Privacy Policy | Trilogy Credit Pro

Business Platform Privacy Policy
Trilogy Credit LLC

Effective Date: August 1, 2025

This Business Platform Privacy Policy ("Privacy Policy") describes how Trilogy Credit LLC ("Trilogy," "we," "us," or "our") collects, uses, shares, and protects information when Business Subscribers and their authorized personnel ("you" or "your") access and use the Trilogy Credit Pro platform ("Platform"), including all associated web applications, software tools, and related services ("Services").

This Privacy Policy also addresses how Trilogy handles information about your clients that you submit to the Platform in connection with your use of the Services. Business Subscribers are separately responsible for their own privacy obligations with respect to their clients under applicable law, including but not limited to the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA"), and applicable state consumer data privacy laws.

This Privacy Policy explains:

The information we collect from Business Subscribers and their clients
Online activity, cookies, and information collected by automated means
How we use the information we collect
How we share the information we collect
How we protect and store information
Your privacy options
Information about clients who are minors
Updates to this Privacy Policy

By using the Platform and Services, you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy does not apply to non-Trilogy websites or services that state they are offered under a different privacy policy.

For questions about our privacy practices, contact us at: privacy@trilogycreditpro.com.

Information We Collect. Depending on the nature of your interaction with Trilogy and the Platform, we may collect information as follows:
1. Information Collected Directly from Business Subscribers.
  - Business contact information and account registration data, including the name, email address, phone number, and business details of the Business Subscriber and authorized personnel who register for or access the Platform;
  - Billing and payment information necessary to process Subscription Fee payments;
  - Business Subscriber Content, including consumer credit reports and related documents uploaded to the Platform on behalf of clients; and
  - Any additional information you choose to provide, including feedback, questions, and support inquiries.
2. Information About Your Clients. When you upload client credit reports or other client information to the Platform, we collect and process that information on your behalf as a service provider. This may include:
  - Consumer credit report data obtained by your clients from authorized sources such as annualcreditreport.com;
  - Any personal information contained within or extractable from those credit reports, such as name, address, Social Security number (partial or full), account information, and payment history; and
  - Any additional client information you choose to submit to the Platform.
  As a Business Subscriber, you are solely responsible for ensuring that you have obtained all required consents and authorizations from your clients before submitting their information to the Platform, and for complying with all applicable laws governing your collection, use, and sharing of client data.
3. Information Collected Automatically. When you interact with the Platform, certain information is automatically collected, including:
  - Usage details, such as the date, time, and duration of sessions; pages or features accessed; search terms entered; and referring URLs;
  - Device information, including IP address, device type, unique device identifiers, operating system, and browser type;
  - Location information, where you choose to grant the Platform access to your device's location data; and
  - Site usage and session information, including mouse movements, clicks, page visits, text entered, time spent on pages, and other interaction data.
4. Information from Third Parties. We may receive information about Business Subscribers and their personnel from third parties, including marketing data from online advertising companies and information from payment processors or identity verification services used in connection with account registration or billing.
Cookies and Automated Data Collection. We use cookies, web beacons, and other tracking technologies to collect information about your use of the Platform. Some of these technologies may be operated by our partners, who assist us in collecting usage information, serving relevant content, or providing other services.
For example, we use Google Analytics to collect usage data about the Platform. You can learn more about Google's privacy practices at https://support.google.com/analytics/answer/6004245, and you may opt out of Google Analytics data collection using the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Your browser or device may offer a "Do Not Track" functionality. Please note that we do not currently respond to such signals. You may be able to control the use of cookies through your browser settings or through opt-out mechanisms provided by our advertising partners.
How We Use Information. We use the information we collect from Business Subscribers and, where applicable, from client data submitted through the Platform, for the following purposes:
- To provide, operate, and deliver the Platform and Services to Business Subscribers, including generating credit report analyses and summaries;
- To process Subscription Fee payments and manage Business Accounts;
- To communicate with Business Subscribers, respond to inquiries, and provide customer support;
- To notify Business Subscribers of important changes to the Platform, these Terms, or this Privacy Policy;
- To monitor and improve the performance, reliability, and security of the Platform;
- To conduct internal research, develop new features and services, and analyze usage trends;
- To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity; and
- To comply with applicable legal obligations, respond to legal process, and enforce our Terms.
We may use and share aggregated or de-identified information at our discretion for research, analytics, and product improvement purposes, provided such information cannot reasonably be used to identify any individual or business.

We will not use client credit report data or other client personal information submitted by Business Subscribers for any purpose beyond providing the Services to the applicable Business Subscriber, except as required by applicable law.
How We Share Information. We may share information about Business Subscribers and, where applicable, client data submitted through the Platform, as follows:
1. Service Providers. We may share information with third-party service providers that perform services on our behalf, such as cloud hosting, payment processing, billing and collections, IT services, customer support, marketing, accounting, auditing, and other professional services. Our service providers are contractually required to use information only as necessary to perform services for us and to maintain appropriate security measures.
2. Business Transfers. We reserve the right to transfer information about Business Subscribers and their clients to another entity or its affiliates or service providers in connection with, or during negotiations of, any merger, acquisition, sale of assets, change in ownership or control, or financing transaction. We cannot guarantee that an acquiring party or the merged entity will have the same privacy practices or treat information the same as described in this Privacy Policy, and we will notify Business Subscribers of any such transfer as required by applicable law.
3. Legal Disclosures. We may disclose information where necessary to comply with applicable law, respond to requests from law enforcement agencies or other government authorities, protect the rights and safety of Trilogy, Business Subscribers, clients, or the public, or enforce our rights under these Terms.
4. With Your Consent. We may share information with third parties in other ways not described above with your prior written consent.
We do not sell the personal information of Business Subscribers or their clients to third parties.
How We Protect and Store Information. Trilogy uses a combination of physical, technical, and administrative safeguards designed to protect the information we collect through the Platform, including Business Subscriber data and client data submitted through the Services. These measures include, as applicable, encryption of data in transit and at rest, access controls, and regular security assessments.
While we implement these safeguards, no security measure is perfect or impenetrable, and we cannot guarantee the security of the networks, systems, servers, devices, or databases we operate or that are operated on our behalf. Business Subscribers are encouraged to implement their own appropriate security measures and to limit the personal information submitted to the Platform to what is necessary for the Services.

If you use the Platform from outside the United States, you understand that we may collect, process, and store information in the United States and other countries, which may have different data protection laws than your jurisdiction.
Data Retention. We retain Business Subscriber account information and Business Subscriber Content for as long as your account is active and for a reasonable period thereafter, as needed to fulfill the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Upon termination of your Business Subscription, your data will be handled in accordance with the data retention and deletion practices described in the Business Terms of Use.
Business Subscribers may submit a data deletion request by contacting us at privacy@trilogycreditpro.com. We will permanently delete your data from our systems upon request, subject to any retention obligations required by applicable law.
Your Privacy Options. Business Subscribers may exercise the following privacy options:
- Marketing communications: If you no longer wish to receive marketing communications from Trilogy, you may click the unsubscribe link at the bottom of any marketing email or contact us at privacy@trilogycreditpro.com.
- Account information: You may update or correct your Business Account registration information by logging into your account or contacting us at privacy@trilogycreditpro.com.
- Data deletion: You may request deletion of your Business Account data as described in Section 6 above.
Please note that certain information may be retained as required by law or for legitimate business purposes even after a deletion request.
Client Data and Minors. The Platform is not intended to be used to process the personal information of individuals under the age of 18. Business Subscribers agree not to submit credit report data or other personal information of minors to the Platform. If we become aware that we have inadvertently received personal information of an individual under the age of 18, we will take steps to delete such information from our systems. Business Subscribers who become aware that a minor's personal information has been submitted to the Platform must promptly notify us at privacy@trilogycreditpro.com.
Updates to This Privacy Policy. We may update this Privacy Policy from time to time. The "Effective Date" at the top of this page indicates when this Privacy Policy was last revised. When we make material changes to this Privacy Policy, we will notify Business Subscribers via email or through the Platform. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.
Contact Us. For questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us at:
Trilogy Credit LLC
Email: privacy@trilogycreditpro.com
Website: www.trilogycreditpro.com