Debt Borrow To Invest, LLC (“DBTI,” “we,” “us”) is an Illinois limited liability company that originates personal consumer loans to qualified individuals. Because we are engaged in financial activities, we operate as a “financial institution” under the Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq., and as a “business” under the California Consumer Privacy Act of 2018, as later amended by the California Privacy Rights Act. This notice tells you, in fourteen plain sections, what data we collect, what we do with it, who else gets to see it, and what you can do about all of that.
Information We Collect
Three streams of information land with us. The first is what you hand us directly during an application: your full legal name, residential address, telephone number, email, date of birth, Social Security number, government-issued identifier numbers, employment status, sources and amount of income, bank-account routing and account numbers, and authentication credentials you create for your account. Anything you write into a chat, email, or phone call with our team is also kept.
The second is information we observe automatically as you use our website or mobile application. That includes your IP address, approximate location derived from that address, device and browser fingerprints, operating-system version, time-zone setting, the pages you visit, the order you visit them in, time on page, referring URL, and cookies and similar technologies that we set for session management, fraud prevention, attribution, and analytics.
The third is information we receive from third parties: consumer reporting agencies (Experian, Equifax, TransUnion, and certain specialty bureaus); identity-verification and fraud-prevention vendors; bank-account verification services that you authorize; and public-record databases used for compliance screening, including OFAC sanctions lists.
How We Use Your Information
We use your information for the purposes that are necessary to provide you with the loan product you have asked for and to operate a regulated lending business. Specifically: (i) to evaluate your application, including underwriting, pricing, identity verification, and fraud screening; (ii) to originate and service any loan that we offer to you; (iii) to comply with our obligations under the Truth in Lending Act, the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Bank Secrecy Act, and applicable state lending statutes; (iv) to detect and prevent fraud, identity theft, and money laundering; (v) to operate, secure, and improve our website, mobile app, and back-end systems; (vi) to communicate with you about your account, complaints, and inquiries; (vii) to send you transactional and (where permitted) marketing communications; and (viii) to conduct internal research that helps us underwrite better and serve customers better.
We do not sell your personal information for monetary consideration to third-party data brokers, and we do not engage in cross-context behavioral advertising that targets you based on activity across unaffiliated websites.
Information Sharing and Disclosure
We disclose your information to a limited set of recipients, only for purposes consistent with what you have authorized or with what applicable law allows. Those recipients fall into the following categories: affiliates under common ownership or control with DBTI; service providers and processors (cloud-hosting vendors, payment processors, identity-verification services, customer-support platforms, mailing houses, analytics providers), each bound by written agreements that limit their use of your information to providing the contracted service; consumer reporting agencies, both to obtain reports about you and to furnish information about your account, including payment history; governmental authorities in response to lawful requests, subpoenas, or as required by law; successors in interest in the event of a merger, acquisition, asset sale, reorganization, or similar transaction; and professional advisors retained by us, subject to confidentiality.
Nonpublic Personal Information (GLBA)
The Gramm-Leach-Bliley Act and Regulation P (12 C.F.R. Part 1016) require us to give you a privacy notice describing our practices for collecting and disclosing nonpublic personal information (“NPI”) about consumers and customers. NPI is any information about you that is not publicly available, that you provide to us in connection with obtaining a financial product or service, that we obtain about you in connection with providing the product or service, or that arises out of a transaction with us.
We may share NPI with affiliates and with nonaffiliated third parties as permitted by GLBA and Regulation P, including for the everyday business purposes of processing transactions, maintaining your account, responding to court orders or legal investigations, reporting to credit bureaus, and protecting against fraud.
Your right to opt out. You may direct us not to share NPI with nonaffiliated third parties for purposes other than those permitted by law. To exercise this right, write to us at ceo@debt-borrow-to-invest.com or by U.S. mail to the address in Section 14, including your full legal name, residential address, the last four digits of your Social Security number, and a clear statement of your election. Your election will remain in effect until you revoke it. An opt-out cannot prevent sharing for everyday business purposes.
Credit Reporting and FCRA Disclosures
To evaluate your application and to service your loan we obtain consumer reports about you from one or more consumer reporting agencies. By submitting an application you authorize us to obtain those reports for any “permissible purpose” under the Fair Credit Reporting Act, 15 U.S.C. § 1681b, including in connection with a credit transaction initiated by you and for the review or collection of an account.
If we take adverse action against you in whole or in part on the basis of information contained in a consumer report, we will provide the notice required by 15 U.S.C. § 1681m, which will identify the reporting agency that furnished the report, state that the agency did not make the adverse decision, and inform you of your right to obtain a free copy of the report from that agency within sixty days and to dispute the accuracy or completeness of any item in it.
We may furnish information about your account, including payment history and any default, to consumer reporting agencies. Late or missed payments may be reflected in your credit report and may negatively affect your credit score.
Your Privacy Choices and Opt-Out Rights
You may exercise any of the choices below at any time, free of charge and without affecting your access to our products or services.
- Marketing communications: opt out by following the unsubscribe link in any marketing email, or by writing to us. Transactional and servicing communications, which we are required to send, will continue until your account is closed.
- Cookies and similar technologies: disable non-essential cookies through your browser settings. Strictly necessary cookies cannot be disabled because they are required for fraud prevention, account security, and basic site operation.
- GLBA opt-out: see Section 4.
- FCRA affiliate-marketing opt-out: where the FCRA gives you the right to limit the use of certain information shared among our affiliates for marketing purposes, we will provide a separate notice and opportunity to exercise it. You may also exercise it at any time by contacting us.
California Privacy Rights (CCPA / CPRA)
If you reside in California, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 grants you the following rights with respect to personal information we have collected about you in the preceding twelve months. You have the right to know the categories and specific pieces of personal information we have collected, the categories of sources, the business or commercial purposes for collecting or sharing that information, and the categories of third parties with whom we have shared it. You have the right to delete personal information we collected from you, subject to legal exceptions including information we are required to retain to provide a product you requested or to comply with law. You have the right to correct inaccurate personal information we maintain about you. You have the right to opt out of sale or sharing of personal information; although we do not sell or share for cross-context behavioral advertising, we honor opt-out signals and provide a "Do Not Sell or Share My Personal Information" mechanism on this site out of an abundance of caution. You have the right to limit the use of sensitive personal information to that necessary to perform the services you requested. You have the right of non-discrimination: we will not deny you services, charge you a different price, or provide a different level or quality of services because you exercised your privacy rights.
You may exercise these rights by writing to us at ceo@debt-borrow-to-invest.com. We will respond within forty-five days as required by statute, after verifying your identity using information already on file. An authorized agent may submit a request on your behalf with proof of authorization.
Personal information we collect or process in connection with originating, servicing, or collecting on a consumer loan is also subject to a separate, federally-required privacy notice under the Gramm-Leach-Bliley Act (see Section 4) and is, to that extent, exempt from certain CCPA requirements; however, we honor the rights described above wherever applicable law allows.
Children’s Privacy (COPPA)
Our services are intended only for adults aged eighteen (18) or older. We do not knowingly collect personal information from children under the age of thirteen, and we do not direct any of our services or marketing to children. If you believe a child under thirteen has provided personal information to us, please contact us at the address in Section 14 and we will promptly delete it.
Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards include encryption of personal information in transit and at rest using industry-standard protocols, role-based access controls, multi-factor authentication for employees with access to sensitive systems, network segmentation, intrusion-detection systems, written information-security policies, employee training, and periodic risk assessments. No system is absolutely secure, and we will notify you of a security incident affecting your personal information in the manner and within the timeframes required by applicable state and federal law.
Data Retention
We retain personal information for as long as it is needed for the purposes described in this notice and as required by applicable law and our internal records-retention policies. Loan-application and servicing records are kept for the longer of the period required by federal and state lending law (typically twenty-five months from the date of action under Regulation B, but longer for certain records) and the period reasonably necessary to defend against potential legal claims. Information used solely for marketing is retained only until you opt out or your account is closed, whichever is shorter. When personal information is no longer needed, we securely delete or anonymize it.
Third-Party Services
Our website and mobile application may contain links to or embed services operated by third parties, such as bank-verification widgets, identity-verification flows, payment processors, and customer-support tools. Those services are governed by the third party’s own privacy policy, which we encourage you to read. We are not responsible for the privacy practices of services we do not control.
International Users
We operate exclusively within the United States. We do not direct our services to individuals outside the United States, and our services are not intended for individuals located outside the United States. If you access our website or services from outside the United States, you do so at your own initiative, and the information we collect about you will be transferred to and processed in the United States, where data-protection laws may differ from the laws of your jurisdiction.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, in technology, in legal requirements, or for other operational reasons. The "In effect" date at the top of this page indicates when the current version took effect. If we make material changes, we will provide notice by posting the updated policy on our website and, where appropriate, by sending you an email or other notice consistent with applicable law before the changes take effect.
How to Contact Us
If you have questions about this Privacy Policy, wish to exercise any of the rights described above, or wish to make a complaint:
Debt Borrow To Invest, LLC
Attn: Privacy Officer
5060 N Marine Dr
Chicago, IL 60640-3273
USA
Email: ceo@debt-borrow-to-invest.com
Telephone: +1 (646) 907-9518