Privacy policy

 

1.

1.1          BrokeredIn LLC., its website(s) and loan platform (the “Platform”) are committed to safeguarding the privacy of our subscribers and other 3rd Party users.

1.2          This policy applies where we are acting as a data controller with respect to the personal data of our subscribers, and any of their respective 3rd Party affiliate’s data uploaded into the Platform; in other words, where we determine the purposes and means for processing any personal data.

1.3          We may use cookies on our platform. Insofar as those cookies are not strictly necessary for the provision of the Platform, we will ask you to consent to our use of cookies when you first encounter them on our Platform.

1.4         

1.5          In this policy, "we", "us" and "our" refer to BrokeredIn, LLC.  For more information about us, see Section 13.

How we use your personal data

3.1        In Section 3 we will illustrate:

(a)         the general categories of personal data that we may process;

(b)        in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)         the purposes for which we may process personal data; and

(d)        the legal bases of the processing.

3.2       We may process data about your use of our platform and any other Platform services ("data usage"). This data usage may include your IP address, geographical location, browser type & version, operating system, referral source, length of visit, page views and platform navigation paths, as well as information about the timing, frequency and pattern of your service use. We source the data usage with an analytical tracking system. Data usage may be processed for purposes of analyzing the use of our platform and services. The legal basis for this processing is your consent and our legitimate interests with improving our platform, services and overall user experience.

3.3        We may process your Platform user account data ("account data"). The account data may include your name and email address. The source of the account data is from you and or your employer. The account data may be processed for operating our platform, providing our services, ensuring the data security of our platform and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent and our legitimate interests, specifically for the proper administration of our platform and business

3.4        We may process information that you post for publication on our platform or through our services ("publication data"). This publication data may be processed before the purposes of enabling such publication and administering platform and its services. The legal basis for this processing is your consent. Data usage may be processed for the purposes of analyzing the use of our platform and services. The legal basis for this processing is your consent and our legitimate interests with improving our platform, services and overall user experience

3.5        We may process data contained in every enquiry submitted to us regarding goods and/or services ("data enquiry"). The data enquiry may be processed for the purposes of analyzing the use of our platform and or services. The legal basis for this processing is your consent and our legitimate interests with improving our platform, services and overall user experience. The legal basis for this processing is your consent.

3.6        We may process information relating to transactions completed on our platform, including purchases of goods and/or services, that you enter into with us and/or through our platform ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, specifically the proper administration of our platform and business

             We may process information that you provide to us by subscribing to our email notifications and other publications or newsletters ("notification data"). The notification data may be processed for the purposes of sending you relevant notifications and/or publications newsletters. The legal basis for this processing is your consent and our legitimate interests, namely communications with our website visitors and service users as well as the performance of a contract between you and us and taking steps, at your request, to enter into such a contract.

3.8        We may process your personal data. This data may include any information you submit to the Platform. The source of this data is you and any 3rd party source. This data may be processed for any purposes. The legal basis for this processing is your consent. Data usage may be processed for the purposes of analyzing the use of our platform and or services. The legal basis for this processing is your consent and our legitimate interests with improving our platform, services and overall user experience

 

3.9        We may process any of your personal data identified in this policy where necessary for the creation, exercise and defense of legal claims, whether in court proceedings, in an administrative proceeding or an out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10     We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.11     In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.12     Please do not supply any other person's personal data to us, unless we prompt, you to do so and you have received their written permission.

4.          Providing your personal data to others

4.1        We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.2        Your personal data held in our database will be stored on the servers of our hosting services providers identified at https://www.digitalocean.com/.

4.3        We may disclose any personal data to our suppliers or subcontractors as reasonably necessary for business purposes.

4.4        In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.          International transfers of your personal data

5.1        In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the United States (US).

5.2        The hosting facilities for our website are situated in specific countries. US Federal Regulators have set regulatory financial privacy standards with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely with Privacy Shield through our host Digital Ocean

5.3        General Programming, Infrastructure, Maintenance, Marketing, and limited Customer Service are situated in the Philippines & Mexico. US Federal Regulators have set regulatory financial privacy standards with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely through the use of standard data protection clauses adopted or approved by Federal regulations, primarily represented by the Bank Secrecy Act, Right to Financial Privacy Act, the Gramm-Leach-Bliley Act, and the Fair Credit Reporting Act. Provisions within other laws like the Credit and Debit Card Receipt Clarification Act of 2007 as well as the Electronic Funds Transfer Act also contribute to financial privacy in the United States.

5.4        You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.          Retaining and deleting personal data

6.1        This Section 6 sets out our data retention policies and procedure, designed to help ensure we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2        Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3        We will retain your personal data as follows:

 (a)        usage data will be retained for a minimum 1year period following the date of collection, and for a maximum period of 1year following that date;

(b)        account data will be retained for a minimum period of 1year following the date of closure of the relevant account, and for a maximum period of 1year following that date;

(c)         publication data will be retained for a minimum period of 1year following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 1year following that date;

(d)        enquiry data will be retained for a minimum period of1year following the date of the enquiry, and for a maximum period of 1year following that date;

(e)        transaction data will be retained for a minimum period of 1year following the date of the transaction, and for a maximum period of1year following that date;

(f)         notification data will be retained for a minimum period of 1year following the date that we are instructed to cease sending the notifications, and for a maximum period of1year following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications); and

6.4        Notwithstanding the other provisions of Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

7.          Your rights

7.1        In Section 7, we have listed the rights that you have under data protection law.

7.2        Your principal rights under data protection law are:

(a)         the right to access - you can ask for copies of your personal data;

(b)        the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)         the right to erasure - you can ask us to erase your personal data;

(d)        the right to restrict processing - you can ask use to restrict the processing of your personal data;

(e)        the right to object to processing - you can object to the processing of your personal data;

(f)         the right to data portability - you can ask that we transfer your personal data to another organization or to you;

(g)         the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)        the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3        These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting the Financial privacy laws in the United States

7.4        You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

8.          About cookies

8.1        A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2        Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3        Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

9.          Cookies that we use

9.1        We use cookies for the following purposes:

(a)         authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b)        personalization - we use cookies to store information about your preferences and to personalize the website for you;

(c)         security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(d)        advertising - we use cookies to help us to display advertisements that will be relevant to you;

(e)        analysis - we use cookies to help us to analyses the use and performance of our website and services; and

(f)         cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (.

 

10.       Cookies used by our service providers

10.1     Our service providers may use cookies and those cookies may be stored on your computer when you visit our website.

10.2     We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy. The relevant cookies are: identify cookies.

10.3     We use Digital Ocean as our server provider, this service uses cookies for various reasons. You can view the privacy policy of this service provider at https://www.digitalocean.com/legal/.

11.       Managing cookies

11.1     Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)         https://support.google.com/chrome/answer/95647 (Chrome);

(b)        https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)         https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)        https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)        https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)         https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

 

11.2     Blocking all cookies may have a negative impact upon the usability of many websites.

11.3     If you block cookies, you may not be able to use all the features on our website.

 

12.       Amendments

12.1     We may update this policy from time to time by publishing a new version on our website.

12.2     Please check this page on occasionally to ensure you’re happy with any changes to this policy.

12.3     We may notify you of significant changes to this policy by email.

13.       Our details

13.1     BrokeredIn® is owned and operated by BrokeredIn LLC.

13.2     We are registered in State of N. Carolina, our registered office is at 114 Old Bridge St, Jacksonville, NC 28540

13.3     Our principal place of business is at 7211 SW 48th St., Miami, FL 33155.

13.4     You can contact us:

(a)              by post, to the postal address given above;

(b)              using BrokeredIn contact form;

(c)              by telephone, on the contact number published on BrokeredIn; or

(d)              by email, using the email address support@BrokeredIn.com available under https://BrokeredIn .com/contact.

 

14.       Data protection officer

14.1     Our data protection officer's contact details are: support@BrokeredIn.com and address available under https://BrokeredIn .com/contact