Sagent M&C, LLC, together with their affiliates (collectively, “Sagent,” “we,” or “us”), is the operator of the website with the home page at https://www.Sagent.com (referred to as the “Site”). We know privacy is important to you; it is also vital to our business. This Privacy Policy is designed to help you understand how we collect, use, and share “Personal Information” (information that is identifiable to a particular person) and to help you understand and exercise your privacy rights. Sagent is the data controller for the Personal Information we process, unless otherwise stated. We recommend that you read this Privacy Policy in full to ensure you are fully informed. For more information on how to contact us, please refer to Section 11 below.
This Privacy Policy applies to information processed by us in connection with the Site and is considered part of the Terms and Conditions of Use at https://www.Sagent.com/terms-of-use/ (the “Terms”). This Privacy Policy does not apply to any of the Personal Information that our corporate clients (e.g., lenders, servicers) may process using Sagent’s products and services (“Customer Data”). Our clients’ respective privacy policies govern the collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our clients, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our client.
This Site is intended and offered to residents of the United States, and may not be appropriate for use in, or comply with the Laws of, any other location or jurisdiction.
1. WHAT DOES SAGENT DO?
Sagent improves the lending experience for everyone. The company’s suite of comprehensive origination, servicing, and processing offerings come together to deliver flexible, scalable, and configurable solutions that deliver on the brand commitments of our clients.
For more information about Sagent, please see the “About” section of our Site at https://www.Sagent.com/about/.
2. “PERSONAL INFORMATION” WE COLLECT, AND HOW WE COLLECT, USE, AND DISCLOSE IT.
The Personal Information that we collect depend on how you interact with us and broadly fall into the following categories:
- Personal Information you directly submit to us. Sagent may collect Personal Information, such as your name, your company’s name, your company email address or other contact information, when you voluntarily subscribe to email alerts regarding Sagent events or company news, request company information, or request product or service information through an email contact form. It is up to you whether to provide this information. Such information will be used and disclosed as reasonably necessary to meet your needs and respond to your requests, such as disclosing it to our email service provider to send you emails or to one of our affiliated entities to provide you with requested product information.
- Information that we collect automatically. When you visit the Site, we may collect certain information automatically from your device, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of the Site, such as pages that you visit before, during and after using the Site, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use the Site. Additional details about how we use cookies, browser information and tracking technology is provided in section 5 below.
- Personal Information that we obtain from third party sources. From time to time, we may receive Personal Information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose Personal Information about you to us.
3. DISCLOSURE.
Sagent will only share information about you as described or permitted by this Privacy Policy. We may disclose Personal Information about you for a variety of business purposes, including to operate the Site and provide our services. We may share your information with our business partners to provide you with a product or service you requested. We may also share your information with our third party service providers who provide data processing services to us and help us operate the Site (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site), or who otherwise process Personal Information for purposes that are described in this Privacy Policy. Parties with whom we may share Personal Information are bound to contracts requiring them to use and disclose Personal Information only for the permitted purposes set forth in the contract in accordance with this Privacy Policy, and are bound contractually to use reasonable security measures to protect Personal Information from unauthorized access and use.
Sagent may also disclose Personal Information about you to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use such information only for the purposes disclosed in this Privacy Policy.
Sagent may also use and disclose Personal Information about you to external parties to comply with court orders and lawful instructions from government agencies, where we, in good faith, believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to protect your vital interests or those of any other person, or (iv) to assist with investigating or prosecuting suspected or actual illegal activity.
4. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION.
Sagent may use your information as requested by you or as permitted by applicable law. We may collect or otherwise process Personal Information about you (i) where we need to process the information to perform a contract with you (such as managing your information and accounts, responding to your queries, communicating with you about your account, activities and policy changes, or processing your financial information and other payment methods for loans held), (ii) where the processing is in our legitimate interests (such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention), (iii) where we have a legal obligation to process the information, (iv) where we need to process the information to protect your vital interests or those of another person, or (v) where we have your consent to do so.
If we ask you to provide your Personal Information to comply with a legal requirement or to enter into a contact with you, we will make this clear at the relevant time and advise you whether providing such information is mandatory or not (as well as of the possible consequences if you do not provide Personal Information).
We also use your information for various administrative purposes, such as:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in the Site (through analytics);
- Improving the operation or security of the Site;
- Developing new products and services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Debugging to identify and repair errors with the Site or our products or services;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
If you have questions about or need further information concerning the legal basis on which we collect and use Personal Information about you, please contact us using the contact details provided under the “How to contact us” heading below.
5. MINORS.
This Site is not intended for individuals under age 18. We do not knowingly collect any Personal Information from or about individuals under 18 years of age. Please do not submit such information to us. If you are a parent or legal guardian and believe that your child may have submitted information to us, you may contact us as described below. If we become aware that an individual under age 18 has provided us with Personal Information, we will delete any such information we have collected, unless we have a legal obligation to keep it.
6. COOKIES, BROWSER INFORMATION AND RELATED ISSUES.
- Cookies. We use “cookies” (small data files placed on your computer or other device by the server when you visit the Site) and similar tracking technology described below to collect and use information about you to facilitate and enhance your experience. For further information about the types of cookies we use, why, and how you can control cookies, please see our Cookie Statement.
- Browser Data. We collect certain standard information that your browser sends to every website you visit, such as the originating IP address, browser type and language, access times and referring website addresses. This data may be used, among other reasons, to improve the operation and security of the Site by assisting in “authenticating” who you are when you access the Site, particularly if you register for access to a section of the Site with restricted access and are issued or create a username and password.
- Device Data. In addition, we may collect technical data about the device used to access the Site (“Device Data”) (such as unique device ID, device model, operating system version, application types and versions, plug-ins, and time zone and geolocation information). Device Data may be used as part of our security controls to uniquely identify the device and authenticate the user when accessing the Site. Device Data may be shared (along with information about any fraudulent transactions using the device) with one or more third-party service providers. These providers will compare and add the Device Data and fraud data to a database of similar device and fraud information in order to identify and block access to the Site by devices associated with fraudulent or abusive activity. We will not share with service providers any information that personally identifies the user of the device.
- Site Usage Data. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. We use this information for our internal analytics purposes and to improve the security, quality and relevance of our Site to our visitors.
- Tracking. With respect to information about an individual’s online activities over time and across different websites, devices or online services, when a visitor uses this Site, except as required by law: (1) parties other than the operator of this Site are not permitted to collect such information, and (2) the operator of this Site does not collect such information (except information reasonably necessary to process and document user transactions). Therefore, this Site has no need to respond to and does not respond to Web browser “do not track” signals or other mechanisms that enable individuals to exercise choice regarding the collection of such information.
- YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
- Email: You may unsubscribe from future promotional emails from us by following the unsubscribe link included in each such email. Please note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding the Site and our products or services, and you will not be able to opt out of those communications.
- Cookies and Interest-Based Advertising: You may opt out or restrict the placement of cookies on your device or remove them by adjusting your preferences as your browser or device permits. You should consult your browser or device’s settings or help documentation for more information about exercising these options. Please note that if you adjust your preferences, the Site may not work properly. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative or the Digital Advertising Alliance Error! Hyperlink reference not valid.. Note that the opt-outs described above will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookie, change browsers (including upgrading certain browsers), or use a different device, any opt-out cookie or tool may no longer work, and you will need to opt out again.
- Analytics: We use Google Analytics and related products to better understand how our uses engage with the Site. Google is subject to its own privacy policy. To learn more about Google’s data collection and security practices, we encourage you to review its privacy policy. You may learn more about opting out of certain Google advertising initiatives here and here.
Your Privacy Rights. Our processing of Customer Data is governed by the contracts that we have in place with our clients, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our client. In accordance with applicable law, you may have the right to:
- Access Personal Information about you, including: (i) confirming whether we are processing your Personal Information; and (ii) obtaining access to or a copy of your information;
- Request Correction of your Personal Information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your Personal Information;
- Request Deletion, Anonymization or Blocking of your Personal Information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
- Request Restriction of or Object to our processing of your Personal Information when processing is noncompliant;
- Withdraw your Consent to our processing of your Personal Information. If you refrain from providing your information or withdraw your consent to processing, some features of our services may not be available;
- Request data portability and receive an electronic copy of Personal Information that you have provided to us; and
- Be informed about third parties with which your Personal Information has been shared.
We do not sale Personal Information nor do we render decisions exclusively based on automated processing that could affect data subject rights.
7. HOW WE PROTECT PERSONAL INFORMATION ABOUT YOU.
To protect Personal Information about you from unauthorized access and use, Sagent maintains physical, electronic, and procedural safeguards, and requires those to whom we disclose Personal Information (including our employees and service providers) to do the same. The measures we use are designed to provide a level of security appropriate to the risk of processing Personal Information.
8. DATA RETENTION.
We retain Personal Information about you for as long as necessary to fulfill the purpose(s) for which it was collected, provide you with a service you requested, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable legal, tax or accounting requirements.
When we have no ongoing legitimate business need to process Personal Information about you, we will either delete or anonymize it or, if this is not possible, for example, because the Personal Information has been stored in backup archives, then we will securely store the Personal Information and isolate it from any further processing until deletion is possible.
9. KEEPING UP TO DATE WITH OUR PRIVACY POLICY.
Sagent may update this Policy from time to time in response to changing legal, technical or business developments by posting a revised version on this Site, which will be effective at the time it is posted for all Personal Information collected thereafter unless a delayed effective date is expressly stated in the revision. When we update our Privacy Policy, we will inform you as required by applicable law, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.
10. SCOPE.
- Supplemental Privacy Policies. Some areas, features and services on the Site may be offered on the condition that you view and agree to privacy terms and disclosures specific to those areas, features and services. Those specific privacy terms and disclosures will be deemed to supplement the terms and disclosures in this Privacy Policy.
- Links to Third-Party Sites. This Site may contain links to other websites or applications operated by third parties. These websites are not controlled by Sagent Lending Technologies. If you browse on or submit Personal Information to any of those websites or applications, information about you may be collected by them and will be governed by their privacy policies. Sagent does not endorse, screen or approve, and is not responsible for, the privacy practices or content of such other websites or applications. We encourage you to read the privacy policies of each website and application with which you interact.
11. HOW TO CONTACT US.
If you have any questions or concerns about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Sagent M&C, LLC
info@sagent.com
1000 Continental Drive
Suite 570
King of Prussia, PA 19406