General Privacy Policy
This policy describes how Avant, LLC collects, uses, and shares personal information when you visit our website, communicate with us, submit information to a third party that provides it to us, or provides services for us. If you apply for, or obtain a loan of other financial product offered through Avant, our privacy practices with regard to that information are governed by the Avant and Webbank Privacy Notices. You can jump to particular topics by going to the headings below:
Types Of Information We Collect
The following provides examples of the type of information that we collect from you and how we use that information.
| Source or Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
| Business Partner Information | We collect the name and contact information of our business partners and their employees with whom we may interact. | We have a legitimate interest in contacting our business partners and we use this information to communicate with them concerning normal business administration such as projects, services, and billing. |
| Checking Your Loan Options/Application Process | We collect the information that you enter in connection with online application forms on our website, which includes your name, certain information related to your financial situation such as income and housing status, and other identifying information such as Social Security Numbers, military status, and date of birth, and any personal offer code that you have received. | We ask for your consent to use your information to obtain a consumer report. We also ask your consent to receive communications about our products and services. We also have a legitimate interest in knowing about the individuals who submit an inquiry or begin to submit an inquiry for credit. Once the application information is submitted, your information included in that application is not governed by this privacy policy. Instead you should refer to the Avant Privacy Notice and the Webbank Privacy Notice. |
| Cookies and First Party Tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. | We have a legitimate interest in making our website operate efficiently, and use cookies to do so. |
| Cookies and Third Party Tracking | With your consent, we participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. | We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics. |
| Email Interconnectivity | If you receive emails from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and when you check your credit options through avant.com. | We have a legitimate interest in understanding how you interact with our communications to you. |
| Employment | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. Other demographic information may be collected in this context. | We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and workforce operations. |
| Feedback/Support | If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply. | We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
| Mailing List | We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or using our app. | We have a legitimate interest in identifying unique visitors, developing the mobile version of our web sites, and in understanding how users interact with us on their mobile devices. We also have a legitimate interest in detecting and preventing fraud. |
| Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or using our app. | We have a legitimate interest in identifying unique visitors, developing the mobile version of our web sites, and in understanding how users interact with us on their mobile devices. We also have a legitimate interest in detecting and preventing fraud. |
| Partner Promotion | We may offer you the opportunity to apply for a financial product with a third party. The offer may require you to submit personal information to determine your eligibility. | We collect this information and share with the third party upon your consent. |
| Service Provider Information | We collect the name and contact information of our service providers and their employees with whom we may interact. | We have a legitimate interest in contacting our service providers and we use this information to communicate with them concerning normal business administration such as projects, services, and billing. |
| Surveys | When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party may also provide you with a copy of their privacy policy which would apply to their collection, use, and disclosure of your information. | We collect this information based upon consent granted at the time that you submit your response. We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization. |
| Website interactions | We use technology to monitor how you interact with our website. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
| Web logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services are the most popular and to detect and prevent fraud. |
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
Use And Processing Of Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our website.
- To provide products and services.
- To improve our services and product offerings.
- To streamline the application process.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials, including information relating to products, services, or promotions.
- For internal administrative purposes, as well as to manage our relationships.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an employment application with Avant, we will consensually collect your information in order to make an employment decision. We also have a legitimate interest in keeping that information once the decision is made, in order to comply with existing law, facilitate the potential employment relationship, or maintain records of our applicant search. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products or the provision of services by a third party intermediary.
- Partner Promotion. We may offer promotions with third party partners. If you decide to take part in a promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
- Service Providers. We may share your information with service providers. Among other things service providers may help us administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
California Privacy Rights
You can make the following requests regarding your personal information:
- Access To Your Personal Information. You may request access to your personal information by contacting us at [email protected] or by mailing your request to the address described in the section below titled “Contact Information.” If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. In these cases, we may request additional information from you in order to verify your identity, such as your relationship with Avant. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
- Deletion Of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You have the right under California law to request the deletion of certain information and you may request that we delete your personal information by contacting us at [email protected] with a description of your request or by sending your request in the mail to the address listed in the section below titled “Contact Information.” If required by law, we will grant a request to delete the information after we verify your identity, which may require you to provide additional information, such as your relationship with Avant. You should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, detect fraud, or for another one of our business purposes.
- Designation of an Authorized Agent. If you are a California resident, you may designate an “authorized agent” to exercise any of the rights listed above on your behalf. We will require authorized agents to have a written authorization confirming that authority.
- Objection to Certain Processing. Avant does not sell personal information collected at this time. However, we do provide our website visitors the option to opt-in to sharing information through the use of marketing cookies. If you have already consented to marketing cookies and wish to change your preferences, simply clear the cache and cookies in your browser, and the cookie preference banner will reappear on our website.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
- Revocation Of Consent. If you decide to opt-in to the use of marketing cookies on our website and change your mind, go into your browser settings and clear your cookie cache. You will then be prompted to either consent or not consent to the use of marketing cookies the next time you visit our website.
- Right to Receive Services on Equal Terms. Under California law, Avant shall not discriminate against a consumer because the consumer exercised any of their rights under the California Consumer Privacy Act. We do not discriminate against consumers who exercise any of their rights described in this policy.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
Miscellaneous
The following additional information relates to our privacy practices:
- Transmission Of Information To Other Countries. Avant only seeks personal information from residents of the United States. If you are a resident of another country, and choose to send information to Avant, you agree to the transfer, storage and processing of your information in a country other than your country of residence, including, but not necessarily limited to, the United States.
- Privacy Practices Regarding Minors. Avant products are not intended for individuals under the age of 18, and we do not knowingly collect or share the personal information of minors.
- Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, unless we receive your consent to the new privacy policy, the policy that was in place at the time that you submitted personal information to us will generally govern that information. This policy was last updated at the date indicated below. Your continued use of Avant services after any changes or revisions of this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
- Information for California Residents. California Civil Codes 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we share by going to our California Information Sharing Disclosure. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us at [email protected] or mail it to the address listed in the section below titled “Contact Information.” Please note that we do not sell personal information to third parties at this time, but we do share information with our service providers for the purpose of providing our services to you.
Contact Information
If you have any questions, comments, data requests or complaints concerning our privacy practices, please contact us at the appropriate address below. To make a data request, please email us at the email address below using the email address that you have used in connection with Avant in the past. If submitting a request via mail, please include the email address that you have used in connection with Avant.
Email Data Requests to:
Mail Data Requests to:
Avant, LLC
Attn: Data Request
222 W. Merchandise Mart Plaza. Suite 900 Chicago, IL 60654
Last Revised: December 29, 2020
Effective Date: December 29, 2020
California Information Sharing Disclosure
California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that companies should disclose whether the following categories of information are collected, transferred for consideration, or transferred for an organization’s “business purpose” as that term is defined under California law. Note that while a category may be marked that does not necessarily mean that we have information in that category about you. For example, while we transfer bank account numbers for our business purpose in paying our employees (e.g., direct deposit) we do not collect or transfer bank account numbers of individuals that submit questions on our website’s “contact us” page.
The following table reflects Avant’s data collection and disclosure practices within the last 12 months for information that is governed under the CCPA. It does not include information that is exempt from the CCPA and governed by our Avant Customer Privacy Notice.
| Category of Personal Information | Is Information Collected by Us? | Is Information Transferred for valuable consideration? | Is information transferred for business purpose? |
|---|---|---|---|
| Audio, electronic, visual, or similar information | Yes | No | Yes |
| Thermal or olfactory information | No | No | No |
| Bank account number | Yes | No | Yes |
| Biometric information | No | No | No |
| Characteristics of protected classifications under California or Federal Law* | Yes | No | Yes |
| Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies) | Yes | No | Yes |
| Credit card number | No | No | No |
| Debit card number | No | No | No |
| Driver’s License Number / State ID | Yes | No | Yes |
| Education | Yes | No | Yes |
| Electronic network activity (e.g., browsing history) | Yes | No | Yes |
| Email address | Yes | No | Yes |
| Employment | Yes | No | Yes |
| Employment history | Yes | No | Yes |
| Geolocation data | Yes | No | Yes |
| Health insurance information | Yes | No | Yes |
| Identifiers (e.g., name or alias) | Yes | No | Yes |
| Insurance Policy Number | Yes | No | Yes |
| Medical information | Yes | No | Yes |
| Online identifier (e.g. IP address / cookie) | Yes | Yes** | Yes |
| Other financial information | Yes | No | Yes |
| Passport number | Yes | No | Yes |
| Physical characteristics*** | Yes | No | Yes |
| Postal address | Yes | No | Yes |
| Signature | Yes | No | Yes |
| Social Security Number | Yes | No | Yes |
| Telephone number | Yes | No | Yes |
| Transaction information | Yes | No | Yes |
* We collect your age in connection with your loan application.
** Only upon opt-in.
*** We use this information to verify your identity and prevent fraud.
Sources of Personal Information
We obtain the personal information listed above from the following categories of sources:
- Directly from you or your authorized agents. For example, if you apply for employment at Avant through our website, we will collect and retain that information in order to make hiring decisions.
- Service providers, such as recruiting agencies for employment
- Public record sources or government entities
- Marketing partners
We may disclose your personal information with any of the following third parties listed below:
- Service Providers and vendors who provide services to us, such as software providers, data analytics providers, auditors, customer service providers, and payment processors
- Government entities
- Third party security providers to help us prevent and detect fraud or illegal activity