Privacy Policy

Updated: January 15, 2020

Notice of California Privacy Rights

California Important Privacy Choices for Consumers

Privacy Notice

Introduction

Welcome to CommonBond. This Privacy Statement describes how CommonBond (“we” or “our”) collects, receives and shares information about consumers (“you”) from our website and any off-line communications we may have with you, e.g. emails, telephone calls, text messages and personal communication, located at http://commonbond.co. This Privacy Policy, together with our Terms of Use govern your use of our website and our collection and use of your information.

How does CommonBond work?

CommonBond offers loans for current undergraduate and graduate students, refinancing loans for people who have already graduated and contributions processing for people participating in their employer’s student loan benefits program. Loans are originated by CommonBond Lending, LLC.

What information does CommonBond collect from visitors to this website?

CommonBond collects the following information from students, graduates, and visitors to our website:

  • information you provide on our website such as contact information, school affiliation or feedback; and

  • basic traffic information about your visit such as IP address, host name and pages on our site visited.

  • loan application information such as social security number, income, and assets loan decisions. Such information may be shared with a partner bank.

  • Existing student loan information such as existing balances and loan servicer information.

We use third parties to gather your data from financial institutions. By using our service, you grant our third-party provider the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to the terms of our third-party provider's privacy policy.

We do not collect personally identifiable information from website visitors who do not voluntarily submit such information. However, information collected from prior visits could be associated with personally identifiable information if you later submit such information to us.

Registered users

If you create a registered account on our website, we will collect information from you, including:

Name;
Email Address; and
Password.

Cookies

We may use cookies and similar technologies such as web beacons to support the functionality of our customer portal, monitor traffic patterns and collect information about your previous visits to our web site.

Children and privacy

This website is not intended for use by children. If you are under 18, you may use this website only with the involvement of a parent or guardian. If you are a parent or guardian and believe that we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to info@commonbond.co.

How does CommonBond use information collected from visitors to this website?

We use information collected from website visitors to improve the content and browsing experience of our website, to provide information regarding our products to you, and respond to you. This information is not sold to non-affiliated third parties for marketing purposes, however we may contact you with marketing offers. CommonBond may disclose information collected from website visitors to:

  • trusted services providers who work on our behalf, who do not have independent use of the information we disclose to them, and who have agreed to adhere to the rules set forth in the privacy statement;

  • alert you to new features, products, events, or services;

  • third party service providers and/or joint marketing partners to allow us to make other marketing offers that we think may be of interest of you;

  • third parties as required by law, such as to comply with a subpoena or similar legal process

  • third parties as we deem necessary, based on our good faith belief, (i) to protect our rights, your safety or the safety of others, (ii) to investigate fraud, or (iii) to respond to a government request; and

  • third parties in conjunction with a merger, acquisition or sale of CommonBond. If CommonBond is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information. Information obtained about loan applications and decisions from our partner bank may be used to improve our services or offer additional services. Use of information obtained from a partner bank will be used in accordance with the bank's privacy policy.

Remarketing

This website uses Google AdWords as a third party remarketing service to advertise across the internet to previous visitors of our website. Third-party remarketing services including Google, will use cookies and pixel tags (action tags) on your web browser to collect non-identifiable information about your visits and interaction with our website and display advertisements based on these past visits. The advertisements could be in the form of an advertisement on a Google search results page, a site in the Google Display Network, a banner or link. You can set preferences for how Google advertises to you using the Google Ad Settings page or opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. If you want to you can opt-out page of interest-based advertising entirely by changing your cookie settings or permanently using a browser plugin.

Opt out

You may choose to opt-out of receiving unrequested communications by clicking “unsubscribe” of a given communication or by emailing info@commonbond.co.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, administrative, and technical safeguards to protect the information we collect and maintain.  If you notice a vulnerability, please let us know by submitting this form.

Changes

This Privacy Statement may be updated from time to time for any reason. We will notify you of any changes to our Privacy Statement by posting the new Privacy Statement here, http://commonbond.co/privacy-policy. Please consult this Privacy Statement regularly for any changes.

Your consent

By using our website, you consent to the collection, processing and storage of information as described in this Privacy Statement. Processing activities may take place in the United States. If you reside outside of the United States, your information may be transferred to, and processed and stored in, the United States or other jurisdictions in accordance with applicable law in that jurisdiction. If you do not agree to these terms, do not use this website.

Notice of California privacy rights

Customers may access, review and/or correct all their personally identifiable information that we collect online by sending an email to info@commonbond.co with a subject heading "Customer Choice Privacy Notice," and allow thirty (30) days for a response.

CommonBond, Inc.
524 Broadway, 6th Floor
New York, NY, 10012
United States of America

Notice of California Consumer Privacy Act of 2018 ("CCPA") privacy rights

I. Applicability This section applies to California residents.

II. CommonBond’s Practices Regarding Consumers’ Personal Information

  • Notice at Collection:

    • Category of personal information: Identifiers such as a real name; alias; postal address; unique personal identifiers such as application and loan numbers; email address; telephone number; social security number; driver’s license number or passport number; or other similar identifiers, and Professional or employment-related information.

      • Business or commercial purpose for which collected: To provide you with financial products and services, as well as employer benefits related to student loans and higher education financing.

    • Category of personal information: Anonymized internet or other electronic network activity information including information regarding a consumer’s interaction with an Internet Web site, application, or advertisement such as cookies and marketing pixels.

      • Business or commercial purpose for which collected:  To market products and services that may be of interest to you.

  • Personal Information Collected: CommonBond has collected the following categories of personal information in the preceding 12 months:

    • Category of personal information: Identifiers such as a real name; alias; postal address; unique personal identifiers such as application and loan numbers; email address; telephone number; social security number; driver’s license number or passport number; or other similar identifiers, and Professional or employment-related information.

      • Business or commercial purpose for which collected: To provide you with financial products and services, as well as employer benefits related to student loans and higher education financing.

      • Categories of sources from which this personal information was collected: From you directly, from other financial institutions, and from your employer, as applicable.

      • Categories of third parties with whom we share this personal information: Service providers; third parties as required by law such as to comply with a subpoena or similar legal process; third parties as we may deem necessary based on our good faith belief to protect our rights, your safety and the safety of others and to investigate fraud and respond to government requests, and third parties in conjunction with a merger, acquisition, or sale of CommonBond.

    • Category of personal information: Anonymized internet or other electronic network activity information including information regarding a consumer’s interaction with an Internet Web site, application, or advertisement such as cookies and marketing pixels.

      • Business or commercial purpose for which collected:  To market products and services that may be of interest to you.

      • Categories of sources from which this personal information was collected: From your direct use of our website.

      • Categories of third parties with whom we share this personal information: Third party marketers and social networks.

  • Personal Information Disclosed: CommonBond has disclosed the following categories of personal information in the preceding 12 months for our business purposes:

    • Identifiers such as a real name; alias; postal address; unique personal identifiers such as application and loan numbers; email address; telephone number; social security number; driver’s license number or passport number; or other similar identifiers, and Professional or employment-related information in order to provide you with financial products and services to service financial products and services obtained from us.

    • Internet or other electronic network activity information including information regarding a consumer’s interaction with an Internet Web site, application, or advertisement such as cookies and marketing pixels for marketing to third-party marketers to market our products and services that may be of interest to you.

  • CommonBond has not sold consumers’ personal information for a commercial purpose in the preceding 12 months, and CommonBond will not sell consumers’ personal information to third parties for a commercial purpose.  CommonBond does not sell the personal information of minors under 16 years of age without affirmative authorization.  

III. Your Right to Know and Right to Delete under the CCPA

  • Right to Know: You have the right to request that CommonBond disclose certain items about your personal information subject to the CCPA that we: (i) collect; (ii) sell; or (iii) disclose for a business purpose, as applicable to CommonBond’s business practices (“Request to Know”).

    • Personal Information that we Collect: You have the right to request that CommonBond disclose to you the following regarding your personal information subject to the CCPA that we collect (as applicable to CommonBond’s business practices): (i) the specific pieces of personal information; (ii) the categories of such personal information; (iii) the categories of sources from which such personal information is collected; (iv) the business or commercial purpose for collecting or selling such personal information; and (v) the categories of third parties with whom we share personal information.

    • Personal Information that we Sell and/or Disclose for a Business Purpose: You have the right to request that CommonBond disclose to you the following regarding your personal information subject to the CCPA that we sell and/or disclose for a business purpose (as applicable to CommonBond’s business practices): (i) the categories of personal information that we collected about you; (ii) the categories of personal information about you that we sold; (iii) the categories of third parties to whom the personal information was sold; and (iv) the categories of personal information that we disclosed about you for a business purpose.

  • Right to Delete: You have the right to request that CommonBond delete any personal information subject to the CCPA about you that we have collected or maintained (as applicable to CommonBond’s business practices) (“Request to Delete”).

  • How to submit a Request to Know and/or a Request to Delete: You can submit a Request to Know and/or a Request to Delete by contacting us at info@commonbond.com with the subject line “Request under CCPA,” toll-free 800-975-7812, or the chat function at the bottom of the screen.  We will verify your request by using information we already have on file that we believe will sufficiently confirm your identity.  We may require to ask for additional information to verify your request.

    This request may be denied if you provided your personal information in order to obtain financial products and services from us or if such personal information is required to provide you with products and services you have requested, as regulated by the federal Gramm-Leach-Bliley Act or the California Financial Information Privacy Act.  Please allow 45 days for a response.

IV. Right to Non-Discrimination for the Exercise of Your Privacy Rights under the CCPA
CommonBond is prohibited from discriminating against you because you have exercised any of your rights under the CCPA.  Specifically, CommonBond cannot  do any of the following: (i) deny good or services to you; (ii) charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (iii) provide a different level or quality of goods or services to you; or (iv) suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Notice of privacy rights

Customers may access, review and/or correct all their personally identifiable information that we collect online by sending an email to info@commonbond.co with a subject heading "Customer Choice Privacy Notice," and allow thirty (30) days for a response.

CommonBond, Inc.
524 Broadway, 6th Floor
New York, NY, 10012
United States of America

Contact us

If you have any questions about how we collect, store and use your information, and our privacy policies and practices generally, you may contact us by e-mailing us at info@commonbond.co.

Vermont customers

We will not disclose nonpublic personal financial information about you to nonaffiliated third parties (other than as permitted by law) unless you authorize us to make that disclosure. Your authorization must be in writing or, if you agree, in electronic form.