Please read this disclosure carefully before using the Manor Credit website and related products operated by Momnt Technologies, Inc. d/b/a Manor Credit (“Manor Credit”, “us”, ‘we”, “our”). This disclosure governs use of the website, and the technologies and applications used by Manor Credit to offer financial services.

Purpose
This Privacy Policy is incorporated into the Manor Credit Terms of Use (collectively, the “Terms”). The terms “Manor Credit,” “we,” and “us” include Momnt Technologies, Inc. d/b/a Manor Credit and our affiliates and subsidiaries. The term “you” applies to you, the user of the site, a customer of Manor Credit, or the current person consuming Manor Credit products and services. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information.

Scope
This Privacy Policy applies to Personal Information that is collected and processed by Manor Credit in the course of our business, including on Manor Credit websites (each a “Site”), mobile applications and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Manor Credit, the “Services”). This Privacy Policy applies to all users of the Services, including individual users who access the Services through a merchant who has executed our Merchant Agreement (a “Manor Credit Merchant”) and the Manor Credit Merchant itself. This Policy does not apply to and does not contemplate, any uses of Personal Information by a Manor Credit Merchant. All individuals whose responsibilities include the Processing of Personal Information on behalf of Manor Credit are expected to protect that data by adherence to this Privacy Policy.

This Policy applies to all of Manor Credit’s operating divisions, subsidiaries, affiliates, and any additional subsidiary or affiliate of Manor Credit that we may subsequently form.

Transparency/Notice
Types of Information We Collect And How We Use It

While you are on this website you transmit your IP address to us, in order to access the site. We save that address in our “Access Logs” which shows date and time you accessed the site, and what page you accessed. There is no “personal information” sent by your browser to us, without your knowledge, other than this IP address. Any information transmitted to us may be used to determine if the website is working as intended, perform website health diagnostics, or perform analytics such as determining which country our website is popular in. These activities do not personally identify you, and any reports are for internal use only. The information collected through this process is not shared with any third parties.

Access logs will remain on the web server for a short period of time, usually 7 days, before they are deleted. In the event a law enforcement agency or other security event requires these logs, they will be saved for a longer period of time in a secure fashion as required to comply with the request.

If you fill out a contact us form on the website, we collect that form information and save it so that we can contact you for the purposes stated on the form. For example filling out a form for sales information will result in a sales person contacting you. The information you give us will be saved as a potential customer to enable that transaction.

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Manor Credit and the requirements of applicable law. Some of the ways that Manor Credit may collect Personal Information include:

• You may provide Personal Information directly to Manor Credit through interacting with the Services, participating in surveys, and requesting Services, or information.
• You may provide Personal Information to Manor Credit by interacting with the Services via a Manor Credit Merchant.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
• We endeavor to collect only that information which is relevant for the purposes of Processing your business transaction with our software platform.

Manor Credit collects Personal Information regarding its current, prospective, and former clients, users, visitors, guests (collectively “Individuals”).

When you use the Services or engage in certain activities, such as registering for an account with Manor Credit, responding to surveys, requesting Services or information, purchasing services from Manor Credit through the Services, or contacting us directly, we may ask you to provide some or all of the following types of information:

• Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us.
• Surveys. From time to time, we may contact you to participate in marketing, customer satisfaction, or feedback surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Sites and Services and in any manner consistent with the policies provided herein.
• Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
• Purchasing Information. When you use the Services to purchase goods or services from a Manor Credit Merchant, we may also collect information about the goods or services you purchase, how frequently you purchase products or services, and any rewards earned due to such purchase.
• Information Submitted Via Services. You agree that Manor Credit is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Manor Credit will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. We use this supplemental information primarily for security and fraud detection purposes. This supplemental information also allows us to verify information that you have provided to Manor Credit and to enhance our ability to provide you with information about our business and Services.

How Manor Credit Uses Your Information
We acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:

• To Provide Services or Information Requested. Manor Credit may use information about you to fulfill requests for Services, or information, including information about potential or future Services, including to:
  • Generally manage Individual information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of Manor Credit’s Services;
  • Contact you to answer requests for customer support or technical support.
• Administrative Purposes. Manor Credit may use Personal Information about you for its administrative purposes, including to:
  • Measure interest in Manor Credit’s Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate about Individual accounts and activities on Manor Credit’s Services and systems, and, in Manor Credit’s discretion, changes to any Manor Credit policy;
  • Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • Process payment for products or services purchased from Manor Credit Merchants;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities;
  • Prevent fraud or impersonation;
  • Enforce our Terms.
• Marketing Manor Credit Services. Manor Credit may use Personal Information to provide you with materials about offers and Services that may be of interest, including new content or Services. Manor Credit may provide you with these materials by phone, postal mail, or email, as permitted by applicable law. Such uses include:
  • To tailor content, advertisements, and offers;
  • To notify you about offers and services that may be of interest to you;
  • To provide Services to you;
  • For other purposes disclosed at the time that you provide Personal Information;
  • Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.

Research and Development
Manor Credit may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Manor Credit may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing

Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Manor Credit’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in the section titled “Redress/Compliance and Accountability” below.

Services via Mobile Devices

From time to time, Manor Credit may provide Services that are specifically designed to be compatible and used on mobile devices. Manor Credit will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Manor Credit’s Services may require that users log in with an account. In such cases, information about the use of mobile versions of the Services may be associated with accounts.

Anonymous and Aggregated Information Use

• Manor Credit may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Manor Credit’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Manor Credit may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Manor Credit and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Automated Decision Making and Fraud Prevention. Manor Credit may use a variety of factors, including, but not limited to, your Personal Information, for the purposes of automated and non-automated decision-making related to fraud prevention and related activities. If we use automated decision making in other contexts, we will inform you of any such processing and provide you with an opportunity to object where required by law.
• Other Uses. Manor Credit may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

Cookies, Pixels Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device“) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies

Cookies are small data collections placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site will not work properly and will show erratic behavior such as inability to login or use other functionality.

Pixel Tags/Web Beacons

A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Sites, Services, applications, and tools. This includes technologies that allow you access to our Sites, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites and Services, applications and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, Services, applications or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
• If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits. Doing so will adversely effect your site experience, and Manor Credit cannot be held responsible for errors or degradation in the site, in the event technologies have been disabled, blocked, or otherwise rendered inoperable by the user.

Third-Party Websites

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Manor Credit does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every 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. Visiting these other websites or applications is at your own risk.

Onward Transfer
Onward Transfer is the act of disclosing your information to a third party. Manor Credit may disclose your information to a third party during the course of business in providing you with goods, services, or products. Here is how:

Information We Share
We may share your information as described in this Privacy Policy with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property or with your permission.

• Manor Credit’s third parties. We may share any information we receive from you with a third party from whom you purchase or seek to purchase products or services in order to facilitate and support the transaction you have requested.
• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for:
  • (i) provision of IT and related services;
  • (ii) provision of information and services you have requested;
  • (iii) payment processing;
  • (iv) customer service activities; and
  • (v) in connection with the provision of the Site and Services.

We have executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

• Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a Service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with us. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we have provided them.
• Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, we may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information (such as demographic information and past purchase history) as well as selected Personal Information we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit other related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in the section titled “Redress/Compliance and Accountability” below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to
  • (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
  • (ii) respond to your requests;
  • (iii) protect yours’, ours’ or others’ rights, property, or safety;
  • (iv) to enforce our policies or contracts;
  • (v) to collect amounts owed to us;
  • (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or
  • (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity and ensure a high level of performance on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such an event, we will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

Opt-Out (Right to Object to Processing)
General
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to our Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting support@heymanorcredit.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

Email and Telephone 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. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding Services you have requested. We may also send you certain non-promotional communications regarding Manor Credit and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy). Communications that are required for our business relationship will typically not have a link to opt-out, as that is not allowed.

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies And Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. Your browser settings are specific to the computer or device your browser runs on.

Rights of Access, Rectification, Erasure, and Restriction
You may inquire as to whether Manor Credit is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to support@heymanorcredit.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Manor Credit. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws and in a reasonably timely fashion.

Although Manor Credit makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Manor Credit is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Manor Credit determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Manor Credit will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Data Retention
Manor Credit retains the Personal Information we receive as described in this Privacy Policy 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.

Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We use encryption, and secure transport protocols whenever available. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot guarantee or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site 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 the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

International Users
By using the Site or the Services, Manor Credit will house data in servers and storage located in the United States. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of Georgia and the adjudication of any disputes arising in connection with Manor Credit, the Services or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

Redress/Compliance and Accountability
If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Manor Credit by email at support@heymanorcredit.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Other Rights and Important Information
Changes to our Privacy Policy and Practices
This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

Revision to the Privacy Policy

We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy

If there are any material changes to this Privacy Policy, Manor Credit will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information

Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Manor Credit will endeavor to comply with the law or contract.

Definitions
The following capitalized terms shall have the meanings herein as set forth below.

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Manor Credit or to which Manor Credit discloses Personal Information for use on its behalf.

“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Manor Credit or Manor Credit’s Agents.