Peer4Peer Privacy Policy
App: Peer4Peer (Android package `com.peer4peer.app`, iOS bundle `com.peer4peer.app`)
Developer / Data Controller: Peer4Peer Lending, LLC, a Pennsylvania, United States limited liability company
Developer email on Google Play: support@peer4peerloans.com
Effective date: October 9, 2026
Peer4Peer Lending, LLC ("Peer4Peer", "we", "us", or "our") operates the Peer4Peer mobile application and related services (collectively, the "Service"). Peer4Peer is a friends-and-family / community micro-lending network that lets individuals in the United States make small-dollar loans to one another. APRs are capped at each borrower's state-specific small-loan statutory maximum; states without a statutory cap use a 35% APR cap, and no loan ever exceeds 35% APR. Pennsylvania borrowers see the strictest cap at 6.0% APR under the Pennsylvania Loan Interest and Protection Act (41 P.S. § 201).
This Privacy Policy explains what information we collect, how we use it, how we share it, how long we keep it, how we protect it, and the choices you have. By creating an account you confirm that you are at least 18 years old and that you have read this Privacy Policy.
1. Who we are (developer identity)
- Legal entity / developer name: Peer4Peer Lending, LLC
- App on Google Play: Peer4Peer (`com.peer4peer.app`)
- Developer account on Google Play: matches the entity above
- Jurisdiction: Pennsylvania, United States
- Business purpose: operate a non-depository friends-and-family micro-lending marketplace. We do not lend our own money, we do not collect interest, and we are not a bank. We facilitate loans between individuals who know each other or who choose to transact through our community network.
- General contact: support@peer4peerloans.com
- Privacy / Data-Protection contact (privacy point of contact): support@peer4peerloans.com with subject line `Privacy inquiry` — we respond within one business day.
2. Information We Collect (comprehensive data disclosure)
Every category below is a complete list of what Peer4Peer may collect from or about you.
2.1 Information you provide directly
- Account information: full legal name, date of birth, email address, mailing address (street + city + state + ZIP), US state of residence (2-letter code — drives your APR cap), and a password.
- Identity verification (KYC): the last four digits of your Social Security Number ("SSN") and, where required, your full nine-digit SSN. Full SSNs are immediately hashed with HMAC-SHA256 using a secret pepper and are never stored in plain text. Only the last four digits are retained in readable form so we can confirm your identity.
- Government-issued ID photos and selfie: during Know-Your-Customer verification you upload a photo of your government-issued ID and a selfie. These images are stored in encrypted object storage and are reviewed only by our compliance staff.
- Role preference: whether you signed up as a borrower or a lender; locked once your first loan is active.
- Financial information: a connected bank account (via Plaid) and a debit card (via Stripe). We never see or store your bank login credentials or full debit-card number; those are held by Plaid and Stripe respectively, who provide us with tokenized identifiers (plus the bank/card last four digits for display).
- Loan activity: loan requests you create, offers you make or accept, repayments, late fees, borrower / lender messages, tipping choices, and support messages.
- User-generated content: profile display name, support-ticket text, legal-review document requests, and user reports you file against another user.
- Beta-tester feedback: when you tap "Beta feedback" we collect the message you type, an optional star rating, the device model, operating system, platform, and app version.
2.2 Information collected automatically
- Device and sign-in information: IP address, device user-agent, and the approximate time of each sign-in. This information powers the "new device" email alert and lockout protection.
- In-app activity logs: records of important actions (sign-ins, loan status changes, payouts, admin overrides, state overrides) used for security, auditing, and compliance.
- Push-notification tokens (optional): if you enable push notifications we store the Expo / FCM / APNs device token so we can send you reminders.
2.3 Information from third parties
- Plaid, Inc. — when you link your bank, Plaid shares a short-lived public token with us; we exchange it for an access token used only to verify ownership of the account you connected. We also receive the bank name, account last 4, and account subtype (checking / savings).
- Stripe, Inc. — when you add a card, Stripe shares a tokenized card identifier and the last four digits so we can display the card in the app.
- Resend (transactional-email provider) — delivery metadata (sent, delivered, bounced) for messages we send you.
- Emergent Platform (hosted managed services) — our infrastructure provider for push notifications, object storage, and email relay. All data remains under our control; the provider acts only as a processor.
2.4 What we do NOT collect
We do not collect precise or coarse device location, device Advertising ID, call logs, SMS messages, contacts, calendar entries, health or fitness data, browser history, or microphone audio. We do not use any advertising, analytics, or tracking SDK, and we do not display ads.
3. How We Use Your Information
We use your information to:
- Create and secure your account, including fraud prevention and session management.
- Verify your identity and (for lenders) satisfy applicable tax-reporting obligations.
- Facilitate loan requests, offers, funding, repayment, late-fee collection, and dispute resolution between you and the counter-party.
- Compute your on-time payment streak, badge status, and in-app credit score.
- Apply the correct APR cap for your US state of residence.
- Send transactional and service emails (sign-in alerts, loan status, support replies, monthly summaries you request).
- Issue and populate tax forms (e.g., 1099-INT for lenders) in accordance with U.S. tax law.
- Monitor the Service for abuse, debug issues reported through beta feedback, and improve the Service.
Pseudonymization. Inside the marketplace and in notifications sent to borrowers or lenders, we display an anonymous Peer ID (format `PEER-########`) instead of your real name. Only you, the counter-party on a specific loan, and Peer4Peer administrators can see your real name.
4. How We Share Your Information (third parties)
We share information only in these limited situations:
- With the counter-party of a loan: the borrower and the funding lender see each other's Peer ID, rating, in-app credit score, and the loan details necessary to transact. Real names are shared peer-to-peer only after a loan is funded, as required for legal recourse.
- With service providers acting on our behalf (processors, not controllers; each bound by a data-processing agreement):
- Plaid, Inc. — bank-account linking and ownership verification (US)
- Stripe, Inc. — debit-card tokenisation and payment processing (US)
- MongoDB Atlas — encrypted database hosting (US region)
- Resend — transactional email delivery
- Emergent Platform — managed infrastructure (object storage for KYC images, push-notification relay, email relay). All data remains under our control.
- For legal and safety reasons: in response to lawful requests from governmental authorities, to protect our rights or those of users, to prevent fraud, or to comply with applicable law (including anti-money-laundering and consumer-lending obligations).
- In a business transaction: if Peer4Peer Lending, LLC is acquired, merged, or sells assets, your information may transfer to the successor entity, subject to this Policy.
We do not sell your personal information. We do not share your data with advertisers. We do not use third-party analytics.
5. Loan terms, fees, and lender interest cap (Google Play disclosure)
The following loan terms are set by Peer4Peer Lending, LLC and apply to every loan originated through Peer4Peer:
| Item | Value |
|---|
| Countries available | United States only (operations centered in Pennsylvania) |
| Minimum loan amount | $50 |
| Maximum loan amount (Basic tier) | $500 |
| Maximum loan amount (Plus tier, $10/month) | $5,000 |
| Minimum repayment term | 7 days |
| Maximum repayment term (Basic) | 30 days |
| Maximum repayment term (Plus) | 60 days |
| Maximum repayment term (5-installment plan) | 35 days (5 weekly payments) |
| Maximum APR charged to borrowers | your US-state statutory small-loan APR limit; 35% in states with no cap; never above 35% (Pennsylvania applies the strictest at 6% under 41 P.S. § 201) |
| Platform service fee (not interest) | 4.0% of loan amount, paid by the borrower to Peer4Peer Lending, LLC with the borrower's final repayment (the borrower receives the full loan amount) |
| Plus membership (optional) | $10 per month, cancel anytime |
| Late fee | $5 flat per installment paid more than 24 hours after its due date |
Representative example — Pennsylvania (strictest cap). A borrower in Pennsylvania requests $500 for 30 days. Interest at 6.0% APR, pro-rated for 30 days = $500 × 0.06 × (30 / 365) = $2.47 (paid to the lender). Platform service fee = 4% × $500 = $20.00, paid by the borrower to Peer4Peer Lending, LLC with the final payment. The borrower receives the full $500.00. Total repaid at the end of the term = $522.47 ($502.47 to the lender + $20.00 fee).
Representative example — states with no small-loan cap (35% APR). A borrower in a state without a statutory small-loan rate cap requests $500 for 30 days. Interest at 35% APR, pro-rated for 30 days = $500 × 0.35 × (30 / 365) = $8.22 (paid to the lender). Platform service fee = $20.00, paid by the borrower with the final payment (borrower receives the full $500.00). Total repaid at the end of the term = $528.22 ($508.22 to the lender + $20.00 fee).
We never exceed your state's statutory small-loan APR cap, and no loan ever exceeds 35% APR. We do not offer short-term, high-APR "payday" style loans.
6. How We Protect Your Information (secure data handling)
- In transit: all API traffic between the app and our servers is encrypted using TLS 1.2 or higher. Public legal and marketing endpoints additionally send `Strict-Transport-Security` and `X-Content-Type-Options: nosniff` headers.
- At rest:
- Full SSNs are stored only as HMAC-SHA256 hashes keyed with a secret pepper that lives outside the database. The nine-digit SSN itself is never written to disk in plain text.
- Passwords are hashed with bcrypt (cost factor ≥ 12).
- KYC ID photos and selfies are stored in encrypted object storage with per-object access tokens that expire; direct public URLs are never issued.
- Payment tokens from Stripe and Plaid are stored encrypted; raw card numbers and bank credentials never touch our systems.
- Access controls: administrator endpoints require an `is_admin=true` role and all admin actions are audit-logged with the actor's user ID. Non-admin requests return HTTP 403.
- Session security: session tokens are signed JWTs with a revocation list. Every password change, password reset, and "sign out everywhere" action immediately invalidates all prior tokens.
- Email HTML is server-escaped to prevent injection; links in verification emails are tokenised and single-use.
- Balance mutations use atomic conditional writes to prevent race-based double-spend / overdraft.
- Dependency hygiene: we track upstream security advisories for Plaid, Stripe, FastAPI, and Expo SDKs and patch within one business day of a critical disclosure.
- No public analytics or crash SDKs: we do not route user data to any third-party analytics, crash-reporting, or advertising platform.
No system is perfectly secure. If you believe your account has been compromised, please contact us immediately at support@peer4peerloans.com.
7. Data Retention and Deletion
- Account data (name, DOB, address, state, email, phone, SSN hash + last 4): retained while your account is active and for up to seven (7) years after closure, to satisfy U.S. consumer-finance recordkeeping and tax obligations.
- Government-ID photos and selfies (KYC): deleted from object storage within twenty-four (24) hours of a verified deletion request, or earlier if your identity has already been confirmed and no open loan remains.
- Loan activity (amount, dates, status, repayment schedule): retained for the duration required by applicable tax and lending laws (typically seven years).
- Beta-feedback messages and support tickets: retained up to two (2) years, or until you request deletion.
- Device sign-in logs: retained up to twelve (12) months.
- Push-notification tokens: deleted immediately when you disable notifications or close the account.
- Session tokens: revoked immediately when you sign out, change your password, or request account deletion.
7a. How to delete your data
You can delete your Peer4Peer account and personal data at any time, in any of three ways:
1. In-app: open Peer4Peer → Profile → scroll to the bottom → tap Delete my account. Deletion is initiated immediately.
2. Public web page (no app required): visit `/api/legal/account-deletion` on our domain, fill the short form, and we will delete your data within 30 days.
3. Email: send a message to support@peer4peerloans.com from the email address on your account with subject `Account deletion request`.
A description of exactly what is deleted and what we must retain to satisfy federal and state financial-services recordkeeping rules is listed on the public deletion page.
8. Your Privacy Rights
Depending on where you live, you may have the following rights under laws such as the California Consumer Privacy Act (CCPA / CPRA), the Virginia / Colorado / Utah / Connecticut consumer-privacy acts, or the EU/UK General Data Protection Regulation (GDPR):
- Access: request a copy of the personal information we hold about you.
- Correction: ask us to correct inaccurate information (certain fields such as date of birth, SSN, and locked state of residence can only be changed through our support team).
- Deletion: ask us to delete your account and personal information, subject to our legal obligations to retain certain data (e.g., completed loan transactions and tax records). See Section 7a for the three ways to request deletion.
- Portability: request a machine-readable export of your data (name, loan history, KYC status, settings).
- Opt-out of marketing: Peer4Peer does not currently send marketing emails. You can disable transactional notifications in-app under Profile → Notification settings.
- Opt-out of sale / sharing: we do not sell or share personal information for cross-context behavioural advertising.
- Non-discrimination: we will not discriminate against you for exercising any of these rights.
- Appeal: if we deny a privacy request you can appeal by replying to our response within 30 days; we will escalate the appeal to our Data Protection Officer.
To exercise any of these rights, email us at support@peer4peerloans.com from the address on your account with the subject line `Privacy request — [access | correction | deletion | portability | appeal]`. We respond to verifiable requests within 30 days.
9. Children's Privacy
Peer4Peer is intended for adults. We do not knowingly collect information from anyone under 18. If you believe a child has given us personal information, contact us and we will promptly delete it.
10. Permissions and data your device may share
Peer4Peer may request the following device-level permissions. Each is used only for the purpose described below; nothing is used for advertising or shared with third parties beyond what Section 4 describes.
- Internet / network state: required to connect to our backend and process loans.
- Camera: required to take a photo of your government-issued ID and a selfie during Know-Your-Customer identity verification. Peer4Peer displays a prominent in-app disclosure before requesting the OS permission. The resulting images are stored in encrypted object storage and reviewed only by our compliance team.
- Notifications (optional): used to send you reminders about upcoming installments, sign-in alerts, and loan status updates. You can disable notifications any time.
- Push-token delivery (Expo / FCM / APNs): when you enable notifications we store an opaque device token so our servers can route messages. The token is deleted immediately when you disable notifications or close your account.
We do not request access to: precise or coarse location, SMS messages, contacts, call logs, calendar, microphone, media library / gallery, Advertising ID, or health/fitness data. The Android manifest also explicitly blocks `READ_MEDIA_IMAGES`, `READ_MEDIA_VIDEO`, and `com.google.android.gms.permission.AD_ID` so these permissions cannot be injected by any third-party library.
11. International Users
Peer4Peer is operated from the United States and is intended for U.S. residents, primarily in Pennsylvania. If you access the Service from outside the United States, you consent to the transfer, processing, and storage of your information in the United States, which may have data-protection laws different from your country.
12. Changes to This Policy
We may update this Policy from time to time. If we make material changes we will notify you by email and update the "Effective date" above. Continued use of the Service after the effective date constitutes acceptance of the revised Policy.
13. Contact (privacy point of contact)
For any question about this Privacy Policy, to exercise a privacy right, or to escalate a privacy concern, contact:
- Developer / Data Controller: Peer4Peer Lending, LLC
- Privacy email (preferred): support@peer4peerloans.com — please use the subject line `Privacy inquiry` or `Privacy request`
- General support: support@peer4peerloans.com
- Mailing address: available on written request to the email above
- Jurisdiction: Pennsylvania, United States
- Response time: we acknowledge every privacy inquiry within one business day and resolve verifiable requests within 30 days
This Privacy Policy is published at `/api/legal/privacy-policy` on our domain and is also linked inside the Peer4Peer app under Profile → Privacy policy.