the form page loads, including before you submit it. We do not allow advertising cookies, pixels, or tags on our form pages to receive the information you type into the form
We receive information from affiliate publishers and advertising partners who refer you to us, and from fraud-prevention and data-validation vendors (currently IPQualityScore) who verify that the contact details submitted are valid and not fraudulent.
Your Social Security number is sensitive personal information under California and other state privacy law. We collect it, and we disclose it to Marketing Partners only as described in section 2.1.
Where a lender requires it, we also collect your bank routing and account number, but only after that lender has accepted your inquiry. We do not collect online banking usernames, passwords or security codes, and we do not collect payment card numbers. We treat bank details as restricted information and protect them to the same standard as a Social Security number.
We collect and disclose this information for one purpose: to transmit your inquiry to Marketing Partners so that they can verify your identity and assess it. We do not use it to infer characteristics about you, and we do not use or disclose it for any purpose that is not reasonably necessary to provide the Services or otherwise permitted by law. Because we use sensitive personal information only for these purposes, which California law permits without offering a right to limit, we do not currently offer a "Limit the Use of My Sensitive Personal Information" link. If that changes, we will add one.
The Services are not directed to and are not intended for anyone under 18. We do not knowingly collect information from anyone under 18. If we learn we have, we will delete it. To report this, contact us at [PRIVACY EMAIL].
We do not ask about your citizenship or immigration status, and we do not collect information about your race, ethnicity, religion, health, or sex life. Please do not include this information in any free-text field on our form.
- To match your inquiry with Marketing Partners and transmit your information to them, where a lender requires it, including your Social Security number, so they can verify your identity and assess your inquiry
- To validate and verify the information you submit and detect fraud
- To create and retain a record of your consent
- To contact you about your inquiry by call, text, or email where you have consented
- To honor your opt-out and do-not-contact requests, and to forward them to Marketing Partners that received your information from us
- To operate, secure, analyse and improve the Services
- To pay and audit our affiliate publishers
- To comply with legal obligations and to establish, exercise or defend legal claims
We sell your personal information to Marketing Partners. When you submit the form, we offer your inquiry to lenders and lead purchasers, and we are paid when one accepts it. That transfer may be a "sale" under California and other state privacy laws. Seperately, where we use advertising cookies or pixels on pages of our website other than our form pages, that use may be a "share" for cross-context behavioral advertising, or "targeted advertising," under those laws. See section 7.4 and our Cookie and Tracking Notice.
Some Marketing Partners are lead aggregators or networks. A lead aggregator that buys your inquiry from us may sell or pass your information to lenders in its own network so that they can contact you about loan products. You may opt out of it, and all other sales and sharing, at borrowexperts.com/do-not-sell.
The Marketing Partners we may transmit your information to are listed and kept current at borrowexperts.com/partners, which identifies which Marketing Partners are lenders and which are lead aggregator.. The list displayed to you at the time you submitted is the list that applies to your consent.
Once a Marketing Partner receives your information, that partner controls it under its own privacy policy. We require Marketing Partners, by contract, to use your information only for the purpose described in this policy and in the consent you gave, and to protect it. If you ask us to delete information, we will also notify each Marketing Partner that bought it from us and direct it to delete your information, as required by state laws, unless doing so proves impossible or involves disproportionate effort. Each Marketing Partner remains responsible for its own copy, and consent you gave directly to a Marketing Partner is between you and that partner. We recommend that you also contact any Marketing Partner directly.4.2 Service providers
We disclose information to vendors who process it on our behalf under contract and may not use it for their own purposes: our lead delivery and auction platform, hosting, analytics, consent certification, fraud prevention, communications, and professional advisers. Our contracts with these vendors require them to protect your information and to process it only as we instruct.
To comply with law, subpoena or lawful request; to enforce our terms; to protect the rights, safety or property of any person; and in connection with a merger, acquisition or sale of assets.
We do not sell or share the personal information of consumers we know to be under 16. We do not sell your information to anyone for purposes unrelated to loan products. We do not sell your Social Security number or bank details except as described in sections 2.1 and 2.4.
Federal laws, such as the Gramm-Leach-Bliley Act, gives consumers the right to limit so, but not all sharing of personal financial information. When you submit our form, you direct us to disclose the information you provide to Marketing Partners so that they can contact you about the loan products you requested. We make that disclosure at your direction and with your consent. We do not disclose your nonpublic personal information to nonaffiliated third parties for any other purpose, except as permitted by law, such as to our service providers, to prevent fraud, or to comply with legal requirements. We protect your information as described in section 8.
If you provided consent on our form, you agreed that BorrowExperts and the Marketing Partners named or linked in that consent may contact you at the telephone number you supplied — including by automatic telephone dialling system, artificial or prerecorded voice (including AI-generated voice), and SMS text message — about loan products, even if your number is on a federal or state do-not-call list. Consent is not a condition of any purchase or of receiving results. Message and data rates may apply.
To stop contact from us: reply STOP to any text, click unsubscribe in any email, tell us during any call, email [PRIVACY EMAIL], or use any other reasonable means to tell us. We honor opt-out requests within 10 business days and maintain an internal do-not-call list. See our Do Not Call Policy.
To stop contact from a Marketing Partner: we will forward your opt-out request to each Marketing Partner that received your inquiry from us. Because each Marketing Partner keeps its own records, we recommend that you also tell that partner directly. We will provide their contact details on request.
Text Messaging: Text messaging opt-in data and consent that you give to BorrowExperts for BorrowExperts' own text messaging are not shared with or sold to any third party. A Marketing Partner that texts you does so under the consent you gave to that Marketing Partner on our form, not under BorrowExperts' messaging program.
| Data | Retention period |
|---|---|
| Consent records (TrustedForm/Jornaya certificates, timestamp, IP, user agent, URL, consent text version, credit authorization record) | 5 years from submission |
| Social Security number | 30 days from submission, after which it is deleted or irreversibly truncated to the last four digits |
| Bank routing and account number (where collected) | Deleted within 7 days after delivery to the lender that accepted your inquiry. |
| Inquiry and financial information | 3 years from submission |
| Internal do-not-call and suppression records | Indefinitely, so we can continue to honour your request |
| Website analytics and cookie data | 13 months |
We retain information for as long as needed for the purposes described, to comply with legal obligations, and to defend legal claims.
If you are a California resident you have the right to:
- Know what personal information we have collected, the sources, the purposes, and the categories of third parties we disclose or sell it to
- Access a copy of that information
- Delete your personal information, subject to exceptions
- Correct inaccurate personal information
- Opt out of sale and sharing — see borrowexperts.com/do-not-sell
- Limit the use of sensitive personal information. We use sensitive personal information only for the purposes described in section 2.4, which California law permits, so this right does not currently apply to our processing.
- Non-discrimination for exercising your rights
Categories collected, sold and shared in the preceding 12 months:
| Category (Cal. Civ. Code § 1798.140) | Collected | Sold / Shared | Disclosed to service providers |
|---|---|---|---|
| Identifiers | Yes | Sold | Yes |
| Personal information under § 1798.80 | Yes | Sold | Yes |
| Characteristics of protected classifications (age, from date of birth) | Yes | Sold | Yes |
| Commercial information | Yes | Sold | Yes |
| Internet or network activity | Yes | Shared (advertising cookies on non-form pages only) | Yes |
| Geolocation (approximate, from IP) | Yes | Sold (IP address delivered with consent record) | Yes |
| Professional or employment information | Yes | Sold | Yes |
| Inferences | No | No | No |
| Sensitive personal information (Social Security number; and see 2.4 on bank details) | Yes | Sold | Yes |
We sell the categories marked "Sold" to Marketing Partners (lenders and lead aggregators). We share the category marked "Shared" with advertising partners. We do not have actual knowledge that we sell or share the personal information of consumers under 16.
Residents of states with comprehensive privacy laws in effect — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and others as they take effect — have rights confirm whether we process their personal data,to access, correct, delete, obtain a portable copy, and opt out of the sale of personal data and of targeted advertising and certain profiling. Residents of some states, including Oregon and Minnesota, may also request a list of the specifc third parties to which we have disclosed personal data; that list is maintained at borrowexperts.com/partners.
Some states allow you to appeal a refused request. If we deny your request you may appeal by emailing [PRIVACY EMAIL] with "Appeal" in the subject line. We will respond within the period required by your state's law. If we deny your appeal, you may contact the attorney general of your state.
- Web form: borrowexperts.com/privacy-request
- Email: [PRIVACY EMAIL]
We will verify your identity by matching the information you provide against our records. We may ask for additional information where we cannot verify you. An authorised agent may submit a request on your behalf with written permission and proof of identity.
We respond within 45 days, extendable by a further 45 days with notice.
We honour the Global Privacy Control (GPC) and other recognised opt-out preference signals as a valid request to opt out of sale and sharing for the browser transmitting the signal and, where can we associate that browser with your inquiry, for you. Our website displays whether we have processed an opt-out preference signal from your browser.
We use administrative, technical and physical safeguards including encryption in transit and at rest and access controls limited to personnel with a business need. We maintain a written information security program designed to meet the Federal Trade Commission's Safeguards Rule. If a security incident affects your information, we will notify you and regulators as the law results. No method of transmission or storage is completely secure and we cannot guarantee absolute security.
The Services link to sites we do not control, including Marketing Partner sites. This policy does not apply to them. Review their privacy policies before providing information.
We may update this policy. We will change the "Last updated" date and, where required, provide additional notice. We maintain archived copies of prior versions, and the version in force at the time you submitted your information governs that submission. If we make a material change to how we use or disclose information we have already collected, we will ask for your consent where the law requires it.
WeLead LLC d/b/a BorrowExperts 30 N Gould St, Ste N, Sheridan, WY 82801 Email: [PRIVACY EMAIL] Telephone: [PHONE]