Privacy Policy

Union Perks Loans LLC (“Union Perks Loans,” “we,” “us,” or “our”), a Colorado limited liability company with its principal office at 1957 Galena St, Aurora, CO 80010-2224, operates the Perks Loans mobile application (the “App”) and the website at unionperksloans.com (together, the “Services”). The App is a loan-matching and lead-generation platform. It helps U.S. consumers explore financing options by collecting information you provide and connecting you—or selling your information—to third-party lenders, financial institutions, and marketing partners.

We are not a lender. We do not extend credit, set interest rates or fees, underwrite loans, or make approval decisions. Any loan you may obtain is offered solely by an independent third party on that party’s terms.

This Privacy Policy describes the categories of personal information we collect, how we use them, how we sell and share them (including for monetary or other valuable consideration), the rights available to you, and the choices you can make. Because our business model includes the sale of consumer data to buyers in our partner network, we describe those practices clearly in Section 5.

By downloading, accessing, or using the App, or by submitting information through the Services, you agree to this Policy. If you do not agree, do not use the Services. The App is intended only for individuals who are at least 18 years old and legal residents of the United States.

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

• Gramm-Leach-Bliley Act (GLBA). Information such as your Social Security number, bank account and routing numbers, income, and employment details may qualify as nonpublic personal information under GLBA when collected in connection with financial products or services.
• California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). The CCPA/CPRA define “sale” and “sharing” broadly. Selling or sharing personal information for cross-context behavioral advertising may trigger opt-out rights.
• Fair Credit Reporting Act (FCRA). If we obtain or furnish consumer report information, FCRA notice and authorization requirements may apply.
• Federal Trade Commission (FTC) rules and guidance on lead generation, data brokers, and truthful advertising.
• CAN-SPAM Act (commercial email) and the Telephone Consumer Protection Act (TCPA) (calls and texts), where applicable.

GLBA and FCRA may impose separate notice obligations and may limit or preempt certain state privacy rights with respect to specific categories of financial information. Where those laws apply, we will comply with their requirements in addition to this Policy.

3a. Information you provide directly

When you create an account, complete an application, or request a match, you may provide:

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 imposed on our lender partners, and help prevent fraud. SSN is transmitted using encryption in transit. We collect your driver’s license number and state of issuance for identity verification, to confirm you meet state eligibility requirements, and for KYC.

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 full bank account and routing numbers so lender partners can verify account ownership, evaluate eligibility, and—if you proceed with an offer—potentially set up ACH disbursement or repayment. Employer name and employer phone number help lenders verify income and employment as part of underwriting.

3b. Information collected automatically

When you use the App or our website, we and our service providers may automatically collect:

• Device identifiers, operating system, device model, and App version
• IP address and general network information
• Usage patterns, session duration, pages or screens viewed, and clickstream data
• Approximate location derived 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
• Consumer reporting agencies and alternative data providers (in circumstances governed by the FCRA)
• Marketing or referral partners that direct you to the App

We may combine information from these sources with information you provide to create a lead profile for matching and sale.

We use personal information for purposes that include:

• Creating and managing your account and user profile
• Verifying your identity (KYC), detecting fraud, and assessing basic eligibility for matching
• Packaging your information into a lead and matching you with lender and financial partners
• Selling your information to third-party lenders, financial institutions, and marketing partners, as described in Section 5
• Processing referrals, transmitting your application to partners you choose to engage, and facilitating communications between you and buyers
• Sending transactional messages (such as application status) and, where you have consented, marketing communications by email, SMS, or push notification
• Improving App performance, conducting analytics, and measuring marketing effectiveness
• Complying with legal obligations, responding to lawful requests, and enforcing our Terms of Use and other agreements

Depending on context and applicable law, we rely on:

• Consent — including consent provided when you submit an application and acknowledge this Policy. You may withdraw consent, but doing so may prevent us from providing matching services.
• Contractual necessity — to perform the matching and lead-delivery services you request.
• Legal obligation — including KYC/AML, recordkeeping, and responses to lawful process.
• Legitimate business interests — such as fraud prevention, network security, and improving the Services, where not overridden by your rights.

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

Data category	Typical retention period
Full applicant profile (name, SSN, address, bank and income details)	Duration of our relationship with you, plus 5 to 7 years after your last activity, or longer if required by law or an active legal hold. Example: last App use in January 2025 → profile 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, email/SMS campaigns)	2 to 3 years after last interaction, or until opt-out plus 90 days.
Device and usage logs (IP, session, clickstream)	12 to 24 months.
Opt-out of sale records (“Do Not Sell” requests)	Minimum 5 years to demonstrate compliance. Example: request received March 2025 → logged until at least March 2030.
Support communications	3 years after ticket resolution.

Actual retention may vary by data type, jurisdiction, litigation, or regulatory guidance. Where law mandates a longer period, we retain data for the legally required minimum.

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

• Encryption in transit (TLS 1.2 or higher) and encryption at rest (AES-256 or equivalent) where applicable
• Role-based access controls and least-privilege access for personnel
• Monitoring, logging, and periodic review of systems and vendors
• Contractual security and confidentiality obligations for service providers and data buyers where feasible

You are responsible for safeguarding your account credentials. Notify us immediately at [email protected] if you believe your account has been compromised.

No method of transmission or storage is completely secure. If we experience a data breach affecting sensitive personal information, we will notify affected individuals and regulators as required by applicable law.

Depending on where you live, you may have the right to:

• Know / access — request the categories and specific pieces of personal information we hold, and information about sales, including buyers where technically feasible
• Delete — request deletion of personal information we maintain, subject to legal and contractual exceptions; data already sold to third parties cannot be deleted from their systems by us
• Correct — request correction of inaccurate personal information
• Portability — receive a copy of certain information in a structured, commonly used, machine-readable format
• Opt out of sale — as described in Section 5.3
• Non-discrimination — we will not deny goods or services, charge different prices, or provide a different level of service solely because you exercised a privacy right; some features require data processing and may be unavailable if you opt out of necessary processing

Submit requests to [email protected] with the subject line “Privacy Request.” We will verify your identity before responding. Authorized agents may submit requests on your behalf where state law permits. We aim to respond within 45 days for California residents and within 30 days for residents of other states with applicable laws, subject to permitted extensions.

• Email. Use the unsubscribe link in any marketing email. We will honor opt-outs within 10 business days as required by CAN-SPAM. Transactional and service-related emails may continue.
• SMS. Reply STOP to opt out of marketing texts; reply HELP for assistance. TCPA rules apply. One-time passwords and transactional texts are not affected by a marketing STOP.
• Push notifications. Manage through your device operating system settings.
• Telemarketing calls. Email [email protected] to opt out of promotional calls. We obtain prior express written consent before auto-dialed marketing calls where required by the TCPA.

Opting out of marketing does not stop the sale of your personal information unless you also submit a separate “Do Not Sell” request under Section 5.3.

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 collected; categories of sources; business or commercial purposes; and categories of third parties to whom we disclosed, sold, or shared personal information—including the fact that we sell data and the categories of buyers.

Right to delete. You may request deletion of personal information we collected from you, subject to exceptions permitted by the CCPA (such as completing a transaction, security, compliance, or internal uses reasonably aligned with your expectations).

Right to correct. You may request correction of inaccurate personal information we maintain.

Right to opt out of sale/sharing. We sell personal information under the CCPA’s definition. Opt out via [email protected] or the in-app “Do Not Sell” link. We will process opt-outs within 15 business days.

Right to limit use of sensitive personal information. SSN, driver’s license number, and full bank account number are “sensitive personal information” under the CPRA. You may request that we limit use to purposes permitted by the CPRA. We may decline requests that are not permitted by law or that prevent us from providing services you request.

Right to non-discrimination. We will not discriminate against you for exercising CCPA rights.

Contact [email protected] with the subject “California Privacy Request.” We will respond within 45 days. You are entitled to two free access requests in a 12-month period. GLBA and FCRA may limit certain rights with respect to financial information covered by those statutes.

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), and other states with comprehensive privacy laws may have rights similar to those in Sections 9 and 11, including access, deletion, correction, opt-out of targeted advertising or sale, and appeal of denied requests.

Submit requests to [email protected]. We will respond in accordance with applicable state law.

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

Where required, we honor Global Privacy Control (GPC) signals from California residents as a request to opt out of sharing personal information for cross-context behavioral advertising under the CCPA/CPRA.

GLBA. Your SSN, bank account number, routing number, income, and employment information may be nonpublic personal information under GLBA. We may provide a separate GLBA Initial Privacy Notice that governs certain financial information. Where GLBA applies, it may limit some state privacy rights for that information.

FCRA. If we obtain consumer reports from consumer reporting agencies, or if information we share is used as a consumer report, your rights under the FCRA (including dispute rights with the reporting agency) may apply. Hard credit inquiries are performed only with your express prior authorization.

We use cookies, mobile SDKs, pixels, and similar technologies on our website and in the App for authentication, fraud prevention, analytics, advertising attribution, and session management. Device fingerprinting may be used by us or partners for fraud and analytics.

You can limit cookies through browser settings and limit mobile tracking through your device OS settings. Disabling certain technologies may impair functionality or prevent access to parts of the Services.

The Services are not directed to anyone under 18. We do not knowingly collect personal information from minors. If we learn that we have collected information from a person under 18, we will delete it promptly. Parents or guardians who believe a minor has provided information should contact [email protected].

The Services are directed to users in the United States. If you access the Services from outside the U.S., you understand that your information will be transferred to, stored in, and processed in the United States, where laws may differ from those in your country. By using the Services, you consent to that transfer and processing.

We may revise this Policy from time to time. The “Effective date” below indicates when the current version took effect. Material changes will be communicated through an in-app notice, email, or a prominent posting on our website. Continued use of the Services after the effective date of an updated Policy constitutes acceptance of the changes.

Union Perks Loans LLC
1957 Galena St
Aurora, CO 80010-2224
Email (general support): [email protected]
Email (privacy requests): [email protected]
Website: unionperksloans.com