Introduction
In this privacy policy, the words “we”, “us”, and “our” mean Agora Data, Inc.; and Agora Trade. The words “you” and “your” mean any visitor or user of a website (a “Site” or “Sites”) that we administer and provide for your online interactions with you.
The Sites covered by this policy include
https://www.agoradata.com,
https://support.agoradata.com,
https://portal.agoradata.com and
https://www.altruvo.ai
We respect your privacy and are committed to protecting it by complying with this policy. This policy describes the type of information we may collect from you or that you may provide when you visit our Sites. This policy informs you of our policies regarding the collection, use and disclosure of the personally identifiable information (“Personal Information”) we receive from users of the Site.
Our Site and Services are intended for use only by United States residents, while located in the United States. If you are not a United States resident or are located in a country other than the United States, you may not use our Site and Services.
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.
Additional privacy rights and notices will apply if you are a California resident. See the section below called
Your California Privacy Rights for more information about your rights under California law.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. By accessing or using this Site, you agree to this privacy policy. This policy may change from time to time (see the section below called
Changes to Our Privacy Policy), so please check this policy periodically for updates. If we change the policy on this Site and you continue to use it, you agree that your continued use of the Site will mean that you have accepted all changes to the updated policy.
Information Collected and Used While Using Our Site.
We may ask you to provide us with certain 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, account ID, 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;
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- 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.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns. 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.
The technologies we use for this automatic data collection may include cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our Site.
- Cookies (or browser cookies). 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.
- Web Beacons. Pages of our Site and URL links with our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single pixel gifs) that permit us, for example, to count users who have visited those pages or interacted with email links, and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
External Data Storage Sites.
We may store your data on servers provided by third party hosting vendors with whom we have contracted.
Data Security.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet or by email is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site or transmitted by email. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
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.
Children Under the Age of 18.
Our Site is not intended for children under 18 years of age. No one under age 18 is allowed to provide personal information on this Site. Agora does not knowingly collect information from children under 18. (See the U.S. Children’s Online Privacy Protection Act.). If you believe we might have any information from or about a child under 18, please notify us via info@agoradata.com
Changes to Our Privacy 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. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the home page of this Site. The date the privacy policy was last revised is identified at the top of the policy. You are responsible for periodically visiting our Site and this privacy policy to check 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.
Your California Privacy Rights
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”). Any terms defined by the CCPA have the same meaning when used in this California Privacy Policy.
Information We Collect.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
Personal information does
not include:
- Publicly available information from government records;
- Deidentified or aggregated consumer information; and
- Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.:
We have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category |
Examples |
Collected |
| A: Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
YES |
| B: Personal Information Categories |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, or any other financial information. |
YES |
| C: Commercial information |
Records of personal property, products or services purchased, obtained, or considered. |
YES |
| D: Internet or other similar network activity |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
YES |
| E. Professional or employment information |
Current or past job history or performance evaluations. |
YES |
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 (com). For example, from submissions through our website portal.
- Indirectly from you. For example, from observing your actions on our Site.
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 example, If you share your name and contact information to request a price quote or ask a question about our product or service, we will use that personal information to respond to your inquiry.
- To provide, support, personalize, and develop our Site, products, and services
- To create, maintain, customize, and secure your account with us.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- For testing, research, analysis and product development, including to develop and improve our Site.
- To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets and business.
- To improve our Site 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 merger, divestiture, reconstruing, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users and consumers are among the assets transferred.
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 required to keep the personal information confidential and prohibited using the disclosed information for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
| Personal Information Category |
Business Purpose Disclosure to Third Party Recipients |
| A: Identifiers. |
Yes, to our service providers. |
| B: California Customer Records personal information categories |
Yes, to our service providers. |
| C: Commercial information |
Yes, to our service providers. |
| D: Internet or similar network activity |
Yes, to our service providers. |
We do not sell personal information and have not sold personal information to third parties in the preceding twelve (12) months.
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.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm our identity (see Exercising Your Rights to Know or Delete), 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;
- Our business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we share your personal information;
- If we disclosed your personal information for a business purpose, a list that describes the disclosure we made for a business purpose, identifying the personal information categories that each category of recipient obtained; and
- The specific pieces of personal information we collected about you in a usable and portable format (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information we have collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Right to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request either by:
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We cannot respond to your request to provide you with personal information if we cannot verify your identity or authority to make the request and confirm personal information relates to you.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us using the contact information included in the section above called Exercising Your Rights to Know and Delete.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosure we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should you allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest you may receive a different price or rate for goods or services or a different level or quality of goods or services.