PRIVACY POLICY
1. INTRODUCTION.
This Privacy Policy (the “Policy”) explains how DRB Capital, LLC (“DRB Capital”, “we”, “us”, “our”) collects, uses, and discloses personal information through its website (the “Site”) and otherwise as a result of its structured settlement and annuity purchasing services (collectively with the website, the “Services”). By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent that we will collect, use, and share your personal information in the following ways.2. INFORMATION COLLECTED AND HOW WE USE IT.
As explained further in this section, you will have the opportunity to provide us with certain personal information. In addition, we may collect certain personal information automatically through your use of the Services. The rest of this section provides a more detailed explanation of the personal information we collect and how we use that personal information.
2.1. Voluntarily Disclosed Information. The following table identifies the specific purposes for which you may voluntarily disclose personal information to us.
| Purpose for Collection | Type of Personal Information | How we collect that information |
| (i) to process your application and determine whether we will make an offer to purchase your structured settlement; (ii) to seek court approval for the purchase; and (iii) to process the purchase | Real name, alias, postal address, email address, social security number, driver’s license number | Directly from you |
| (i) to process your application and determine whether we will make an offer to purchase your structured settlement; (ii) to seek court approval for the purchase; and (iii) to process the purchase | Your signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number. | Directly from you |
| To improve our Site | Internet/Electronic Network Activity Information, and information regarding your interactions with our Site. | Directly from you |
| (i) to process your application and determine whether we will make an offer to purchase your structured settlement; and (ii) to seek court approval for the purchase | Estimates of personal consumer debt, your approximate credit rating, and marriage status. | Directly from you; from a consumer report provider |
| (i) to process your application and determine whether we will make an offer to purchase your structured settlement; and (ii) to seek court approval for the purchase | Medical information, including your current health and medical history. | Directly from you |
| (i) to process your application and determine whether we will make an offer to purchase your structured settlement; and (ii) to seek court approval for the purchase | Commercial Information, including records of personal property. | Directly from you |
| To communicate with you and respond to your feedback and questions | Content within any messages you send to us (such as feedback and questions to customer support). | Directly from you |
| Operational communications about your use of the Services | Content within any messages you send to us (such as feedback and questions to customer support). | Directly from you |
| To communicate with you and respond to your feedback and questions | Real name, email address | Directly from you |
| Marketing communications | Real name, email address | Directly from you |
2.2. Sensitive Personal Information. Certain of the information we collect from you (as identified in the table above) may be deemed to be “Sensitive personal information” under applicable law. We only use your sensitive personal information for the purposes identified in the table above, and do not use it for any other purposes.
2.3. Automatically Collected Information. Whenever you interact with the Site, certain information may be collected via cookies. “Cookies” are identifiers we or our Site vendors transfer to your browser or device that enable recognition of your browser or device. The cookies on our Site solely collect information to the extent needed to provide the functionality of the Site (like our chat function) and track activity on the Site. We use Google Analytics to understand how visitors engage with our Site. You can learn more about the information that Google has access to at the following website: https://policies.google.com/technologies/partner-sites. The National Advertising Initiative provides a helpful overview for disabling cookies. In addition, you may modify cookie settings directly on our Site. Please note that if you delete, or choose not to accept, cookies from the Site, you may not be able to utilize certain features of the Site to their fullest potential.
3. DISCLOSURE OF PERSONAL INFORMATION.
We may disclose your personal information as detailed in this section.
3.1. Personnel and Third Party Service Providers. We employ personnel and engage other companies and people to perform tasks on our behalf and need to share your personal information with them to provide products or services to you. For example, we use a cloud-based records management platform to store the contact information of our customers. In addition, we rely on a third-party vendor to help us review applications from potential customers.
3.2. Business Transfers. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.
3.3. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with governmental requests, law enforcement or court orders, or enforce or apply our Terms of Service and other agreements.
3.4. California Residents Under 16 Years of Age. California law requires us to confirm whether we sell or “share” the personal information of users under 16 years of age, as those terms are defined under California law. We do not sell or share the personal information of users under 16 years of age.
4. SECURITY.
We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. In addition, we rely on the technical safeguards provided by the third-party service providers we use to host, store, and process your personal information. We cannot, however, ensure or warrant that your personal information on the third-party service providers may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.5. YOUR RIGHTS.
5.1. Rights of Users in California. If you live in California, you have the following rights:
5.1.1. Right to Know: The right to request that we disclose to you the personal information we collect, use, disclose, sell, and information about our data practices.
5.1.2. Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.
5.1.3. Right to Request Deletion: The right to request that we delete your personal information that we have collected from or about you. We may reject your request if it is reasonably necessary to maintain your personal information in order to complete the transaction for which we collected the personal information, comply with law, or other applicable reasons that are permitted under applicable law and that will be communicated to you upon receipt of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.
5.1.4. Right to Portability: The right to request that we provide you with your personal information in a common file format.
5.1.5. Right to Opt Out of Sales and Targeted Advertising: The right to opt out of our sale of your personal information and the processing of your personal information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising. We only disclose your personal information as set forth in Section 3 above and do not sell your personal information or share it for the purpose of targeted advertising.
5.1.6. Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
5.2. Rights of Users in Nevada. We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by contacting us. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number- 702.486.3132; email: BCPINFO@ag.state.nv.us.
5.3. Rights of Users in The European Union And The United Kingdom. At this time, DRB Capital does not conduct business with residents of the European Union or the United Kingdom (collectively, the “EU/UK”) and, therefore, does not intend to collect Personal Information of residents of the EU/UK. If you are a resident of the EU/UK, DO NOT USE THE SITE. In the event DRB Capital inadvertently collects and/or processes Personal Information of EU/UK residents, please note that DRB Capital processes Personal Information both as a Processor and as a Controller, as those terms apply under the General Data Protective Regulation of the EU and the United Kingdom General Data Protection Regulation (collectively, the “GDPR”). If you are a resident of the EU/UK and we have inadvertently collected your Personal Information, you have the right to access the information we have on you, and to ask that we correct or delete the data. If requested by you, we will send you a copy of your Personal Information electronically. IF YOU DO NOT AGREE TO THE USE OF COOKIES, PLEASE CONTACT US. This notice, as amended, is effective May 11, 2023.
5.4. Rights of All Other Users. Regardless of where you reside, if you would like to access or modify any of the personal information we have collected about you, you can contact us in accordance with Section 5.3. We may reject your request if it is reasonably necessary to maintain your personal information in order to complete the transaction for which we collected the personal information, comply with law, or other applicable reasons that are permitted under applicable law and that will be communicated to you upon receipt of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.
5.5. How to Exercise Your Rights. If you wish to exercise any of the rights set out above, please contact us at optout@drbmail.com. If you have authorized an agent to exercise your rights on your behalf, the agent may contact us at optout@drbmail.com. Please note that to protect your personal information and the integrity of our Services, we may need to collect additional information to verify your identity (and, if applicable, the authority of your agent) before processing your request.
6. RETENTION OF INFORMATION.
Subject to your right to request deletion of your personal information in accordance with Section 5, we will retain your personal information as long as needed for your use of the Services, your approved receipt of marketing communications from us, our compliance with legal obligations, and to protect our or other’s interests.7. HOW WE RESPOND TO DO NOT TRACK SIGNALS.
We do not track you or collect your personal information across third party websites or online services. Thus, we do not receive Do-Not-Track signals, or other similar signals. To the extent that we do receive any such signals, we will not comply with them as it is not an aspect of the functionality of the Services.8. AGE OF USERS.
Children under the age of 18 are not permitted to use, access or register for the Services in any way. We do not knowingly collect or solicit information from anyone under the age of 18. If we learn that we have collected personal information from a child under the age of 18, we will delete that information as quickly as possible.9. CHANGES TO POLICY.
We’re constantly trying to improve the Services, so we may need to change this Policy from time to time as well. The date of the last modification will be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Services, you are indicating that you agree to be bound by the modified Policy.10. CONTACT US.
If you have any questions or concerns regarding this Policy, please send us a detailed message to info@drbmail.com, and we will try to resolve your concerns.DRB Capital does not provide professional financial or legal advice and the Site is not intended as a substitute for professional financial or legal advice. Persons accessing this information assume full responsibility for the use of the information and understand and agree that DRB Capital is not responsible or liable for any claim, loss or damage arising from the use of the information. All content provided is for informational purposes only. DRB Capital makes no representations as to the accuracy, completeness, currentness, suitability, or validity of such content and will not be liable for any errors, omissions, or delays in this information or any losses, injuries, or damages arising from its display or use.
