Yrefy, LLC (“Yrefy”) is an Arizona limited liability company with offices at 6910 E. Chauncey Lane, Suite 105, Phoenix, AZ 85054. Yrefy takes data privacy seriously. This Privacy Statement explains who we are and how we collect, use and share your personal information, as well as how you can exercise your privacy rights with us.

This Privacy Statement covers the information we collect (1) when providing services through applications, mobile sites, websites, widgets, or communications that are affiliated with Yrefy and that link to this Privacy Statement and (2) in the usual course of Yrefy’s business done through electronic means, such as in connection with our online loan applications, accessing our portal, collections, sales and/or marketing activities (collectively, the “Services”).

We recommend that you read this Privacy Statement in full to ensure you are fully informed. To make it easier for you to review those parts of this Privacy Statement which apply to you, we have divided the document into sections.

This Statement applies to information we collect:

• Through your use of and access to the Services; and
• From email, text, and other electronic messages between you and Yrefy.

The Statement does not apply to information collected by:

• Us from you offline or through any other means, including on any other website or application operated by Us; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from any of our Services.

Please read this Statement 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 not to use the Services. By accessing or using the Services, you agree to this Privacy Statement. This Statement may change from time-to-time. Your continued use the Services after we make changes is deemed to be acceptance of those changes, so please check this Statement periodically for updates.

We last updated this Statement on March 30, 2023.

1. WHO WE ARE

Yrefy, LLC (pronounced “why refi”) refinances private education loans, consumer debts and/or loans (credit cards, auto deficiencies, and personal loan). Yrefy is a diversified finance company offering financing while utilizing software products for the management of consumers, and business partners. Yrefy provides a customized solution to delinquent, defaulted and distressed private student loans, consumer debt sand/or loans for borrowers to refinance their loan(s) and/or debts into a new Yrefy loan. All loan rates, fees and terms are presented without guarantee and are subject to changes pursuant to Yrefy’s or its partners discretion and may not be available in all states or for all loan programs. There is no guarantee you will be approved or qualify for the advertised rates, fees, or terms presented.

Your personal financial situation is unique, and it is your responsibility to evaluate the information and content provided before making any financial decisions. You should consider obtaining additional information and/or advice from a qualified financial advisor who is fully aware of your individual circumstance.

1. 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.
• De-identified or aggregated consumer information.

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, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	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 (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
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.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

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

2.1 Information we collect directly.

The personal information you provide may include:

• Contact Information: When setting up an Yrefy account to access or subscribe to the Services, you may be required to register. You will be asked to provide certain information, including contact information (such as name, address, email, or telephone number), and professional information (such as job title, department, or job role). You agree to provide and maintain true, accurate, current, and complete information about yourself as prompted.
• Financial Information: If you are making payments for escrow or monthly loan payments, through any of service of ours or associated with us, we may require you to provide bank account, debit card, or other financial information to process a payment from you. You should never provide detailed debit card information directly to Yrefy via an unsecure form (such as email).
• Transaction Information: We will maintain a record of your transactions, your information, your services history, and usage. We may also retain your communications with us and our responses.
• Partner Products & Services Offered on the Services: Third parties, such as our partners, sponsors, or advertisers whose services are promoted or advertised on the Services, may request that you provide personal information. Please see How We Share Information in Section 4 below for further details.
• Surveys: You may elect to provide information in connection with surveys in which you participate.
• Emails or SMS Text Messages: If you send us emails or text messages, you should be aware that any information provided in an email or text message may not be secure or encrypted and therefore may be available to others. Please exercise caution if you decide to disclose any personal or confidential information to us in any email.

2.2 Information we collect automatically. When you opt-in for the Loan Program, we (or our third-party partners) may collect information about your device and usage.

We use a variety of technologies (collectively, “Tracking Technologies”) to collect some of this information. Our use of Tracking Technologies is discussed in more detail in Tracking Technologies and Advertising and Analytics Services in Section 5 below.

The use Tracking Technologies to automatically collect the information described below:

• Device Information: We collect certain information about the device you use to access the Services for our Loan Program, including but not limited to IP addresses for your devices, unique device identifiers, browser types, and browser language.
• User History: We log certain usage information about your use of the Services for our Loan Program, which can include a history of the pages you view. If you download and use any Yrefy software or application on your device, the log files will automatically be collected by the application and sent to our servers when your device syncs up for the latest content available.
• Mobile/Location Information: We may collect additional information from you if you access the Services for information on our Loan Program through a mobile device. We may collect your unique device identifier, your device’s operating system, mobile carrier, and/or your location, if you have opted-in for us to do so. The specificity in which your location can be identified depends on the device you are using and how you are connected to the internet. If you enable location services for the Services, we may collect your regional location data periodically as you use or leave open the Services. We may also collect your location information from your IP address or zip code that has been provided to us directly by you. We will use your location data to identify what products, if any, we are legally allowed to offer you.

We may also use location data internally or in conjunction with our third-party service providers to customize your experience and provide offers that may be relevant to you. Depending on the device you use to access the Services, you may be able to control whether location data is collected from the settings on your wireless device.

2.3 Information we collect from third-party sources.

• Third-Party Sources: From time-to-time, we may obtain personal information about you from third-party sources, such as public databases, social networking services, third-party data providers and our joint marketing partners. Examples of the information we may receive from third-party sources include job title, company, location, updated contact information, and other demographic and professional information. We use this information, alone or in combination with other information (including personal information we collect), to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.

1. HOW WE USE THE INFORMATION WE COLLECT

We may use the personal information that we collect through the Services to:

• Provide the products and services you request, process transactions, and send you related information, including confirmations and receipts.
• Provide support and improve the Services and to manage system administration and security.
• Respond to your comments, inquiries, requests, and provide customer service.
• Link or combine information that we collect directly with information from third-party sources or multiple devices to help understand your needs, provide you with personalized content, and provide you with better service.
• Perform statistical and marketing analyses of user behavior.
• Manage your account(s) and send you technical privacy statement and service updates, security alerts, and other administrative messages.
• Send you push notifications via our apps or text (SMS) alerts. Please see Your Choices/How to Opt Out in Section 7 below.
• Conduct surveys.
• Comply with or enforce legal requirements, agreements, and policies.
• If you log in with or connect a social media service account with an Yrefy Service, we may use this data to facilitate your sharing of information between the Yrefy Service(s) and your social media service. This includes using Facebook or another service to comment on Yrefy.com or an affiliated site.
• Carry out any other purpose for which the information was collected.
• Perform other activities that are in our legitimate business interests and consistent with this Privacy Statement.

1. HOW WE SHARE INFORMATION

We may share your personal information with the following types of third parties for the purposes described in this Privacy Statement:

• Administrator Uses: If your use of the Services is managed for you by an account administrator then your account administrator and resellers who provide user support to your organization may have access to your personal information (including your email and other data). Please refer to your account administrator’s privacy policy for more information.
• Partner Products & Services Offered on the Yrefy Services: If you provide personal information to access products or services offered by third parties, such as our partners or advertisers that are offered or promoted on or through the Services, you may be providing your information to both Yrefy and the third party prior to or after applying for the loan. Your personal information will be subject to this Privacy Statement as well as the privacy statements and practices of the other third party service providers. Yrefy is not responsible for, and this Privacy Statement does not cover, such third party’s use of your personal information. The federal Fair Credit Reporting Act permits us to share among our affiliated companies your name, address, and information about your transactions.
• Sharing Information with Third Parties: For our customers with mailing addresses in the United States, Yrefy selectively makes its postal mailing address list email list and other application data available to third parties, including third-party lenders so that they may provide you with information about product or service offerings, events or promotions which may be of interest to you. For example, if your loan application with us is denied, we may provide your contact information to another potential lender. You may opt-out of having such information shared for this purpose. Please see Your Choices/How to Opt-Out in Section 7 below.
• Third parties Providing Functionality: We also work with third parties to provide certain functionalities on the Services and to improve the effectiveness of the Services and its content. Separate and distinct from information Yrefy shares with third-parties, third-party companies may also use Tracking Technologies to independently collect and store information about you and your usage of the Services and may combine this information with information they collect from other sources. The third-party companies that we currently utilize to provide additional functionality with the Services are Google Ads PPC. Please note, we do not control Tracking Technologies used by third parties, and their use of such Tracking Technologies may be governed by their own privacy policies. You can find the privacy statement for Google here.
• Compliance with Law: Yrefy may release information if it is required to do so by law or in the good-faith belief that such action is necessary to: (1) comply with the law or comply with legal process served on Yrefy; (2) protect and defend the legitimate business interests, rights or property of Yrefy, its users, advertisers, customers, sponsors, advertisers, or affiliates; and (3) if we believe your actions are inconsistent with our policies.
• Service Providers: Sometimes we need to share your information with our third-party service providers who help us provide and support the Services and other business functions. For example, we use service providers to assist with the following: analyzing data, hosting data, engaging technical support, processing payments, delivering content, mailing statements to borrowers, email distribution, and providing customer service.
• Advertising Partners: We may partner with third-party advertising networks and exchanges to display advertising on our websites or to manage and serve our advertising on other sites and may share your personal information with them for this purpose. Please see more information in Your Choices/How to Opt Out in Section 7 below.
• Organizational Changes: Should Yrefy undergo a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, Yrefy’s accumulated customer information will be treated as an asset and, like other business assets, subject to transfer to or acquisition by a third-party. We may also disclose information about our users in connection with a commercial transaction where we are seeking financing, investment, support, or funding.
• With Your Consent or at Your Direction. As directed by you or with your consent we may share your information with a third-party.
• All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

1. TRACKING TECHNOLOGIES AND ADVERTISING AND ANALYTICS SERVICES

• Targeted Advertising: We and our third-party partners and vendors (such as Facebook, Instagram, Impact Radius, TikTok, Google) may use Tracking Technologies, such as cookies, pixels, and web beacons and collect and store information about you when you use or interact with our Services, marketing communications, advertising content and/or third-party websites, in order to provide you with targeted advertising based on your browsing activities and interests. These third parties automatically receive your IP address or mobile device identifier when you access the Services or third-party websites. They may also use Tracking Technologies to measure the effectiveness of advertisements, to personalize the advertising content, and to serve you advertisements that are relevant to your regional location. We may also use information collected using third-party cookies and beacons on the Services and in our emails to deliver advertising about our Services when you visit third-party websites.
• Analytics and Ad Serving: When you access the Services, our third-party vendors, including Google, use third-party cookies (such as the Google DoubleClick cookie) to serve you ads based on your previous visit to our website and other websites. To learn more about your choices and in particular Google’s currently available opt-outs for the Web, please see Your Choices/How to Opt Out in Section 7 below.

1. MANAGING TRACKING TECHNOLOGIES

Following is a description of the Managing Tracking Technologies we use and how to manage your preferences.

• Cookies: “Cookies” give users a special ID, which are small text files that are stored in the memory of a user’s computer, mobile, e-reader, tablet or other device used to access the Services. Yrefy employs cookies to recognize you and your access privileges for certain locations on the Services as well as to track site usage. Subscribers who do not accept cookies from the Services cannot access many areas of the Services. We use both “session ID cookies” and “persistent cookies.” Session ID cookies are used to store information while a user is logged into the Services and expire when the user closes his/her browser. Persistent cookies are used to make tasks like logging into the Services easier for returning users by remembering a user’s login information. Persistent cookies stay on a user’s hard drive from one session to the next. “Flash cookies,” known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from standard browser cookies because of the amount of data, type of data, and how data is stored.
• Web Beacons: Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for several purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
• Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Services and is deactivated or deleted thereafter.
• HTML5: We may use HTML5 in the Services, including without limitation in Yrefy mobile websites and certain mobile applications for the iPhone or iPad (and any other Apple iOS device). HTML5 has browser web storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 storage doesn’t use the browser “cookies” file. The ability of a user to disable HTML5 storage while simultaneously leaving cookies enabled is browser dependent.
• E-tags/Cache Browsers/Web Logs: Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and Device identification to improve security, analyze trends and administer the Services. We may track your movement within the Services, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the Internet address from which you linked to our Services, the operating system of your computer, the unique IP address of the computer or Device identification from the Device that you used to access our Services and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Services, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather information. We may also use individual information we collect through web logs to send you targeted offers and other communications.

1. YOUR CHOICES/HOW TO OPT OUT

• Email:
  • Opt-out Links: Any recipient of email notices may opt out of receiving them at any time. To opt out of receiving emails, follow the unsubscribe instructions located near the bottom of each service update, newsletter, or promotional email, or email your request to [email protected].
  • Email Newsletters: You can view, change, or update any or all your email newsletter subscriptions by going through the email preferences link in the footer of the email newsletter or contacting us at [email protected].
  • Marketing Emails: You can view, change, or update any or all of your email newsletter subscriptions by going through the email preferences link in the footer of the email newsletter or contacting us at [email protected].
  • Transactional Emails: If you are a borrower and do not wish to receive email statements, annual notices, and other communications regarding your account by email, you can email your request to [email protected]. Please note that even if you opt out of receiving communications by email, we may continue to send you borrower communications by direct mail.
  • Surveys Sent by Email: You may elect not to receive surveys conducted by Yrefy that are sent by email by using the opt-out link contained in such emails.
• Postal Addresses: Yrefy collects postal mailing address information from you so that Yrefy may keep your contact and account information current. We may also use it to inform you of Yrefy programs, products, and services in which you may be interested. If you want to opt out of receiving marketing communications via postal mail from Yrefy in the future, please send an email to [email protected]. Please note that even if you opt out of receiving marketing communications by postal mail, we may continue to send you transactional communications about your account by postal mail.
• Push Notifications: If you use an Yrefy mobile app, we may ask if you want to receive push notifications so that we can send you updates, communications, and other messages about the Services. To opt out of getting these push notifications or other messages, you must turn off the push notification function in your device settings.
• Sharing with Third-Party Partners: Yrefy selectively makes its postal mailing address list and email list of customers available to third parties whose products or service offerings may be of interest to you. If you do not wish for Yrefy to provide either your postal mailing or email information (or both) to third-parties for this purpose, please send us a notice using the contact details provided in Contact Information in Section 15 below. Nevada, Maine, and California Residents also see Section 9 below. You can also specify that you do not want your email information shared with third-party marketing partners by contacting us at [email protected].
• Turning Off Tracking Technologies: You can choose to have your computer warn you each time a persistent or session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies and may not disable HTML5 storage. To learn how to manage privacy and storage settings for Flash cookies. It is important to remember that many of Yrefy’s services may not function properly if your cookies are disabled. For example, Yrefy needs first-party cookies to log you in to the Services that require registration. In that case, you may set your browser to block third-party cookies and allow Yrefy’s first-party cookies only.
• “Do Not Track” Signals: Some third-party browsers provide “do not track” machine readable signals for websites which are automatically applied by default and therefore do not necessarily reflect our visitor’s choice as to whether they wish to receive advertisements tailored to their interests. As a result, currently, Yrefy does not respond to browser “do not track” signals or other similar mechanisms.
• Google Opt-Outs: Google is one of the companies that we use to serve advertising and perform analytics on some of the Services. To learn about Google Analytics’ currently available opt-outs for the Web, click here. To learn more about how Google uses cookies in advertising, you can visit the Google Advertising Privacy & Terms policy located here. You can opt out of receiving interest-based Google ads, or customize the ads Google shows you, by clicking here. Yrefy also uses third-party services for remarketing Yrefy’s products and services, such as Google’s Customer Match via the Google platform, whereby we will deliver targeted ads to you based on your prior usage on the Services. If you want to opt-out of remarketing, please email us at [email protected].
• Credit Bureaus Opt-Outs: TransUnion and Experian allow Yrefy to offer “pre-screened” offer of credit based on the information in your credit report indicating that you meet certain criteria. If you do not want to receive prescreened offers of credit contact;

• Equifax at (888) 567-8688; or visit the website at optoutprescreen.com; or write Equifax Information Services, LLC P.O. Box 740123, Atlanta, GA 303074-0123;

• • TransUnion at (888) 567-8688; or visit the website at www.optoutprescreen.com; or write TransUnion Opt Out Request PO Box 505 Woodlyn, PA 19094-0505;
  • Experian at (888) 567-8688; or visit the website at www.optoutprescreen.com; or write Experian Opt Out Request PO Box 919 Allen, TX 75013.

1. RIGHT OF ACCESS

You may access, correct, or update the information you have provided to us. Yrefy takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You can update your account information by logging into your online account and updating your contact and profile information. You can view, change or update your editorial newsletter preferences, and email marketing preferences by contacting email us [email protected]. You may also contact us at any time by using the contact details provided in Contact Information in Section 15 below.

1. DATA PRIVACY RIGHTS – NV, ME, CA RESIDENTS ONLY

1. 1. Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

2. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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.) (for California residents only).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a 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 de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

1. 1. Exercising Access, Data Portability, and Deletion Rights

To exercise your rights to access, data portability, and deletion of your personal information from the Site, you must submit a verifiable consumer request to the Operator by emailing us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

1. 1. 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 [email protected].

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.

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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time by:

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing [email protected].

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by:

1. 1. Non-Discrimination

We will not discriminate against you for exercising any of your California Consumer Privacy Act of 2018 (“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 a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

1. 1. Shine The Light Law (CA Residents only)

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected], or submit a Do Not Sell My Personal Information request or call (844) 674-8161 (within US) or (845) 267-3007 (outside the US).

1. LINKS TO OTHER WEBSITES

Yrefy is not responsible for the content or the privacy policies of websites to which it may link. This Privacy Statement applies solely to information collected by Yrefy. You should consult the respective privacy policies of any applicable third parties to learn more about their privacy practices.

1. HOW WE KEEP YOUR INFORMATION SECURE

To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate technical, organizational, physical, electronic, and managerial procedures designed to protect the information we collect. Specific measures we use include installing anti-intrusion hardware and firewalls, virus scans, monitoring Operating System and software logs and applying software patches. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Yrefy restricts access to non-public personal information about you to those employees who need to know that information to provide products and services for you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

Please understand, however, that while we try our best to safeguard your personally identifiable information once we receive it, no transmission of data over the Internet or any social media or other public network can be guaranteed to be 100% secure.

To help protect the privacy of your own information, including maintaining the confidentiality of any account information or access credentials, we recommend you take precautions to protect the security of any personal information that you transmit over any public or untrusted network by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personally identifiable information. You are responsible for the security of your information when using unencrypted, open access, public or otherwise unsecured networks.

1. CHILDREN

Our Services are directed at a general audience and not directed to those under the age of 18. Yrefy asks that minors not submit any personal information. Yrefy does not knowingly collect personal information from individuals under 16 years of age and if we obtain actual knowledge that a user is under 18 years of age, we will take steps to remove that individual’s personal information from our systems.

1. HOW LONG DO WE RETAIN YOUR INFORMATION?

We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, we retain information to provide you with services, to comply with applicable legal, tax, or accounting requirements, and to enforce our agreements, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, or take other actions permitted by law. We may also retain information to prevent re-registration if your account has been suspended or terminated or to create an archival copy of your information, which might be used by us for record keeping and internal purposes.

1. CHANGES TO THIS PRIVACY STATEMENT

From time-to-time, Yrefy may update its Privacy Statement. Where these changes are material in nature we may notify you either by prominently posting a notice of such changes prior to implementing them, by directly sending you a notification, or by posting the most recent version of the Privacy Statement on the Services, with the “Last Updated” date posted at the top. You should check the Services frequently for updates. By accessing the Services after the “Last Updated” date, you are deemed to consent to our then-current Privacy Statement. We encourage you to review this Privacy Statement frequently to be informed of how Yrefy is collecting and protecting your information.

1. CONTACT INFORMATION

If you have any questions, comments, or concerns, please contact us using the details below:

For United States and other Non-EEA residents:

Yrefy, LLC

Data Privacy Management: Compliance and Customer Service Departments

Attention: Customer Service

Address: 6910 E. Chauncey Lane, Suite 105, Phoenix Arizona 85054

Phone: (888) 703-6501

Email: [email protected]

For the avoidance of doubt, it is important to understand that this opt-out shall not prohibit any disclosures made for non-marketing purposes.

• Corrections/Cancellations and Questions. Upon your request, Yrefy will provide you with its record of the personal information you gave Yrefy at registration. For security reasons, this information will only be sent to the email address on file for the subscriber ID associated with it. With respect to corporate or company accounts, aggregated or individual user history may be shared with the account holder, upon request. If you have any questions about this Statement or would like Yrefy to correct any of your personal information, you can email your corrections to [email protected]. We will endeavor to comply with your requests as soon as reasonably possible, but changes requested of us may not be effective immediately. We are not responsible unless required by law, to inform third parties with whom we have already shared your information of any changes requested pursuant to this section. We are not responsible for removing information or causing information to be removed from the databases or records of such entities.
• Options for Paper or Non-Electronic Records. You may request this Privacy Statement or other documentation in paper copy by contacting Yrefy. Yrefy will provide paper copies at no charge. Yrefy will retain all requests as applicable by law. To obtain a paper copy from Yrefy, please email us at [email protected] with your request.