Privacy Policy

1. Introduction and scope

Alameda Loans helps consumers explore financing options by collecting information you provide and matching you with third-party lenders, financial institutions, and marketing partners. We package that information into leads and transmit it to buyers who may contact you with offers.

We are not a lender. We do not extend credit, make underwriting decisions, set rates or fees, or disburse loan proceeds. Any loan terms are offered solely by third parties.

This Policy applies to personal information we collect through the App, our website, customer support, and related channels. It describes our practices for U.S. residents who are at least 18 years old. By downloading, accessing, or using the App, you acknowledge that you have read this Policy. If you do not agree, do not use the Services.

2. Laws and regulatory framework

Our handling of personal information is subject to multiple U.S. federal and state frameworks, including:

• Gramm-Leach-Bliley Act (GLBA) — Social Security numbers, bank account and routing numbers, income, and employment details are “nonpublic personal financial information” under GLBA. GLBA may require separate notices and can limit certain state privacy rights for financial data.
• California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) — including broad definitions of “sale” and “sharing” of personal information.
• Fair Credit Reporting Act (FCRA) — where we or partners obtain or use consumer reports or credit-related data.
• Federal Trade Commission (FTC) rules and guidance on lead generation, data brokers, and truthful advertising.
• CAN-SPAM Act and Telephone Consumer Protection Act (TCPA) — for email, SMS, and telemarketing where applicable.
• State comprehensive privacy laws (for example, Colorado CPA, Virginia VCDPA, Connecticut CTDPA, Texas TDPSA).

Where GLBA or FCRA applies to specific data, those laws may preempt or limit certain state privacy rights for that information.

3. Information we collect

3a. Information you provide directly

When you use the App, you may provide the following categories of information:

Personal identifiers

• Full legal name (first, middle, last)
• Date of birth
• Email address
• Phone number (mobile and/or home)
• Full residential address including street, city, state, and ZIP code

Government and identity documents

• Social Security Number (SSN)
• Driver’s license number and issuing state

We collect your SSN to verify your identity, satisfy know-your-customer (KYC) requirements expected by lender partners, and help prevent fraud. SSN is transmitted using encryption in transit (TLS).

We collect driver’s license information to confirm identity, validate state eligibility, and meet partner KYC obligations.

Financial and employment information

• Bank account number (full account number)
• Bank routing number
• Bank name and account type (checking / savings)
• Employer name
• Employer phone number
• Employment status and job title
• Monthly or annual gross income
• Source of income (employment, self-employment, benefits, other)
• Purpose of the loan or cash advance request

We collect bank account and routing numbers so lender partners can verify account ownership, evaluate eligibility, and—if you proceed with a lender—potentially set up ACH disbursement or repayment as described in that lender’s disclosures.

We collect employer name and employer phone number because lenders may use them for income and employment verification.

3b. Information collected automatically

When you interact with the App or website, we and our analytics partners may automatically collect:

• Device identifiers, operating system, device model, and App version
• IP address and network connection type
• Usage patterns, session duration, screens viewed, and clickstream data
• Approximate location inferred from IP address or device signals
• Data from cookies, mobile software development kits (SDKs), pixels, and similar technologies

3c. Information from third parties

We may receive information about you from:

• Identity verification and fraud-prevention vendors
• Credit bureaus and alternative data providers (in FCRA-governed contexts)
• Marketing or referral partners who direct users to the App
• Service providers that support hosting, analytics, and communications

4. How we use your information

We use personal information for purposes that include:

• Creating and managing your account and authenticating your identity
• Performing KYC, fraud screening, and eligibility checks
• Packaging your data into a lead and matching you with lender and marketing partners
• Selling your information to third-party lenders, financial institutions, and marketing partners (see Section 5)
• Processing referrals and facilitating connections you request
• Sending transactional messages and, where you have consented, marketing communications
• Improving App performance, debugging, and conducting analytics
• Complying with legal obligations, responding to lawful requests, and enforcing our Terms of Use

5. Sale and sharing of personal information

This section is important. We sell personal information. Please read it carefully before using the App.

5.1 We sell your personal information

ALAMEDA HOME LOANS LLC sells personal information as defined by the CCPA/CPRA and applicable state privacy laws. “Sale” includes disclosing personal information to third parties for monetary or other valuable consideration—not only cash payments, but also referral fees, per-lead fees, revenue share, or other benefits.

We sell data to categories of buyers that include:

• Third-party lenders and financial institutions
• Marketing partners and advertisers
• Data aggregators and lead buyers
• Insurance, debt relief, and related financial product providers

Data we sell may include, among other fields: your name; phone number; email address; full address with ZIP code; SSN; driver’s license number and state; bank account number; bank routing number; bank name; employer name; employer phone number; income; employment status; and loan purpose.

Compensation we receive may influence which partners receive your data first, how quickly leads are routed, or how offers are ranked or displayed in the App. Buyers act independently; we do not control their underwriting decisions or final terms.

5.2 Categories of third parties who buy or receive your data

• Licensed lenders and financial institutions — personal loans, installment loans, cash advances, lines of credit, and similar products
• Insurance companies and financial product providers
• Debt relief and credit counseling companies
• Marketing partners who may contact you about financial and non-financial products
• Data brokers and aggregators who may resell or further license the data to additional parties. Once sold, we do not control downstream use.

After a sale, the buyer’s own privacy policy and practices govern further use of your information. We encourage you to review a buyer’s policies before accepting an offer or providing additional information.

5.3 Your right to opt out of sale

If you are a California resident—or reside in another state that provides a comparable opt-out right—you may direct us to stop selling your personal information going forward.

How to opt out:

• Email legal@alamedahomeloans.com with the subject line “Do Not Sell My Information”; or
• Use the in-app “Do Not Sell My Personal Information” link in Settings (where available).

We will process verified opt-out requests within 15 business days. Opting out stops future sales but does not delete information already sold to third parties; we cannot recall data from buyers’ systems.

Even after an opt-out, we may share limited information as required by law, to prevent fraud, or to complete a specific transaction you initiate through the App (for example, forwarding your application to a lender you choose to contact).

6. Legal basis for processing

Depending on context, we rely on one or more of the following:

• Consent — obtained before collection and sale; you may withdraw consent, though some features may become unavailable
• Contractual necessity — to provide matching and lead-delivery services you request
• Legal obligation — KYC/AML, recordkeeping, and regulatory compliance
• Legitimate business interests — fraud prevention, security, analytics, and service improvement, balanced against your rights

7. Data retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required by law. Example retention periods include:

Data category	Typical retention period
Full applicant profile (name, SSN, address, bank info, income)	Duration of the business relationship plus 5 to 7 years after last activity, or longer if required by law or legal hold. Example: last App use in January 2025 → retained until at least January 2030–2032.
Lead and sale records (buyer identity, date, compensation)	5 to 7 years for FTC recordkeeping and dispute resolution
Marketing and communication records (consent logs, campaigns)	2 to 3 years after last interaction, or opt-out plus 90 days
Device and usage logs (IP, session, clickstream)	12 to 24 months
Opt-out of sale records	Minimum 5 years to demonstrate compliance. Example: opt-out received March 2025 → logged until at least March 2030.
Support communications	3 years after ticket resolution

Actual retention may vary by data type, litigation, audits, or regulatory guidance. Where law mandates a longer period, the legal minimum controls.

8. Data security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption in transit using TLS 1.2 or higher; encryption at rest using AES-256 where applicable
• Role-based access controls and least-privilege access for personnel
• Monitoring, logging, and periodic review of systems
• Contractual security and confidentiality obligations for vendors and lead buyers

You are responsible for safeguarding your device and account credentials. Notify us immediately at support@alamedahomeloans.com if you suspect unauthorized access.

No security program is perfect. If we experience a data breach affecting sensitive personal information, we will notify affected individuals and regulators as required by applicable law.

9. Your privacy rights

Depending on your state of residence, you may have the right to:

• Know / Access — learn what personal information we collect, how we use it, and categories of third parties to whom we have sold or disclosed it
• Delete — request deletion of personal information we maintain, subject to legal and contractual exceptions; data already sold to buyers cannot be “undeleted” from their systems
• Correct inaccurate personal information
• Portability — receive a copy in a structured, machine-readable format where applicable
• Opt out of sale — see Section 5.3
• Non-discrimination — we will not deny services solely because you exercised privacy rights, though some features require data processing or sale to function

Submit requests to legal@alamedahomeloans.com with subject line “Privacy Request.” We will verify your identity before fulfilling a request. Authorized agents may submit requests where permitted by law with proof of authority. We generally respond within 45 days for California residents and 30 days for other applicable states, with extensions where permitted.

10. Marketing opt-outs

Marketing preferences are separate from “Do Not Sell” requests under Section 5.3.

• Email — use the unsubscribe link in each marketing email; we process opt-outs within 10 business days (CAN-SPAM). Transactional messages (account alerts, security notices) may continue.
• SMS — reply STOP to opt out; reply HELP for help (TCPA). One-time passwords and transactional texts are not affected.
• Push notifications — adjust in your device operating system settings.
• Phone marketing — email support@alamedahomeloans.com to opt out of promotional calls. Autodialed marketing calls require prior express written consent under TCPA.

Opting out of marketing does not stop the sale of your personal information unless you also submit a separate Do Not Sell request.

11. California residents (CCPA / CPRA)

If you are a California resident, the following additional rights apply under the CCPA as amended by the CPRA.

Right to Know. You may request the categories and specific pieces of personal information we collect; categories of sources; business purposes; and categories of third parties to whom we sell or disclose information—including the fact that we sell data and the categories of buyers.

Right to Delete. Subject to CCPA exceptions (legal compliance, security, completing transactions you request, and similar grounds).

Right to Correct. Inaccurate personal information may be corrected upon verified request.

Right to Opt-Out of Sale/Sharing. We sell personal information under California’s broad definition. Opt out via legal@alamedahomeloans.com or the in-app Do Not Sell link. We process requests within 15 business days.

Right to Limit Use of Sensitive Personal Information. SSN, driver’s license, and full bank account numbers are “sensitive” under CPRA. You may request that we limit use beyond purposes permitted by CPRA.

Right to Non-Discrimination. We will not unlawfully discriminate against you for exercising CPRA rights.

Contact legal@alamedahomeloans.com with subject “California Privacy Request.” We respond within 45 days. You are entitled to two free access requests per 12-month period. GLBA and FCRA may limit certain rights for financial information covered by those statutes.

12. Other state privacy rights

Residents of Colorado (CPA), Virginia (VCDPA), Connecticut (CTDPA), Texas (TDPSA), and other states with comprehensive privacy laws may have rights similar to those in Section 9, including access, deletion, correction, opt-out of targeted advertising or sale, and appeal of denied requests. Submit inquiries to legal@alamedahomeloans.com.

13. Do Not Track and Global Privacy Control

There is no uniform standard for “Do Not Track” (DNT) browser signals. We do not currently respond to DNT signals.

Where required by law, we honor Global Privacy Control (GPC) signals as a request to opt out of “sharing” for cross-context behavioral advertising under CCPA/CPRA for California users.

14. GLBA and FCRA notices

GLBA. SSN, bank account number, routing number, income, and employment data are nonpublic personal financial information under GLBA. We may provide a separate GLBA Initial Privacy Notice that governs certain financial information.

FCRA. If we or a partner obtains a “consumer report” or shares information with consumer reporting agencies, FCRA rights (including dispute rights and adverse action notices) may apply. A hard credit inquiry occurs only with your express prior authorization to the relevant lender.

GLBA and FCRA may limit or preempt certain state privacy rights, including some CCPA rights, with respect to covered financial information.

15. Cookies and tracking technologies

We use cookies, mobile SDKs, pixels, and similar tools for authentication, fraud detection, analytics, advertising attribution, and session management. You can limit cookies through browser settings (web) or device settings (mobile). Disabling certain technologies may impair functionality or prevent access to the Services.

16. Children’s privacy

The App is intended for adults 18 and older and is not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe we have collected information from a minor, contact support@alamedahomeloans.com and we will take steps to delete it.

17. International users

The Services are directed to users in the United States. If you access the App from outside the U.S., you understand that your information will be processed in the United States, which may have different data protection rules than your country. Using the App constitutes consent to U.S. processing.

18. Policy updates

We may revise this Policy from time to time. When we do, we will update the “Last updated” date above and, for material changes, provide notice through the App, by email, or by other legally permitted means. Continued use after the effective date constitutes acceptance of the revised Policy.

19. Contact us

ALAMEDA HOME LOANS LLC
3033 Oro Blanco Dr
Colorado Springs, CO 80917-3733
United States
Website: alamedahomeloans.com
General support: support@alamedahomeloans.com
Privacy requests: legal@alamedahomeloans.com