Laurel Road from KeyBank
Online Privacy Statement
Last Updated: January 1, 2020
Laurel Road is a brand of KeyBank National Association offering online lending products in all 50 U.S. states, Washington, D.C., and Puerto Rico. Mortgage lending is not offered in Puerto Rico. All loans are provided by KeyBank National Association, Member FDIC and Equal Housing Lender. As used throughout this Online Privacy Statement (“Statement”), the terms “we”, “us”, and “our” mean KeyBank National Association and its affiliates, agents, guaranty insurers, investors, assigns, and successors in interest.
This Statement only applies when you visit the Laurel Road website (www.laurelroad.com) and any associated websites, products, services, online platforms, or mobile applications (collectively, the “Site”). By using the Site, you are accepting the terms of this Statement and you are consenting to our collection, use, disclosure and protection of your information as described in this Statement.
We are committed to maintaining the privacy and security of personal information submitted by visitors of the Site. This Statement explains how this Site collects, uses, and shares information. Other Key policies, such as the KeyCorp Privacy Notice, may also apply when visiting the Site.
We use trusted third-party content and service providers to enhance our customers’ online experiences. The enhancements offered to you by these service providers and third-party websites may include surveys, advertisements, online calculators, forms, and other online tools and applications. As such, we may provide links to websites neither owned nor operated by us. This Statement does not apply to the online practices of these third-party websites.
Information We Collect
When you visit our Site, we collect information about your online session, as well as any information that you provide to us during your session, such as when you log in or fill out an application for a product or service.
The following table describes the categories of personal information we collect online and via our other interactions with you, as well as the business purpose for collecting each category of personal information.
|Information Collected||Business Purpose|
|Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers||
|Characteristics of protected classifications under California or federal law||
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||
|Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement||
|Audio, electronic, visual, thermal, or similar information||
|Professional or employment-related information||
|Inferences drawn from any of the above information to determine consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||
How We Collect Information
We or our service providers collect information in several ways. Information is collected when you provide it to us as well as through “cookies” and other tracking methods. Cookies are small amounts of data stored by your web browser that provide a web site with information such as the time of your last site visit and the pages you viewed.
Your IP address is an identifying number that is automatically assigned to your computer by your ISP. This number is identified and logged whenever you visit the Site.
If you are a customer or have applied for a product or service with us, we may also obtain your information from credit reporting agencies or other service providers, in order to verify the information you have submitted.
We also collect prospective customer contact information from marketing partners, credit reporting agencies, and referrals from business partners and customers.
Other Ways Information Is Collected
- Online Surveys and Forms
Information you provide while completing surveys and forms on the Site may also be collected and stored. Unless otherwise stated, this information is used to help us develop a superior Web experience and enhance products and services.
- Email and Online Chat
Information sent via email or Laurel Road’s Online Chat functionality may be retained in order to respond to your requests or inquiries and for quality assurance purposes.
- Online Behavioral/ Interest-Based Advertising
To learn more about this type of advertising, including how to opt out of certain types of online advertisements, please visit the Network Advertising Initiative’s website at www.networkadvertising.org.
- Google Analytics
We have implemented several Google Analytics for Display Advertisers Features, including:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Platform Integrations and/or
- Google Analytics Demographics and Interest Reporting
These features are used to understand how our advertising performs and to improve our marketing efforts and the Websites. For example, we use Google Remarketing and/or DoubleClick to advertise our products and services. Third- party vendors, including Google, show our ads on sites across the Internet.
We and third-party vendors, including Google, use first-party Google Analytics cookies and third-party DoubleClick cookies together to serve advertisements that may be of interest to you based on your past visits to the Website. For more information on how Google Analytics collects and processes data, please see http://www.google.com/intl/en/policies/technologies/ads/.
We will not use these features to track, collect or upload any data that personally identifies an individual (such as a name, email address or billing information), or other data which can be reasonably linked to such information by Google.
You Can Opt Out of Google Analytics for Display Advertisers Features By:
- Changing your settings at Google’s Ad Settings (http://www.google.com/settings/ads)
- Installing an Opt-Out browser add-on available at https://tools.google.com/dlpage/gaoptout/
- Adjusting the settings on your web browser (See http://www.google.com/intl/en/policies/technologies/managing)
- Social Media
How We Share Information
The personal information described in the “Information We Collect” section above may be shared with third parties for our business purposes and to comply with applicable law. These third parties may include: marketing partners and service providers, data analytics providers, consultants and advisors, technology service providers, and government agencies as required or permitted by law. We disclose this information for business purposes including to provide you with information regarding our products and services; for analytics purposes; to our service providers to support our operations; and to maintain compliance with applicable laws and regulations.
Please see the KeyCorp Privacy Notice to learn more about how information may be shared by us and how you may limit certain types of sharing.
Please note, we do not sell personal information as that term is defined under the California Consumer Privacy Act.
How We Safeguard Information
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption and firewalls. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.
How You Can Manage Information Collected
Keeping your account information accurate and up to date is important. If your account information is incomplete, inaccurate or not current, please update your information through the Site or call Laurel Road’s customer contact center at 855-245-0989
You can also limit how we share your information (as outlined in the KeyCorp Privacy Notice) and adjust your solicitation preferences by calling Key’s Privacy Line at 1-800-361-0968.
California Consumer Privacy Act (CCPA) Requests
If you are a California resident, the CCPA allows you to request information about the data we collect and use about you, including:
- The categories of personal information we have collected about you;
- The categories of sources from which your personal information is collected;
- The business or commercial purpose for collecting your personal information;
- The categories of personal information we have disclosed about you for a business purpose;
- The categories of third parties with whom we share personal information; and
- The specific pieces of personal information we have collected about you.
If you are a California resident and wish to make a request for the above information, please visit our CCPA request page. You may authorize another individual to submit this request on your behalf.
To submit this request, you must submit your:
- Last 4 digits of SSN.;
- An email address, if you wish to receive a response via email.
Once your request is submitted, we will conduct a search of our systems and provide you with a response within 45 days.
California prohibits businesses from discriminating against you for exercising any rights under the CCPA, including, but not limited to, by:
- Denying you goods or services;
- Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level or quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, you may be charged a different price or rate, or provided a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your data. Businesses may offer financial incentives to you, including payments as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information.
California Data Deletion Requests
If you are a California resident, you have the right to request that we delete personal information we hold about you. To submit a deletion request, please visit our CCPA request page. You may authorize another individual to submit this request on your behalf. Please note, however, that there are many instances in which we are required to maintain, or otherwise are not required to delete, your personal information. For example, we are not required to delete your information if it is being used:
- To complete a transaction or provide a good or service requested by you;
- To detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity;
- To enable solely internal uses based on your relationship with us, such as a Do Not Solicit request;
- To comply with a legal obligation, such as federal recordkeeping requirements; or
- Internally, in a lawful manner that is compatible with the context in which the you provided the information.
“Do Not Track” Requests
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals, but we do provide you the option to opt out of Google advertising features, as noted above.
This Site is not directed to individuals under the age of thirteen and does not knowingly collect information from these individuals. We request that those under the age of thirteen do not provide information through our Site. You can learn more about the Children’s Online Privacy Protection Act (COPPA) at the Federal Trade Commission’s website.
Changes to this Statement
This Statement is subject to change from time to time. When changes are made, we will communicate these changes to you by posting the revised Statement on this page and adjust the “Last Updated” date. Any changes to this Statement will become effective on the date of posting unless indicated otherwise.
Last Updated: January 1, 2020