CERTAIN DISCLOSURES REGARDING LEAD GENERATION
These disclosures are made to you by Round Sky, Inc., a Nevada corporation (“we” or “us”). Although you are applying for a loan through a website maintained by us (or a website maintained by a third-party lead seller), we are not a lender. The following disclosures describe how we operate and will process your loan request.
- We have a network of lead generators from which we buy leads and a separate network of purchasers to whom we sell leads. Lead generators do not know the identities of the lead purchasers in our network or details about the terms of the credit products offered to consumers, and the lead purchasers do not know the identities of the lead generators or the methods they use to attract consumers.
- Lead generators operate websites that advertise loans and through which consumers submit loan applications. Lead generators sell the applications to us, and we sell the applications to lead purchasers. The purchasers are online payday and installment lenders, as well as, in certain instances, data managers, data brokers, and remarketing companies. (Data managers are intermediaries for lenders that outsource their lead-purchasing activities, and data brokers are lead aggregators that have their own networks of lead purchasers to which they sell leads after they purchase them from us.) We do not know the end purchasers of the leads we sell to data managers or data brokers. Remarketing companies buy consumer information to send marketing materials to consumers for products other than the loans for which the consumers applied.
- To filter leads to lead purchasers, we use a “ping tree,” which sets the order in which lead purchasers have the option to purchase a given lead from us. The position of each purchaser in the ping tree is determined primarily by the price the purchaser is willing to pay for a lead; the higher the price, the better the purchaser’s position in the ping tree.
- A consumer who submits a loan application on a lead generator’s webpage is nearly immediately redirected from that page to a lender’s webpage. This automated process takes just seconds, and the consumer is not informed that the loan application has been sold to us or sold by us to a lead purchaser.
- Before we “on-board” a prospective lead generator into our network, the company performs an introductory review of the lead generator’s website to check for misleading or inaccurate statements to consumers. After we “on-board” a lead generator, we have an automated tool called “web crawler” in place to monitor lead generator websites daily or weekly for misleading or inaccurate statements. But no technology is perfect, and lead generators can change their websites without any notice to us.
- Despite our initial investigations and ongoing automated monitoring, we may purchase leads from lead generators whose websites include misrepresentations that are likely to mislead consumers into believing that lenders in our network have been evaluated and meet certain standards. Some lead generators have incorrectly represented that they themselves were lenders. Lead generators sometimes also falsely suggest that they help consumers find the best rates or lowest fees or that they review consumers’ applications to match them with appropriate lenders.
- Our lead generators typically do not provide loans directly to consumers, do not select the lenders that will see a consumer’s application, and have no involvement in or knowledge of the terms of the loan a consumer receives after we sell the lead. Lead generators do nothing more than forward applications to us.
- We do not know the loan terms that consumers will be offered by lead purchasers, and we make no attempt to match consumers with the best loan for their needs, as consumers may be led to believe by lead generators. Once we sell the lead, we do not know whether a loan is actually made, or whether the consumer accepts or rejects the lender’s terms.
- We do not require data managers or data brokers to disclose the ultimate purchasers of our leads. We therefore do not know the identity of all lenders that obtain consumer applications through our lead-purchaser network.
- We perform only limited initial screening of the lead purchasers in our network for compliance with applicable laws. We do not perform any ongoing compliance monitoring.
- Lead purchasers provide regular feedback to us regarding the quality of our leads, including the number of leads that convert to loans and reasons why leads did not convert. We use this information to refine our lead processing to optimize lead conversion.
- Some of our lenders are entities organized by Indian tribes, known as tribal lenders, or organized under the laws of foreign jurisdictions, known as offshore lenders. These lenders typically claim immunity from state regulation, do not comply with the laws of the states where the consumers to whom they make loans are located, and do not concede that they are subject to jurisdiction in a forum convenient to the consumer.
- Tribal lenders and offshore lenders typically charge higher interest rates than lenders adhering to state laws. Because they charge higher interest rates, these lenders generally are willing to pay more for leads and thus rank at the top of our ping tree.
- Many of the tribal lenders among our purchasers offer contracts providing for the application of tribal law to the contract and providing an exclusive tribal dispute-resolution process.
- If you are seeking a particular form of credit for which you do not qualify, you may receive solicitations for a form of credit that you are not seeking. The terms of the credit offered may be inferior to those you were originally seeking. You do not have to accept or respond to these solicitations.
- We may sell your email address to third parties who will use your address to solicit you for goods and services for which you have not applied or which you have not otherwise sought. You do not have to accept or reply to these solicitations.
- Parties to whom we sell leads, including data mananagers and brokers, regularly combine the information provided by you with information available about you from other sources, such as public records and credit bureaus, for the purpose of offering you goods and services. Some of these goods and services may be other than those for which you have applied. You do not have to accept or reply to these offers.