Defined terms used in this Policy
- References to the “Vaya Capital Program” mean a program operated by Vaya that makes short-term loans to businesses for commercial or business purposes only.
- References to “Vaya”, “our”, “we” or “us” mean Vaya Technologies Inc.
- References to “you” mean each business providing information through the Application for Vaya’s use in underwriting and otherwise considering that business’s participation in the Vaya Capital Program, regardless of whether or not the business participates in the Vaya Capital Program. A business can be either an entity or an individual who is a sole proprietor.
- References to “Participating Lender” mean any third party directly or indirectly providing funds for extensions of credit under the Vaya Capital Program.
- References to “Platform” mean the online service or platform in connection with which you are considered for a potential offer of credit under the Vaya Capital Program.
- References to “Information” mean the data elements listed in this Policy under “Information that we collect” that are collected by Vaya from you through the Application in the course of underwriting, making, administering and collecting extensions of credit under the Vaya Capital Program. Information does not include data elements provided directly to Vaya by a third party, including the Platform.
- References to the “Application” mean a web-based application through which Vaya collects information for and administers the Vaya Capital Program.
Purpose and application of this policy
Vaya is committed to maintaining the privacy and security of your information. As part of that commitment, we have adopted this Policy to inform you of our information collection practices and the ways in which we may use the information we receive. This Policy applies to all Information collected by Vaya. By using the Application, including providing your Information to us through the Application, you consent to the collection, use, processing, disclosure and transfer of your Information in accordance with this Policy.
Information that we collect
Information collected by Vaya consists of the following data elements:
- Names of individuals
- Telephone numbers of individuals
- E-mail addresses of individuals
- Residential addresses of individuals
- Birth dates of individuals
- Social Security Numbers or Individual Tax Identification Numbers of individuals
- Platform user names of individuals
- Business name
- Business telephone number
- Business e-mail address
- Business street address
- Employer Tax Identification Number
- Business bank account number, name, routing number, and bank name
How we use your Information
We will use your Information to comply with governmental “Know Your Customer” requirements; to underwrite loan offers under the Vaya Capital Program; to make loans to you under the Vaya Capital Program and to administer those loans; and to collect repayment of amounts due from you under the Vaya Capital Program. To the extent necessary to perform those activities, we will disclose your Information to third parties, such as a service provider assisting with underwriting and risk assessment, or a financial institution originating an ACH debit to your bank account for repayment of a loan made under the Vaya Capital Program, or a third party assisting in the collection of a past-due amount.
We will also use your Information to analyze, and prepare materials regarding, operational aspects and results of the Vaya Capital Program, such as utilization, procedural efficiencies and potential improvements, the amount of any loan losses, and profitability. We may provide your Information to third-party services and applications in the course of conducting such analyses and preparing such materials. We will use the results of those analyses and materials for our internal corporate purposes. We may share the results of those analyses and materials with the Platform in a manner in which your Information is separately identifiable. To the extent we share the results of those analyses and materials with a third party other than the Platform, we will provide them in a manner that your Information is not separately identifiable.
In addition, we will disclose your Information when you have given us permission to do so, and without your permission when we believe in good faith that disclosure is required by law or is necessary to investigate and protect against activity that is harmful to us, our customers, or third parties with which we do business. If Vaya is involved in a business combination with, or a transfer of a substantial portion of its assets to, another business, your Information may be included in the Vaya assets acquired by that business.
Vaya will not use, disclose or transfer your Information except as described in the preceding paragraphs.
Protection of your Information
Vaya will take reasonable precautions to protect your Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, we can not guarantee the security of your Information and our measures may not be sufficient to achieve such protection. It is important for the protection of your Information that you also take precautions to guard against the unauthorized use of your credentials to access the Application and the unauthorized use of your computer.
Retention of your Information
We will retain your Information as received for five years after we collect it to comply with regulatory requirements. Thereafter, we will delete those elements of your Information by which you are identifiable and we will retain your Information in a de-identified form for an additional period of time determined at our sole discretion. Vaya retains the right to dispose of your de-identified Information at any time. You agree that Vaya has no duty or obligation to provide you with copies of or access to your Information except as provided by statute or regulation.
Amendment of this policy
We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy by posting such change, update, or modification at www.vaya.finance. Any such change, update, or modification will be effective immediately upon such posting. The date in this section will be updated whenever this Policy is changed. You agree that we may notify you about material changes in the way we treat Information by e-mail or any other notification method we consider to be reasonable.