Privacy Policy

ENSTEAD Company Limited (operating as YourCreditPal, “we”, “us”, or “our”) operates as a loan referral and lead generation platform. Our primary business is to assist consumers in identifying and connecting with qualified third-party lenders and financial service providers (“Lending Partners”) within our network. By collecting personal and financial information voluntarily submitted by you through our platform at yourcreditpal.com, we facilitate a matching process that allows you to be connected with Lending Partners regarding loan products, credit offers, and related financial services.

YourCreditPal is not a lender. We do not make lending decisions, issue credit, determine eligibility for any loan product, or bear responsibility for any lending terms offered by Lending Partners. We provide digital infrastructure and lead generation services to connect your request for financial products with providers within our network.

We are the data controller responsible for your personal data collected through this website and our services. As controller, we determine the purposes and means of processing your personal data as described in this Privacy Policy.

This Privacy Policy describes how we collect, use, share, sell, retain, and protect your personal data through your use of this site, our mobile application, any associated applications, and any other means by which you interact with us (collectively, “Services”). It applies to all personal data collected:

This website and our Services are not intended for children under the age of 18. We do not knowingly collect data from children.

Please read this Privacy Policy carefully before using our Services. By using this site or submitting personal information through our lead generation forms, you acknowledge that you have read and understood these terms. Where you provide personal information, you will be asked to provide explicit consent to our collection, sale, sharing, and use of your information as described herein. If you do not agree with any part of this Privacy Policy or our Terms of Use, please refrain from using this site or our Services.

You may give us your personal data by filling in online lead generation forms, corresponding with us by telephone, email, post, or otherwise. This includes personal data you provide when you:

As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions, and patterns using Data Technologies including cookies, pixels, web beacons, and similar technologies. We may also receive Technical Data if you visit other websites that employ our cookies or tracking technologies. Please see Section 15 (Cookies and Tracking Technologies) for further details.

We use TrustedForm, a third-party lead consent recording service, which captures and stores a record of your web session at the time you submit a Consumer Request, including your IP address, browser type, the date and time of submission, and the form environment you experienced. These records are maintained to evidence the consent you provide and for TCPA compliance purposes.

We may receive personal data about you from third parties and public sources, including:

We may publish uniquely generated, trackable telephone numbers on the site or in advertisements. If you call one of these numbers, we or a service provider working on our behalf may record the date, time, and duration of your call and the telephone number from which the call originated, for service quality and compliance purposes.

We may combine personal data obtained from third parties with personal data we have collected about you, including data about your use of our site and services, your interactions with Lending Partners, your interests and preferences, and other information. This combined data may be used for the purposes described in Section 5.

The law requires us to have a legal basis for each purpose for which we process your personal data. We rely on one or more of the following:

The table below describes in detail all the ways we plan to use the various categories of your personal data, the legal basis we rely on for each purpose, and the applicable retention periods.

You will receive marketing communications from us if you have requested information from us, submitted a Consumer Request, or otherwise consented to receive marketing. We may also analyze your Identity, Contact, Technical, Usage, and Profile Data to determine which products, services, and offers may interest you.

We will obtain your express consent before we share your personal data with any third party for their own direct marketing purposes (beyond the lead sale process described in Sections 6 and 7).

You can ask us to stop sending you marketing communications at any time by following the opt-out links in any marketing email or SMS, by replying STOP to any text message, or by contacting us via the details in Section 20. Even if you opt out of marketing, you will continue to receive service-related communications that are essential for administrative or customer service purposes, including updates to our Terms of Use and this Privacy Policy.

The Telephone Consumer Protection Act of 1991 (TCPA) regulates the use of automated telephone equipment to make calls and send text messages to consumers. The TCPA requires prior express written consent before any person or entity may contact you using an automatic telephone dialing system (ATDS), automated text infrastructure, or an artificial or pre-recorded voice for marketing purposes.

We comply with TCPA consent disclosure standards by:

By checking the consent box, submitting a Consumer Request, and utilizing our platform, you provide your prior express written consent under the TCPA for YourCreditPal and the Lending Partners within our hyperlinked network (including their agents or representatives) to contact you at the telephone number(s) you provided via:

This consent applies even if your telephone number is listed on a Federal or State Do Not Call Registry or Do Not Contact list. You understand and agree that providing this consent is not a condition of purchasing any product or service.

You may revoke your TCPA consent at any time. Revocation is effective with respect to future contacts and does not affect the lawfulness of contacts made prior to revocation. To revoke consent:

Please note that Revocation of consent to YourCreditPal does not automatically revoke consent previously given directly to Lending Partners. You must contact each Lending Partner separately to revoke consent with them.

YourCreditPal maintains internal Do Not Call lists. If you wish to be placed on our internal Do Not Call list, contact our Privacy Team as provided in Section 20. Requests will be processed within ten (10) days.

Our primary disclosure of your personal data is the sale, matching, or transfer of your Lead profile to Lending Partners within our network when you submit an inquiry. By inserting a hyperlink to our partner network directly into the consent text, we ensure you have clear visibility into the entities receiving your profile. Each Lending Partner will act as an independent controller of your data, and their processing will be governed by their own privacy policies.

In some cases, we may sell Leads to other digital marketing and lead generation companies that subsequently transfer those Leads to their own clients (including lenders). When we do so, we disclose this practice to you at the time of collection and require contractual assurances that such resellers comply with applicable law, including TCPA consent requirements.

We engage Service Providers and Contractors that process personal data on our behalf, including:

We require all Service Providers and Contractors to only process personal data for specified, lawful purposes and in accordance with our instructions.

We may share personal data with lawyers, bankers, auditors, and insurers in the course of obtaining professional services.

We will disclose personal data to governmental agencies, regulators, courts, or law enforcement authorities as required by applicable law, rule, regulation, or legal order, including in response to subpoenas or lawful requests.

Personal data is a business asset of YourCreditPal. In connection with any merger, acquisition, sale of assets, debt financing, restructuring, insolvency, or receivership, personal data may be transferred as part of the transaction. We will make reasonable efforts to ensure that any successor respects this Privacy Policy.

You may opt out of the sale or sharing of your personal data at any time by:

We will act upon opt-out requests within fifteen (15) business days of receipt. Please note that opting out of future sales does not affect Leads already transferred to Lending Partners prior to your opt-out, as those Lending Partners will have already received and may retain your data pursuant to their own privacy policies and our contractual arrangements.

In the event of a data breach involving your personal data, we will notify you and any applicable regulatory authority as required by applicable law, including applicable state breach notification statutes. We have internal procedures for detecting, assessing, and reporting data security incidents.

You have the right to request access to your personal data and to receive a copy of the personal data we hold about you, to check that we are processing it lawfully, and to obtain information about how it is being used.

You have the right to request correction of inaccurate or incomplete personal data we hold about you. We may need to verify the accuracy of new data you provide.

You have the right to request erasure of your personal data in certain circumstances. Note that we may not always be able to comply with your request for erasure for specific legal reasons. We will notify you of any applicable exceptions at the time of your request.

You have the right to opt out of the sale or sharing of your personal data to third parties. See Section 8 for how to exercise this right.

You have the right to object to processing of your personal data where we are relying on legitimate interests. You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.

You have the right to request restriction of processing of your personal data in certain circumstances, including where you contest the accuracy of the data or object to our processing.

You have the right to request transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format, where we process it based on your consent or performance of a contract.

Where we rely on your consent to process personal data, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

We will not discriminate against you for exercising any of your privacy rights. We will not deny you services, provide different levels of service, or retaliate against you for exercising your rights.

How to Submit a Privacy Rights Request

To exercise any of the rights described above, please contact our Privacy Team by:

We will confirm receipt of your request within ten (10) business days and respond substantively within forty-five (45) calendar days of receipt. If we require additional time, we will notify you of the extension and the reasons for it. We do not charge a fee to process privacy rights requests unless they are manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act.

Verification of Identity

We may need to verify your identity before processing your request to ensure that personal data is not disclosed to an unauthorized person. We will use commercially reasonable methods to verify your identity, which may include requesting information we already hold about you. We may also permit authorized agents to submit requests on your behalf with appropriate proof of authorization.

We use Data Technologies including cookies, local shared objects (flash cookies), pixel tags, web beacons, device identifiers, JavaScript tags, and similar technologies to collect information about your use of yourcreditpal.com and to enable certain features and functionality. These technologies may be placed by us or by third parties we authorize.

Most web browsers automatically accept cookies. You can modify your browser settings to decline cookies; however, certain features of the site may not function properly if you do so. You may also:

As of the effective date of this Privacy Policy, there is no universally accepted standard for responding to browser Do Not Track (DNT) signals. We do not currently respond to DNT signals. However, we do recognize and honor Global Privacy Control (GPC) opt-out preference signals. If we detect a GPC signal from your browser, we will treat it as a valid request to opt out of the sale and sharing of your personal data, as required by the California Privacy Act and other applicable state privacy laws. You may also exercise your privacy rights using the methods described in Section 12.

California residents have the right to request that we disclose information about our collection, use, sale, sharing, and disclosure of their personal information over the past 12 months, including the categories of personal information collected; the categories of sources; the business or commercial purposes for collection; the categories of third parties to whom personal information is disclosed; and the specific pieces of personal information collected. We may be required to provide this information for periods beyond 12 months for personal information collected on or after January 2, 2022.

California residents have the right to request that we delete their personal information, subject to certain exceptions under the California Privacy Act.

California residents have the right to request correction of inaccurate personal information we maintain about them, and we will use commercially reasonable efforts to correct such information.

California residents have the right to direct us not to sell or share their personal information to third parties. YourCreditPal sells and shares Consumer Leads. California residents may exercise this right by:

California residents have the right to direct us to limit the use and disclosure of their Sensitive Personal Information to purposes necessary to perform the services reasonably expected by an average consumer, except as otherwise permitted by the California Privacy Act.

We will not discriminate against California residents for exercising their rights under the California Privacy Act. We will not deny goods or services, charge different prices, provide different quality levels, or retaliate against employees or contractors for exercising these rights.

California residents have the right to file a complaint with the California Privacy Protection Agency (CPPA) if they believe their privacy rights under the California Privacy Act have been violated. Complaints may be submitted through the CPPA’s website at https://cppa.ca.gov or by contacting the Office of the California Attorney General at https://oag.ca.gov.

To exercise your Right to Know, Right to Delete, or Right to Correct, submit a verifiable consumer request to our Privacy Team:

We will confirm receipt within ten (10) business days and respond substantively within forty-five (45) calendar days. We will verify your identity using commercially reasonable methods. Authorized agents may submit requests with proper documentation.

California residents may request information about whether we have disclosed personal information to third parties for direct marketing purposes in the immediately preceding calendar year. To submit such a request, contact our Privacy Team as provided above.

YourCreditPal and all associated services are strictly intended for individuals who are at least 18 years of age. We do not knowingly market to, solicit, or permit registrations from individuals under the age of 18. However, if you are a California resident under the age of 18 and have registered an account on our site, California law permits you to request the removal of content or information you may have submitted or posted to our platform. Contact our Privacy Team to make such a request, noting that complete removal cannot always be guaranteed.

As required by the California Privacy Act, YourCreditPal will publish annual metrics regarding the number of requests to know, requests to delete, requests to correct, and requests to opt out of sale received in the prior calendar year, as well as the median number of days within which YourCreditPal substantively responded to each type of request. These metrics will be published on yourcreditpal.com and updated annually.

Delaware residents have the following rights with respect to their personal data:

To exercise any of the rights described above, contact our Privacy Team using the details in Section 20. We will acknowledge receipt of your request within ten (10) business days and respond substantively within forty-five (45) days, with a possible extension where reasonably necessary, which would be duly communicated.

Under the DPDPA, we will not process sensitive personal data without your prior consent. If we intend to collect sensitive data in connection with our Services, we will present you with a clear and prominent consent notice at the time of collection.

If we deny your appeal of a privacy rights request, we will inform you of your right to contact the Delaware Department of Justice to submit a complaint. Delaware residents may file a complaint with the Delaware Attorney General by emailing privacy@delaware.gov or by visiting https://attorneygeneral.delaware.gov.

If you have any questions about this Privacy Policy, how we handle your personal data, or to exercise any of your privacy rights, please contact our Privacy Team:

You have the right to make a complaint to the relevant supervisory authority if you believe we have processed your personal data in violation of applicable law.

Before submitting a complaint to a regulatory authority, we encourage you to first contact our Privacy Team so that we have the opportunity to address your concern directly.