Debt MD is committed to protecting your privacy and take great care with your personal information. This policy will help you understand how we use and protect your data. If you have any questions, feel free to contact us at firstname.lastname@example.org.
Effective Date: September 30, 2018
2. Information We Collect
Some of the Site requires us to learn more about you so that we can best meet your needs.
2.1 Personal Information We Collect Directly From You
We receive Personal Information directly from you when you voluntarily provide us with such Personal Information, including, without limitation, the following:
(1) contact data (such as your name, e-mail address and phone number);
(2) demographic data (such as your gender, your date of birth and your zip code);
(3) credit score data (such as your credit score);
(4) financial data (such as annual income, outstanding debt payment); and
(5) other identifying information that you voluntarily choose to provide to us, including Personal Information in emails or letters that you send to us.
We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access and use some of the Site if you choose not to provide us with any Personal Information, but features of the Site that require your Personal Information will not be accessible to you.
2.2 Information From Third Party Sources
Some third parties, such as our business partners and service providers, provide us with Personal Information about you, such as the following:
2.3 Information we automatically collect when you use our Site
Some information, which may include Personal Information, is automatically collected when you use our Site, such as the following:
Traffic Data: We also may automatically collect certain data when you use the Site, such as (1) IP address; (2) domain server; (3) type of device(s) used to access the Site; (4) web browser(s) used to access the Site; (5) referring webpage or other source through which you accessed the Site; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Site (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.
3. How We Collect Information
We collect information (including Personal Information and Traffic Data) when you use and interact with the Site, and in some cases from third party sources. Such means of collection include:
When you use the Site’s interactive tools and services, such as searching for debt solution providers, taking and/or completing the smart-debt analyzer survey;
When you voluntarily provide information in free-form text boxes through the Site or through responses to surveys, questionnaires and the like;
Through cookies, web beacons, analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; and
When you use the “Contact Us” function on the Site, “Subscribe Now” to email newsletters, send us an email or otherwise contact us.
4. Tracking Tools, Behavioral Advertising, and Opt Out Options
4.1. Tracking Tools
We may use tools outlined below in order to provide our Site to, advertise to, and to better understand users.
Some cookies are placed by a third party on your device and provide information to us and third parties about your browsing habits (such as your visits to our Site, the pages you have visited, and the links and advertisements you have clicked). These cookies can be used to determine whether certain third party services are being used, to identify your interests, and to serve advertisements relevant to you. We do not control third party cookies.
Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Site, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Site, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
Web Service Analytics: We may use third-party analytics services in connection with the Site, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site. We use the information collected from these services to help make the Site easier to use and as otherwise set forth in Section 5 (How We Use Your Information). These analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across web services that do not use their services.
Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help Debt MD learn more about our users’ demographics and internet behaviors in order to personalize and improve the Site. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data.
4.2. Behavioral Advertising
We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools, such as cookies, pixel tags, and web beacons, to collect information about a user’s online activities to display Debt MD ads to the user based on the user’s interests (“Behavioral Advertising”). Such partners may include third-party service providers, advertisers, advertising networks or platforms, traffic measurement service providers, marketing analytics service providers, and other third party service providers (collectively, “Advertising Service Providers”). Other Tracking Tools used by our partners may collect information when you use the Site, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help Debt MD learn more about our users’ demographics and internet behaviors.
4.3. Options for Opting out of Cookies
Some web browsers allow you to reject cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Debt MD’s cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Site.
5. How We Use Your Information
We may use information that is not Personal Information to better understand who uses Debt MD and how we can deliver a better debt relief solution experience, or otherwise at our discretion.
We use information, including Personal Information, to provide services and to help improve the Site, to develop new services, and to advertise (for example, to display Debt MD ads on other web services). Specifically, such use may include:
Providing you with the products, services and information you request;
Responding to correspondence that we receive from you;
Contacting you when necessary or requested;
Providing, maintaining, administering or expanding the Site, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Site, and other products and services we offer;
Customizing or tailoring your experience of the Site, which may include sending customized messages or showing you Sponsored Results;
Notifying you about certain resources or services we think you may be interested in learning more about;
Sending you information about Debt MD;
Sending emails and other communications that display content that we think will interest you and according to your preferences;
Showing you advertisements, including interest-based or online behavioral advertising;
Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities;
Protecting against or deterring fraudulent, illegal, or harmful actions; and
6. How We Share Your Information
In certain circumstances, and in order to perform the Site, we may share certain information that we collect from you, as described in this section:
Debt Solution Providers: We may share your Personal Information with Debt Solution Providers with whom you choose to connect with through the Site. For example, if you complete a Smart-Debt Analyzer survey using the Site and elect to connect with a selected Debt Solution Provider, we may share your Personal Information with such selected Debt Solution Provider. Provided that you choose to use the applicable services, we may share your Personal Information with your Debt Solution Provider to enable them to refer you to solutions with other Debt Solution Providers on your behalf. We may share your Personal Information with Debt Solution Providers in the event of an emergency.
We do not sell email addresses to third parties. We may share your Personal Information with our partners to customize or display our advertising.
We may share your Personal Information and/or Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics, or ad serving) and/or who make certain services, features or functionality available to our users.
Cross Device Matching: To determine if users have interacted with content across multiple devices and to match such devices, we work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of the Site across devices.
Business Transfers: We may transfer your Personal Information to another company in connection with a proposed merger, sale, acquisition or other change of ownership or control by or of Debt MD (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Protection of Debt MD and Others: We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (2) protect the rights, property or safety of you, Debt MD or another party; (3) enforce the Agreement or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.
Other Information: We may disclose information that is not Personal Information at our discretion.
7. Storage and Security of Information
The security of your Personal Information is important to us. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, when you enter sensitive information on our Site, we encrypt that information using Secure Socket Layer (SSL) technology.
We store and process your information on our servers in the United States. We maintain industry standard backup and archival systems.
Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at email@example.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.
8. Your Choices
You can always opt not to disclose information to us, but keep in mind some information may be needed to take advantage of some of our features.
9. How Long We Retain Your Information
We retain Personal Information about you for as long as otherwise necessary to provide you services. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, prevent fraud, enforce the Agreement, or as otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
10. Information Provided on Behalf of Children and Others
By accessing, using and/or submitting information to or through the Site, you represent that you are not younger than age 13. If we learn that we have received any information directly from a child under age 13 without his/her parent’s written consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child that he/she cannot use the Site, and we will subsequently delete that information. If you believe that a child under 13 may have provided us Personal Information, please contact us at firstname.lastname@example.org.
If you use the Site on behalf of another person, regardless of age, you agree that Debt MD may contact you for any communication made in connection with providing the Site or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Site on behalf.
11. Other Web Services
13. Contact Us