Privacy Policy

Last updated: [1st March 2023]

If you visit our website or download or use our mobile application (“App,” together, the “Services”), Lvble Inc. ("Lvble," "we," "us," and "our") will ask for, collect, and store personal information about you (your “Personal Data”). This document (“Privacy Policy”) describes the types of personal information we collect, how we use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.

If you do not want us to collect Personal Data from you or share Personal Data with any third parties or otherwise disclose your Personal Data, you should not use the Services.

1. Information We Obtain

We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with any of our representatives. The types of personal information we may obtain about you include:

• Identifiers such as name, Social Security number, date of birth, postal and email address, and phone number;
• Government-issued photo ID, such as a driver’s license or passport, photograph, proof of address documentation (such as a utility bill) and proof of identity documentation (such as a marriage document);
• Login credentials for your tenant portal and Lvble account;
• Information about your apartment lease, such as transaction history, identifying information (name, address, phone number, email address, property management company name), and lease contract information;
• Financial information, including transaction history, assets, and debts collected through Plaid Technologies, Inc. (“Plaid”);
• Credit score and other credit history data from a credit reporting agency;
• Employment information, including occupation, information about your employer, and income details (such as source of income, approximate annual income and how frequently you are paid);
• Physical characteristics, demographic information and similar details (such as sex, gender, race, color, marital or family status, citizenship status, military or veteran status, signature, language preference and national origin) present in documents (e.g., IDs, tax returns) you provide;
• Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or services;
• Voice recordings (such as when you call Lvble’s member services);
• Biometric information (such as a facial image collected for identity verification, if you use certain features of our App);
• Information you provide through member services interactions and that you provide about your experience with Lvble, including via questionnaires, surveys, participation in user research or other feedback;
• Geolocation data;
• Information provided by marketers and other websites on which Lvble advertises;
• Information you provide through contacts integration, including a list of contacts from your phone’s operating system; and
• Other information you choose to provide, such as through emails or other communications (such as with our representatives), referrals, on social media pages, or in registrations and sign-up forms.

 

• Provide the Services;
• Process and fulfill transactions;
• Establish and manage your account;
• Personalize your experience on our Services;
• Facilitate direct deposits to your Lvble account;
• Facilitate transfers between your external bank accounts and Lvble accounts;
• Verify your identity, including to facilitate a name change request;
• Respond to inquiries, provide member support and resolve disputes;
• Advertise and market our products and services, and send information about third-party products and services we think may interest you;
• Provide you targeted offers and notify you of nearby third-party locations where you may use our products and services;
• Provide member support and quality assurance, and conduct customer service training;
• Collect fees and other amounts owed in connection with your Lvble account;
• Operate, evaluate and improve our business;
• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
• Exercise our rights and remedies and defend against legal claims; and
• Comply with and enforce applicable legal requirements, relevant industry standards and Lvble policies.

We also may use the information in other ways for which we provide specific notice at the time of collection.

3. Information We Share

We may share the information we obtain about you with our affiliates and subsidiaries; our business partners; and consumer reporting agencies. We also may share the information we obtain about you with third-party vendors and other entities we engage to perform services on our behalf, such as payment and check deposit processors, risk detection and mitigation tools, and modeling and analytics tools.

We may share your Personal Data in order to comply, as necessary, with applicable laws and regulatory requirements, as well as legal process, respond to mandatory legal or governmental requests or demands for information, enforce our agreements, policies, procedures and terms of use, and protect ourselves, our customers, or the general public from illegal activities.

We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

4. Third-Party Analytics Services

We may use third-party analytics on our Platform.

5. Interest-Based Advertising

In our Services, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This section of our Privacy Policy provides details and explains how to exercise certain choices.

We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications.  These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information.

The Services are not designed to respond to “do not track” signals from browsers.

To learn how to opt out of interest-based advertising in the U.S., please visit www.aboutads.info/choices.

6. Your Rights & Choices

You may exercise certain choices in connection with the personal information we collect from you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the “How to Contact Lvble” section of this Privacy Policy. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you are a Lvble member, you may update, correct, or delete some of your account information by logging into your account on our Services or by emailing us at [contact@nowlvble.com].

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device.  You can deactivate these messages at any time by changing the notification settings on your mobile device.

7. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.

8. Children’s Privacy

Our Services are designed for a general audience and are not directed to children. We do not knowingly collect, use, sell, or share any Personal Data from anyone under the age of 18. If we become aware that a child under the age 18 has provided Personal Data to us, we will delete it.

9. Links to Third-Party Services and Features

For your convenience and information, our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Lvble, we are not responsible for these third parties’ information practices.

10. Updates to this Privacy Policy

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the policy when it was most recently updated.

11. How to Contact Lvble

You can update your preferences, ask us to remove your information from our mailing lists, submit a request or ask us questions about this Privacy Policy by writing to us at [contact@nowlvble.com].

12. California Consumer Privacy Rights

As a California resident and consumer, you have certain choices regarding your personal information, as described below.

• Right to Access. You may request, up to twice in a 12-month period, information about the Personal Data we have collected, used, disclosed or sold about you during the past 12 months, including:
  • the categories and specific pieces of Personal Data we have collected about you;
  • the categories of sources from which we collected the Personal Data;
  • the business or commercial purpose for which we collected the Personal Data;
  • the categories of third parties with whom we shared the Personal Data; and
  • the categories of Personal Data about you that we disclosed for a business purpose and sold to third parties, and the categories of third parties to whom the information was disclosed or sold.
• Right to Delete. You may request that we delete the Personal Data we have collected from you, subject to certain limitations under the CCPA.
• Right to opt-out from sale of Personal Data. You have the right to opt-out of the sale of your Personal Data. Lvble does not sell your Personal Data.
• Right to non-discrimination. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

To submit a request to exercise any of the rights described above, you may email us at [contact@nowlvble.com]. We will verify your identity before responding to your request by either verifying that the email address from which you send the request matches your email address that we have on file, or by requiring you to log into your account.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request under the CCPA on your behalf, we require the authorized agent to submit the following information so that we can confirm their authority to act on your behalf:

• Evidence of authorization to act on behalf of the California consumer: (1) California Secretary of State authorization, (2) notarized written permission from the California consumer, or (3) power of attorney.
• Evidence of identity of the California consumer: (1) first and last name, (2) email address, and (3) password.

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL DATA TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING [support@nowlvble.com]. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.