Online Privacy Notice

Last Modified: 06/11/19

IMPORTANT DISCLOSURE ABOUT THE FDCPA: Nothing in this Site Privacy Notice is intended to contradict your rights under the Fair Debt Collection Practices Act. Insight Capital, LLC will not disclose any information to third parties to the extent prohibited by the FDCPA. Insight Capital, LLC reserves the right to collect outstanding debt in accordance with permissible legal remedies.

INTRODUCTION

Insight Capital, LLC (“Company” or “We”), respects your privacy and is committed to protecting it through our compliance with this online privacy notice (the “Notice”).

This Notice describes the types of information we may collect from you or that you may provide when you visit the website [www.insight-capital.com] (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Notice applies to information we collect:

• On this Website.
• In e-mail, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Notice 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 our Website. By accessing or using this Website, you agree to the terms of this Notice. This Notice may change from time to time (see Changes to our Online Privacy Notice). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Notice periodically for updates.

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Consumer Privacy Notice which offers you certain choices with respect to the use and sharing of your personal information.

CHILDREN UNDER THE AGE OF 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at customerservice@insight-capital.com.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We may collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, Social Security Number, or any other information the Website collects that is defined as personal or personally identifiable information under an applicable law (“personal information”);
• That is about you but individually does not identify you; and/or
• About your Internet connection, the equipment you use to access our Website, and usage details.

We may collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.
• From third parties, for example, our business partners.

INFORMATION YOU PROVIDE TO US

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us or when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we may ask you to complete for research purposes.
• Details of transactions you carry out through our Website. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “Posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and Internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may include personal information; we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Notice:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business; we expect those parties who handle your personal information to keep your information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use an “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our Consumer Privacy Notice.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

For our customers who would prefer we not deliver marketing offers in email, postal mail, or through telemarketing, you may manage your direct marketing choices by telephone at 1-833-774-6744, or you can email us at customerservice@insight-capital.com (for all customers who do business with us).

For non-customers who wish to be placed on our Do-Not-Contact registries for marketing (phone, mail, text, email), non-customers may make that election by contacting us at 1-833-774-6744, or you can email us at customerservice@insight-capital.com.

We currently do not have software recognizing do-not-track (DNT) settings that you may have set in your browser. Such DNT signals or mechanisms may provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities overtime and across third-party websites or online services. However, the Company does not track your activities over time across various websites except as otherwise stated directly above. In limited circumstances, third parties may track your activities over time across sites, including this Site, such as website analytic tools.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website such as message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

The Company is not responsible for third parties’ (companies to which we link from our Website) online security practices. In most cases, we provide links to non-Company websites solely to help you find more information about topics that interest you. Third-party websites may have different privacy policies and/or security standards to govern their sites; we encourage you to learn about their privacy and security policies and practices.

CHANGES TO OUR ONLINE PRIVACY NOTICE

It is our policy to post any changes we make to our Notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you. To the extent you engage in an online business with our Company, then we will notify you by email via the email address specified in your account. Otherwise, we will notify you through a temporary notice on the Website home page. The date the Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Notice to check for any changes.

CONTACT INFORMATION

To ask questions or comment about this Notice and our privacy practices, contact us by telephone at 1-833-774-6744, or you can email us at customerservice@insight-capital.com.