Privacy Policy

Banker’s Toolbox, Inc., d/b/a Abrigo, Inc. (“Abrigo”, “us”, “our” or “we”) owns or operates several websites, applications (“Customer Applications”), and other online interactive features and services, including, but not limited to, emails, newsletters, communities, and webinars (collectively “Services”).  This Privacy Policy (“Policy”) covers personal information Abrigo collects, records, organizes, stores, adapts and otherwise uses (“Processes”) about the individual who uses our Services (“you” or “your”), regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.  

Scope of Policy 

This Policy only applies to Personal Information we Process as a “data controller” / “business”; for example, when you visit our website. As used in this Policy, “Personal Information” means information that is about an individual, or from which any individual is directly or indirectly identifiable. Abrigo is a financial technology company that provides technology and related services to enable financial institutions, such as banks, credit unions, and auto finance lenders (“Customers”) to offer financial offerings, such as automating their lending and credit processes and managing fraud detection. We provide the Services to our Customers under the Abrigo Master Terms and Conditions. Sometimes individuals provide information about themselves to our Services, but we receive this information to provide the Services to our Customers. We refer to these individuals as “Consumers” in this Policy. We make Customer Applications available to Consumers based on our direct relationship with our Customers, as part of providing Services to our Customers. Our Services are only provided to our Customers, which are businesses; we are a “service provider” / “data processor” to our Customers. We do not provide our Services directly to Consumers. If you are a Consumer who uses our Services and would like to learn more about how your Personal Information is handled or how our Customers handle Personal Information about you, please contact the relevant Customer that appears when you utilize the respective Services, including when the Services are a white-labeled UI. 

Categories of Information Collected  

Section Summary:  We may Process your personal details (e.g., your name), demographic data (e.g., your age), your contact details (e.g., your address), records of your consents, details of your employer (where relevant), information about your interactions with our content or advertising, and any views or opinions you provide to us.  We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising.  

We may Process the following categories of Personal Information about you:  

1. Account information: your full name; username or login details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).  
2. Demographic information: gender; age/date of birth; nationality; and language preferences. 
3. Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).  
4. Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).  
5. Location information:  location data that describes the geographic location of your device (“Location Data”).  
6. Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.  
7. Employment details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address), job title, company information, education, work experience and other professional information. 
8. Consumer Information: information about Consumers, such as name, address, bank account number, and credit history.  
9. Other information you choose to provide to us: any views and opinions that you or other users choose to send to us or publicly post about us on social media platforms or in the Services, including on forums.  

We also collect other kinds of information from you or other sources, which we refer to as “Usage Information” in this Policy. Usage Information may include, but is not limited to:  

1. Internet Protocol (IP) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet and generally includes your internet service provider.  
2. Device information, such as device type and settings, including browser and other software used.  
3. Websites or other services you visited before and after interacting with the Services.  
4. Search terms used to find and link to the Services.  
5. Information about your use of the Services, such as usage data and statistical information, which may be aggregated.  
6. Information collected using cookies, pixel tags, local storage, anonymous identifiers, and other technologies, including information collected using such methods and technologies about:  

• Your visits to, and interaction and engagement with, the Services, content and ads on third-party websites, applications, platforms and other media channels (“Channels”), and  

• Your interaction with emails including the content and ads therein (collectively, “Online Data”).  

• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).  

• Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps, and/or clickstream data, including any clicks on customized links.  

 We may combine certain kinds of Personal Information with Usage Information that may not singly identify you, at which point it becomes Personal Information. For more information about how we Process Usage Information and your choices, see “Cookies and Similar Technologies” below.   

Sources of Personal Information  

Section Summary:  We may collect or obtain Personal Information about you directly from you (e.g., where you contact us), in the course of our relationship with you, when you visit our Services, when you register to use any part of the Services, when you interact with any third-party content on the Services, or when you download, install, or use any of our Services.  We may also receive Personal Information about you from third parties (e.g., social network sites). We may also supplement Personal Information about you, such as with records of your interactions with us. Abrigo is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This Policy does not cover the practices of third parties who may provide information about you to Abrigo.  

We may collect Personal Information about you from the following sources:  

1. Data you provide.  When you provide it to us across our Services (e.g., where you sign up for emails, newsletters, webinars or white papers; register for site membership or create a profile or account on any part of the Services; participate in surveys; perform search queries through the Services; contact us via email, telephone, SMS text message or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).  
2. Our Customer. In the ordinary course of our relationship with you or our Customer (e.g., if you or our Customer purchase a Service from us).  
3. Publicly available sources. When you make Personal Information public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.  
4. Service data.  When you visit, download, use or register to use any part of our Service.  
5. Content and advertising.  If you choose to interact with any third-party content or advertising on the Services or Channels, we may receive Usage Information about you from the relevant third-party.  
6. Third-party information. From third parties who provide it to us.  This may include offline channels such as telephone or direct mail efforts; from vendors, suppliers, third parties, commercially available, or publicly available sources (e.g., data brokers, data aggregators, public databases, etc.); third-party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.).  

Please note that Abrigo is not responsible for the information you volunteer about yourself in the discussions in certain areas of the Services, such as forums, blogs, communities, message boards, or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content.  We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us by emailing [email protected]. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.  

This Policy does not cover the practices of third parties, including those that may disclose information to Abrigo.  

 We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.  

Purposes for Processing and Using Personal Information  

Section Summary:  We may Process Personal Information for the purposes of providing the Services to you, communicating with you, providing advertising to you, analyzing engagement with our audience, observing user engagement and purchase activity across the Services and Channels, marketing our services and offerings to current and prospective customers, managing our IT systems, financial management, conducting surveys, ensuring the security of our systems, conducting investigations where necessary, compliance with applicable law, and improving our Services.  

The purposes for which we may Process Personal Information, subject to applicable law, include: 

1. Provision of the Services to You: providing the Services, such as: 

• reselling and providing third-party services (“Authorized Services”),  

• allowing you to search for other website members using information you may already know about that member such as username, full name and identify users matching those criteria, 

• management of your account, and 

• customer support and relationship management. 

2. Offering and Improving the Services:  operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services. 

3. Promoting our Services and Authorized Services: posting of your personal testimonial alongside other endorsements; display of your personal reviews of products or services. 

4. Surveys:  engaging with you for the purposes of obtaining your views on our Services. 

5. Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required by applicable law.  For more information about our marketing practices, please see the “Marketing Communications” section below. 

6. Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using Usage Information to serve you advertisements.  For further information, please see the “Cookies & Similar Technologies” section below. 

7. Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels. 

8. User Engagement and Purchases: tracking activity across the Services and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made. 

9. Marketing to Customers: market to current and prospective Customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Abrigo in order to further generate and promote our business.  Such efforts include sending marketing emails or conducting phone calls to drive the purchase of Services, lead generation, and other business services offered by Abrigo. 

10. IT Administration: administration of Abrigo’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements. 

11. Security: to help mitigate the risk of and provide the ability to identify and rectify a security incident; protect the security or integrity of our Services, your information, the public, and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities, and managing risk exposure. 

12. Financial Management: general business and financial management purposes, including economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements. 

13. Quality Assurance: perform quality assurance; to assist with fraud identification and to assist our customer representatives, we use tools to monitor and record certain user experience information, including, without limitation, audio of customer service calls and information resulting from such calls. 

14. Investigations: detect, investigate, and prevent breaches of policy, laws, and criminal offenses, in accordance with applicable law. 

15. Legal Proceedings: establish, exercise and defend legal rights. 

16. Regulatory Compliance:  Subject to applicable law, we reserve the right to release information concerning any user of the Services when we have grounds to believe the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations.  We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of Abrigo, any of our users or the public, or to respond to an emergency. 

Deidentified Information 

Abrigo may deidentify information about you and/or Consumers such that it cannot reasonably be used to infer information about an individual or otherwise be linked to an individual (or we may collect information that has already been deidentified), and we may use and disclose such deidentified information for any purpose, including without limitation, so we can build and continually improve our industry benchmark database, financial models, and other products. To the extent we possess or Process any deidentified information, we will maintain and use such information, in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements. 

Data Security  

Section Summary:  We implement appropriate technical and organizational security measures to protect your Personal Information.  Please ensure that any Personal Information that you send to us is sent securely.  

While we have implemented commercially reasonable technical and organizational security measures designed to protect your Personal Information, we cannot guarantee the security of our systems or the transmission of data over the Internet. We are not responsible for any breach of security or for the actions of any third parties. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.  

Data Retention  

Section Summary: We retain Personal Information for as long as needed.  

We Process Personal Information for the minimum period necessary for the purposes set out in this Policy. We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide our products and services, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests. The length of time we retain personal information depends on the nature of the information, the purposes for which it is processed, applicable legal requirements, contractual commitments, and operational needs. When personal information is no longer required, we delete or de-identify it in accordance with our records retention practices and applicable law. 

Marketing Communications  

Section Summary:  We may Process your Personal Information to contact you with information regarding services that may be of interest to you.  

We may Process your Personal Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services (or Authorized Services) that may be of interest to you. We may send information to you regarding the Services (or Authorized Services), upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.  

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in the email we send.  We will not send you any emails from a list from which you have unsubscribed, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.  You may opt out of any telephone marketing by contacting us by emailing [email protected].  

Cookies & Similar Technologies  

Section Summary:  We may Process your Personal Information via Cookies and similar technologies on the Services and Channels.  Certain tracking technologies enable us to assign a unique identifier to you and relate information about your use of the Services to Other Information about you, including your Personal Information for the purposes of learning more about you so we can provide you with relevant content.  We and our advertising partners also use these technologies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to marketing campaigns.  

Abrigo and third parties who assist with advertising, retargeting, measurement, audience insights, and marketing activities (“Advertising Partners”) collect information about you, such as Usage Information, including Online Data, through cookies and similar technologies (such as pixel tags, SDKs, or local storage) to operate, secure, measure, and improve the Services, and deliver cross behavioral online advertising. These technologies also help us analyze trends and usage patterns, measure traffic, and understand how users interact with the Services, assess the performance of our marketing campaigns, and understand user behavior and general demographic trends to improve functionality and advertising relevance. We and our Advertising Partners may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information.  For example, these advertisements may appear when you are on another Channel.  

You can control the use of certain tracking technologies at the individual browser level, but if you choose to disable certain tracking technologies, it may limit your use of certain features or functions on the Services. Please see our Cookie Policy for more information, including a more in-depth explanation of what cookies are, the different types of cookies used on the Services, and how to change or delete them.  

Tracking technologies on the Services may be deployed by Abrigo and/or by our service providers or Advertising Partners.  Certain tracking technologies enable us to assign a unique identifier to you and relate information about your use of the Services to other information about you, including your Usage Information.  We may combine information collected at different times and obtained from different sources (including from third parties) to learn more about you, understand usage patterns, and improve and personalize content and advertising.  

When you receive email messages or newsletters from us, we may use tracking technologies to determine whether the email has been opened and which links you click so that we can measure engagement, refine future communications and improve the Services.  

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices.  This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.  We may link this information to Personal Information.  

We may use Usage Information, Online Data as well as other Personal Information to send you advertisements. For example, if you read an article about a subject on the Services, we may use tracking technologies to later serve you an advertisement for a specific product or service related to the viewed article.  

For information about how to opt out of tracking methods for these entities and others, click here. For more details about cross behavioral online advertising and opting out, see the Controlling Your Information section of this Privacy Policy. 

Do Not Track & Global Privacy Controls  

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of information about you when you visit various websites.  

Our website recognizes the Global Privacy Control (GPC) signal which enables you to opt out of certain uses or disclosures of information about you. If you notify us of your preference through GPC, we will honor your request only for the browser or device that sends the GPC signal. If you do not have an account or are not logged into your account, your request to opt out through the GPC will not apply to any account information. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org or https://innovation.consumerreports.org/data-rights-protocol-and-global-privacy-control/. 

Disclosure of Personal Information  

Section Summary:  We may disclose your Personal Information to legal and regulatory authorities, our external advisors, parties who Process Personal Information on our behalf (“Processors”), any party as necessary in connection with legal proceedings, any party as necessary for investigating, detecting or preventing criminal offenses, any purchaser of our business, and any third-party providers of advertising, plugins or content used on the Services.  

We may disclose your Personal Information to other entities within the Company for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law.   

In addition, we may disclose your Personal Information to:  

1. Legal and regulatory authorities, upon request, or for the purpose of reporting any actual or suspected breach of applicable law or regulation  
2. Outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality  
3. Third-party Processors (such as analytics providers; data centers; etc.) subject to the requirements noted in this section  
4. Relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise, or defense of legal rights  
5. Relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security  
6. Third parties in connection with or anticipation of a sale, transfer, merger, reorganization, dissolution, bankruptcy, or liquidation  
7. Third-party provider, where our Services use third-party advertising, plugins or content  
8. Advertising Partners for purposes of advertising, including online cross-contextual advertising, such as ad platforms and ad networks. 

California Residents  

Section Summary: This section provides California-specific disclosures required under the California Consumer Privacy Act (“CCPA”). We describe the categories of personal information we collect, sell, and share for cross-context behavioral advertising. 

This section applies to you only if you are a California resident. For purposes of this section, references to Personal Information shall include “sensitive personal information,” as these terms are defined under the CCPA. 

Processing of Personal Information 

In the preceding 12 months, we collected the categories of personal information listed in the table below (as enumerated and defined in the CCPA). For each category of personal information, we indicate: (i) the business or commercial purposes for which the information was collected or used, as described in the Uses of Information and Legal Bases section above, and (ii) the categories of recipients to whom we disclosed the information for a business purpose, as described in the Disclosure of Information section above. 

We only use and disclose sensitive personal information for the purposes permitted under the CCPA. 

Do Not Track & Global Privacy Controls