Agora - Privacy Policy

Agora Data, Inc. Privacy Policy

This Privacy Policy (this “Policy”) was last modified on January 14, 2020.

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 collect other information that cannot be readily used to identify you, such as (for example) the domain name and IP address of your computer, browser type, browser version, session data for your login session (so that our computer can ‘talk’ to yours while you are logged in), account-preference information you provide us, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. 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.

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.

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 W Arkansas Ln

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. Agora’s operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) to the United States. By providing Personal Information to us, you are consenting to its storage and use as described herein.

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”). “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:

	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, employment history, bank account number, or any other financial information.	YES
C	Protected classification characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.	NO
D	Commercial information	Records of personal property, products or services purchased, obtained, or considered.	YES
E	Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F	Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G	Geolocation data	Physical location or movements.	NO
H	Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I	Professional or employment information	Current or past job history or performance evaluations.	YES
J	Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf.	NO
K	Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

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. 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.

Customers interested in exercising their rights under the CCPA must submit their request to the original company that collected your information.