GREATER NEVADA COMMERCIAL LENDING, LLC
WEBSITE PRIVACY POLICY

Last modified: May 22, 2023

Introduction

Greater Nevada Commercial Lending, LLC (“GCL”, “Company”, “we” “us” or “our”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website Greaterlendingxchange.com (the “Website”), in using the GCLXchange (the “Exchange”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.  This Privacy Policy is a part of our Terms of Use which governs your use of the Website and the Exchange.  In addition, the use and sharing of information with respect to loan participations offered through the Exchange will be subject to the terms and conditions set forth in the applicable master participation agreements, participation agreements, participation certificates, and related materials relating to the applicable loans and participations (collectively, the “Participation Materials”). Please contact GCL for additional information about the information collected for participations and the use of information for the Exchange.   Any conflicts between this Privacy Policy and the Participation Materials shall be governed by the applicable Participation Materials. 

This policy applies to information we collect:

  • On the Website.
  • In application for registration for use of the Website, and all functions relating thereto. 
  • In application to be a user of the Exchange or an originator of participants of loans through the Exchange.
  • In email, text, and other electronic messages between you and the Website.
  • Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website and the Exchange. By accessing or using the Website, you agree to this privacy policy.

 

Changes to Our Privacy Policy

We may revise our Privacy Policy from time to time in our sole discretion. All changes are effective immediately when we post them, and apply to all access to and use of the Website thereafter. Your continued use of the Website following our posting of a revised Privacy Policy means that you accept and agree to the Privacy Policy as changed. You are expected to check this page each time you access the Website so you are aware of any changes, as they are binding on you.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you or your organization may be identified, such as name, postal address, e-mail address, telephone number, social security number, any other identifier by which you may be contacted online or offline, or ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”);
  • That is about you or your organization but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, including but not limited to our business partners.

 

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website and by applying for membership. This includes information provided when you register to use our Website, post material to our Website, or requesting further information or services when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain Website pages and you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs such as browsing history, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our user base size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.
  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Use and Disclose Your Information” below.

 

How We Use Your Information

We use information that we collect about you and your organization or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To consider acceptance of membership of you or your organization in the Exchange or to participate in loans through the Exchange or the Website.
  • To provide information on the Exchange.
  • To provide members with notices about their membership, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures in your account profile.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • As otherwise required by law.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, and for billing and collection purposes if applicable.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Greater Nevada Commercial Lending, LLC and Greater Nevada Credit Union, their respective officers, directors, employees and agents, our members, other users, or other parties in interest.

Choices About How We Use and Disclose Your Information

The following mechanisms may help you to better control the use of your information:

  • Account Profile Settings.  Your account profile offers choices regarding the personal information you provide to us.  You can access your account profile when you log on to our Website.
  • Tracking Technologies and Advertising. Many browsers permit you to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may offer you with ways to choose not to have your information collected or used in this way.  For more information you may wish to contact a particular third party directly or visit that third party’s Website. You can opt out of receiving targeted ads from members of the National Advertising Initiative (“NAI”) by visiting the NAI Website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you delete information or other material you posted to our Website, copies of that information or other material may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. 

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 is authorized to use our Website or provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Website or on or through any of its features, make any purchases through the Website, use any of the interactive or public comment features of the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at:

833-519-9474 or [email protected].

California Privacy Rights

California Civil Code Section §1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: [email protected].

 

Data Security

While we take measures designed to secure personal information from accidental loss and from unauthorized access the safety and security of personal information depends on each registered member of the Exchange. If you are a registered Member with a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website if any. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we take commercially reasonable precautions to protect personal information, we cannot guarantee the security of all personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

 

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

[email protected]