Effective Date: April 1, 2023
Last Updated on: April 1, 2023
Esusu Inc. (“Esusu” or “we” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices for collecting, using, maintaining, protecting, and disclosing Personal Information (defined below) we collect from users of our websites, located at www.esususavings.org, www.esusurent.com and www.esusurentrelief.com (collectively, the “Sites”) and online services (“Services”). Any terms not defined herein shall have the meaning given to them in the associated Terms of Use at the following sites:
This Privacy Policy applies to the information we collect: on this website; in email, text, and other electronic messages between you and these Sites; when you interact with our advertising and applications on third party websites and services, if those applications and advertising include links to this policy. This Privacy Policy does not apply to information collected by: (i) us offline or through any other means, including on any other website operated by Esusu or any third party (including our affiliates and subsidiaries); or (ii) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Site.
This Privacy Policy applies to all visitors, users, and others who visit and use the Sites (“consumers” or “you”). This Privacy Policy complies with The Fair Credit Reporting Act, 15 U.S.C. § 1681 (“FCRA”), California Consumer Privacy Act (as amended) (the “CCPA”), including as modified by the California Privacy Rights Act of 2020 (the “CPRA”), upon the CPRA’s enforcement date of January 1, 2023, as applicable to Personal Data, Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (”CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Utah Consumer Privacy Act (”UCPA”).. Any terms defined in the CCPA have the same meaning when used in this Policy.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you disagree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this privacy policy. This policy may change from time to time. Your continued use of these Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 16
Our Sites are not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Sites. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on these Sites or register on the Sites or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under16 without affirmative opt-in for a child between 13 and 16, or verification of parental consent for a child under age 13, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@esusu.org. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Personal Information Sales Opt-Out and Opt-In Rights for more information.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“) or (Personally Identifiable Information”) or (“PII”). Personal information does not include:
In particular, through our Sites, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Example | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
| B. 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. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Through our Sites, we obtain the categories of personal information listed above from the following categories of sources:
Sensitive Information
We do not process sensitive information.
Payment Data
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. Stripe stores all payment data. You may find their privacy notice link(s) here: https://stripe.com/privacy
Application Data
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information You Provide to Us
If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
The information we collect on or through our Sites may include:
| Information We Collect Through Automatic Data Collection Technologies |
As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Sites and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
| Third-Party Use of Cookies and Other Tracking Technologies |
Some content or applications, including advertisements, on the Sites are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties tracking technologies or how they may be used. You should contact the responsible provider directly if you have any questions about an advertisement or other targeted content.
Do Not Track Features
Most web browsers include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized at this stage. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
We may also use your information to contact you about our own and third-parties goods and services that may interest you.
We may use the information you collected to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Data Retention
We will only retain your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for no longer than seven years past the termination of the user’s account unless the data retained is de-identified and no longer meets the criteria of being “personal data.”
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Sharing Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:
The categories of third parties we may share personal information with are as follows:
We may also disclose your personal information:
We may share your personal information by disclosing it to a third party for a business purposes. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Esusu disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell or share personal information.
| Personal Information Category | Category of Third-Party Recipients | |
|---|---|---|
| Business Purpose Disclosures | Sales | |
| A: Identifiers. | • Credit Bureaus (acting as Data Brokers or Aggregators) • Partners | None |
| B: California Customer Records personal information categories. | • Partners | None |
| C: Protected classification characteristics under California or federal law. | • Credit Bureaus (acting as Data Brokers or Aggregators) • Partners | None |
| D: Commercial information. | • Credit Bureaus (acting as Data Brokers or Aggregators) • Partners | None |
| E: Biometric information. | None | None |
| F: Internet or other similar network activity. | None | None |
| G: Geolocation data. | None | None |
| H: Sensory data. | None | None |
| I: Professional or employment-related information. | None | None |
| J: Non-public education information. | None | None |
| K: Inferences drawn from other personal information. | None | None |
Reselling Personal Information
Some applicable privacy laws prohibit a third party from reselling personal information unless you have received explicit notice and an opportunity to opt out of further sales. We do not resell your personal information.
Choices About How We Use and Disclose Your Information; Your Rights and Choices
Under applicable privacy laws , California residents have specific rights regarding their personal information. The section below describes a California resident’s CCPA rights and explains how to exercise those rights and applies to all Sites users.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
The categories of personal information we collected about you.
We do not provide a right-to-know or data portability disclosure for B2B personal information.
Right to Correct or Delete
You have the right to request that we delete or correct any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete” and the “right to correction”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or de-identify personal information not subject to one of these exceptions from our records and direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know, Correct, or Delete
To exercise your rights to know, correct, or delete described above, please submit a request by either:
Only you or your authorized agent may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use the personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.]
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@esusu.org .
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. Our response will also explain why we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer 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.
Personal Information Sales Opt-Out and Opt-In Rights
Generally, if you are age 16 or older, you have the right to direct a company not to sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of any consumers, no matter their age. Generally, under CCPA, consumers may opt out of future sales at any time if they are opt-in to personal information sales.
Data Security
We have implemented appropriate and reasonable technical and organizational security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Sites like message boards. Any Sites user may view the information you share in public areas.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumventing any privacy settings or security measures on the Sites.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless the CCPA permits, we will not:
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@esusu.org.
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we change this privacy policy, we will post the updated notice on the Sites and update the notice’s effective date. Your continued use of our Sites after posting changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, how Esusu collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at
Email: privacy@esusu.org
Postal Address:
Esusu Inc.
200 Broadway, 3rd Floor, Suite 209
New York, NY 10038
If you need to access this Policy in an alternative format due to having a disability, please contact support@esusu.org or call 1-929-269-8032.