PRIVACY POLICY

Last Updated: November 25, 2024  

At Repo-IQ, we take great pride in being a part of the repossession industry—a field that plays a crucial role in supporting businesses of all sizes, and in many fields. We welcome the opportunity to collaborate with our peers and colleagues, working together to create a more approachable environment and to enhance the industry’s standards and practices. Our commitment to fostering a collegial atmosphere reflects our belief in the importance of integrity and professionalism. We look forward to working with you. 

We respect your privacy and invite questions to be sent to support@repo-iq.com, should you wish to contact us.   

This Privacy Policy is designed to explain how we collect, use, share, and protect the information provided to us when you access our “website” (www.repo-iq.com), contract with Repo-IQ, purchase our services or related products, attend our events or engage with us on digital platforms, as well as your rights to the information we collect. As used in this policy, terms such as “we” or “our” and “company” refer to Manaray Consulting LLC dba Repo-IQ, a Texas Limited Liability Company, and any current or future affiliates. The website is not intended for use by minors under the age of 18. We do not knowingly collect Personal Data as defined hereunder from minors under the age of 18. 

Please read this Privacy Policy carefully before using, working with, or otherwise engaging with Repo-IQ.   

We will alert you to any changes to this Privacy Policy by changing the “last updated” date at the top of this page.  Any changes become effective immediately upon publication on our website, and you waive specific notice of any changes to the Privacy Policy by continuing to use and access our website.  We encourage you to review this Privacy Policy periodically, when you use our website for any purpose or otherwise engage with us. You are deemed to have accepted any changes to any revised Privacy Policy by your continued use of our website after the revised Privacy Policy is posted. 

At the end of this Policy, we will ask those of you located in the European Economic Area (which includes all EU countries plus Iceland, Liechtenstein and Norway) to click a box indicating that you agree to this Policy. If you do not wish to click the box, then please do not use the website. 

You understand and agree to the following terms: 

  1. INFORMATION THAT WE COLLECT 

We collect a variety of information from you when you visit our website, make purchases, or interact with us on social media. By accepting this Privacy Policy, you are specifically consenting to our collection of the data described below, to our use of the data, to our direct, indirect or facilitation in the aggregation of data, to the processing of this data, and to our sharing of the data with third party processors as needed for our legitimate business interests and within the parameters of the law. The information we collect may include: 

 

  1. Personal Data: Personal Data, also commonly known as Personally Identifiable Information or PII (collectively “personal data”) is information in any format that can be used to identify you specifically, including, but not limited to, your name, shipping address, email address, telephone number or demographic information like your age, gender, or hometown. You consent to giving us this information by providing it to us voluntarily when visiting or engaging with the website or any digital, mobile or social application, or when engaging with Repo-IQ. You provide some of this information when you register with or make purchases via our website.  You may also provide this information by participating in various activities associated with our website, including responding to us or contacting us with questions. Your decision to disclose this Personal Data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website or from making purchases. Please note that information that has been anonymized, aggregated, or scrubbed of PII so that it no longer can be used to identify you specifically, is not considered Personal Data under this Privacy Policy or the Terms and Conditions governing the website; please reference the license outlined in this Privacy Policy and the Terms and Conditions (collectively, the “governing documents”), for further details. Such scrubbed or aggregated data, which cannot be used to identify you, may be used or shared without restriction. 
  1. Aggregated Data: Aggregated data includes, but is not limited to, any Personal Data that the company assembles and compiles, through various methods including third-party data aggregation tools that collect, process and present the aggregated data, from which all identifying information has been removed so that the Personal Data cannot be used to identify you specifically. Such aggregated data, which cannot be used to identify you, may be used or shared by the company without restriction. Find additional information about the aggregation of data in the governing documents, including the below Section II(2). 
  1. Derivative Data: Derivative data includes, but is not limited to, the information that our servers automatically collect about you when you access our website, such as your IP address, browser type, the dates and times that you access our website, and the specific pages you view.  If you are using a mobile application, our servers may collect information about your device name and type, your phone number, your country of origin, and other interactions with our application. 
  1. Financial Data: Financial data includes, but is not limited to, the data that is related to your payment method, such as credit card or bank transfer details. We collect financial data to allow you to submit payment for our services. We store limited financial data. Most financial data is transferred to our payment processor or any other third-party payment processor that we may employ, and you should review the processor’s Privacy Policy to determine how they use, disclose, and protect your financial data.  
  1. Publicly Disclosed Data: Information that you publicly disclose or share online, whether through social media platforms, public forums, blogs, or other publicly accessible websites, is not considered confidential or protected under this Privacy Policy. Repo-IQ reserves the right to collect, use, and analyze such publicly available information for purposes including, but not limited to, aggregation, metrics, analytics, reporting, or research. Publicly disclosed information may also be combined with other data, anonymized, or aggregated for business insights, statistical analyses, or to improve our services. This usage of publicly disclosed information is not restricted and does not require further consent from you, as it is not subject to the same protections as confidential or Personal Data under this Privacy Policy. 
  1. Mobile Device Data: If you use our website via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information. 

 

  1. HOW WE USE YOUR INFORMATION 
  1. Types of Usage: Your information allows us to offer you services including the use of our website, to fulfill our obligations to you, to customize your interaction with our company and our website, and to allow us to suggest other products and services we think might interest you. We generally store your personal data and transmit it to a third party for processing. Specifically, some of the ways that we may use the information and data described above are to: 
  1. Create and administer your account.  
  1. Deliver any products or services purchased by you to you. 
  1. Correspond with you. 
  1. Process payments pursuant to your Master Services Agreement (“MSA”).  
  1. Contact you about updated or new offerings. 
  1. Interact with you via social media. 
  1. Deliver targeted advertising. 
  1. Request feedback from you. 
  1. Resolve disputes and troubleshoot any issues. 
  1. Generate a profile that is personalized to you, so that future interactions with our website will be more personal. 
  1. Anonymize, scrub and aggregate data for our own use or for a third party’s use. 
  1. Assist law enforcement as necessary. 
  1. Prevent fraudulent activity on our website. 
  1. Analyze trends to improve our website and offerings. 
  1. License for Anonymizing, Scrubbing, and Aggregating Data: By providing us with your Personal Data, you grant Repo-IQ a limited, non-exclusive, royalty-free license to process, use, and disclose such information to our personnel, consultants and hired professionals, who are subject to a non-disclosure agreement and handling instructions for such Personal Data, for the specific purpose of anonymizing, scrubbing, or aggregating it, at which point it will no longer be Personal Data per the terms of this Privacy Policy or the Terms and Conditions. This process is intended to transform the data so that it no longer identifies you personally or discloses confidential aspects of your personal data. For the purposes of the governing documents: 
  1. Anonymizing means modifying Personal Data and/or Confidential Information so that it cannot be used to identify you personally, directly or indirectly, by removing or obscuring identifiable elements, including but not limited to names, contact information, and demographic details. 
  1. Scrubbing means removing or altering specific elements of Personal Data and/or Confidential Information to eliminate any information that could potentially be linked back to you or any specific individual or entity, ensuring the data cannot be reconstructed to reveal identifiable details. 
  1. Aggregating means combining your personal data with the data of other individuals or entities in such a way that it is presented as part of a larger dataset, and individual identities or specific confidential details are no longer distinguishable or discernible. 

Once Personal Data or Confidential Information has been anonymized, scrubbed, or aggregated pursuant to this license, the resulting data will no longer be considered Personal Data or otherwise Confidential Information, under this Privacy Policy or any applicable legal framework. As such, Repo-IQ may use, share, sell, or otherwise disclose this transformed data without restriction or further notice to you. 

 

  1. WHY WE DISCLOSE YOUR INFORMATION 

We may share your personal data with third parties in certain situations. In particular, we may share your personal data with third-party processors as needed to serve our legitimate business interests, which include, but are not limited to, administration of our website, administration of your account, entering into contracts with you, communicating with you, taking orders for goods or services, delivering our goods and services, identifying trends, protecting the security of our company and website, and marketing additional goods and services to you. The legal basis for our disclosure of your personal data is both your consent to this Privacy Policy, the license and grants outlined hereunder, and our own right to protect and promote our legitimate business interests. 

The following are specific reasons why we may share your personal data: 

 

  1. Third Party Processing: We may disclose your personal data to third parties who assist us with various tasks, including payment processing, hosting services, email delivery, and customer service.  For more information, see the “Processing Your Information” section below. 
  1. By Law: We may share your personal data as required by law or to respond to legal process, including a subpoena, or as necessary to protect the rights, property, and safety of others.  This includes sharing information with other parties to prevent or address fraud and to avoid credit risks. 
  1. To Protect Our Company: We may use your personal data to protect our company, including to investigate and remedy any violations of our rights or policies. We may also disclose your personal data as reasonably necessary to acquire and maintain insurance coverage, manage risks, obtain financial or legal advice, or to exercise or defend against legal claims. 
  1. Other Third Parties: We may share information with service providers, our investors, or other third parties for business purposes.  
  1. Sale or Bankruptcy: In the event that our company is party to a merger, or investment, accepts new members, is sold, goes out of business, or enters bankruptcy, your personal data may be an asset that is disclosed to or transferred to a third-party successor.  Such a successor may not bound by our Privacy Policy and may have its own; you accept that while we will make a reasonable effort to notify you of such an event, it is your sole responsibility to check the website’s Privacy Policy for any updates.  
  1. Interaction with Others: If you interact with others on our website, other users may have access to some of your personal data, including your name, profile picture, and your history of interaction with our website, such as prior comments or posts. 
  1. Online Postings: When you post online, your posts may be viewed by others, and if they pertain to us, we may distribute your comments outside the website. 
  1. External Links: Our website may include hyperlinks to other websites not controlled by us. We suggest you exercise caution when clicking on a hyperlink. Although we use reasonable care in including a hyperlink on our own web page, we do not regularly monitor the websites of these third parties, and we are not responsible for any damage or consequences you suffer by using these hyperlinks. We are not bound by the privacy policies of any third-party website that you access by a hyperlink, nor are they bound by ours. We encourage you to read the Policies of those third-party websites before interacting with them or making purchases. They may collect different information and by different methods than we do. 
  1. Other Purposes: We may disclose your personal data as necessary to comply with any legal obligation or to protect your interests, or the vital interests of others or our company. 

 

  1. COOKIES, LOG FILES AND WEB BEACONS. 

Like many other websites, we make use of log files, which log visitors to the site, usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track a user’s movement around the site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable. We also use cookies – small text files sent to us by your computer – and web beacons to store certain information. We may use cookies to authenticate your identity, to determine if you are logged onto our website, for personalization, for security, for targeted advertising, or for analysis of the performance of our website and services. We use cookies that are not specific to your account but unique enough to allow us to analyze general trends and use, and to customize your interaction with our website. Cookies may include “single-session cookies” that generally record information during only a single visit to a website and then are erased, and “persistent” cookies that are generally stored on a computer unless or until they are deleted or are set to expire. Most browsers are set to accept cookies by default.  In addition, when you first encounter our website, you will be asked to “consent to cookies.” If you wish to disable cookies, you may do so through your individual browser options.  However, this may affect your ability to use or make purchases from our website. By continuing to use our website and not disabling cookies on your browser, you are consenting to our use of cookies in accordance with the terms of this Policy.   In addition, we may use third-party software to post advertisements on our website or mobile app to oversee marketing or email campaigns or manage other company initiatives. This third-party software may use cookies or similar tracking technology. We have no control over these third parties or their use of cookies. For more information on opting out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool. 

 

  1. WEBSITE ANALYTICS 

We may partner with third-party analytic companies. The analytic companies may also use cookies or other tracking technologies to analyze visitors’ use of our website to determine the popularity of the content, and better understand online activity. We do not transfer personal information to these third-party vendors. However, in order to access our website, you must consent to the collection and use of your personal data by these third-party analytic companies. You should review their Privacy Policy and contact them directly if you have questions.  

 

  1. PROCESSING YOUR INFORMATION 

For the most part, we do not process your personal data in-house, but give it to third-party processors for processing. They process your payment and remit the funds to us. So, in many instances, it will be necessary for us to transmit your personal data to a third-party processor, as we do not have the capability to perform these functions. More detail on third-party processing is detailed below. However, we may, from time to time, process your personal data internally. The legal basis for this processing is both your consent to the processing and our need to conduct our legitimate business interests.  Our purposes in processing this information, if we do, is to administer, maintain, and improve our website and offerings, to enter into contracts with you, to fulfill the terms of those contracts, to keep records of our transactions and interactions, to be able to provide you with goods and services, to comply with our legal obligations, to obtain professional advice, and to protect the rights and interests of our company, our customers (including you), and any third parties.  For example, we may process the following data: 

  1. Data associated with your account, such as your name, address, email address and payment information. 
  1. Data about your usage of our website, such as your IP address, geographical information, how long you accessed our website and what you viewed.   
  1. Data related to your personal profile, such as your name, address, profile picture, interests or employment details. 
  1. Data that you provide us in the course of using our services. 
  1. Data that you post on our website, such as comments or responses. 
  1. Data that you submit to us when you make an inquiry regarding our website or offerings. 
  1. Data related to your transactions with us, including your purchase of our goods or services. This information may include contact details and payment information. 
  1. Data that you provide to us when you subscribe to our emails or newsletters, including your email address and contact information. 
  1. Data that you submit to us via correspondence, such as when you email us with questions. 
  1. Any other data identified in this Policy, for the purpose of complying with our legal obligations, or to protect the vital interests of you or any other natural person. 
  1. INTERNATIONAL DATA 

Our website is hosted by servers located in the U.S.  Therefore, if you reside outside the United States, some of your personal data may be transferred internationally to those servers and stored on them. Transfers will be protected by appropriate safeguards.   

 

  1. DATA RETENTION 

We retain personal data as long as it is needed to conduct our legitimate business purposes or to comply with our legal obligations, or until you ask us to delete your personal data, unless deletion is earlier required by law. For example, we will retain certain personal data indefinitely for the purposes of maintaining your account, unless and until you delete your account.  Data that we gather for a specific and particular purpose, such as analyzing trends, will not be kept for longer than is necessary for that particular purpose. Data that is no longer needed by us for any of the purposes listed above will be permanently deleted. 

 

You may request that we delete your personal data at any time.  However, note that we cannot control the retention policies of third parties.   If you wish to have any third parties, including those to whom we’ve transmitted your personal data, delete that data, you will need to contact those third parties directly.  You may request from us a list of all third parties to whom we have transmitted your personal data. 

 

  1. SECURITY OF YOUR INFORMATION 

We take reasonable steps to safeguard your Personal Data through the implementation of reasonable administrative, technical, and physical security measures. We use industry-standard encryption technologies and secure protocols to protect the information we collect from unauthorized access, use, or disclosure. Despite these efforts, no method of transmission over the internet or electronic storage is entirely secure, and we cannot guarantee absolute security of your data. In the event of a data breach involving Personal Data, we will comply with all applicable state and federal breach notification laws and will notify you of any breach involving your Personal Data via email, letter, or other appropriate methods. The notification will include all information that is then required by law. Further, where required by law, we will also notify state regulatory authorities, law enforcement, and other relevant bodies. By consent to this Privacy Policy, you acknowledge that your personal data may be available, via the internet, around the world. We cannot prevent the use or misuse of your personal data by other parties. 

 

  1. YOUR RIGHTS 

You have certain rights with respect to your personal data, as outlined below. Note that we may charge you a reasonable fee for actions that you ask us to take with respect to your personal data, unless otherwise set forth in this Privacy Policy.  In addition, we reserve the right to request that you provide us with evidence of your identity before we take any action with respect to the exercise of your personal data rights. Further, your rights may be restricted or nullified to the extent they conflict with our compelling business interests, the public interest, or the law. 

  1. Update Account Information: You have the right to update or change any information you have provided to us. To update or delete your personal data, please contact us at support@repo-iq.com. 
  1. Confirm Personal Data and Its Use: You have the right to request that we confirm what data we hold about you, and for what purposes. You also have the right to confirmation of whether we process your personal data or deliver your personal data to third party processors, and for what purposes. We will supply you with copies of your personal data unless doing so affects the rights and freedoms of others.   
  1. Change Consent: You have the right to change your consent to our use of your personal data.  In such cases, we may require you to delete your account with us, as described above, and you may not have full access to our website. 
  1. Request a Copy of Data: You have the right to request a digital copy of the data that we hold about you. Your first request for a copy of your personal data will be provided free of charge; subsequent requests will incur a reasonable fee. 
  1. Transfer Your Data: You have the right to request that we gather and transfer your personal data to another controller, in a commonly used and machine-readable format, unless doing so would cause us an undue burden. 
  1. Delete All Data: You have the right to request that we delete all data that we hold about you, and we must delete such data without undue delay. There are exceptions to this right, such as when keeping your personal data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, or is necessary for the exercise or defense of legal claims. Such a request may result in termination of your account with us, and you may have limited or no use of our website. 
  1. Emails and Communications: You may opt out of receiving future email correspondence from us by contacting us at support@repo-iq.com. 
  1. Processing: You may, in some circumstances, restrict the processing of your personal data, such as when you contest the accuracy of your personal data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your personal data but will not pass it on to third-party processors without your consent, except as necessary to comply with legal obligations or protect your rights or those of others or our company.  In addition, you may opt out of any processing of your personal data altogether. Note however that doing so may result in the termination of your account and loss of access to our website. 
  1. Complaints: You have the right to complain to a supervising authority if you believe we are misusing your personal data or have violated any of your rights under this Privacy Policy or applicable law. 
  1. Newsletter or Similar Communication Privacy: We offer the opportunity for you to volunteer certain information to us that is used for email and marketing purposes. This information includes, but is not limited to, your name and email. This data is collected and held pursuant to Company security protocols and in Company files. You will have an opportunity to unsubscribe from any future communications via email, but we reserve the right to maintain a database of past email subscribers. We reserve the right to use this information as reasonably necessary in our business and as provided by law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting our business. We do not ever sell your personal data to third parties. 

 

  1. LEGAL NUTS AND BOLTS 
  1. Severability. If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be enforced to the fullest extent permitted by applicable law, and the remaining provisions of this Privacy Policy shall continue in full force and effect. The invalid, illegal, or unenforceable provision will be deemed modified so that it is enforceable to the maximum extent permitted by law, consistent with the intent of the original provision. 
  1. Please see the Terms and Conditions for additional applicable governing clauses, which govern where this Privacy Policy is silent – LINKED HERE. 

For users who are residents of the forgoing EU Countries listed at the outset of this Policy: I consent to this Privacy Policy Insert Checkbox.  

THE FOLLOWING PROVISIONS INCLUDE STATE-SPECIFIC REQUIREMENTS. In addition to the above terms of our Privacy Policy, some states have implemented state-specific laws, which we address below:  

  1. TEXAS RESIDENTS: The entirety of this Privacy Policy applies in addition to the following provision. 
  1. AI: We may use automated decision-making technologies like artificial intelligence (AI) in the automatization of our website and business processes, which may thereby include processing or handling of your personal data. By engaging with the website, you acknowledge that we may use AI, and that it may interact with your personal data, and you are opting-in to use doing so.  

 

  1. CALIFORNIA RESIDENTS: The entirety of this Privacy Policy applies in addition to the following provision.  
  1. The CCPA And Personal Information. 
    This Privacy Notice only applies to California residents. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and, as amended, the California Privacy Rights Act of 2020 (“CPRA”). This Notice describes how we may collect, use, and disclose information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). This Notice applies to personal information we may collect online and offline in connection with the purchase of distressed consumer receivables, business cards and lines of credit and receivable account management services for creditors in the recovery of past due accounts, including when you use our websites or applications, contact us, or otherwise interact with us (collectively, “Services”). A consumer has rights regarding his/her PI, including: 
  1. A right to know what PI is collected, used, shared or sold by the Company. 
  1. A right to access PI collected and retained by the Company. 
  1. A right to require businesses and, by extension, their service providers, to delete PI, subject to certain exceptions; 
    o A right to opt-out of the Company’s sale of PI; and 
    o A right to non-discrimination in terms of pricing or service for choosing to exercise a privacy right under the CCPA. 

 

We are committed to safeguarding your privacy and will comply with all applicable state, federal, and international laws regarding the collection, use, and protection of personal information, when such laws are applicable to our business operations.  

 

If you require any more information or have any questions about our Privacy Policy, please feel free to contact us by email at support@repo-iq.com.