Privacy Policy

Effective as of 1st of September 2021

This “Privacy Policy” describes the privacy practices of [Eagle Data, Inc.] and our subsidiaries and affiliates (collectively, “Eagle Data”, “we”, “us”, or “our”) in connection with the [www.eagledata.biz] website, the matching service we offer and any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”). The Eagle Data Service allows lenders and website publishers to improve their eligibility matching for offers to consumers. Eagle Data does not directly interact with consumers (unless you visit our website). Eagle Data may provide additional or supplemental privacy policies to individuals for specific products or services. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

Table of Contents

Information We Collect

Generally, we collect data from three types of people and entities: (1) our publishing partners and their authorized users (e.g., those website publishers that enter into an agreement with us to exchange data with us to allow them to make lending offers to consumers (our “Publishing Partners”)); (2) our lending partners and their authorized users (e.g., lenders and other card issuers who have entered into an agreement with us to better target digital offers to consumers through a publishing partner (our “Lending Partners”)); and (3) consumers (in the limited manner described below). When we use the term “you” or “your” in this Privacy Policy, we are referring to our Publishing Partners, Lending Partners and consumers (unless we state otherwise). When we use the term “business partners” we mean just our Publishing Partners and our Lending Partners. Information you provide to us. For our Publishing Partners and Lending Partners, we collect personal information you provide to us through the Service, including:

Information we obtain from social media platforms

We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from other third parties

We may receive personal information about you (including consumers) from third-party sources, such as marketing partners, publicly-available sources and data providers.

Consumer Information from Publishing Partners

Our Publishing Partners send us anonymized information and additional information consumers may enter on the publisher website (e.g. income, employment status, etc.). We ask that our Publishing Partners do not send us any personally identifiable information and we do not intentionally collect any personally identifiable information from consumers. We merge the anonymized consumer information sent to us by a Publishing Partner with criteria provided to us by our Lending Partners to match offers available from our Lending Partners to consumers profiles (without sharing any personally identifiable information with those Lending Partners or with the Publishing Partners). We do not sell any personal information; we simply match incoming offers from our Lending Partners with the criteria provided from those Lending Partners and pass back available offers for that consumer to our Publishing Partners.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications. On our webpages, this information is collected using cookies and similar technologies. Our Publishing Partners also may have our web beacons on their sites in order to facilitate the matching our Service provides for our Lending Partners. See our Cookie Policy for more information.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection: To operate the Service. For our Publisher Partners and Lending Partners, we use your personal information to:

For research and development

We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying business partner user demographics and use of the Service.

To send you marketing and promotional communications

We may send you Eagle Data-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent

In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data

We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data to analyze and improve the Service. We also use anonymous, aggregated or de-identified consumer data to provide the Services to our Lending Partners and our Publishing Partners (e.g., we use de-identified consumer data to match Lending Partner Offers with profiles and then pass those offers to the Publishing Partners to be presented to the consumer).

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliates

We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers

We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety

We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Sharing of Consumer Information

We may sometimes share a consumer’s de-identified information with Lending Partners in order to match Lending Partner Offers with consumer profiles and present the Offers that match the Lending Partner Criteria to the consumer through the Publishing Partner. However, typically, we do not even share de-identified information with the Lending Partner.

Please note, that our Publishing Partners may otherwise separately collect information from consumers and such collections are not subject to this Privacy Policy.

Your Choices

Access or Update Your Information

If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage

We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. For more details, see our Cookie Policy.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Other Sites and Services

Our Publishing Partners may otherwise separately collect information from consumers and such collections are not subject to this Privacy Policy. In addition, our content may be included on web pages or online services of our Publishing Partners. We do not control our Publishing Partner’s websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to [email protected]. You may also write to us via postal mail at:

Eagle Data
Attn: Legal – Privacy
71 South Deeplands Grosse Pointe Shores, MI 48236

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at [email protected]. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

How to Exercise Your Rights

You may exercise your California privacy rights described above as follows:

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal Information That We Collect, Use and Share

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.

Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

We have not sold your personal information in the preceding 12 months.

Category of personal information (PI) (click for details) Collected from: PI we collect Source of PI Business/commercial purpose for collection Categories of third parties to whom we “disclose” PI for a business purpose
Identifiers
  • Publishing Partner Users
  • Lending Partner Users
  • Contact data
  • Identity data
  • Data about others
  • You
  • Public sources
  • Business partners
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
Commercial Information
  • Publishing Partner Users
  • Lending Partner Users
  • Contact data
  • Identity data
  • Transaction data
  • Communications
  • Marketing data
  • You
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
Online Identifiers
  • Publishing Partner Users
  • Lending Partner Users
  • Consumers
  • Device data
  • Identity data
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
Internet or Network Information
  • Publishing Partner Users
  • Lending Partner Users
  • Consumers
  • Device data
  • Online activity data
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
Geolocation Data
  • Publishing Partner Users
  • Lending Partner Users
  • Consumers
  • Device data
  • Automatic collection
  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Professional advisors
  • Authorities and others
  • Business transferees
Inferences
  • Publishing Partner Users
  • Lending Partner Users
  • Consumers
 May be derived from your:
  • Device data
  • Online activity data
Professional or Employment Information
Protected Classification Characteristics

Glossary

Statutory category Definition (categories may overlap)
Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education Information Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Inferences The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Internet or Network Information Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
Professional or Employment Information This term is not defined in the CCPA, but likely includes any information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations).
Protected Classification Characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
 

This Cookie Policy explains how [Eagle Data, Inc.] (“Eagle Data”, “we”, “us” or “our”) uses cookies and similar technologies in connection with the www.eagledata.biz website and any other website that we own or control and which posts or links to this Cookie Policy (collectively, the “Sites”).

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.

Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.

What types of cookies and similar tracking technologies does Eagle Data use on the Sites?

On the Sites, we use cookies and other tracking technologies in the following categories described in the table below.

Type Description Who serves the cookies (link to privacy policy/site) How to control them
Analytics These cookies help us understand how our Service is performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients. Google Analytics

Mixpanel 		See ‘your choices’ below.

Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here.
Essential These cookies are necessary to allow the technical operation of our Service (e.g., they enable you to move around on a website and to use its features). Google Tag Manager See ‘your choices’ below.
Functionality/performance These cookies enhance the performance and functionality of our Service. Intercom See ‘your choices’ below.

Other technologies

In addition to cookies, our Sites may use other technologies, such as pixel tags to collect information automatically.

Browser Web Storage

We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.

Web Beacons

We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and those of our Publishing Partners and in our HTML formatted emails to track the actions of users on our Sites, advertisements and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails, advertisements and to compile statistics about usage of the Sites, so that we can manage our content more effectively.

Where information collected through web beacons, buttons, and similar technologies is collected directly by third parties, their collection and use of information is subject to that third party’s own privacy policies. Some of these third parties are members of the Network Advertising Initiative or the Digital Advertising Alliance and participate in the industry’s opt out, available at http://optout.aboutads.info/#!/ or at http://optout.networkadvertising.org/#!/. Additionally, you may opt out of the use of Google Analytics Cookies here: https://tools.google.com/dlpage/gaoptout.

Due to differences between using websites and apps on mobile devices, you may need to take additional steps to opt out on both platforms. Many mobile devices allow you to opt out of interest-based advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our app using the standard uninstall process available on your mobile device or app marketplace. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out.

Your choices

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.

For more information about how we collect, use and share your information, see our Privacy Policy.

Changes

Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.

Questions

If you have any questions about this Cookie Policy, please contact us by email at [email protected].

 

Last modified 1st of September 2021.