Privacy Policy

Elite Finance Data Services and Website Privacy Policy

**Elite Finance** (“We,” “Our,” “Elite Finance”) provides data marketing services (the “Services”) designed to help for-profit and non-profit organizations, and companies that work with them, to market their goods and services in a relevant and efficient way. Our solutions, many of which are described on this website, are used principally to support email marketing.

We take very seriously the privacy interests of the individuals whose information we handle and maintain in our database. We provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage information, and what rights consumers have to control how their information is used in marketing.

To review the “Addendum” we have created specifically to address disclosures required under the California Consumer Privacy Act, please see our **“ADDENDUM FOR CALIFORNIA RESIDENTS”** below.
We also operate corporate websites, designed for our own customers and prospective customers, and others who want to learn about our services. We address the information we collect and use for those business purposes (such as information we use to communicate with our corporate customers, and potential customers) in Section 6 of this Privacy Policy.

#### Information That We Collect and Use in Our Services
In order to provide our Services, we receive data, including personal information, from a variety of sources, including from websites and apps that collect the information, public sources, and other data compilers. We refer to the information that we collect and process throughout this Privacy Policy as “Information” or “the Information.”

The Information in our database includes various identifying information, such as:
- Personal email
- Professional email
- Information and actions associated with an email, such as whether an email has recently been in use, and amount and type of marketing or “email open” activity associated with an email
- IP address
- A cookie or device identifier, which uniquely identifies your browser or device
- Usage data related to your email interactions, such as whether you receive, open, or respond to an email, and related information
- Usage data related to your website interactions, such as whether you visit or log in to a website, page visits, and related information
- Demographic information, such as inferenced income or age range, household size, or homeownership
- Information regarding consumer interests, such as what type of products you may be interested in, or what types of hobbies you might have, such as whether you are a likely pet owner or a sports or art enthusiast
Some of the above information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range.

We may combine any of the points of Information we collect or receive with other Information.
Elite Finance also receives information through this website (and any other website we operate), and our business operations. We describe this information in Section 6.

#### How We Use the Information
Elite Finance uses the Information for various purposes, including the following:
As Part of Our Services:
- **Data Marketing Services**: Our Services include providing marketing information to our customers, generally regarding which customers or prospective customers are most likely to be interested (or disinterested) in certain offers. We also help our customers identify and understand their customers better, by providing insights about them. Our customers include (but are not limited to) small and medium-sized businesses, ad and media agencies, brands, and marketing data platforms that help their customers to market and advertise to their own customers (and prospective customers). Our customers also may include other data compilers, who work with their own customers.
 
- **Retargeting Services**: We sometimes help our customers to “retarget” marketing content to website visitors. In particular, our Services help customers send emails to people who visited or logged in to their websites by cross-referencing information such as cookie identifiers and emails for those purposes.
 
- **Additional Marketing Services**: Other Services we may provide to our customers (or help them provide to their own customers), which may supplement the above Services, may involve (a) assisting customers to target and optimize email campaigns, display, or other marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases; (d) helping customers to detect and prevent fraud and provide “validation” or data hygiene services, e.g., by verifying or removing or correcting old, incorrect, or outdated information or evaluating whether an email address recently has been active.

#### To Operate Our Services
We also use the Information described above for our own internal purposes – such as to improve, test, update, and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.

#### We Don’t Share Your Data with Third Parties
Elite Finance does not share data with third parties for marketing or promotion purposes. No mobile information will be shared by us with third parties/affiliates for marketing/promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties unless required by law or you give us permission.

As required by law or to protect any person or entity: Elite Finance may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property, or safety of Elite Finance, our customers, or any other person or entity.

#### Information That We Collect on Our Website and Use for Our Own Marketing and Business Operations
Elite Finance also collects information through this website and through other websites we operate. We also may collect and use information in connection with our own business operations, such as to send marketing communications or other correspondence to current and prospective customers, to help to ensure that we meet our contractual obligations to our customers, to operate and expand our business, and to develop new products and services.

The types of information we collect and use include:
- **Customer Information**: Elite Finance collects customer information through our customer websites, and our own websites. This includes, for instance, name, email, and phone number.
- **Cookie-Based Information**: Elite Finance collects cookie-based information on our websites. A cookie is a piece of data stored on the user’s computer tied to information about the user. Cookies on our websites are not linked to personal information.
- **Log File Information**: Like most websites, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and a number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. Log file information is not linked to personal information.

 

#### Children's Privacy
Elite Finance does not knowingly collect or solicit personal information from children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

#### Changes to This Privacy Policy
Elite Finance may update this Privacy Policy from time to time in order to reflect changes to our practices or for other operational, legal, or regulatory reasons. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

#### Contact Us
If you have questions or comments about this Privacy Policy, please contact us at:
Elite Finance, or in the contact us part of our website.