Introduction
Agora Data, Inc. (“Agora”, “us”, “we”, or “our”) operates https://www.agoradata.com, https://app.agoradata.com and https://support.agoradata.com (all such websites, individually and collectively, the “Site”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site. We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this Policy. Please note that this Policy does not govern the collection and use of information by companies that we do not control, nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information.

Information Collected and Used While Using Our Site.
We may ask you to provide us with certain personally identifiable information (“Personal Information”) that can be used to contact or identify you. Personal Information is information that may be used to identify you individually, including, without limitation, your name, shipping and billing addresses, phone number, email address, credit card information and date of birth. It is always up to you whether to disclose Personal Information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services.

If you do provide Personal Information to us, either directly or through a reseller or other business partner, we will:

• not sell or rent it to a third party without your permission — although unless you opt out (see below), we may use your contact information to provide you with information we believe you need to know or may find useful, such as (for example) news about our services and products;
• take commercially reasonable precautions to protect the Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
• not use or disclose the Personal Information except:
  • as necessary to provide services or products you have ordered;
  • in other ways described in this Policy or to which you have otherwise consented;
  • in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
  • as required by law, for example, in response to a subpoena or search warrant;
  • to outside auditors who have agreed to keep the Personal Information confidential;
  • to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion of Agora’s assets. The successor organization’s use and disclosure of Personal Information will continue to be subject to this Policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your Personal Information will be subject to the successor organization’s own privacy policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use Agora’s services). If you submit Personal Information after such a transfer, that information may be subject to the successor entity’s privacy policy;

• • • • • as necessary to enforce the Terms of Use;
        • as necessary to protect the rights, safety, or property of Agora, its users, or others; this may include (for example) exchanging information with other organizations for fraud protection and/or risk reduction.

Use of Personal Information.
Personal Information collected by Agora is used for three main purposes:

• To provide products and services to you or one or more third party service providers (collectively, “Third Parties”) who are obtaining services on your behalf or in connection with a transaction involving you;
• To improve our products and services that we perform for you or for Third Parties; and
• To communicate with you and to inform you about Agora’s, affiliates’ and Third Parties’ products and services.

Additionally, we may use information provided through our Site and services to compile performance and analysis reports pertaining to buyers, sellers, lenders, investors, consultants, vendors and other users of our Site and services. We may additionally collect website data to contact any entities who access or use our Site unless the entity “opts-out” from being contacted. You may choose to opt-out from being contacted by removing your information from our databases as provided in this Policy.

Other Information We Collect.
We may, automatically or through the use of third-party software, collect other information that cannot be readily used to identify you about your use of our Site. For example, we may capture the domain name and IP address of the device you use to access our Site, computer operating system, browser type and version, session data for your login session (so that our computer can ‘talk’ to yours while you are logged in), information about the websites you came from and visit next, account-preference information you provide us, the pages of our Site that you visit, your activity on and interaction with those pages, the time and date of your visit, the time spent on those pages and other statistics. If you access our Site using a mobile device, we may also collect unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information (such as precise geo-location information). We may use this information, individually or in the aggregate, for technical administration of our Site(s); research and development; customer and account administration; and to help us focus our marketing efforts more precisely. In addition, we may later associate the usage and other information we collect online with personal information about you.

Cookies.
We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our Site. Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

External Data Storage Sites.
We may store your data on servers provided by third party hosting vendors with whom we have contracted.

Security.
We use industry-standard security measures to protect the loss, misuse, and alteration of the information under our control, and we make good-faith efforts to store Personal Information in a secure operating environment. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect Personal information, we cannot ensure or warrant the security of any information you transmit to, and you do so at your own risk.

Your Privacy Responsibilities.
To help protect your privacy, be sure:

• not to share your user ID or password with anyone else;
• to log off the Agora website when you are finished; and
• to take customary precautions to guard against “malware” (viruses, Trojan horses, bots, etc.), for example by installing and updating suitable anti-virus software.

Accessing, Updating or Deleting Personal Information.
Currently, we do not have a method for users to delete Personal Information contained in our database. However, you can contact us to withdraw your consent for us to use your information at any time, subject to legal or contractual restrictions.

You may access or update the Personal Information we have collected by calling us or logging into your Agora account if you created one. We will use commercially reasonable efforts to respond to requests regarding Personal Information and our provision of the same is subject to legal and business restrictions. In addition, you may delete the cookies stored on your computer, which will cause our system to perceive you as a new user with no known user data. You may also set your browser to reject cookies but doing so may prevent you from using some of our services.

Opt-Out Policy.
You may opt out of receiving certain communications from us (i.e. notices about new services or products) by emailing us at: info@agoradata.com or writing to us at:

Agora Data, Inc.
700 West Arkansas Lane
Arlington, TX, 76013

In addition, we may contact you via email or use targeted online advertising as permissible by law. In the case of email, we may include instructions to enable you to unsubscribe from future emails if you so choose. You agree and understand that while we will do our best to comply with your request, we shall not be liable for any problems or delays associated with the opt-out process.

Notice to European Union Users.
If you are a user in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following information applies with respect to personal data collected through your use of the Website:

Under applicable law, Agora Data, Inc. is considered the “data controller” of the personal information we handle under this Policy. In other words, Agora is responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We process personal data consistent with our disclosures in this Policy. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide the Site to you; and (3) as necessary for our legitimate interests in providing the Site where those interests do not override your fundamental rights and freedoms related to data privacy.

Agora’s operations are located primarily in the United States. Personal Information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or processors maintain facilities. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards. By providing Personal Information to us, you are consenting to its storage and use as described herein.

If you are a resident of the EEA, the United Kingdom, or Switzerland, you have certain rights under Chapter 3 of the EU General Data Protection Regulation, the UK GDPR, or the Swiss DPA, respectively. To make a request or otherwise exercise your rights under such laws, you can contact us at info@agoradata.com. In order to respond to your request, we will need to verify your identity and residency and may require you to provide us with supporting information.

Information Collected from Children.
You must be at least 18 years old to use Agora’s Site(s) and service(s). Agora does not knowingly collect information from children under 18. (See the U.S. Children’s Online Privacy Protection Act.)

Changes to This Policy.
We reserve the right to change this Policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. We will notify you of any changes by posting the new privacy policy on the Site. You are advised to review this Policy periodically for any changes.

Disclaimer.
By using the Site, you irrevocably acknowledge and agree that Agora provides technology services that banks, investment funds, asset managers, advisors, brokers, lenders, originators, servicers, vendors and other financial services companies or individuals may use to transact business. Agora is not involved in the actual transaction between the aforementioned parties, or any other related party, and is not the agent of, nor has any authority on behalf of any of the aforementioned parties or any other third party, for any purpose whatsoever. At no time and in no event shall Agora become involved in any dispute or transaction between the aforementioned parties or have any responsibility or liability in connection therewith, including, but not limited to, making or guaranteeing any payment that may come due as a result of any transaction or agreement between the aforementioned parties or any other third party.

Questions or Comments?
If you have questions or comments about this Policy, please send an email to info@agoradata.com, or contact us via any of the ways described at https://www.agoradata.com.

Thank you for choosing Agora.

CALIFORNIA SUPPLEMENT

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy above and also the Terms of Use of Agora and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”). “Clients” or “Client” in this statement refers to automobile dealerships, finance companies, investors, lenders, credit unions, and banks (“Agora Members”).

Information We Collect.
We have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their partners interested in selling, financing, analyzing or otherwise reviewing a portfolio of loans. For example, from a pool of loans downloaded to our website, Agora Application, Agora Platform, Agora FTP and help ticket (support site) and chat, text, email, USPS and other delivery services to documents that our clients provide to us to conduct our due diligence.
• Directly from activity on our website (agoradata.com). For example, from submissions through our website portal.

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To improve our Platform for any of the Agora features to include but not be limited to; analysis for purchase or servicing, providing financing, benchmarking and peer analysis.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a business transaction or combination, such as a merger or sale.

The CPRA created a sub-category of personal information, labeled as “sensitive personal information”. The definition of sensitive personal information includes 20 different data points, such as racial origin, religious beliefs, sexual orientation and geolocation. We do not collect sensitive personal information.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes outside of our contractual agreement with the business that provided the personal information.

Sharing Personal Information.
We may disclose your personal information with another third party for a business purpose.  When we disclose personal information for a business purpose, it is only through a contractual agreement where the recipient is held responsible for safeguarding the personal information and to only use the personal information for the purpose described in the terms of the contract.  In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers
Category B: Personal information categories
Category D: Commercial Information

We disclose your personal information for a business purpose to the following categories of third parties:

• Our Members who we have an agreement with; automobile dealers, investors, finance companies, credit unions, and banks.
• Potential service providers.

You have the right to ask that Agora disclose certain information to you about our collection and use of your personal information in the past twelve (12) months. Once Agora processes your request, we will disclose to you:

• The categories of personal information Agora collected about you;

• The categories of sources from which your personal information was collected;
• Agora’s business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom Agora shares your personal information; and
• The specific pieces of personal information we collected about you in a usable and portable format (also called a data portability request).

You have the right to request that Agora delete any of your personal information we have collected from or about you unless otherwise required. Once we process your request, Agora (and our third parties) will delete your personal information except when:

• Agora needs to retain the personal information to comply with applicable law, exercise our rights, detect and protect against fraudulent and illegal activity, or comply with other legal obligations;
• Agora is using the personal information internally in a manner that you have authorized or is reasonably within your expectations as a consumer, such as if we need to complete a transaction for you.

You may request that Agora correct your personal information if it is inaccurate, and we will use commercially reasonable efforts to correct personal information upon receiving a verifiable consumer request.

If you would like to exercise any of the above rights, please note:

• Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request regarding your personal information. We may take steps to verify your identity before completing your request. You may also make a request on behalf of your minor child. You may only make a request to Agora for access or data portability two (2) times within a twelve (12) month period.
• You may make a request at no cost or fee to you unless Agora determines that such request is excessive, repetitive, or unfounded. In this case, Agora will inform you of the cost to comply with such request prior to carrying out your request.