November 1, 2022
Acra Lending (“we”, “us”, “our”) recognizes that certain jurisdictions, most notably those subject to the United Kingdom’s Data Protection Act (DPA) and the European Union’s General Data Protection Regulation (GDPR), require that there be a lawful basis to process personal data. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so for those jurisdictions that require a legal basis. We have also identified what our legitimate interests are where appropriate.
Note that in those jurisdictions that require a legal basis in order to process your personal information, we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal ground(s) we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity |
Type of Personal Data |
Lawful basis for processing including basis of legitimate interest |
| Account Services: (1) To fulfil or meet the reason for which the information is provided; or (2) To provide you with information, products or services that you request from us. |
(a) Contact information
(b) Unique identifiers
(c) Geolocation data
(d) Financial information
(e) Communications preferences
(f) Search queries
(g) Comments and other information
(h) Correspondence and other information
(i) Additional information
(j) Technical Information |
Performance of a contract with you. |
| Contractual Obligations: To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections. |
(a) Contact information
(b) Unique identifiers
(c) Geolocation data
(d) Financial information
(e) Communications preferences
(f) Search queries
(g) Comments and other information
(h) Correspondence and other information
(i) Additional information
(j) Technical Information |
Performance of a contract with you. |
| Website Improvement: To improve our Website and present its contents to you. |
(a) Geolocation data
(b) Search queries
(c) Comments and other information
(d) Additional information
(e) Technical Information |
Necessary for our legitimate interests (to develop our Website interface and performance to improve the customer experience and grow our business) |
| Internal Research: For testing, research, analysis and product development. |
(a) Demographic information
(b) Geolocation data
(c) Communications preferences
(d) Search queries
(e) Comments and other information
(f) Correspondence and other information
(g) Additional information
(h) Technical Information |
Necessary for our legitimate interests (to study how customers use our services products and to develop them)
|
| Advertising and Marketing Services: To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you. |
(a) Contact information
(b) Unique identifiers
(c) Demographic information
(d) Geolocation data
(e) Communications preferences
(f) Search queries
(g) Comments and other information
(h) Correspondence and other information
(i) Additional information
(j) Technical Information |
Necessary for our legitimate interests (to grow our business and to inform our marketing strategy) |
| Security Purposes: As necessary or appropriate to protect the rights, property or safety of us, our clients or others. |
(a) Contact information
(b) Unique identifiers
(c) Financial information
(d) Geolocation data
(e) Communications preferences
(f) Search queries
(g) Comments and other information
(h) Correspondence and other information
(i) Additional information
(j) Technical Information |
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (for provision of administration and IT services, network security, and to prevent fraud)
|
| Legal Obligations: To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. |
Depending upon the law enforcement or legal request, this could include any information |
Necessary to comply with a legal obligation
|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where required or permitted by law. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose under the DPA or GDPR, please contact us at [email protected].
Transferring Personal Data
Where we transfer your personal data out of the UK or EEA, we ensure that your data is afforded a similar degree of protection by using specific contracts approved by the European Commission (known as the Standard Contractual Clauses). Please contact us at [email protected] if you want further information on the specific mechanism used when transferring your personal data out of the UK or EEA.
Notice of Rights for Residents of the United Kingdom or European Economic Area
This Privacy Notice is issued on behalf of Acra Lending, having its registered office at 25531 Commercentre Drive, Suite 160, Lake Forest, CA 92630, United States of America. Acra Lending is the controller for the purposes of this Privacy Notice and is responsible for this Website. In the UK and the EEA, please contact Acra Lending’s representative at [email protected].
Additionally, you have the right to make a complaint at any time to the appropriate supervisory authority in your country of residence. We would, however, appreciate the chance to resolve your concerns directly, so please contact us first and/or fill out our Privacy Request form located here.
Acra Lending is a dba name of Citadel Servicing Corporation
