Privacy Policy

Last Updated: October 25, 2023
Valid since: January 5, 2020

1. Who are we?

1.1. ("," "our," "us," or "we") values your privacy and will do everything in our power to keep it secure. In light of this, we have created this Privacy Policy (or Policy) to explain to you what data we may collect when you visit (the "Website"), and use the services made available through our Website.

1.2. This Privacy Policy outlines the information we can collect from you, how we can use it, with whom it can be shared, and the security measures we put in place to keep it safe. You agree to the privacy practices outlined in this Policy by using our Website.

1.3. In general, we operate under the General Data Protection Regulation ("GDPR") as the legal foundation for our Privacy Policy. The California Consumer Privacy Act ("CCPA") disclosures are included in the Privacy Policy and only apply to "personal information" covered by the CCPA. If you reside in California, the CCPA may be applicable to our Website. We also have included specific provisions for New York, Colorado, Nevada, Virginia and other states Residents to our Policy.

This Privacy Policy should be read in conjunction with the Terms and Conditions, which are available on our Website.

1.4. Our Website is not constructed for minors. We don't knowingly collect personal information from kids and minors under the age of 18 years old. No one under the age of 18 is not authorized to provide their personal information to us. Without first verifying parental consent, we will immediately delete any personal information we learn was collected from a child or a minor under the age of 18. If you believe we may have any information from or about a child or a minor under the age of 18, please, get in touch with us at [email protected]

1.5. We may change this Privacy Policy by posting a new version on our Website or through the Service, and it is your responsibility to review this Policy periodically. When we do change the Policy, we will also revise the "Revised" date and may notify you or post a message on the Website and/or through the Service. Your continued use of the Website or the Service constitutes your agreement to this Privacy Policy and any updates to it.

1.6. We will notify you about material changes in the way we treat your information, including by placing a prominent notice on the Website or by sending you an email so that you can choose whether to continue using the Website.

1.7. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Privacy Policy. Immaterial modifications are effective upon posting of the updated Privacy Policy on the Website. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Terms in effect at the time the dispute arose.

1.8. This is our entire and exclusive Privacy Policy and it supersedes any earlier version.

2. What categories of data does collect?

2.1 Personal data. “Personal data” means any information that may be used to identify, describe or be reasonably linked to an individual (such as name, surname, email address, telephone number, credit or any other bank card, SSN etc.). We do not collect, use, store and transfer any of your Personal data. We do not have any accounts, or registration forms on the Website, Users can freely surf the Website and we do not collect any data, including personal data, from our Users.

We may receive your Personal data only from correspondence with you, if you first contact us by email and provide such Personal data by yourself. Please, note, it is always your choice whether or not to provide that Personal data.

We may only collect personal information from you if you provide it voluntarily. By voluntarily providing this personal information to us, by sending us a comment or suggestion, you consent to the collection, use and disclosure of your personal information by us for the purposes set out herein.

2.2. Non-personal data

Non-personal data is information that, by itself, cannot be used to track or identify a person, i.e. information without specific reference to the identity of the user from whom it was collected.

When you visit our Website, information about your visit (e.g. how you navigate the Website) may be collected and stored. This information may include the duration of your visit, the date and time of your visit, the pages you view and the sites you visit before and after leaving our site. It does not include personally identifiable information such as your name, postal or e-mail address or telephone number. We use this non-identifiable and aggregate information to better design our Website and to optimize our services and/or our activities. We may also share this general non-identifiable information with our affiliates, suppliers, Partners and advertisers.

When you access the Website, some Technical information may be gathered automatically such as your IP address, browser and device characteristics, operating system, preferred language, referring URLs, device name, and other technical information may be included in this information even though it does not specifically identify you. This data is largely required for internal analytics and reporting, as well as to ensure the security and functionality of our services.
How much information we collect depends on the type and settings of the device you use to access the Website. You can always limit the amount of technical information that can be accessible to us by changing your device settings, but please note that it can influence your ability to use our Website successfully.

2.3. Cookies uses cookies to associate certain internet-related information about you and others who use the Website with information about you in our database.
A cookie is a small amount of data stored on your computer’s hard drive, allowing us to identify you with the corresponding data in our database. Cookies do not reveal any personal information. The only personal information that a cookie can be linked to is information you provide yourself, such as your email address, or information about your actions and behavior while using our Website, such as purchases and preferences. Cookies cannot read data off your hard drive. If you want to delete cookies from your computer, please go to your browser settings and do it manually.

3. We need your consent to this Privacy Policy. Our Privacy Policy and our Partners

3.1. By using the Website, you agree to this Privacy Policy.

It is not our regular activity, but we understand, that in the course of our cooperation during your use of our Website we can face different situations, so we need you to know that we are committed to:

- delivering commercial emails only to those users who have been given appropriate notice and choice regarding the intended use of their personal data, and who have not requested not to receive future commercial e-mail communications from that sender at an email address;
- refrain from falsifying email header and transmission information (including, but not limited to, source, recipient, and routing information);
- refrain from seeking or gaining unauthorized access to your computer or other device for the purpose of sending any commercial email;
- include in all commercial emails sent: clear and conspicuous opt-out notice with the most up-to-date unsubscribe link; a clear and conspicuous identification that the e-mail message is an advertisement (if it is so).

3.2. We represent and warrant that, at all times, we will comply with all applicable state and federal laws, rules and Federal Trade Commission enabling regulations (including the CAN-SPAM Act of 2003, as amended from time to time) and any other applicable laws. We make every effort to ensure that all our partners and counterparties act in the same way, however, we cannot fully vouch for them. If you have received spam and there is good reason to believe that our partners sent it, please let us know about that case and try unsubscribing (opt-out from the message).

If you provide us your telephone number and email, you provide your consent to obtain emails and call from us to obtain commercial information - advertisements provided by us or our partners via SMS/text message (“SMS”) and this means that you provided “prior express written consent,” as defined in the Telephone Consumer Protection Act, 47 U.S.C. §§ 227 et seq., all implementing regulations (47 C.F.R. § 64.1200 (f)(8)), and all applicable FCC rulings and orders (collectively, the “TCPA”) to receive SMS from us, by and on behalf of us or from our partners.

We will perform all of our activities, obligations and responsibilities contemplated hereunder in compliance with all applicable laws, rules and regulations, including but not limited to the TCPA, the Telemarketing Sales Rule (“TSR”) all Do Not Call (“DNC”) rules. We respect all suppression lists. But please, note that if you provide your telephone number, you can receive a call from us. If you disagree with this, please, do not provide your telephone number.

3.3. Please, pay attention, that our Website is constructed in the way that we may display the links on our Website that can redirect Users to the websites or other resources of our Partners.
By going via the link on the Website that can direct you to our Partner`s website, you acknowledge that you can be asked to provide/disclose your personal data to our Partner. You agree and understand that the choice to disclose any personal information to our Partner or other third party is your own risk and decision. Regarding the use or disclosure of information given to third parties, such as our Partners, has no control over it and makes no guarantees in that regard.
You acknowledge and agree that does not control any third parties, including our Partners and service providers, and that is not liable for how any third parties use your information, personal data. If you go to any of our Partner`s website that asks about your personal data provision, please read their privacy policy before to be acquainted with the privacy practices they are ruled by and to be sure that you can agree with them.

4. What rights do you have with regard to your Personal Data?

4.1. Yes, as we mentioned, we do not collect your Personal data.
At the same time, we want you to know about the rights you can have if some of your Personal data is provided to us.

You are entitled to the full range of rights under the GDPR, and we are committed to respect your rights. Among these, you have the right to:

4.1.1. require access to your Personal data (Art. 15 GDPR);

4.1.2. require your Personal data rectification (Art. 16 GDPR);

4.1.3. require your Personal data deletion (Art. 17 GDPR; CCPA);

4.1.4. require restriction of your Personal data processing (Art. 18 GDPR);

4.1.5. require your Personal data transfer (Art. 20 GDPR; CCPA);

4.1.6. object to your Personal data processing (Art. 21 GDPR);

4.1.7. object to an automated processing (if any) of your Personal data (Art. 22 GDPR);

4.1.8. withdraw your consent to your Personal data processing, if applicable (Article 7(3) GDPR);

4.1.9. lodge a complaint with your national supervisory authority (in the EEA) if you believe that your privacy rights have been violated (Art. 13(2)(d), 14(2)(e), 15(1)(f) GDPR);

4.1.10. If you are a California resident, you can request to receive certain information about the personal data we have collected about you in the last 12 months. You may make such a request no more than 2 times within a 12-month period (CCPA).

4.2. To exercise these rights, please contact us as indicated in this Privacy Policy's ‘How To Contact Us’ section. If you are a California resident, please consult the section 5 below for more information about your rights. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your Personal data that we maintain.

5. Special Notice For California Residents

5.1. If you are a California resident, then if you provide us with your personal data, you have certain rights under the California Consumer Privacy Act ("CCPA”) regarding your Personal data:

5.1.1. Access to Personal data Rights. You have the right to request us to provide you with certain information about our collection, use and disclosure of your Personal data. This includes your right to request the specific pieces of Personal data that we have collected about you.

5.1.2. Deletion Request Rights. You have the right to request us to delete any of your Personal data that we collected from you and retained, subject to certain exceptions provided by law.

5.2. To exercise your access or deletion request rights, please submit a verifiable consumer request to us as indicated in the ‘How To Contact Us’ section of this Privacy Policy.

5.3. Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal data. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

5.3.1. Provide sufficient information that allows us to reasonably verify you as the person about whom we collected Personal data or an authorized representative of such a person.

5.3.2. Describe your request with sufficient detail that allows us to understand, evaluate and respond to it properly. We cannot respond to your request or provide you with Personal data if we cannot verify your identity or authority to make the request and confirm that Personal data relates to you.

5.4. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

5.4.1. deny you goods or services;

5.4.2. charge you different prices or rates for goods or services;

5.4.3. provide you a different level or quality of goods or services;

5.5. We also plan to introduce new opportunities for the implementation of the rights of users - residents of California after the entry into force California Privacy Rights Act (CPRA), which introduces four California consumer privacy rights that are not present in the CCPA:

5.5.1. Right to Correct Information: User has the right to request to correct any inaccurate personal information.

5.5.2. Right to Limit the Use and Disclosure of Personal Information: User has the right to limit the use and disclosure of their personal data to that “use which is necessary to perform the services or provide the goods reasonably expected by an average User who requests such goods and services’.

5.5.3. Right to Access Information About Automated Decision Making: User has the right to request “meaningful information about the logic involved in those decision–making processes, as well as a description of the likely outcome of the process concerning the consumer (if any).”

5.5.4. Right to Opt–Out of Automated Decision-Making Technology: User has the right to opt–out of being subject to automated decision–making processes, including profiling.

5.6. We do not sell personal information to third parties for monetary value.

6. Information for New York, Colorado, Nevada, Virginia and other states Residents

US state privacy regulations provide New York, Colorado, Nevada, and Virginia residents with specific rights regarding their personal information. If you are a resident of the mentioned state, for more information, please see the NY Privacy act (NYPA), Colorado Privacy Rights Act, Nevada Privacy Law (NPICICA) and Amendment SB-220 and Virginia Consumer Data Protection Act and find rules that applies to you: makes all necessary efforts to be compliant with NYPA, Colorado Privacy Act (CPA), Nevada Privacy Law,Virginia Consumer Data Protection Act (VCDPA) . will not use your personal data in a way that

(i) benefits an online service providers to the detriment of you;

(ii) would result in reasonably foreseeable physical or financial harm to you; or

(iii) would be unexpected and highly offensive to you.

If you are a resident of the states mentioned above, in case you will provide us your personal data your rights will include:

- Right to notice – by posting this Policy we made publicly and consistently available a notice to you containing: (i) a description of the your rights (ii) the categories of personal data processed by us; (iii) the sources from which personal data is collected; (iv) the purposes for processing personal data; (v) the categories of third parties to whom we disclosed, shared, transferred your personal data (vi) retention period for personal data that we process.
- Right to opt out - means the right to opt out, at any time, of processing your personal data concerning : (i) targeted advertising; (ii) the sale of personal data; and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects on you.
- Right to access - upon your verified request we will: (a) confirm whether or not we are processing or have processed personal data, and provide access to a copy of any such personal data; and (b) provide the category of each processor or third party to whom we disclosed, transferred your personal data.
- Right to portable data - upon your verified request, and to the extent technically feasible, we will: (a) provide you copy of all of, or a portion of, as designated in a verified request, personal data in a structured, commonly used and machine-readable format and (b) transmit the data to another person of your designation.
- Right to correct - upon your verified request we will conduct a reasonable investigation to determine whether personal data, the accuracy of which is disputed by you, is inaccurate. If personal data is found to be inaccurate or incomplete, or cannot be verified, we will correct the inaccurate or incomplete personal data.
- Right to delete - upon your verified request we will: (i) within 45 days after receiving the request, delete any or all of your personal data. That period may be extended once by 45 additional days where reasonably necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within 45 days of receipt of the request, together with the reasons for the delay.

We also want to emphasize that cares about the privacy of its Users. We have listed some of the states whose residents have the specific additional rights. However, if you are a resident of another state or territory not listed in this Policy but your local privacy law gives you some special right in the sphere of privacy, you are guaranteed to be able to use it.

7. How does receive your Personal data?

7.1. We may collect your Personal data from you directly, including through direct interaction and communication (for example, if you contact our support team or submit a request or complaint to us). Non-personal data can be collected automatically.

7.2. We may receive your Technical information automatically. When you visit the Website we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation:

7.2.1. IP address or other device address or ID.

7.2.2. Web browser and/or device type.

7.2.3. Geolocation data, including if you use the Website on a mobile device.

7.2.4. Hardware and software settings and configurations.

7.2.5. Pages you view on the Website.

7.2.6. Your actions on the Website.

8. How does use your Personal data?

8.1 will only use the information provided by you for the purposes for which you provided it, including

- to operate, provide, improve and maintain our Website and services;
- to respond to your questions; as well as for other administrative and internal business purposes.

8.2. We can use Non-personal and Technical data:

8.2.1. to operate, maintain and improve the Website and create new features and functionality;

8.2.2. to understand and analyze usage trends and preferences of our users across different devices;

8.2.3. to perform data analyses (including market and consumer research, trend analysis, financial analysis)

8.2.4. for fraud detection and information security, to protect against, identify and prevent fraud and other criminal activity, claims and other liabilities, and comply with and enforce applicable legal requirements, relevant industry standards and our policies.

8.3. We can contact you only if you give us your email directly and voluntarily:

- for administrative purposes such as customer service;
- to send you promotional materials, offers, and/or messages related to the Website and the activities of third parties we work with only after receiving your active consent. Generally, you can opt out of receiving promotional communications through the links provided in the messages or by contacting us directly by the email below.

8.4. We are not selling your personal data and will not use it to infringe your privacy rights, property rights, or any other rights (yours or of any third party).

9. How do we share your Personal data?

9.1. Your personal data will not be shared unless you have provided your data to us and we have first informed you that we might share your data and you have given us your consent to do so.
Your non-personal data will not be linked to your personal data or shared unless we have informed you as described above and you have given us your consent.

9.2. We may share Technical information such as IP address as well as de-identified information:

9.2.1. with nonaffiliated third-party lending partners when you leave our Website (for example, from a rate table or review);

9.2.2. with third-party service providers to support our internal and business operations. In such cases, service providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure. For example:

- for Website hosting, data storage, maintenance, and other services for us.

- for internal marketing, delivery of emails, including promotional, marketing and transactional materials, other promotional materials, postal mailers, SMS and text messaging, and online and social media promotions and advertising.

- for fraud prevention and security purposes.

9.3. We may share de-identified and/or aggregate analytics with third-party service providers to understand how users interact with our Website, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Website.

9.4. By submitting a request through our Website, you consent to the disclosure of your information for us to carry out your request.

9.5. The collection, use and disclosure of your information by our Partners is subject to each specific privacy policies. has no control over how third parties further use or disclose your information.

10. How do we secure your personal data?

10.1. Although we do not collect Personal Information from our Users, we are prepared that it may be available to us and in this case we promise to take all available and possible measures to ensure that this information is properly protected.

Our systems are built to safeguard Personal data from unauthorized use, and we maintain physical, electronic, and procedural safeguards to do so. We make an effort to put administrative, physical, and technical safeguards in place to protect all information given to us, including Personal Information. We also make sure that all such safeguards, including the way Personal Information can be gathered, accessed, used, stored, processed, disposed of, and disclosed, comply with applicable data protection and privacy laws.

11. How to Contact us

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email: [email protected]