Read our privacy statement

eCommission Financial Services, Inc. Privacy Notice

Effective Date: October 19, 2026
Last Updated: October 19, 2026

eCommission Financial Services, Inc. provides commission advance, payment disbursement, and financial wellness solutions and services to residential real estate brokers and agents. This Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights. For residents of California and other states that provide additional rights, more information about the data we collect is available in our California Notice at Collection and Supplemental Notice for Residents of Certain Other States, which is found in Section 9 below.

Scope and Updates to This Privacy Notice
Personal Information We Collect
How We Use Your Personal Information
How We Disclose Your Personal Information
Your Privacy Choices and Rights
Security of Your Information
International Data Transfers
Retention of Personal Information
Notice at Collection and Supplemental Notice for California Residents and Residents of Certain Other States
Supplemental Notice for Certain International Countries
Children’s Information
Other Provisions
Contact Us

1. Scope and Updates to This Privacy Notice

This Privacy Notice applies to personal information processed by us and our company affiliates (collectively “Company,” “we,” “us,” or “our”), including on our websites and other online or offline offerings, including but not limited to Symba. To make this Privacy Notice easier to read, our websites and other offerings are collectively called the “Services.”

Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. Personal Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect personal information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. For residents of certain jurisdictions, additional disclosures about the information we collect is available in our supplemental disclosure below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Creation. We may collect personal information when you create an account, such as name, email address, username, profile picture, etc. We may also collect information about you if we conduct a “soft inquiry” or “soft credit inquiry” as part of our decision-making process to allow you to create an account and receive our Services. Any such “soft” inquiries are conducted only on a limited basis in certain circumstances and do not constitute credit checks. We are not a creditor or lender and therefore do not use any such “soft” inquiries as the basis for deciding whether to offer you a loan or other extension of credit.
Purchases and Payments. We may collect personal information and details associated with your purchases or payments to you, including payment and bank account information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card or bank account information entered through our Services, but we may receive information associated with your payment card and bank account information.
Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our Services, request customer or technical support, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
Interactive Features. We may collect personal information that you submit or make available through our interactive features, such as messaging and chat features.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. You can find more detailed information about cookies and how they work at http://www.aboutcookies.org.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

When you visit our websites and use our Services, we may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to make your experience with our Services more personal and interactive. Our uses of these Technologies fall into the following general categories:

Strictly Necessary. This includes Technologies that enable your access to our Services and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of necessary functionality;
Optional Cookies and Technologies. These are Technologies that we like to use to provide optional features, improve our website and support advertising, and social media. These include:
Analytics Cookies. These are first and third-party Technologies that help us understand how people use our website. These allow us (including our analytics providers) to collect information such as the pages you viewed on our websites, the number of times you accessed our websites, the amount of time you spent on our websites, and other web traffic data. We can then use this data to improve how our website works. This data is shared with the analytics providers. (See Analytics Providers below for specific examples).
Advertising and Marketing Cookies. These are first and third-party Technologies that we (and our partners) use to track you on and off our website to understand what you’re interested in and serve you relevant, personalized advertising and marketing. (See Advertising Technology Providers below for specific examples).

Analytics Providers. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:

Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

Advertising Technology Providers. We may use Technologies and other third-party tools to help us advertise more effectively. These Technologies allow us to better reach people interested in our Services and serve more relevant, targeted advertisements. Some of our Advertising Technology partners include:

Facebook Connect and Meta Pixel. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
Microsoft Advertising UET. For more information about Microsoft’s use of your personal information, please visit Microsoft Privacy Statement – Microsoft privacy. To learn more about how to control Microsoft’s use of your information for ads, see Microsoft account | Privacy.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Social Media Platforms. Our Services may contain social media buttons, such as Facebook, YouTube and LinkedIn, which might include widgets such as the “share this” button or other interactive mini programs. These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your colleagues and friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend or colleague to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, colleague, or co-worker). If a person you refer does not sign up for our Services, we may retain their contact information and may contact them about our Services unless they ask us to delete it or opt out of further communications.

3. How We Use Your Personal Information

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or Services purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for Services.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Short-term, transient use, such as contextual customization of ads;
Improving, upgrading, or enhancing our Services;
Developing new products and services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions, and other compliance activities;
Sharing personal information with third parties as needed to provide the Services;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.
We may use your information for other legitimate business purposes as permitted by law.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, text messages (if you have given us prior express written consent), and custom audiences advertising.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. Text Messaging Communications with You

We may use your mobile telephone number to send you text messages relating to your accounts, transactions, products, services, and promotions, consistent with applicable law and the communication preferences and consent provided by you. For marketing text messages, message frequency varies and message and data rates may apply. You may opt out of receiving marketing text messages at any time by replying STOP. Opting out of marketing text messages will not affect your ability to use our services.

E. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

F. Additional Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

Automated Decision Making. We may engage in automated decision making, including profiling. For example, we may engage in automated decision making to analyze and approve cash advances. Company’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as analyses we create about the total number of users in a location or how users interact with our Services.
Artificial Intelligence. Certain features of our Services, including Symba, use artificial intelligence and machine learning technologies to provide financial insights, analysis and other information to users. To provide these features, we may process information you provide to Symba, including your questions and other inputs, together with information available through your account with us and information from third-party sources or services you have authorized us to access, such as financial account, transaction and real estate information.
We may use third-party artificial intelligence and technology service providers to process this information on our behalf for purposes of providing and supporting the Services. Information submitted to these providers is subject to contractual and technical safeguards designed to protect the information and limit its use to providing services to us. We do not permit our third-party artificial intelligence model providers to use your personal information, prompts, or other content submitted through Symba to train their general-purpose artificial intelligence models. We may use information about your interactions with Symba to operate, maintain, evaluate, secure and improve Symba and our Services, including improving the quality and usefulness of Symba's responses, subject to this Privacy Notice and applicable law.
Symba may generate information using automated technologies. Its responses are provided for informational purposes and should not be considered a substitute for professional financial, tax, legal, accounting or other professional advice.
Transaction Verification. In order for us to properly fulfill our obligations to our customers and provide our Services, it may be necessary for us to independently verify each sale contract with the attorney, escrow company or title company that is closing the sale. We do this by calling the contact name on the customer's sale contract. We tell the contact we are funding a portion of the commission on the sale and ask for their confirmation that they have opened escrow and are acting as the closing entity. We never contact buyers or sellers.

4. How We Disclose Your Personal Information

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Affiliates. We may share your personal information with our company affiliates for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Services).
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “cross-context behavioral advertising,” “targeted advertising,” or “personalized advertising.”
APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. If you have questions about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
Text Messaging Consent Information. Text messaging originator opt-in data and consent will not be shared with third parties for their marketing or promotional purposes. However, text messaging opt-in data and consent may be shared by us with aggregators, telecommunications providers, and other service providers as necessary to provide our text messaging services.

We may also share your personal information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and are described in Section 5 below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Your Privacy Choices and Rights

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice).
Text Messages (SMS Terms). By opting in to receive marketing text messages from us, you agree to receive text messages regarding our products, services, promotions, and offers at the mobile number you provide. Message frequency varies. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. Consent to receive marketing text messages is not required as a condition of using our services. Information obtained in connection with your text messaging consent will be handled in accordance with this Privacy Notice. Text messaging originator opt-in data and consent will not be shared with third parties for their marketing or promotional purposes. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us, such as replying STOP, or by otherwise contacting us as set forth in “Contact Us” below.
Push Notifications. If you enable them, we may send you push notifications through your web browser or device, such as alerts about activity or changes in your account. You may opt out of receiving push notifications at any time by changing your browser or device settings.
Phone calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals; however, we do honor the Global Privacy Control (“GPC”) where required by applicable law.
Cookies and Personalized Advertising. You can control use of certain cookies and Technologies on our Services in the following ways:
- When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking technologies used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be for targeted advertising. Please note that cookies are browser specific. Your request to opt-out or reject the use of these technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the “Your Privacy Choices” link at any time to manage your preferences.
- You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. These tools are generally available in the help section of browsers. You can also use the quick links, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
- In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
- You may exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). You can learn more about the Global Privacy Control here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request Restriction of or Object to our processing of your personal information where the processing of your personal information: (i) is based on our legitimate interest for direct marketing purposes; (ii) involves processing or sharing of your sensitive personal information for certain non-essential purposes, or in contexts that require your consent; and (iii) is based solely on automated decision making or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
Opt-out of Sale, Sharing for Cross-Contextual Advertising, or Targeted Advertising involving your personal information. Although we do not “sell” your personal information as the term “sale” is typically understood, we may share your information with analytics providers and advertising networks in order to understand how visitors use our websites and serve you ads on and off our websites. You may opt-out of this “sharing” and “targeting advertising” by adjusting your privacy choices as described above.
Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

We will require you to prove your identity when making most types of requests. We may verify your identity by phone or email. Depending on your request, we will ask for information such as your name, the last transaction you placed with us, or the date of your last transaction with us. We may also ask you to send us a signed declaration confirming your identity.

In some circumstances, you may designate an authorized agent to exercise rights on your behalf. If you are an authorized agent, you must provide proof of your identity and the customer on behalf of whom you are submitting the request, together proof that you are authorized to act on their behalf.

6. Security of Your Information

We use commercially reasonable efforts to protect the confidentiality and security of personal information we process, including by maintaining appropriate administrative, technical, and physical security safeguards. Such safeguards may include measures to protect against unauthorized access, alteration, disclosure, or destruction of personal information. However, despite these efforts, since no system or security measure is completely secure, we cannot guarantee the security of personal information during its transmission or its storage. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. International Data Transfers

We and our service providers may process your personal information from time to time across borders, including in Canada and in the United States. The privacy laws of other countries might be different from the laws of the jurisdiction in which you reside and might permit the government, government agencies, courts, law enforcement agencies and security authorities in those countries to access your personal information without notice. Any such transfers will be undertaken in accordance with this Privacy Notice and in compliance with applicable laws.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

8. Retention of Personal Information

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.

9. Notice at Collection and Supplemental Notice for California Residents and Residents of Certain Other States

This Notice at Collection and Supplemental Notice is for residents of U.S. states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Nevada, Oregon, Texas, Virginia, and Utah (to the extent applicable to processing of residents personal information, “Applicable State Laws”).

The following table describes the categories of personal information Company has collected and whether we disclosed that personal information for a business purpose (e.g., to a service provider) or for certain advertising purposes to a third-party.

Category of Personal Information Collected by Company	Category of Third Parties Personal Information is Disclosed to for a Business Purpose	Category of Third Parties Personal Information is Shared for Advertising Purposes
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	Service providers Business partners Affiliates Advertising networks Data analytics providers Operating systems and platforms Social networks	Only online identifiers shared with: Advertising networks Data analytics providers Social networks
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.	Service providers Business partners Affiliates Advertising networks Data analytics providers Operating systems and platforms Social networks	Only online identifiers shared with: Advertising networks Data analytics providers Social networks
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Service providers Business partners Affiliates Advertising networks Data analytics providers	Online browsing shared with: Advertising networks Data analytics providers Social networks
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	N/A	Advertising networks Data analytics providers Social networks
Geolocation data Physical location or movements.	N/A	N/A
Professional or employment-related information Current or past job history or performance evaluations.	Service Providers Business partners	N/A
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N/A	N/A
Sensitive Personal Information. Social Security Number, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security access code, password, or credentials allowing access to the account.	Service providers Business partners Affiliates	N/A

“Sales” of Personal Information, including under California’s CCPA and Opting Out of Targeted Advertising.

For purposes of Applicable State Laws, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 18 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising and targeted advertising. To the extent that such sharing is considered a “sale” or “sharing” or disclosing for targeted advertising under California or other Applicable State Law, you may limit such sharing by:

Contact Us. Contacting us as set forth in “Contact Us” below.
Managing Your Cookie Preferences.
- Website Cookie Controls. When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking technologies (“Technologies”) used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Depending on the laws applicable in your jurisdiction, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising. Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these Technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the “Your Privacy Choices” link at any time to manage your preferences.
- Browser and Device Controls. You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
- Ad Industry Opt-outs. In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and customer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.
- Global Privacy Control. You may exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). You can learn more about the Global Privacy Control here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request.

The categories of data we share for cross contextual advertising and targeted advertising include:

Online Identifiers such as IP address, marketing id, device identifiers and characteristics,
Commercial Information;
Internet or other Electronic Network Activity, such as Browsing and Usage Information.

Each of these categories may have been shared with advertising networks and data analytics providers for the purpose of providing targeted advertising and marketing.

Sources of Personal Information We Collect

As more fully described in the section titled Personal Information We Collect, the sources from which we collect personal information include directly from you when you interact with us, automatically from you when you use our sites and services (for example through cookies and other online technologies), from third parties (for example, from our business partners and service providers) and through referrals from others.

Purposes for which We May Use the Information We Collect

The business purposes for which we collect personal information are described in more detail in the section titled, How We Use Your Personal Information, and include:

To provide our Services to you;
For our Administrative purposes (including security, fraud detection and protection, and improve our Services);
To process your requests, orders, and transactions (including provide customer service to you);
To Advertise and Market our products and Services to you;
With your consent; and,
To comply with law and enforce our rights and the rights of others.

Our full Privacy Notice appears above.

Retention of Personal Information.

Processing Sensitive Information.

Under applicable laws, you may have the right to limit the processing of sensitive personal information for certain purposes such as profiling or inferring characteristics about you. We do not process sensitive personal information for such purposes.

Additional Privacy Rights for Residents of Certain States

Subject to Applicable Law, if you are a resident of certain states you may have the rights described in the section titled Your Privacy Rights and Choices, in the Privacy Notice, which may include the following rights: The right to know and access the personal information we have collected about you; the right to delete personal information we have collected; the right to opt-out or restrict the processing of personal information for specified purposes, such as targeted or cross contextual advertising, and, the right to correct inaccurate personal information.

In accordance with Applicable Law, you may also have the following rights:

Non-Discrimination. We will not discriminate against you, in terms of price or services that we offer, if you exercise any of the rights listed above.

Authorized Agent. Depending on where you live, you may have the right to use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a user to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the user, and have sufficient access to that user’s laptop, desktop, or mobile device to exercise that user’s right digitally. If you are an authorized agent trying to exercise rights on behalf of one of our users, then you can make a request on the user’s behalf by contacting us as set forth below in the “Contact Us” section: Such requests must include the following information: (1) a written authorization from the customer that includes the customer’s full name, address, telephone number and valid email address used by the customer to interact with us, that is signed by the customer and clearly bestows upon the agent the proper authority; and (2) a certificate of good standing with your state of organization. Alternatively, an acting agent can provide a valid power of attorney signed by the customer on the agent’s behalf and a valid email address used by the customer to interact with us. The email address of the customer will be used to separately verify the agent’s authority with the customer.

Verification. We are required by law to take reasonable steps to verify your identity prior to responding to your request. Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If we are unable to process your request via you authenticating yourself on the Services, we may verify your request by asking for information sufficient to confirm your identity, based on the information we have on file. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.

We will respond to your request within forty-five (45) days or within the time provided for under Applicable Law. However, in certain circumstances, we may require additional time to process your request, as permitted by applicable law. We will advise you within forty-five (45) days after receiving your request if such an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.

We do not charge a fee to process or respond to your customer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will not discriminate against you for exercising your privacy rights.

Appeal. You may have the right to appeal our decision or response to your request. To exercise your right to appeal, you can submit an appeal request using the same method used to submit your original request, including by contacting us as set forth in “Contact Us” below.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with Applicable Law or in accordance with our Privacy Notice.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Refer-a-Friend and Similar Incentive Programs. As described above in “Personal Information We Collect” (“Referrals and Sharing Features”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide your personal information in exchange for a reward, or provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program. If a referred party does not sign up, we may retain the contact information you provided unless the referred party asks us to delete it.

10. Supplemental Notice for Certain International Countries

Supplemental Notice for Canada

This Supplemental Notice for Canada only applies to our processing of personal information that is subject to the applicable data protection laws of Canada.

Accountable Organization. The entity with custody and control of your personal information is eCommission Financial Services, Inc.
Consent. We collect, use, and disclose your personal information with your consent except where permitted by law. Where personal information is processed with your consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as set forth in Contact Us below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain parts of our Services.
Security of Your Information. We protect personal information using safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. We limit access to personal information to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information. Personal information is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfilment of the purposes for which it was collected, in accordance with prudent business practices on general document retention, or as otherwise required by law.
International Transfers and Access. Personal information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about Company’s policies and practices with respect to service providers outside of Canada, please contact us as set forth in Contact Us below.

11. Children’s Information

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

12. Other Provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

13. Contact Us

Company is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact our Privacy Manager at:

eCommission Financial Services, Inc.
11612 Bee Caves Rd., Building II, Suite 200
Austin, Texas 78738
privacymanager@ecommission.com
1-877-882-4368
Attn: Privacy Manager

Our Privacy Statement