Weemba

Our Commitment to Privacy
Weemba respects your privacy and is committed to protecting your Personal Information. Weemba is an online financial community that revolutionizes the way Borrowers and Lenders find each other and interact with one another. Weemba connects individual and commercial Borrowers with professional Lenders in a non-traditional format without regard to conventional limitations of time and geography. Using unique proprietary methods and state-of-the-art safeguards, Weemba may exponentially increase the likelihood of successful financial outcomes for both Borrowers and Lenders.

In this Privacy Policy (“Policy”), we describe the information that we collect from any visitor to our Website, such as registered visitors—which include persons registered as Community Members, Borrowers, Lenders—and other people simply visiting our Website. Unless we distinguish otherwise, references to “you” include Community Members, Borrowers, Lenders, and all other visitors to our Website. This Policy governs the use of our Website http://www.weemba.com and of our blog, blog.weemba.com (collectively, “Website”), as well as our online products, services and features of the Website that we may make available from time to time (collectively, “Services”). This Policy is incorporated by reference to the Terms of Use of our Website. Capitalized terms used but not defined in this document will have the same meanings that they are given in our Terms of Use.

How Weemba Works
Before we dive into the details of our information collection practices, we want to provide you with an overview of how Weemba works. Additional information can be found in our Terms of Use. Of course, if you have any questions about our information collection, use and sharing practices, please contact us at support@weemba.com.

Interested persons may join Weemba as “Community Members,” “Borrowers,” or, if applicable, “Lenders.” A Community Member is any person (or business) with interest in Weemba who has created a basic user account. Community Members may create accounts on our Website, view our products and Services, create draft Loan Projects, and participate in Forums and blogs. Community Members, however, may not publish Loan Projects.

We require all Community Members to undergo an identity validation process before becoming a Borrower and being able to publish a Loan Project. Therefore, to change your status from Community Member to Borrower, we will submit your information to a third party service to validate your identity. We also require all potential Lenders to undergo an applicable identity validation process to confirm that they can be registered as Lenders in the United States. For additional information about the identity validation process, please see here.

An interested Borrower will create a profile and post a Loan Project in the hope of obtaining financing from one of the many Lenders registered with Weemba. When the Borrower creates a profile, he/she/it chooses a Borrower ID for him/herself/itself that will be displayed with the Loan Project. Any visitor to our Website, including potential Lenders and the public will be able to view your Loan Project; Lenders and the public will see the username that you have chosen for yourself, but they will not see your full name when they view your Loan Project at this stage.

U.S.-based Lenders that have registered with Weemba will be able to search Loan Projects created by Borrowers and narrow them down by a wide range of criteria, including credit score, amount needed, location, and purpose of loan; searches can be as broad or specific as the Lender chooses. Weemba itself is not a Lender; we do not lend money or extend credit, among other things (please see “What Weemba Does Not Do” in our Terms of Use. Instead, we have created a platform where interested Borrowers can meet up with prospective Lenders. When a Lender finds an interesting Loan Project, the Lender then may request access to the Borrower’s Private Information (defined below) and seek additional non-public details about the project. The Borrower is free to decline any Lender’s request. Notwithstanding the foregoing, Lenders may also contact Borrowers through the applicable Forum to request questions regarding the Loan Project before requesting Borrower’s identity. Lenders, however, are prohibited from requesting Borrower’s contact information directly; and Borrowers are prohibited from responding to such request; all requests for additional information must go through Weemba’s official process. A request and/or answer of Borrower’s contact data through a Forum shall be considered a breach of our Terms of Use and this Privacy Policy.

The rest is up to the Borrowers and Lenders; Weemba is not in any way involved in the financial transaction, which will take place off-line.

Information We Collect from Community Members, Borrowers, Lenders, and Other Visitors to Our Website
Our Website is available to Community Members, Borrowers, Lenders, and any other visitors to our Website, and we collect information from each of these categories. In this section, we describe the information collection practices applicable to each category.

We may collect information about you from a variety of sources, including information we collect from you directly when you join Weemba and create your profile, information we collect about you when you visit our Website, use our services and view our online advertisements; and information we collect about you from other sources, such as third party partners and affiliates (where permitted by law).

Information We Collect Directly From Community Members and Borrowers: Any person or entity is a potential Borrower—a Borrower might be an individual or a company—and we collect slightly different information depending upon whether the Borrower is an individual or a commercial entity. We may collect information directly from you, including Personal Information, when you visit our Website, create a profile on our Website, post a Loan Project, register to make comments on Forums, or request information from us.

You do not have to provide us with any Personal Information to view our Website, and you are permitted to browse our Website anonymously. If you choose to create an account, prepare a draft Loan Project, or publish a Loan Project, we collect the following information from you:

Create an Account: Creating an account will enable you to save searches, comment on articles and blogs, participate in Forums (both general and project-specific), and to create a Draft Loan Project, visible to you. We collect the following information from you when you set up an account either as a Community Member or a Borrower:

• Your chosen Community ID
• Email address
• Password
• Secret question and secret answer to such question
• Acceptance of Terms of Use

Account Profile/Loan Project: If you would like to publish a Loan Project, we require you to provide certain information for identity validation purposes, which we will include in your profile. You may provide this information to us at any time before you publish the Loan Project; in fact, you can provide us with this information even before you create your Loan Project.

If you are an individual seeking a loan, we require you to provide the following information:

• Your Chosen Borrower ID
• Full name including suffix
• Gender
• Social security number
• Personal phone number
• Driver’s license number or state-issued non-driver ID number
• Date of birth
• Home postal address

For business applicants, we will request information about both the company and a company representative. For the company representative, we require the following information:

• Your Chosen Borrower ID
• Full name including suffix
• Gender
• Social security number
• Personal phone number
• Driver’s license number or state-issued non-driver ID number
• Date of birth
• Home postal address

We require the following information regarding the company:

• Business name
• Federal Employer Identification Number
• “D&B” D-U-N-S Number
• Business phone number
• Business postal address

In addition to the required information listed above, Borrowers may submit any other information that they would like to provide in support of their Loan Project, including, without limitation, text, graphics, photos, videos linked from YouTube and voluntary answers to a set of financial profile questions. Borrowers also could provide additional financial documents, such as tax returns, wage statements, or other files containing financial information. Any information that you provide beyond the required information is at your discretion.

Weemba provides the means for you to obtain your credit score, at no cost, from a third-party such as Dun & Bradstreet or Equifax (as applicable based on the applicant type); you also may attach your score to your Loan Project.

Information We Collect Directly From Prospective Lenders: We collect information directly from you, including Personal Information, when you visit our Website, create an account on our Website, request information from us, contact us regarding a particular Loan Project, or choose to complete our surveys or questionnaires (either online or paper). In particular, to become a Lender, we require you to submit information about both the Lender and a legal representative as follows:

From the legal representative:

• Full name including suffix
• Gender
• Title
• Social security number
• Personal phone number
• Home postal address
• Date of birth
• Driver’s license number or state-issued non-driver ID number
• Email address
• Password
• Secret question and secret answer to such question
• Acceptance of Terms of Use

From the prospective Lender we collect:

• Lending Institution Name
• Federal Employer Identification Number
• “D&B” D-U-N-S Number
• Business phone number
• Business postal address
• Lending or Business License, if applicable
• Lending Institution bank account information for payments to Weemba

Information We Collect When You Visit Our Website: We use cookies and other tracking technologies to automatically collect information about you when you visit our Website or use our Services, including IP address, browser type, operating system, date and time of visit, time spent on and/or logged in to Website, browser referrer header or other mechanism by which you came to our Website, links clicked on our Website. Please see the section below entitled “How Do We Use Cookies & Other Tracking Technologies” for additional information.

Information We Collect From Other Sources: We may obtain information about you, either individually or in the aggregate, from other sources, such as third party partners and affiliates, including, but not limited to, usage patterns regarding visitors to our Website. At your request, we also may collect a credit score from Equifax or Dun & Bradstreet. Weemba is not responsible for the accuracy of any information obtained from third parties or affiliates.

“Private Information” and Privacy Settings on our Website
We treat the following mandatory information that we collect to become a Borrower as Private Information: full name including suffix; gender; social security number or FEIN and “D&B” D-U-N-S Number; contact phone number; driver’s license number (or other government-issued identification number); date of birth; bank account and financial information, if requested; postal address and any files you upload that may identify you or your entity. Private Information is not viewable by the general public, and only part of it is viewable to a Lender after you consent to release that information to the Lender. In addition, the default setting for files that you upload to our Website is private and only viewable by Lenders upon your authorization. If you change the default setting to public, please be aware that any person or entity viewing our Website will have access to the information that you have made public. Information contained in links to other websites, such as YouTube, can be viewable by any visitor to such websites.

How We Use The Information We Collect About You
Community Members, Borrowers, and Other Visitors to Our Website: We use the information that we collect about you for several purposes, including to verify your identity; to create and manage your account; to fulfill your present and future requests for information, products and services from us or from our business partners that we believe would be of interest to you; and to enforce our terms and conditions and otherwise manage our business.

Lenders: We use the information that we collect about you for several purposes, including to verify your identity; to create and manage your account; to fulfill your present and future requests for information, products and services from us; where permitted by law, to inform you about the latest product developments and other information from us or from our business partners that we believe would be of interest to you; and to enforce our terms and conditions and otherwise manage our business.

Sharing Your Information
We may share information about Community Members, Borrowers, Lenders, and other visitors to our Website as discussed below. In addition, all visitors to our Website (including non-registered visitors, Community Members, Borrowers, and Lenders) may share the publicly posted information about a Loan Project as discussed below.

Identity Validation: As stated above, we validate the identity of all potential Borrowers and Lenders. Before we will permit a potential Borrower to publish a Loan Project, we will share the Borrower’s Private Information with a third party (currently, Equifax, Duns & Bradstreet, and/or Gulf Management Systems, Inc., but subject to changes without notice) to validate your identity. Similarly, before we will authorize a potential Lender, we will share the Lender’s information with a third party to validate Lender’s identity and we may confirm that the potential Lender is authorized to provide loans in the United States. For additional information about how and why we validate your identity, please see our Terms of Use.

Credit Score: Upon request by a Borrower, we also will share your information with a third party (currently, either Equifax or Dun & Bradstreet, but subject to changes without notice) for the purpose of obtaining your credit score. Weemba is not responsible for the accuracy of any information obtained from third parties or affiliates.

Loan Project Private Information/Profile Information: If a Lender is interested in a Loan Project, the Lender shall have the possibility of contacting the Borrower through our Website asking if the Borrower is interested in making available his Private Information to that Lender. If the Borrower agrees to do so, then the Lender will be able to see the Borrower’s Private Information that the Borrower has provided on our Website, and the locked additional information (e.g., wage statements) of the Borrower’s Loan Project. We share a Borrower’s Loan Project’s Private Information to Lenders only at the Borrower’s request and direction. The Private Information shared includes information provided by you. For an individual borrower, this means your first and last names; social security number, home postal address and contact information provided by you in your loan project. For business Borrowers, this includes your legal representative’s first and last names, representative’s social security number, business name, business postal address, FEIN and “D&B” D-U-N-S Number and contact information provided in your loan project. For both types of Borrowers, this includes any locked files that you have posted to the Website (e.g., tax returns). Once the Borrower provides access to the Lender, all further contact and any negotiations will take place outside, and without intervention of Weemba and this Website.

To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service.

Joint Marketing: We also may engage in joint marketing activities with third parties. We may share your information with third parties for the purpose of such joint marketing activities, for example, to make you aware of products and services that we believe would be of interest to you.

Sale/Transfer of Business: Weemba reserves the right to disclose your information if it licenses, sells, or otherwise transfers its technology or business, or a portion thereof, to third parties.

To Protect Ourselves/For Legal Purposes: We also may disclose your Personal Information to protect our rights and property, to prevent against fraud and abuse, and to protect other users of our services. We also may disclose your information as permitted or required by law, for example, in response to court orders, subpoenas, or other requests from government agencies.

Social Networks: We offer visitors to our Website and Users the ability to indicate that they want to “Share” a particular Loan Project on Facebook, Twitter, LinkedIn and by email. We may add other social networks to that list as appropriate. If a visitor sees a Loan Project that it would like to share via social media, then the visitor may click on the “Share” button on the Loan Project page. The visitor will be asked to log onto his or her social media account by that website, as usual. Weemba does not store log in information for any outside website. Such Loan Project then will be shared on that person/entity’s social media profile, page or stream.

How Do We Use Cookies & Other Tracking Technologies?
When you interact with the Website, we strive to make your experience easy and meaningful. We may use or engage others to use cookies, clear gifs and Flash LSOs to track user activity and collect site data. We may combine this data with other user information.

Cookies
When you come to the Website, our web server sends a cookie to your computer. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. There are two types of cookies: session-based and persistent-based cookies. We also may permit certain third party cookies to be placed on our Website.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you while you are logged into the Website. This allows us to process your online transactions and requests, and to verify your identity, after you have logged in, as you move through our Website.
• Persistent cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
• Third Party Cookies. We also may engage third parties, including, without limitation, Google Analytics, to track and analyze non-personally identifiable Website data. We use the data collected by such third parties to help us administer and improve the quality of the Website and Services and to analyze usage. We do not have access to or control over these third party cookies nor does this Privacy Policy cover such third parties’ use of data.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Website visitors who disable their web browsers’ ability to accept cookies will be able to browse the Website; however, you must enable cookies to use most of our Services.

Clear Gifs (Web Beacons/Web Bugs). We or the third parties we engage to track and analyze Website data may employ clear gifs (a.k.a. Web Beacons/Web Bugs) to help us better manage content on the Website. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on Web pages.

Flash LSOs. We may use local shared objects, also known as Flash cookies, to store your Website preferences, to personalize your visit, or to display content based upon what you view on our Website. Flash cookies are different from browser cookies because of the amount and type of data stored. In addition, you cannot control, delete, or disable the acceptance of Flash cookies through your browser. To learn how to manage your settings for Flash cookies click here.

Opting Out of Marketing Communications
We may send you promotional email messages if you request to receive information from us via email. You may stop receiving promotional email messages by configuring your “Notification Settings” at any time from My Account / Edit My Preferences page, in the Notifications section.

Updating Your Information
Currently, you may modify certain information that you provided to us when you created your profile by signing in at http://www.weemba.com and going to My Account / Edit My preferences. You can change, among others, your email address, password, postal address and phone number. You also may update information contained in your profile.

Security of Your Information
We want the information that you submit to us to be secure. We use industry-standard techniques to safeguard the information that you provide to us through our Website. Notwithstanding our commitment to your information, please be aware that there is a risk that others could find a way to thwart our security systems or the security systems of the third parties that host our server. As a result, we cannot ensure or warrant the security or privacy of any information that you choose to submit to us.

User Generated Content
Portions of our Website permit users to submit their own content for blogs or to respond to blog postings. Weemba is not responsible for the privacy of any information that you choose to submit through a public Forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Children’s Privacy
You must be 18 years of age to register as a Borrower with our Website. As such, our Website and our Services are only intended for persons ages 18 and older. We do not knowingly collect information from persons under 18, including from children under the age of 13.

Changes to this Privacy Policy
We will post changes to this Policy to this Website. Changes will become effective upon posting. If we make a material change to this Policy, then we will highlight that change upon posting.

Contact Us
Please contact us at support@weemba.com if you have any questions regarding this Policy.

Effective Date: July 31, 2011