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 or 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:
Information We Collect
We collect information about you in a variety of ways depending on how you interact with us and our websites, mobile application, products, and services, including:
- Directly from you when you provide it to us, such as when you check your loan options or apply for a loan, sign up to receive communications from us, or contact us by phone, email, or otherwise.
- Automatically through the use of cookies, server logs, and other similar technologies when you interact with our websites, mobile application, advertisements, and emails.
- From other sources, including, for example, our affiliates, business partners, and service providers; financial institutions; online social media networks; other third parties; or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
- From outside companies or organizations that provide data to support activities such as fraud prevention, underwriting, and marketing, including internet service providers, operating systems and platforms, data brokers, advertising networks, and data analytics providers.
- From outside companies or organizations to support human resource and workforce management activities.
The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.
| 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 use this information to contact 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 Number, military status, 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 for your consent to receive communications about our products and services. 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. These first-party cookies may tell us from which websites you have navigated to our website and/or to which websites you navigate after visiting our site. | We use cookies to ensure that our websites operate efficiently, to provide you with more customized offers and information, to customize our websites to match your personal preferences, to improve our services and products offered, and to prevent fraud. |
| Cookies and Third-Party Tracking | We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to 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 report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites. | We collect this information to analyze how our websites are being accessed and used, to improve user experience and the overall quality of our websites, and to customize advertising and content. Please see the Your Choices section below for information on how to disable targeted advertising. |
| Demographic Information | We collect personal information, such as your age or gender. | We use this information to understand our users and providing tailored services. |
| Location Information | When you use one of our mobile applications, we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device. | We use this information to understand our users and providing personalized location-based services. In some contexts, we also ask your consent to provide us with geolocation information. |
| Email Interconnectivity | If you receive email 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 check your credit options through avant.com. | We use this information to understand 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 our obligations in anticipation of a contract of employment, with you. In some contexts, we are also required by law to collect information about employees or applicants. We also use this information to maintain 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 use this information to receive and act upon your feedback or issues. |
| Mailing List | We collect your email address and/or postal address when you request information about loan options. | We use this information to share information about products or services. |
| Mobile Devices | We collect information from your mobile device, such as unique identifying information broadcast from your device when visiting our website or when using our mobile application. | We use this information to determine unique visitors, develop the mobile version of our websites, and understand how users interact with us on their mobile devices. We also use this information to detect and prevent 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 it with the third party upon your consent. |
| Public Health and Safety | In certain situations where a serious public health threat has been identified, we may collect information from employees, guests, and other individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions. In some cases, we may also collect medical, health, and related information about an employee’s children, his or her family member, or other individuals under the employee’s care. | We use this information to protect the health and safety of our employees and guests. In some jurisdictions, we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety. |
| 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 also use this information to understand your opinions and to collect information relevant to our organization. |
| Sweepstakes or Contests | When you participate in a sweepstakes or contest, we collect information about you, which includes contact information to notify you if you are selected. | We use this information to conduct our sweepstakes and contests. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes. |
| Website Interactions | We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We use this information to understand 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 use this information to detect and prevent 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 your visit. | We use this information to monitor our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular and detect and prevent fraud. |
How We Use 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 process payments and transactions.
- To provide access to financing.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To maintain and service accounts.
- To facilitate event management and execution.
- To send marketing and promotional materials including information relating to products, services, or promotions.
- To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
- To debug, identify, and repair errors that impair existing intended functionality of our website and services.
- To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
- For internal administrative purposes, as well as to manage our relationships.
- For such other purposes as you may consent (from time to time).
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 maintaining your 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.
To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal 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, our business, or our assets, we will also share information with that company, including at the negotiation stage.
- 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 to, or the provision of services by, a third-party intermediary.
- Partner Promotion. We may offer contests, sweepstakes, or other promotions with third parties. If you decide to enter a contest, sweepstakes, or 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 to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
- Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.
Your Choices
Some jurisdictions give you a right to make the following choices regarding your personal information.
Please note that not all of the rights described below are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law:
- Access To Your Personal Information. You may request access to your personal information or confirmation that we have and/or process information about you.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. Our website and mobile application allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information be modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
- Opt-out of Targeted Advertising. Although we do not “sell” your personal information for money, we may use some of your personal information for advertising performance analysis, use your information for audience modeling for ongoing advertising, disclose your information to data brokers, and/or participate in data co-ops, which may constitute a “sale” under certain privacy laws. You may opt-out of online tracking-based targeted advertising (e.g., cookies) here:
- Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference. You may also opt out of other forms of targeted advertising by submitting a request via that link.
- Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Online Tracking. We do not currently recognize the “Do Not Track” signal.
- 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.
Submitting Requests
You may exercise the rights described above by contacting us as indicated in the Contact Information section below. To make a data request via email please email us at the email address below using the email address that you have used in connection with Avant in the past. If you submit a request via mail, please include in your correspondence the email address that you have used in connection with Avant in the past.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name and your relationship with Avant. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct, or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of signed permission indicating that you are able to act on another person’s behalf.
How We Protect and Retain 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.
We retain your personal information for only as long as necessary to fulfill the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information, and whether we can achieve those purposes through other means, as well as applicable legal requirements.
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. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible, we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction, you can contact us using the contact information below.
Third-Party Applications/Websites
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices, websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.
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, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. 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.
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
Email: [email protected]
Mail: Avant, LLC
Attn: Data Request
222 W. Merchandise Mart Plaza. Suite 900
Chicago, IL 60654
Phone: 1 (800) 712-5407
Additional Information For California Residents
California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.
- California Shine the Light. 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 using the information in the Contact Information section above.
- Notice of Collection. The table below describes the categories of personal information we collect, disclose for a business purpose, “sell,” and/or “share” (as those terms are defined by California law). Please note that in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. Additionally, this table does not include information that is exempt from the CCPA and governed by our Avant Privacy Notice. We do not knowingly sell the personal information of minors under 16 years of age. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising. For more information, please see the Information We Collect section of this Privacy Policy. For information regarding how long we retain personal information, please refer to the How We Protect and Retain Information section of the Privacy Policy.
| Category of Personal Information | Category of Recipients: Disclosures for a Business Purpose | Category of Recipients: Selling or Sharing for Cross-Context Behavioral Advertising |
|---|---|---|
| Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers. | Affiliates or subsidiaries, Business partners, Data analytics providers, Data brokers, Internet service providers, Joint marketing partners, Operating systems and platforms, Other service providers, Payment processors and financial institutions, Professional services organizations, which may include auditors and law firms, Social networks | Advertising networks |
| Government-issued identification – this may include Social Security Number, driver’s license number, state-issued identification number, or passport number. | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Payment processors and financial institutions, Professional services organizations, which may include auditors and law firms | |
| Financial information – this may include bank account number, credit card number, debit card number, and other financial information. | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Payment processors and financial institutions, Professional services organizations, which may include auditors and law firms | |
| Health-related information – this may include medical information, mental or physical condition or treatment, or health insurance information. | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc. | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Affiliates or subsidiaries, Data analytics providers, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Payment processors and financial institutions, Professional services organizations, this may include auditors and law firms | Advertising networks |
| Biometric information – this may include imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns, or rhythms, and sleep, health, or exercise data that contain identifying information. | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. | Affiliates or subsidiaries, Data analytics providers, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Geolocation data | Affiliates or subsidiaries, Data analytics providers, Other service providers | |
| Audio, electronic, visual, thermal, olfactory, or similar information | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Professional or employment-related information | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Non-public education information (as defined in the Family Educational Rights and Privacy Act) | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Inferences drawn from any of the information listed above | Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Professional services organizations, which may include auditors and law firms | |
| Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number. | Affiliates or subsidiaries, Government entities, as may be needed to comply with law or prevent illegal activity, Other service providers, Payment processors and financial institutions, Professional services organizations, which may include auditors and law firms |
- California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): account log-in; financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, information concerning health; and information concerning sex life or sexual orientation.This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121.
Effective Date: December 29, 2020
Last Update: July 7, 2023
