Global Debt Registry Privacy Policy for General Debt and Mortgage Debt Services



1. What the Privacy Policy Covers

Global Debt Registry. (Hereinafter referred to as “GDR”, “us” or “we”) is in the business of registering the ownership of debt portfolios (“Debt Portfolios” or “Portfolios”), establishing title for Debt Portfolios, and recording the sale of Debt Portfolios (“Debt Registry”). In addition, GDR is in the business of facilitating the distribution of documentation (statements, applications, TOU’s, etc.) supporting accounts in a Portfolio (“Media”) to the current owner of an account. The activities referred to in the previous two sentences are collectively referred to as the “Services.” The person and/or entity who accesses www.globaldebtregistry.com (the “Website”) for the purpose of reviewing the Website, or considering a purchase of or participation in the Services, is hereinafter referred to as “you” and “your”). GDR recognizes the appropriateness of protecting confidential data. This policy defines GDR’s policy for protecting your information. In addition, this policy defines in general terms GDR’s commitment to protect the information which is required to perform the Services.

This policy documents data we collect from you and what we do with the information including:

the type of personal information GDR collects about you through this Website; how that information is collected; the general purposes for which that information is collected; what disclosures of information will be made; and how, and to what extent, you can limit those disclosures In addition, this policy documents what data we collect from you and what we do with the information including:

the type of information collected from you acting as a buyer or seller of portfolios; how the information is collected; the general purposes which that information is collected; what disclosures of information will be made; and how, and to what extent, you can limit those disclosures.

  1. The policy defines:

reasonable precautions which are implemented to protect your personal information and information you provide to us from unauthorized access, misuse, disclosures, alteration or destruction; reasonable policies and procedures which have been put in place to insure that your personal information and information you provide to us is kept only for the purposes for which it was gathered; provides for reasonable access to any personal information and/or information you provide to us; and a procedure for correcting or modifying your personal information or information you provide to us, if appropriate. Reasonable precautions which are implemented to protect confidential information which is contained in Debt Portfolios and in Media. You can contact GDR about the Website either via e-mail at compliance@globaldebtregistry.com or by regular mail at 2 Mill Road, Suite 100-A Wilmington, DE 19806

  1. Collecting Information

A. Personal Information

What we collect from browsing this Website

Some information about your IP address, Web browser, and computer system are automatically transmitted to our Web servers by default. We reserve the right to automatically collect and/or track this information including but not limited to:

Domain names, e-mail addresses, type of client computer, and type of Web browsers of visitors to our Website.

Browsing history at the GDR Website.

What we collect from you when you enroll in the registry

When you enroll with the registry, we will ask you for personal information including your name, contact information, and ask questions about you and your history which we use in the process of authenticating you identification. The personal information we ask you may include but is not limited to your name, e-mail address, birth date, home address, etc. The only information we store is your name and contact information (phone number, address, email, etc). The rest of the information we collect is only used in authenticating you as you.

What we collect from you to pay for participation in this Website

We may ask for credit card number and other related payment card data, billing contact information, billing addresses, business tax id numbers, and other information needed to bill and collect payment for services you and/or your company authorized. This could include personal information based upon any number of factors. This is information we will keep in our databases.

What we collect from you when you enroll and participate in the Website

When you enroll in the debt registry, GDR may ask for some authentication information about you. This information could include previous residences, education and other type of information which can be verified against public databases. We do not keep this authentication information after authenticating you as a user.

B. Company Information

Company information, which is available to users of the Website, is available only through information provided by you or your designees. Company information that appears is available only as a result of information provided directly to the Website as part of participating in the Website or that was placed there because GDR received a request from your company to act on its behalf.

In addition, we may ask for credit card number and other related payment card data, billing contact information, billing addresses, business tax id numbers, and other information needed to bill and collect payment for services that you and/or your company authorized. This could include personal information based upon any number of factors. This is information we will keep in our databases.

There are times when GDR may request additional information from your company to assist GDR in assisting your company in its uses of the Website. We may or may not store this data depending upon business need.

C. Portfolio Data, Media and other data

The contents of Debt Portfolios and/or Media provided to GDR by you and/or your firm may contain information that is considered Confidential Information under a Participation Agreement that you sign with GDR, by law and/or by contract. GDR will retain this data.

  1. Cookie Disclosure Information

A “cookie” is a file which transferred to your computer when you visit a website. Cookies can retain information for which is used each time you return to the website. Some of the information, which is stored in a cookie, may include personal information or company information. The use of cookies is a widespread industry practice.

Most browsers are in initially configured to accept and process cookies. You can configure your browser to refuse cookies; however, use of the website may be negatively affected by such a configuration. Most browsers allow you to configure them to notify you when you receive a cookie and to thereby allow you to decide whether to accept that cookie.

We reserve the right to use cookies on our Website.

  1. Use of Data Collected

Personal data we collect will be used to

monitor and improve our internal operations bill you appropriately properly perform the services you request editorial and feedback purposes marketing and promotional purposes to you exclusively customize content and layout of our site properly provide the services you request properly respond to your inquiries provide general information that may be of interest to you Information we collect on your company will be used to

monitor and improve our internal operations bill you appropriately properly perform the services you request editorial and feedback purposes customize content and layout of our site properly provide the services you request properly respond to your inquiries prepare and distribute reports in aggregate (not company or Portfolio specific) Debt Portfolio data and Media we collect will be used to

bill you appropriately perform Services Media distribution properly respond to your inquiries provide other services which may be offered under this Website prepare and distribute reports in aggregate to you or other participants in the Website (not company, Portfolio, account – including protected personal identification information - and/or Media specific)

  1. Disclosure of Data to Third Parties

A. Personal Information

We will notify you before disclosing data to third parties, unless a Participation Agreement allows us to do so without notifying you.

We reserve the right to disclose personal data, with proper notification to you of the disclosure, in special cases when we believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with our Website, other users of our Website, or anyone else who could be harmed by such activities unless we have a good faith belief that notifying you would be contrary to applicable law.

We may disclose personal data when we believe in good faith that the law requires it or we have received a request from law enforcement agencies to disclose the information. In these instances, we are not required to notify you of the disclosure.

We may share any personal data necessary to complete the type of transactions requested by you or your Company in order for you and/or your company to receive requested services. This would include disclosure to vendors which are used by GDR to complete your and/or your Company’s requested services.

B. Company Information

Information provided by your company may be disclosed to any third party who is authorized to receive it by the terms of a Participation Agreement with us..

This includes any information provided by you which is required for performing Services or to send/receive Media. This does not include billing and/or payment information. Billing and/or payment information is maintained exclusively by GDR. We may share any your company’s information necessary to complete the type of transactions requested by Company in order for your company to receive requested services. This would include disclosure to vendors which are used by GDR to complete your company’s requested services.

We may aggregate information collected from the use of this Website. This information can be used by GDR to produce reports consistent with the usage of data as defined in Section 5 ) (“GDR Reports”) which may be available to registered and/or non registered participants in this Website. These generic reports may be provided for free or for a fee to registered members of the Website or to any third party GDR determines it wishes to share the information.

GDR will not provide GDR Reports which contain information which is considered confidential under federal and/or state law to any third party without the prior written consent of the current owner of a Portfolio.

C. Debt Portfolio and Media Data

Debt Portfolio and Media data provided by Company may be disclosed to any third party who is authorized to receive it under a Participation Agreement with us.

This includes any information provided by you which is required for Services or to send/receive Media. This does not include billing and/or payment information. Billing and/or payment information is maintained exclusively by GDR. We may aggregate information found in Debt Portfolios and/or Media. This information can be used by GDR to produce GDR Reports which may be available to registered and/or non registered participants in this Website. These generic reports may be provided for free or for a fee to registered members of the Website or to any third party GDR determines it wishes to share the information.

No other disclosure of this information is allowed unless permitted or required by law.

  1. Your Right To Opt Out

A. Personal Information

You may not opt out of having your personal information collected. Information collected by GDR is required to complete the services provided by GDR from this Website. If you do not want GDR to collect any additional personal information, then you must stop participating in the Website and, if you have signed a Participation Agreement, terminate that Agreement.

B. Company Information

You may not opt out of having your company information collected. Information collected by GDR is required to complete the services provided by GDR from this Website. If you do not want GDR to collect any additional company information, then you must stop participating in the Website.

C. Debt Portfolio and Media Data

You may not opt out of having Debt Portfolio and/or Media information collected. Information collected by GDR is required to complete the services provided by GDR from this Website. If you do not want GDR to collect any additional Debt Portfolio and/or Media data from you, then you must stop participating in the Website.

  1. Access To And Ability To Correct Personal Data, Company Information, and Debt Portfolio and Media Data

A. Personal Information

You may request, via e-mail or regular mail, that we provide you with a summary of personal information we retain concerning you.

You may request, via e-mail or regular mail, that we modify or correct any personal information we retain concerning you.

If you terminate the use of the Website and notify us in writing, your personal information will automatically be removed from our records upon GDR having met its legal requirements for archiving of material or business records.

B. Company Information

You may request, via e-mail or regular mail, that we provide you with a summary of information we retain concerning your company.

You may request, via e-mail or regular mail, that we modify or correct any information we retain concerning your company.

If your company terminates the use of the Website, your company information will be retained for the following purposes:

Archiving of information needed to meet legal data retention requirements. Retention and use of data which is required to continue to deliver debt registry services to current and future GDR Clients.

C. Debt Portfolio and Media Data

You may request, via e-mail or regular mail, that we provide you with a summary of Debt Portfolio and/or Media data we retain which was provided to GDR by you and/or your Company.

You may request, via e-mail or regular mail, that we modify or correct any Debt Portfolio and/or Media data we retain which was provided to GDR by you and/or your Company.

If your company terminates the use of the Website, your company information will be retained for the following purposes:

Archiving of information to meet legal data retention requirements. Retention and use of data which is required to continue to deliver debt registry services to current and future GDR Clients. Retention and use of data which is required to continue to deliver Media to current and future owners of Accounts GDR will destroy and/or return all original files provided by Company to GDR upon meeting all legal data retention requirements.

  1. Collecting Personal Data From Children

Features on this Website are not intended to be accessible to individuals under the age of 18.

  1. Disclosure Notice

As you navigate within our Website, we will be collecting and tracking personal information, either by directly asking you to tell us something about yourself (such as your name, address or e-mail address) or passively by using data-tracking software that tells us what parts of the Website you have browsed. We will also be collecting and tracking information about your activities in our Website on an aggregate (i.e., group basis), where we will not know or keep track of precisely who you are. We do this to keep track of what users may be interested in, to help us in our marketing efforts. Contact Person. You may contact our Compliance Administrator at compliance@globaldebtregistry.com for inquiries concerning our information practices. We will employ reasonable methods to insure we are communicating with the parent or legal guardian during this contact, and during any contact requiring verifiable parent consent. 11. Third Party Links

Our Website may include links to other Internet websites. We encourage our partners, contributors and third parties to implement policies and practices that respect the privacy of visitors to our Website.

We are not, however, responsible for the privacy practices or content of any other website not covered by this Privacy Policy.

You may occasionally receive cookies from third parties including, but not limited to, advertisers/partners/vendors. We do not control these cookies.

  1. Our Right To Change This Privacy Policy

We reserve the right to change this policy at any time. We will send you notification to the most current email address provided by you 45 days prior to any changes in this Privacy Policy.

  1. Protections Of Data Provided To GDR

GDR has implemented a number of security practices and procedures to protect the information provided by you and/or Company. Such practices include but are not limited to:

Restricted access to Services offered via the Website Restricted physical and virtual access to the devices used to deliver these services. Training of GDR employees and contractors on acceptable security practices Third party monitoring of our security practices on a regular basis Requiring Confidential Information to be maintained confidential by recipients of this Website. As a user of this Website, you are responsible for safeguarding your access credentials (not sharing them with another person, not posting/storing them in an unsecure location).

  1. Adherence to EU Privacy Directives

GDR complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. The company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the company’s certification, please visit http://www.export.gov/safeharbor/

  1. Safe Harbor Complaints

In compliance with the US-EU and US-Swiss Safe Harbor Principles, GDR commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact

GDR through either of the following means:

a) Send an email to: compliance@globaldebtregistry.com

b) Or send notification in writing to:

Global Debt Registry Attn: Compliance Department 2 Mill Road, Suite 100-A Wilmington, DE 19806

GDR has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by GDR please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

  1. Your Acceptance Of This Privacy Policy

By your continuing use of this Website you signify your assent to this Privacy Policy. If you do not assent to this Privacy Policy, please do not use this Website.

When we make changes to the Privacy Policy, your continuing usage of this Website following posted changes to this Privacy Policy and after having notified you of the changes signifies your continuing assent to the changes.

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2 Mill Road, Suite 100, Wilmington, DE 19806
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