Privacy Policy

Last updated: October 28, 2021

Loanelo (“us”, “we”, or “our”) operates the www.loanelo.com website (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at www.Loanelo.com

Information Collection And Use

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information”) may include, but is not limited to:

• Name
• Telephone number
• Email Address
• We use third third-party vendors, identified below, to help with delivery of the Content and processing of your payment. We never see your full credit card number, which is handled through Stripe;
• If you participate in the Forum, you will create additional user-generated content, which is used for the Forum only.

Legal Basis for Collection of Information

Loanelo asserts the following legal grounds for the collection of data:

Explicit Consent

When you sign up for any Content (either free or paid) or any other account at loanelo.com, you provide explicit consent for Loanelo to collect the above listed personal information.

Contract

If you enter an agreement with Loenelo for the provision of services in exchange for payment, Loanelo will be required to collect the above listed personal information.

Legitimate Interests

Finally, Loanelo may have additional legitimate interests, including account maintenance and administrative purposes, for the collection of the above listed personal information.

Using Personal Information

Loanelo may use your personal information to:

• fulfill or meet the reason you provided the information. Specifically, access to the Content. If you provide your personal information to purchase Content, a product, or service, we will use that information to process your payment and facilitate delivery.
• create, maintain, customize, and secure your account with Loanelo.
• provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• administer Loanelo and the Content;
• personalize the website for you by displaying your name or changing the appearance of the website according to your settings if you log in;
• enable your access to and use of the Content and the website services;
• deliver podcasts to subscribers;
• send to you the newsletter and account-related email;
• send to you statements and invoices;
• collect payments from you;
• collect your personal information or as otherwise set forth in the GDPR, CCPA, or the applicable laws.
• prevent transaction fraud;
• respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
• send you marketing communications.

Where Loanelo discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement. Except for the third-party vendors that collect your data separately when you sign up and pay, Loanelo does not share any of its user data with any third parties.

In addition to the disclosures reasonably necessary for the purposes identified in this privacy policy, Loanelo may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.

Data Processors

Loanelo uses the following data processors with respect to the personal information collected:

• Discourse: Discourse manages the Forum and all related data, including user-created content. Discourse Privacy Policy.
• Stripe: Stripe manages all payment processing and subscription management. Your credit card payment details are managed by Stripe and not released to Loanelo except the date and amount of each payment, the last four digits of your credit card, expiration date, and zip code. Stripe Privacy Policy.

3rd-party Service Providers

In addition, Loanelo uses the following 3rd-party service providers for certain content served on Loanelo.com. By using Loanelo you are accessing these services. Loanelo does not provide or receive any personal information to or from these services.

• AWS: The content delivery service runs on AWS. AWS Privacy Policy.
• Cloudflare: The content and other related site performance and protection services. Cloudflare Privacy Policy.
• Google Analytics: Google Analytics provides data concerning site visitors and activity at the website. Google Analytics Privacy Policy.
• Jetpack: Jetpack provides security and backup services for Loanelo.com, and recommends additional articles to read. Jetpack Privacy Policy.
• InMotion Hosting: InMotion Hosting manages the hosting of Stratechery.com. InMotion Hosting Privacy Policy.
• Mailchimp: If you enter your mobile phone number in order to receive SMS updates, you are using a service provided by MailChimp. Loanelo does not retain your phone number. MailChimp privacy policy.
• Typekit: Typekit, which is owned by Adobe, provides Loanelo.com fonts. Adobe Fonts Privacy Policy.

In addition, by using Loanelo.com you are accessing Stripe, but Loanelo does not provide or receive any personal information to or from these services unless you are a subscriber.

Sales of Personal Information

Loanelo has never sold personal information. In addition, Loanelo has no intention of ever selling personal information.

Data Retention Policy

Data will only be retained until you request us to delete it pursuant to this privacy policy.

Securing Your Data

Loanelo will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. If Loanelo stores any of your data, it will do so on secure servers.

Forum Posts

Be advised that Loanelo does not monitor Forum posts for disclosure of any personal information you may post in any user-generated content. The forum software (Discourse) includes tools allowing you to edit or delete your posts. If you need assistance, you may contact Loanelo with the contact information below.

Cross-border Data Transfers

Information that Loanelo collects may be stored and processed in and transferred between any of the countries in which Loanelo operates to enable the use of the information in accordance with this privacy policy. You agree to such cross-border transfers of personal information.

In addition, personal information that you post to the Forum will be published on the internet and may be available around the world.

Log Data

We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

Google AdSense, DoubleClick, Facebook, Pinterest, Twitter Cookie

Google, Facebook, Pinterest & Twitter, as  third party vendors, uses cookies to serve ads or track performance of results on our Service.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Behavioral Remarketing

Loanelo uses remarketing services to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.  These include Google, Facebook, Pinterest & Twitter.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 13 (“Children”).

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register with the Website or Newsletter. If you are under 18, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 is allowed to provide any personal information to or on Loanelo. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we discover that a Children under 13 has provided us with Personal Information, we will delete such information from our servers immediately.

Compliance With Laws

We will disclose your Personal Information where required to do so by law or subpoena.

California Online Privacy Protection Act Notice

(1) Loanelo does track users, who interact with its website across the web, and therefore does use “do not track” signals.

(2) Loanelo does not authorize the collection of personally identifiable information from users on any Loanelo website for third party use through advertising technologies.

GDPR and CCPA Compliance

Loanelo seeks to fully comply with the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other laws and regulations protecting consumer privacy. As such, you have the following rights on this website:

1. Right to be forgotten: You may cancel your account at any time. If you wish your data to be permanently deleted, you may contact us at [email protected] and it will be deleted within 72 hours.
2. Right to object: We have never performed any data science projects on user data and do not anticipate doing so in the future. If, at some point in the future we determine a use for any sort of data science project on our user data, we will notify you in writing before doing so. In that event you may remove your contact data from any such project by emailing us at [email protected] with the subject line “Opt Out of Data Science”.
3. Right to access and rectification: You can contact us at [email protected] at any time to access copies of all user data we retain for you. We will remove, update, or change any personal information about you from our servers immediately upon your request.
4. Right of portability: We only retain your name and email address. Nevertheless, we will provide that information to you upon your request.
5. Right of restriction: You can make a request for restriction or suppression of your personal data through the contact information at the end of this privacy policy.

Without prejudice to any other administrative or judicial remedy, if located in the European Union, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

In addition to the above, an “unsubscribe” option is automatically included in the footer of every newsletter sent from the Loanelo. This allows you to easily unsubscribe from the newsletter. In the event you unsubscribe, we will immediately stop sending you the newsletter. Please note that unsubscribing from the newsletter with the newsletter’s “unsubscribe” button does not cancel your account with Loanelo. In order to do so, please log in at Loanelo.com and cancel your account.

Non-Discrimination

Loanelo will not discriminate against you for exercising any of your GDPR, CCPA, or other consumer privacy rights. Unless permitted by law, Loanelo will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, the nature of the services provided by Loanelo, a membership website, newsletter, and podcast feed, will require basic information including an active account and your email address in order for Loanelo to provide its services. Should you opt out entirely, Loanelo will be unable to provide you any of its services.

Statement of Rights and Choices with the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Below is a summary of information collected by category.

Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, Loanelo has disclosed the following categories of personal information for a business purpose to the service providers described earlier in this Privacy Policy:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category K: Inferences drawn from other personal information.

Access to Specific Information and Data Portability Rights

You have the right to request that Loanelo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information Loanelo collected about you.
• The categories of sources for the personal information Loanelo collected about you.
• Loanelo business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom Loanelo shares that personal information.
• The specific pieces of personal information Loanelo collected about you (also called a data portability request).
• If Loanelo sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Loanelo delete any of your personal information that Loanelo collected from you and retained, subject to certain exceptions. Once Loanelo receives and confirms your verifiable consumer request, Loanelo will delete (and direct our service providers to delete) your personal information, unless an exception applies.

Loanelo may deny your deletion request if retaining the information is necessary for Loanelo or its service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
5. Comply with a legal obligation.
6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Sending a email to us at [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows Loanelo to reasonably verify you are the person about whom Loanelo collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows Loanelo to properly understand, evaluate, and respond to it.

Loanelo cannot respond to your request or provide you with personal information if Loanelo cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with Loanelo. Loanelo will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Loanelo endeavors to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), Loanelo will inform you of the reason and extension period in writing.

If you have an account with Loanelo, Loanelo will deliver its written response to that account. If you do not have an account with Loanelo, Loanelo will deliver its written response by mail or electronically, at your option.

Any disclosures Loanelo provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Loanelo provides will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, Loanelo will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Loanelo does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Loanelo determine that the request warrants a fee, Loanelo will tell you why it made that decision and provide you with a cost estimate before completing your request.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of Loanelo’s website that are California residents to request certain information regarding Loanelo’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Other Websites

Loanelo.com, the Newsletter, Podcast, and website contain links to other websites and embedded links to other content on the Internet, such as tweets and YouTube videos. Loanelo is not responsible for the contents of those third-party websites or responsible for the privacy policies or practices of any third party.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected].