Oportun privacy policy

Last updated: December 2023

This privacy policy explains how personal information (as such term is defined below) is collected, used, stored, and disclosed when you visit any online services offered by Oportun Inc. (“Oportun”).  Our online services include our websites, mobile applications, and social sites.  Other privacy principles or policies may apply depending on how you interact with Oportun, the specific Oportun financial products and services you have, or your state of residence.  For example, California residents may have rights under the California Consumer Privacy Act as described in our California Consumer Privacy Act notice.  Likewise, if you are an Oportun member, you may be subject to one or more of the following privacy notices for those accounts:

Oportun privacy notice For all Oportun personal loan customers

WebBank privacy notice For Oportun^® Visa^® Credit Card customers

Pathward privacy notice For all Pathward^®, N.A. personal loan customers

To the extent there is a conflict between this privacy policy and an applicable consumer privacy notice regarding Oportun’s handling of personal information for your account(s), the consumer privacy notice will take precedence.

Information we collect

Information You Provide

We collect the personal information you provide us along with data from other sources when you visit or use our online services for purposes such as researching or applying for Oportun products and services, responding to surveys, or managing the Oportun products you already have. Personal information is any information that we can use to identify, locate, or contact you. It also includes information that may be associated with your personal information, such as your financial history. The types of personal information we may collect include name, address, email address, phone number, date of birth, Social Security number, or other identifying information such as fingerprints or other biometrics.

Information About Your Transactions

We collect Personal Information about your transactions with us and others, as well as other information associated with your transactions such as amount received, amount paid for products or services, account balance, merchant information, Device Information and Log Information.

Information From Third Parties

We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from affiliates, consumer reporting agencies, product marketing companies, transaction data providers and other third parties (such as those that assist with fraud prevention and AML compliance).

By way of example, Oportun works with Plaid to help you connect your external bank accounts (i.e., your accounts at financial institutions other than Oportun) to our services and to retrieve transaction and balance information for these accounts. To provide this service and to help create a secure connection to your external bank accounts, you consent to let Plaid collect and use your financial institution login information and access your account(s). If you have more than one external bank account at a particular financial institution, you can choose which account(s) you want to add. Not all accounts are supported. The personal information we and Plaid receive depend on the purpose(s) for which you or we are using Plaid, but may include your bank account number and bank routing number; other financial account numbers; your name, address, phone number and email address; and account transaction history and balances.  We use this information as described in the “How we use information” section and in accordance with any specific disclosures given to you when you connect your bank account through Plaid.

You can terminate Plaid’s and our access to your external financial accounts at any time by specifically updating your Oportun account settings through the application, by contacting us at the appropriate number or email provided in the “Updating Your Information” section below, or by using the Plaid Portal.  Please note that terminating Plaid’s access to your external financial accounts may impact the availability of certain Oportun products and services.  In particular, our automated savings tool, sometimes referred to as Set & Save, is contingent on our access to your external financial account information through Plaid.  If you terminate Plaid’s or our access, we will disable the saving features of your account with us.

Information Automatically Collected

We or our third-party service providers may use a variety of technologies – including cookies and web beacons – that automatically (or passively) store or collect certain information whenever you visit or use our online services. This information may include Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our online services may include:

• Device Information: We may collect information about the electronic device(s) that you use to access our online services (such as hardware model, operating system version, unique device identifiers, and mobile network information, including your mobile phone number).
• Log Information: We may record or log information from your devices, their software, and your activity accessing or using our online services. This information may include:
  • Internet Protocol (“IP”) address
  • Identification numbers associated with your devices
  • Device event information, such as crashes, system activity, and hardware settings
  • Location preferences
  • Date and time stamps of transactions
  • System configuration information
  • Other interactions with our online services
• Information on Your Device: We may collect Personal Information contained on your device (for instance your precise geolocation data) where you give us explicit permission to do so.

How we use information

In accordance with legal requirements, we will use your personal information to help deliver to you the best of what we and our partners offer, including to:

• provide you with, or evaluate your eligibility for, products and services that you have requested from us or our partners
• to enable features or functionality in relation to your membership, including to inform our automated savings decisions
• operate, evaluate, and improve our business (including developing new products and services; improving existing offerings; and performing accounting, auditing, and other internal functions)
• respond to your questions or communicate with you about your accounts or transactions with us or our partners, including changes to applicable policies or other terms, conditions, or agreements
• comply with and enforce our legal and regulatory obligations, relevant industry standards, contractual obligations, and our policies
• detect, investigate, or prevent fraud or other activity that may be illegal, violate our policies, cause harm to our operations, or compromise our security
• allow participation in surveys, sweepstakes, contests, and other promotions
• offer products and services from Oportun or from third parties that we think you might like
• personalize online or mobile content (including email) and user experiences
• display content, including advertising, based on your interests or interactions with us
• measure the effectiveness of our marketing efforts

Please note that we may also use and disclose information that we maintain on an aggregate or anonymous basis (such that it does not identify any individual) for various business purposes in accordance with applicable laws and regulations.

Information Collected Through Cookies and Similar Technologies

We and our third-party service providers use various tracking technologies to collect information for debugging, fraud prevention, evaluating the performance of our marketing campaigns, and other purposes. The technologies, some of which may detect characteristics or settings of the device(s) you use to access our online services, include:

• Cookies. Cookies are small files containing a string of characters that we may store on your computer or mobile device when you access the online services. When you access the services again, the cookies allow us to recognize your browser.  In this way, cookies can help us, our service providers, and others relate your use of our online services over time to customize your experience.  Most web browsers allow you to adjust your browser settings to decline or delete cookies but doing so may degrade your experience with our online services.
• Web beacons. Also known as clear GIFs or pixel tags, web beacons are typically one-pixel, transparent images located in a webpage, advertisement or email message that help us recognize and track your use of our online services.  Web beacons allows us, for example, to monitor how users move from one page within our websites to another, to track access to our communications, to understand whether users have come to our websites from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve site performance.
• SDKs and mobile advertising IDs. Our mobile applications may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your use of these applications. In addition, some mobile devices come with a resettable identifier (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your device over time for marketing purposes.
• Third-party plugins. Our online services may include third-party plugins (e.g., Facebook’s “Like” button) that collect information about things like the pages you visit. These plugins may share information with the company that created the plugin even if you do not click on the plugin, and use of such information is governed by that company’s privacy policy and terms.

Targeted Advertising

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) use cookies, over which we have no control.  These companies may use information about your visits to this and other websites to deliver advertisements – including across the internet and mobile apps and other devices – for goods and services that your browsing behavior suggests might interest you.  For example, when you visit the Oportun website and explore our products, our advertising providers may use that information to determine which ads to show you after you leave our website.

For more information or to opt out of certain targeted advertising, please see the NAI’s Understanding Digital Advertising page or https://www.aboutads.info/choices/.

Please note that you may still see ads from Oportun after opting out of targeted advertising.  The ads will be general rather than customized based on your web-browsing activities.  Please also note that because opting out is dependent upon information stored in browser cookies or unique mobile or device identifiers, you will need to opt out separately on each of the browsers and devices that you use.

Do-Not-Track Signals

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. While our online services should respond to browser DNT signals and similar mechanisms, we do not guarantee that they will respond to all types of DNT signals or similar mechanisms.

Your privacy choices

If you want to stop receiving marketing offers and other promotional email messages from us, you can “opt out” by contacting us as indicated at the end of this Privacy Policy or by following the “unsubscribe” instructions in any communication you receive from us. You can ask that we stop sending marketing and other promotional text messages by replying “stop” to any such message you receive.

Please note that even if you opt out of marketing messages, we may still reach out to you with information about your account(s). For example, we may still send you payment reminders and confirmations.

You may have additional rights under applicable law, such as the California Consumer Privacy Act for California residents. For more information about these rights or choices and how to exercise them, please review our California Consumer Privacy Act notice (for California residents), the consumer privacy notice(s), for your Oportun account(s), or contact us using the information provided below at “How to reach us.”

Updating your information

Keeping your account information current is key to getting the best experience from us. In particular, please make sure you inform us of email address and phone number changes, since these are the quickest ways for us to communicate with you.

If you cannot make changes to your personal information through our online services, or you prefer to make them offline, you can tell us about changes and ask us to update our records by calling or writing to us using the contact information below.  Before making changes to your personal information, we will ask you to provide adequate proof of your identity.

Keeping your information secure

We use reasonable physical, electronic, and procedural safeguards that are designed to protect and limit access to personal information. These measures include computer safeguards and secured files and buildings. We authorize our employees to access your information only when they need it to perform their job responsibilities, and we require companies that partner with us to protect your information.

Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us (such as your Social Security number).

You also play a role in protecting your Personal Information. Please safeguard your username and password for your Oportun account(s) and do not share them with others. Tell us right away if you detect any unauthorized use of your Oportun account(s).

Links to Third-Party Websites

When you use our online services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our online services. We are not responsible for the privacy practices of any third parties or the content of linked websites, and this Privacy Policy will not apply.  We encourage you to read the applicable privacy policies and terms and conditions of such parties and websites before providing any Personal Information to them.

How we share information

We may share your Personal Information with our affiliates and unaffiliated third parties when it is permitted or required by law.  For example, we may share your Personal Information with:

• Third-party service providers who help us operate our online services, conduct our business, or service our members, as long as these providers agree to keep this information confidential and secure
• Oportun affiliates and partners as appropriate to enhance your experience across our family of products and services, when permissible under relevant laws and regulations
• Oportun affiliates or unaffiliated third parties in connection with a corporate transaction, such as a sale, merger, consolidation, transfer of assets, reorganization, or liquidation of Oportun
• Law enforcement, regulators, government bodies, and other third parties when we believe release is appropriate to (a) comply with, or to allow our investors or potential investors to comply with, any law, regulation, legal process, or government request; (b) verify or enforce our terms of use or other policies for our online services; (c) address fraud, security or technical issues; (d) respond to an emergency; or (e) otherwise protect our or others’ rights, property, or safety; and
• any other person in accordance with your instructions, or any specific notice we give you when we collect your Personal Information.

If applicable, we will limit sharing of your personal information in accordance with any choices you’ve made under the privacy notice(s) for your account(s).

We may share information that is anonymized or aggregated, such that it does not identify any specific individuals, with our affiliates and third parties to help deliver products, services, and content that are better tailored to the users of our online services and for other purposes.

Children’s privacy

Our online services are not intended for children under the age of 13, and we request that these individuals not provide Personal Information through our online services. We do not knowingly collect Personal Information from children under 13.

Changes to our Privacy Policy

We may change this privacy policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised version on this page with a new effective date. Any changes to this privacy policy will become effective when posted unless otherwise indicated.

How to reach us

If you have any questions about this Privacy Policy or Oportun’s handling of your personal information, please contact us:

Oportun

PO Box 4085

Menlo Park, CA 94026

866-488-609