The categories of information we collect from each of these groups, and the ways in which we

use it, differs. As you may have noticed, it’s possible that the same person could fall into more

than one group. Most of this statement addresses our processing and sharing of personal

information collected from visitors to and users of our online and mobile resources and our

customers.

WHAT WE COLLECT

There are two types of information that we obtain from you online and then store and use: (i)

non-personal information that’s collected automatically from each visitor, such as your device

operating system; and (ii) personal information that you voluntarily provide to us or that is

collected automatically.

By using our online and mobile resources or purchasing our products or services, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described.

Voluntarily Submitted Information.

If you participate in certain activities via our online and mobile resources, you may be asked to

provide us with information about yourself. The types of personal information we collect in those

situations includes identifiers (such as your name, email address, physical address, and phone

number), professional information (such as the business you are in), and financial account information

(such as your credit card information). We do not sell, rent, or trade voluntarily submitted personal information with third parties.

If you don’t want us to collect this type of personal information, please don’t provide it. This

means you shouldn’t participate in the activities on our online and mobile resources that request

or require it and you may want to communicate with us by phone or regular mail instead.

Participation is strictly your choice. Not participating may limit your ability to take full

advantage of the online and mobile resources, but it will not affect your ability to access certain

information available to the general public on the online and mobile resources.

Some of the ways you voluntarily give us your personal information and how we use it:

Emails and Online Forms – When you send us an email or fill out an online form, such as to

contact us, your email address and any other personal information (e.g., home address or phone

number) that may be in the content of your message or attached to it, are retained by us and used

to respond back directly to you and to process your request. Depending on the personal

information provided, communications from us may be in the form of emails, telephone calls,

and/or text messages. We may also send you information about any of our products or services

we think may be of interest to you.

Registering for an Account – When you register for an account, you submit personal

information to us such as your name and email address which we then retain. We use that

information to create and manage your account and, in some cases, establish a password and

profile to communicate with you via email.

Registering for Events – When you register for services, webinars, events, conferences, or

programs we ourselves may host (rather than outsourced to a third-party event manager with its

own privacy policies), you will be submitting the types of identifiers described above. If the

event requires a fee, we may also ask you to submit credit card or other financial information.

We use this information to register you for the event and send you communications regarding the

event.

Becoming a Subscriber to Our Service – We use any information provided from our customers

to perform our contractual obligations and provide the products and services purchased to them,

to manage their accounts and communicate with them.

Social Media and Community Features – Some of our online and mobile resources may offer

social media-like community features letting users post messages and comments, and/or upload

an image or other files and materials. If you choose to make use of these features, the information

you post, including your screen name and any other personal information, will be in the public

domain and not covered/protected by this statement.

Automatically Collected Information.

When you visit our online and mobile resources, basic information is passively collected through

your web browser via use of tracking technologies, such as a “cookie” which is a small text file

that is downloaded onto your computer or mobile device when you access the online and mobile

resources. It allows us to recognize your computer or mobile device and store some information

about your preferences or past actions.

We allow third party vendors to use cookies or similar technologies to collect information about

your browsing activities over time following your use of the site. For example, we use Google

Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses

cookies to help us analyze how you use the online and mobile resources and enhance your

experience when you visit the online and mobile resources. For more information on how Google

uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how

to opt out of Google Analytics by going to

https://tools.google.com/dlpage/gaoptout.

The internet activity information collected through cookies and other similar means includes such

things as: the domain name and IP address from which you accessed our online and mobile

resources; the type of browser and operating system you use; the date and time and length of your

visit; the specific page visited, graphics viewed and any documents downloaded; the specific

links to other sites you accessed from our online and mobile resources; and the specific links

from other sites you used to access our online and mobile resources.

Additionally, if you access our online and mobile resources from a phone or other mobile device,

the mobile services provider may transmit to us uniquely identifiable mobile device information

which allows us to then collect mobile phone numbers and associate them with the mobile device

identification information. Some mobile phone vendors also operate systems that pinpoint the

physical location of devices and we may receive this information as well if location services are

enabled on your device. If you do not want us to collect and use geolocation data, disable location

services through your device settings.

Regardless, we use both automatically collected information and mobile device information to

compile generic reports about popular pages on our online and mobile resources, and to see how

our customers and followers are accessing our online and mobile resources. We then use that

data to administer the online and mobile resources and make them better, make your activities

more convenient and efficient and to enhance the functionality of our online and mobile

resources, such as by remembering certain of your information in order to save you time.

We use and retain your personal information in accordance with applicable law and as long as

necessary to carry out the purposes described above in accordance with our internal data

retention procedures.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally

retained for a shorter period, except when this data is used to strengthen the security or to

improve the functionality of Our Service, or We are legally obligated to retain this data for longer

time periods.

User Beware: External Sites, Apps, Links and Social Media.

We maintain a presence on one or more external social media platforms such as Twitter,

Facebook, Instagram, YouTube, and LinkedIn. We may further allow features of our online and

mobile resources to connect with, or be viewable from, that external social media presence.

Similarly, our online and mobile resources may contain links to other websites or apps controlled

by third parties.

We are not responsible for either the content on, or the privacy practices of, social media

platforms, or any third-party sites or apps to which we link. Those apps, sites and platforms are

not controlled by us and therefore have their own privacy policies and terms of use. If you have

questions about how those apps, sites and platforms collect and use personal information, you

should carefully read their privacy policies and contact them using the information they provide.

HOW WE USE YOUR INFORMATION

Credit Counsel Elite, LLC may use the information we collect from and about you for a variety of

business purposes; in general, to provide the services, improve customer experience and

engagement and develop the services. We are committed to protecting and maintaining the

privacy of your information. Therefore, we will process your data only in accordance with

applicable data protection law and this Privacy Statement.

We will have a lawful basis for processing your data if:

• we need to process your information in order to provide you with the products or service

you have requested or to enter into a contract;

• you have consented to such processing;

• we have a legitimate interest for processing your data – e.g., for fraud prevention; direct

marketing; network and information systems security; data analytics; enhancing

modifying or improving our services; identifying usage trends; determining the

effectiveness of promotional campaigns; and advertising personalization of the service

using data to make it easier and faster for you to place orders; and/or

• we are legally obliged to process it.

We may use any and all information that we collect from you for the following customer service

and transaction purposes:

• To provide the requested Services to you.

• To manage your account.

• To personalize your experience: Your information helps us to better respond to your

individual needs.

• To improve our website: We continually strive to improve our website offerings based on

the information and feedback we receive from you.

• To diagnose problems with our servers or our Services.

• To improve customer service: Your information helps us to more effectively respond to

your customer service requests and support needs.

• To process transactions, such as purchases and subscriptions.

• To use and disclose your credit, debit or payment card or other financial information only

to process payments and prevent fraud.

• To administer a contest, promotion, survey, or other site feature.

• To develop new products or services and to enhance current products and services.

• To send periodic emails about Services updates, your orders, or your subscription.

• To protect the security or integrity of our Services and our business, such as by protecting

against and preventing fraud, unauthorized transactions, claims, and other liabilities.

We may use your information for the following commercial purposes:

• To send you marketing and promotional emails.

• To target prospective customers with our services (such targeting is only performed with

your permission where your consent is required by applicable law).

We may also use information you provide to us for other purposes as disclosed at the time you

provide your personal information or otherwise with your consent.

WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION

We use voluntarily provided personal information to respond to your inquiries and provide you

with the services you have requested, amongst other uses as further described below. We do not

sell or rent your personal information to third party data vendors or marketing companies. As you

might expect, we disclose your information when required by law.

Affiliates.

In addition to those third parties set forth above, we may share your information, including

personal information, within our family of companies. Those companies will use such

information in generally the same manner as we do under this privacy statement which includes

sending you information about their products, services, or initiatives that may be of interest to

you.

Legally Compelled Disclosures.

We may disclose your information, including personal information, to government authorities,

and to other third parties when compelled to do so by such government authorities, or at our

discretion or otherwise as required or permitted by law, including but not limited to responding to

court orders and subpoenas.

To Prevent Harm.

We may disclose your information, including personal information, when we have reason to

believe that someone is causing injury to or interference with our rights or property, other users

of the online and mobile resources, or anyone else that could be harmed by such activities.

Business Transfer.

If we or any of our affiliates, or substantially all its or their assets, are acquired by one or more

third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or

liquidation, personal information may be one of the transferred assets.

Vendors and Business Partners.

We may share your information, including personal information, with our vendors and other third

parties with whom we have a contractual relationship. We may also share your information,

including personal information, with vendors who provide third party software services that you

have chosen to assist you. We do our best to disclose only the information each of those parties

need.

We have adopted standards for those vendors and business partners who receive personal

information from us. We attempt to bind such vendors and business partners to those standards

via written contracts. We further attempt to contractually restrict what our vendors and business

partners can do with the personal information we provide to them such that it is used only to the

extent necessary to carry out the business purpose for which it was provided; is not disclosed to

anyone else without our consent or under our instruction; remains, as between us and the

applicable vendor or business partner, our property; and is not transferred out of the United States

without our consent.

Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.

EMAIL COMMUNICATIONS, NEWSLETTERS, AND MARKETING

We may use Your Personal Data to contact You with newsletters, marketing or promotional

materials and other information that may be of interest to You. You may opt-out of receiving

any, or all, of these communications from Us by following the unsubscribe link or instructions

provided in any email We send or by contacting Us.

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we may use third-

party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to

Our third-party payment processors whose use of Your personal information is governed by their

Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by

the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard,

American Express and Discover. PCI-DSS requirements help ensure the secure handling of

payment information.

YOUR RIGHTS AND OPTIONS

You may have to provide personal information to enjoy most of the features of our online and

mobile resources. Moreover, you can opt out of certain activities like newsletters and

announcements. Residents of California and EU data subjects whose personal information was

obtained while they were in California or a GDPR Jurisdiction, respectively, have certain

additional rights.

When you access your account on the Services, you have the option to change certain

information about yourself, such as your billing or shipping address, and telephone number.

Emails.

If you consented to receive direct marketing from Credit Counsel Elite, LLC , we

provide you with the opportunity to opt out of our marketing communications or change your

preferences by following a link in the footer of all non-transactional email messages from us or

by emailing us support@creditcounselelite.com. Some communications from us are considered

transactional or service communications (for example, account notifications and billing

information). To ensure you have accurate information about your account and purchases, you do

not have the option to unsubscribe from these messages.

GDPR Jurisdictions means the countries composed of the European Economic Area (including

Iceland, Lichtenstein, and Norway) and the following countries: Austria, Belgium, Bulgaria,

Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece,

Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland,

Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden. 

Furthermore, Andorra, Argentina, Canada (only commercial organizations), Faroe Islands,

Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and Japan have

received an “adequacy decision” from the European Commission, adheres to the material terms

of the GDPR. Switzerland also has its own data protection via its Federal Act of Data Protection

(“DPA”).

GDPR no longer has jurisdiction over the United Kingdom. Since the United Kingdom

(“UK”) has now formally left the European Union, it is no longer regulated domestically by the

material terms of the GDPR. The United Kingdom General Data Protection Regulation (“UK-

GDPR”) is the UK's data privacy law that governs the processing of personal data domestically.

If we are using personal information you provided to us in order to enable us to send you

materials, such as newsletters or product alerts via text or email, and you decide you don’t want

to receive such materials, you may opt out by following the opt-out instructions in the email or

other communication (e.g., by responding to the text with “STOP”), or by contacting us using the

contact information below. When we receive your request, we will take reasonable steps to

remove your name from our distribution lists. You need to understand it may take a period to

remove your name from our lists after your request and due to such latency, you may still receive

materials for a period after you opt out. In addition to opting out, you have the ability to access,

amend, and delete your personal information by contacting us using the contact information

below.

Some browsers have a “do not track” feature that lets you tell websites that you do not want to

have your online activities tracked. Currently, we do not specifically respond to browser “do not

track” signals.

CHILDREN’S PRIVACY

Federal law imposes special restrictions and obligations on commercial website operators who

direct their operations toward, and collect and use information from, children under the age of 13.

We take those age-related requirements very seriously, and consistent with it do not intend for

our online and mobile resources to be used by children under the age of 18. If we become aware

that anyone under the age of 18 has submitted personal information to our online and mobile

resources, we will delete that information and will not use it for any purpose whatsoever. If you

believe that someone under the age of 18 has submitted personal information to our online and

mobile resources, please contact us at support@creditcounselelite.com. We encourage parents

and legal guardians to talk with their children about the potential risks of providing personal

information over the Internet.

HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We will take all reasonable security precautions to protect your personal information provided to

our online and mobile resources. We have adopted a security program that includes technical,

organizational, administrative, and other security measures designed to protect, in a manner

consistent with accepted industry standards and applicable law, against anticipated or actual

threats to the security of personal information (the “Security Program”). We cannot, however,

guarantee that your information, whether during transmission or while stored on our systems or

otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or

alteration will not occur. Except for our duty to maintain the Security Program under applicable

law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage

to, or interception of any data or communications including personal information. We have every

reason to believe our Security Program is reasonable and appropriate for our business and the

nature of foreseeable risks to the personal information we collect. We further periodically review

and update our Security Program, including as required by applicable law.

Nonetheless, as part of our Security Program, we have specific incident response and

management procedures that are activated whenever we become aware that your personal

information was likely to have been compromised. We further require, as part of our vendor and

business partner oversight procedures, that such parties notify us immediately if they have any

reason to believe that an incident adversely affecting personal information, we provided to them

has occurred.

THE CALIFORNIA CONSUMER PRIVACY ACT

When we collect personal information from California residents, we become subject to, and those

residents have rights under, the California Consumer Privacy Act or “CCPA”. This section of

our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights.

For purposes of this section, the words “you” and “your” mean only such California residents.

What did we collect from California Residents?

We collect the following categories of personal information: identifiers such as name, address,

IP address, and other similar identifiers; personal information described in subdivision (e) of Section 1798.80

(California customer records statute) such as a name, address, telephone number, credit card number;

commercial information such as products or services purchased; internet/electronic activity

such as browsing history and search history; geolocation data including geographic coordinates/physical location;

and audio, video, electronic or other similar information. We may disclose this information for one or more business purposes permitted by the CCPA. We do not sell, and within the last 12 months have not sold, personal information to

third parties.

Rights of California Residents

If you are a California resident, you have the right to request the following:

• Access: Up to two times per year, you can request that we disclose to you (1) the

categories and specific pieces of personal information that we have collected from you;

(2) the sources of that personal information; (3) the business or commercial purpose for

that collection; (4) the categories of personal information we have disclosed for a

commercial purpose; and (5) the categories of third parties with whom we have shared

your personal information.

• Deletion: You may also request that we delete any personal information that we have

collected from or about you. There may be instances where we will not be able to fully

comply with your request, such as if we need the personal information to complete a

transaction for you, to detect and protect against fraudulent and illegal activity, to exercise

our rights, for our internal purposes, or to comply with a legal obligation.

More information can be found here. It’s important to us that you know that if you exercise these

rights, we will not “discriminate” against you by treating you differently from other California

residents who use our sites and mobile resources or purchase our services but did not exercise

their rights.

To exercise your rights under California law, just contact us at support@creditcounselelite.com.

We may ask you to fill out a request form. The CCPA only allows us to act on your request if we

can verify your identity or your authority to make the request so you will also need to follow our

instructions for identity verification.

If you make a verifiable request per the above, we will confirm our receipt and respond in the

time frames prescribed by the CCPA.

VIRGINIA RESIDENTS

If you are a Virginia resident, you may take advantage of certain privacy rights pursuant to

Virginia Code 59.1-577. For example, you may request to access, correct, or delete your

personal information. Because “selling” personal information and engaging in “targeted

advertising” as these terms are defined in Virginia law, you may also exercise your right to opt-

out of such sales or targeted advertising. You have the right to appeal a denial of your privacy

rights. To take advantage of either of your rights under Virginia law, or to submit an appeal to a

denial of these rights, please contact us at support@creditcounselelite.com. We may ask you to

fill out a request form. We can only act on your request if we can verify your identity or your

authority to make the request so you will also need to follow our instructions for identity

verification. If you make a verifiable request per the above, we will confirm our receipt and

respond in the time frames prescribed by Virginia law.

THE EU GENERAL DATA PROTECTION REGULATION

We do collect or otherwise obtain personal information from data subjects located in the GDPR

Jurisdictions. We fulfill our GDPR obligations with respect to our customers (and their own end-

clients), and our vendors and business partners through a series of separate notices, contracts or

other terms provided to them at the time, and in the manner and form, GDPR and local law

within each GDPR Jurisdiction requires.

We describe, in the immediately following section of this statement, how we comply with the

GDPR for personal information collected from visitors to and users of our online and mobile

resources while they were in a GDPR Jurisdiction. Thus, for purposes of that section, the words

“you” and “your” mean only such GDPR Jurisdiction-based visitors and users.

What do we collect from you in the GDPR Jurisdictions and how do we use it?

We collect from you the categories of personal information already described. The lawful basis

on which we rely for such collection, later use and disclosure, is what the GDPR refers to as

legitimate interest. As stated elsewhere in this statement, we do not sell any of your personal

information to third parties nor do we use it for automated decision making.

Cross-border Data Transfers and Third-Party Processors

If we transfer personal information from the GDPR Jurisdictions to a location that has not been

deemed by the European Commission to have adequate privacy protections, we do so in the

manner the GDPR permits.

Rights of Data Subjects in the GDPR Jurisdictions

While we attempt to allow all visitors and users of our online and mobile resources to exercise a

degree of control over their personal information, under the GDPR we have a legal obligation to

do so for you. More specifically, with respect to personal information collected from you while

you were in a GDPR Jurisdiction, you have these rights: transparency, access, correction and

deletion, portability, who, what, why and where, and restriction/objection (for more information

click here).

If you would like to exercise any of these rights, please contact support@creditcounselelite.com.

Your ability to exercise these rights is subject to certain conditions and exemptions that you can

read about in Articles 12 through 23 of the GDPR. Among those conditions is our right to decline

part or all a request if we cannot satisfy our reasonable doubts and concerns about your identity

in a manner that helps us minimize the risk that unauthorized persons might use a GDPR right to

access your personal information. We will respond to all requests without undue delay, and in

accordance with the time frames, if any, prescribed by the GDPR. If you are not satisfied with

how we use your personal information or respond to your requests, you have the right to

complain to your data protection regulator. Contact information for the EU data protection

regulators can be found here.

AGENT AUTHORIZATION

You may authorize someone to make a privacy rights request on your behalf (an authorized

agent). Authorized agents need to demonstrate that you’ve authorized them to act on your behalf

or must demonstrate they have power of attorney pursuant to applicable probate law. Credit

Counsel Elite, LLC retains the right to request confirmation directly from you confirming that the

agent is authorized to make such a request, or to request additional information to confirm the

agent’s identity. An authorized agent is prohibited from using a consumer’s personal information,

or any information collected from or about the consumer, for any purpose other than to fulfill the

consumer’s requests, for verification, or for fraud prevention.

RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS

In other jurisdictions, with similar data privacy regulations, we may collect from you the

categories of personal information already described. We collect and manage (including disclose)

such data in compliance with applicable local law(s). As noted, we do not sell any of your

personal information to third parties nor do we use it for automated decision making.

CHANGES TO THIS PRIVACY STATEMENT

This privacy statement was drafted on October 5, 2023, and is effective as of this date. The

English language version of this privacy statement is the controlling version regardless of any

translation you may attempt.

We reserve the right to change or update this statement from time to time. Please check our

online and mobile resources periodically for such changes since all information collected is

subject to the statement in place at that time.

CONTACTING US

If you have questions about our privacy statement or privacy practices, please contact us at: