Privacy Policy (last updated December 2023)
Welcome to the Thunderbird Wholesale, LLC, Privacy Policy (the “Policy”). For purposes of this Policy, the terms “TBW” “we,” “us,” and “our” refer to Thunderbird Wholesale LLC, LLC. “You” or “your” refers to you, as a user of our services, including any use of our websites and business loan services, whether operated by us or on our behalf (“Services”).
This Policy describes:
- Personal Information We Collect
- How We Collect Your Personal Information
- How We Use Your Personal Information
- How We Share Your Personal Information With Third Parties
- Choice / Opt-out
- How We Protect Your Information
- California Privacy Rights
- Nevada Privacy Rights
- Other State Privacy Rights
- Changes To This Policy
- Questions About This Policy
Personal Information We Collect
“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
If your business (“Customer”) applies for our Service, we will collect and process certain Personal Information about the following individuals associated with the Customer (referred to as “Related Parties”):
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- Individual members of a partnership.
- Individual members of a limited liability company.
- Individual directors, company secretaries or other equivalent individual office holders and beneficial owners of the company.
- Guarantors and third-party security providers.
- Individuals associated with the directors and beneficial owners of the business.
- Any employees, contractors, representatives, officers or agents of the business.
- Legal representatives and other individuals authorized to act on behalf of the business.
The categories of information that TBW collects about the Customer and Related Parties include:
- Personal details (e.g., name, date of birth, identification information).
- Contact details (e.g., phone number, email address, postal address, mobile number).
- Business-related details (e.g., relationship with the business or Related Parties, business information, information about any equity holdings, business contact details).
- Transactional details (e.g., information about services, requests, queries or complaints).
- Financial details (e.g., information about business accounts, financial history, information from credit reference agencies and fraud prevention agencies).
- Technical Information (e.g., internet protocol (IP) address, browser type and version, time zone setting and location).
- Audio, electronic, and visual information (e.g., call recordings, pictures).
- Usage data (e.g., information about how you use our Services).
- Marketing and communications information (e.g., marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, and your communication preferences).
Cookies and tracking technology
TBW uses cookies and similar technologies on its websites, mobile apps, and in its emails. Cookies are text files that hold small amounts of information, which an individual’s computer or mobile device stores when they visit a website or use a mobile app. When the individual returns to the websites or mobile apps – or visits websites and mobile apps that use the same cookies – they recognize these cookies and, therefore, the individual’s device. TBW and its partners use cookies or similar technologies to analyze trends, administer the website, and track users’ movements around the website. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. For more information about cookies and about turning off cookies, please see: https://www.allaboutcookies.org. If you turn off your cookies, some of the features of the Services may not function properly.
Information you provide to a third-party
The Services may include links and plug-ins to websites operated by third parties, such as X (formerly Twitter), Facebook, and Instagram buttons (“Third-Party Sites”). TBW does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by the privacy policy of such third parties. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.
Children’s privacy
The Services are intended for adult use only and are not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information.
How We Collect Your Personal Information
We may collect Personal Information from a variety of sources and methods. This includes:
- Directly from the Customer and Related Parties when they give us Personal Information by filling in forms, filling out a loan application, or by corresponding with us by post, phone, text, email, “Contact Us” or “Get Started” forms.
- TBW will check its own records for information about (i) any accounts belonging to the Customer or any associated businesses and (ii) the Customer’s equity holders who are beneficial owners of the businesses.
- TBW may carry out searches using credit reference agencies and financial crime prevention agencies for information relating to the Customer and Related Parties.
- TBW may search publicly available sources, such as media stories, for information relating to the Customer and Related Parties.
- TBW may also receive Personal Information from third-party referral sources, brokers, and strategic partners.
Information we collect from third parties
We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third-party service providers
We collect Personal Information from service providers, including where we operate accounts on third-party platforms, such as online application submission and management platforms, email platforms, and social media platforms.
Third-party advertising partners
We collect Personal Information received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
Google Analytics
We use third-party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles Aggregate Data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
Third-party cookies
We may engage third-party service providers, including Google, Facebook, and Instagram to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. You can learn more about Google’s advertising cookies and opt-out options by visiting https://www.google.com/policies/technologies/types/. You can learn more about Facebook’s advertising cookies and opt-out options by visiting https://www.facebook.com/policy/cookies/. You can learn more about Instagram’s advertising cookies and opt-out options by visiting https://help.instagram.com/1896641480634370?ref=ig.
Your ‘do not track’ browser setting
Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, we do not respond to browser DNT signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
How We Use Your Personal Information
Our primary purpose for collecting Personal Information is to provide you with information, products, and services you request. We may also use your Personal Information for the following business purposes:
- Customer administration and management, including relationship management, and for account administration and management purposes.
- Transaction processing, monitoring and analysis activities to develop and manage TBW’s products and services.
- Undertaking Customer due diligence checks for the prevention and detection of financial and other crimes and undertaking checks, including on Related Parties, in relation to identity verification, credit checks, anti-money laundering, compliance and risk screening.
- Communicating with the Customer and Related Parties from time to time about products, services, and events offered by TBW, or our affiliates or subsidiaries, and other communications, such as research and insights, that may be of interest to the Customer or Related Parties.
- Complying with legal obligations to which TBW is subject and cooperating with regulators and law enforcement bodies.
- Exercising TBW’s legal rights where it is necessary to do so, for example to protect TBW against harm to its rights and property interests, to detect, prevent and respond to fraud or other violations of law, for legal and dispute management purposes, and for debt collection and recoveries purposes.
- For purposes disclosed at the time you provide your information or as otherwise set forth in this Policy.
How We Share Your Personal Information With Third Parties
We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our Services and perform any contract we enter into with them or you.
Information you instruct us to share
You may be presented with an option on our Service to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
Service providers
We may use third-party service providers to perform certain business services on behalf of us or the Service, and may disclose Personal Information to such service providers as needed for them to perform these business services. One of the service providers we use is Plaid Inc. ("Plaid"), which gathers your data from financial institutions. By using the Service, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institutions. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, maintenance and repair services, hosting services, software as a service, document management services, communications services, such as email, text, and chat services, software and website development services, collection services, accounting and audit services, compliance services, quality control services, analytics services, call center services, and marketing services.
Internal third parties
We may share Personal Information with our parent company, subsidiaries and other companies owned by or controlled by TBW who may use the Personal Information for the purposes described above.
User disclosures
Some Personal Information is disclosed as a matter of course as a result of your use of the Service. Any Personal Information shared via any public forum using our Service or on another website (such as Facebook, X (formerly Twitter), Google, LinkedIn or Instagram) may become public information. You should exercise caution when disclosing information in these public areas, especially your location data, and be careful how you disclose your Personal Information. Content posted in public areas of our Service, including advice and opinions, represents the views and is the responsibility of those who post the content. We do not endorse, support, verify, or agree with the content posted. If you have any questions or comments about any content posted using our Services, please contact us at the address below. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR OWN VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION IN PUBLIC FORUMS.
Business Partners
We may share some Personal Information with trusted business partners, whose products or services we think may be of interest to you, including, but not limited to, partner lenders and other financing providers and insurance providers. These business partners may use your Personal Information for their own commercial purposes. This may be considered a sale under state law.
Business transactions
We may do business with third parties to which we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.
Legal process
Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
Choice / Opt-out
Text messaging
TBW may send you operational and informational text (SMS) messages about your use of the Services at the mobile phone number you provided us. We may also send marketing or other promotional messages to the extent that you have provided the appropriate opt-in consent. Standard text messaging charges applied by your mobile phone carrier will apply to text messages we send. Your agreement to receive promotional texts is not a condition of any purchase or service offered by TBW. Texts, calls, or prerecorded messages may be generated by automatic telephone dialing systems. If you change or deactivate the mobile phone number you provided to TBW, we ask that you update your account information to help prevent us from inadvertently communicating with anyone who acquires your old number.
Opt-out
You may opt out of receiving text messages from TBW at any time by completing the opt-out request form at https://trythunderbird.com/tcpa-preferences. You may continue to receive text messages for a short period while we process your request.
Email
TBW may send you emails concerning our products and services, as well as those of third parties. You may opt-out of promotional emails by following the unsubscribe instructions in a promotional email or by emailing unsubscribe@trythunderbird.com. This opt out will not apply to operational or informational emails related to your TBW account. You may continue to receive promotional email messages for a short period while we process your request.
How We Protect Your Information
We endeavor to incorporate reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk.
California Privacy Rights
California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
- No more than twice in any 12-month period, request disclosure of the following information:
- Categories of Personal Information we collect.
- Categories of sources from which Personal Information is collected.
- Categories of Personal Information sold or disclosed to third parties.
- Categories of third parties with whom such Personal Information is sold or disclosed.
- Business or commercial purpose for collecting or selling Personal Information.
- Specific pieces of Personal Information we collect.
- Request deletion of your Personal Information, subject to exceptions provided by law.
- Opt-out from having your Personal Information sold to third parties.
Requests can be submitted by email to caprivacy@trythunderbird.com. You can also opt out of having your Personal Information sold to third parties using the caprivacy@trythunderbird.com email address. TBW has no actual knowledge of any sales of Personal Information of minors under 16 years of age.
Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. 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.
The verifiable consumer request must:
- Include your full legal name and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we 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 us. One of our representatives will contact you with further information on how to verify your identity.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
No Discrimination
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and TBW will not discriminate by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Requests should be submitted via email to caprivacy@trythunderbird.com and should include CALIFORNIA PRIVACY RIGHTS in the subject line. We will need your first and last name, mailing address, and email address in order to process your request. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Nevada Privacy Rights
If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from our websites, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).
As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to nvprivacy@trythunderbird.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out.
We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.
Other State Privacy Rights
Residents of Colorado, Connecticut, Virginia, and Utah:
If you are a resident of Colorado, Connecticut, Virginia, or Utah, you have rights to:
- Confirm whether we process your Personal Information.
- Access and delete certain Personal Information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
If you are a resident of Colorado, Connecticut, or Virginia, you have the additional rights to:
- Correct inaccuracies in your Personal Information, taking into account the information’s nature and processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
Residents of Colorado, Connecticut, Virginia, or Utah who wish to exercise any of the above rights must submit a request in writing via email to stateprivacy@trythunderbird.com and should include “STATE PRIVACY RIGHTS” in the subject line. To appeal a decision regarding a consumer rights request, submit the appeal in writing via email to stateprivacyappeal@trythunderbird.com and include “STATE PRIVACY RIGHTS APPEAL” in the subject line. We endeavor to respond to requests and appeals submitted in this manner within a reasonable period of time.
Changes To This Privacy Policy
TBW may change this Privacy Policy at any time. Changes are effective when we post them on this website and we encourage you to visit this site frequently for updates, as these updates will only be made available through this website unless otherwise and specifically requested from you or required by law. The date the Privacy Policy was last revised is identified at the top of the page.
Questions About This Policy
For questions or comments regarding our Policy, please contact: privacy@trythunderbird.com. TBW may also be contacted directly at the following address and phone number:
TBW
P.O. Box 1685
Cranford, NJ 07016
Phone: (212) 220-6020
