Last Updated: October 1st, 2022
We provide important information for California residents below, within the “Important Information for California Residences” section.
- Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies: Cookies are small pieces of data stored on a User’s device.
- Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject: Data Subject is any living individual who is the subject of Personal Data.
- User: The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Personal Information We Collect
Personal information you provide to us. Personal information you may provide to us when you use the Service or otherwise includes:
- Contact data, such as your first and last name, email address, street address (including zip code), and phone number.
Other sources. We may combine personal information we receive from you with personal information we obtain from other sources, including but not limited to:
- Data providers, such as credit bureaus and information services.
- Public sources, such as public social media platforms.
- Business partners, such as lenders, loan aggregators, and insurance companies.
Automatic Collection. We, our service providers and our third-party partners may automatically log information about you, your computer or mobile device, and your activity over time on the Service and other online services, including:
- Online activity data, such as the date and time of your access, visit, or use of the Service, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, searches you conduct on our site, and information about your activity on a page or screen.
- Device data, such as unique device identifier, media access control address, network information, hardware model, browser type, screen resolution, IP address as well as usage and traffic data and information about how the device interacts with the Service.
Cookies and Similar Technologies. The following cookies and similar technologies may be used to facilitate automatic data collection:
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of tracking user activity and patterns, helping you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience.
How We Use Your Personal Information
Service delivery. We may use your personal information to:
- To provide, deliver, and customize your use of the Service;
connect you with other advertisers or affiliates to send you Service related information or other Services that may be of interest to you.
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you site related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out section below.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
- enforce the terms and conditions that govern the Services; and
- prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
How We Share Your Personal Information
Business partners. Third party companies that we partner with to provide content or services to you or to such business partners. For example, we will share your contact and other information with a service provider, lender, loan originator, and/or insurance company if the information you provide in one of our online forms or tools matches certain criteria for products offered by such service provider, lender loan originator, and/or insurance company. PLEASE NOTE: Our business partners that interact with you may retain or use your information whether or not you use their services, and their privacy and information sharing practices are set forth in their respective privacy policies. Pursuant to the contracts between Direct Agents and its business partners, if you select a business partner through our Services, Direct Agents may also receive information about you from that business partner including, but not limited to, the amount, disposition, or other information of your loan or other product or service.
Advertising partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to you and similar users on their platforms.
Business transferees. Relevant participants in business transactions (or potential transactions), such as corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Direct Agents or our affiliates (including, in connection with a bankruptcy or similar proceedings). In any of these cases user information, including personal information, could be one of the assets transferred to or acquired or accessed by a third party.
Service providers. Other companies and individuals that provide services or perform tasks on our behalf to help us operate the Service or our business, such as, for example, customer support, hosting, analytics, email delivery, marketing services, and database management services.
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/intl/en/policies/privacy/
Professional advisors. Professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and privacy parties, when we believe in good faith it is necessary or appropriate for the compliance purposes described above.
Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email, landing page, and/or by emailing us at email@example.com. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.
Cookies. 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 Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Advertising choices. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at https://optout.aboutads.info. Mobile app users may opt-out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
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 https://allaboutdnt.com.
Declining to provide personal information. If you do not provide information that we need to provide the Service, we may not be able to provide you with the Service or certain features. We will tell you what information you must provide to receive the Service when we request it.
The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
Other Sites and Services
The Service may contain links to websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control websites or other online services operated by third parties, and we are not responsible for their actions. Other websites and online 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.
We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. Nevertheless, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
TRANSFER OF DATA
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Direct Agents may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Direct Agents aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Direct Agents relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
149 Fifth Avenue, Floor 16
New York, NY 10010
Important Information for California Residences
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. These rights, however, are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information and, if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out of sales. If we sell your Personal Information, you can opt-out.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
How to exercise your rights. You may exercise your California privacy rights described above as follows:
- Right to information, access, and deletion. You can request to exercise your information, access, and deletion rights by emailing privacy (at) directagents.com
- Right to opt-out of the “sale” of your Personal Information. Like many companies online, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under the CCPA as a “sale” of your Personal Information to the companies that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can opt-out of this “sale” of your personal information by emailing firstname.lastname@example.org
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.