Effective:  June 20th, 2019

Direct Funder, LLC strives to be transparent with all  clients. This document outlines the legal collection, use, distribution, storage, and maintenance of the data and information, both personal and non-personal, collected during any business interaction, whether through phone, email, website form, personal interaction, meeting, etc. Please read through each section of this document, and contact us with any related questions or concerns.

1. Legal Agreement.    Please read this Privacy Policy (“Privacy Policy”) carefully.  Your registration at and use ofvietvon.com (“Website”) for services and information (the “Services”) offered by Direct Funder, LLC, or any of its subsidiaries including without limitation, Direct Funder, LLC; Viet Von; Vietvon or any of its (“Subsidiaries”), on the Website, and your acceptance of the Website Terms and Conditions (“Agreement”), create a binding, legal agreement between Direct Funder, LLC and you (“you” or “your”).  This Privacy Policy is a material component of the Agreement and governs Direct Funder, LLC’s collection, use and/or sharing of any information you provide to Direct Funder, LLC in or about your use of the Website and/or the Services.  This Privacy Policy further governs Direct Funder, LLC’s collection, use and/or sharing of information you provide Direct Funder, LLC in creating an account on the Website, which may include, without limitation, information such as your name, e-mail address, physical address, phone number, cell phone number (“Personal Information”), credit or debit card information (“Credit Card Information”), social security number, business financial information of any kind or nature, description of business plan or opportunity of any kind or nature, and any other personally identifying information related to you and/or your business. (“Sensitive Information”).   Any terms and conditions not expressly set forth in this Privacy Policy are governed by the Agreement.  If you choose to accept this Privacy Policy, as incorporated within the Agreement, you must do so as written, without modification.  If you do not accept this Privacy Policy you will not be allowed to receive the Services.  By using the Website, you openly and affirmatively acknowledge and agree you have read and you accept this Privacy Policy.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY DO NOT USE THE WEBSITE.
2. Information Collected by Direct Funder, LLC.  Direct Funder, LLC, from time to time, may engage trusted, industry-standard third party providers to provide financial account aggregation services. Your Personal Information may be transmitted to such third party providers and securely stored on their servers, including without limitation any of the Subsidiaries.  Direct Funder, LLC is not responsible for any of any third party provider’s actions or inactions.  You authorize Direct Funder, LLC to provide such third party providers with your Personal Information. Any Non-Personal Information used in a combined format with Personal Information will be treated as personal information.

You may use the Website without creating an account.  Even without an account, Direct Funder, LLC may collect Personal Information about your use of the Website.  This may include information about any Internet protocol address you use to access the Website and/or your activity or patterns of activity using the Website.  You authorize Direct Funder, LLC to use cookies, or other small text files stored on your computer, server log files, environmental variables (such as computer type), pixel tags, and other non-personal information you voluntarily provide (such as geographic location) to store data about your visits and you authorize Direct Funder, LLC to access such data.

We collect personal information and non-personal information through the Site. Personal information is information that identifies you as an individual. Non-personal information is aggregated information, demographic information, IP addresses and any other information that does not reveal your specific identity.

Personal information. We may collect the following types of personal information:

• Information provided by you when ordering credit-related products through the Site. For example, you will be required to submit personal information such as your name, address, social security number, date of birth, telephone number and e-mail address
• Information provided about your children when enrolling your children in child identity monitoring products. For example, as a legal guardian, you will be required to submit the child’s first and last name, Social Security number, and date of birth in order to register that child in identity monitoring with the credit bureau.
• Credit and debit card account information collected from you or your credit reports when enrolling in our card registry product. For example, we will collect credit and debit card account information from you on our sites, over the phone, and from your credit reports from the three national credit reporting companies in order to cancel the cards per your request in the event that they are lost or stolen.
• When you make a purchase through the Site, we may collect your credit card number or other payment account number, billing address and other information related to such purchase (collectively, “Payment Information”) from you.
• Other information we collect, such as city of birth and mother’s maiden name, is used to verify your identity in the event you forget your login information required for our online products.
• Information you provide us through customer service correspondence and general feedback.
• Video content you choose to submit to us, such as commentary about our products and services, testimonials, or other similar content you share through video.

Non-Personal information. When you visit the Site, we may collect non-personal information, such as a catalog of the Site pages you visit. Non-personal information is generally collected through the Site from the following sources: server log files, environmental variables, cookies, pixel tags and other similar technologies and information that you voluntarily provide.

• Server Log Files. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site’s servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
• Environmental Variables. We and our service providers may also collect certain environmental variables, such as computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.
• Cookies and Similar Technologies. We, our service providers, and/or non-affiliated Third-parties, may use “cookies” or similar technologies on the Site. Cookies are data that a web server transfers to an individual’s computer for recordkeeping purposes. Cookies are an industry standard used by many websites, and can facilitate your ongoing access to and use of a particular website; cookies do not cause damage to your computer systems or files. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. Additionally, please see the “Your Choices” section below for instructions on how to opt-out of sharing certain information related to the use of cookies.
• Pixel Tags. We, our service providers, and/or non-affiliated Third-parties, may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Site visitors and may be associated with Cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, to provide online advertising, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened.
• Information That You Voluntarily Provide. We also collect non-personal information (e.g., your geographic location, etc.) when you voluntarily provide such information to us. When such information is not combined with any personal information, such information is considered to be non-personal information, as it does not personally identify you or any other user. Additionally, we may aggregate personal information in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using personal information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered non-personal information for purposes of this Policy.
• Please note that if we combine any non-personal information with personal information, the combined information will be treated by us as personal information as long as it is so combined.

Information Disclosed to Third Parties

We may disclose information about you to affiliated and non-affiliated third parties.

• We may disclose the information that we collect to our affiliated companies to provide the products you request, to enhance our products to better suit your needs, and from time to time for marketing purposes.
• Business Partners. We may partner with other companies to offer you products or services or to fulfill the products or services that you order. We may disclose personal information and/or non-personal or de-identified information collected about you to such third-party partners for the purposes described in this Policy.
• Service Providers. We work with third parties who provide services including but not limited to data analysis, order fulfillment, list enhancement and other administrative services. We may disclose personal information to such third parties for the purpose of enabling these third parties to provide services to us. Such services may include: marketing distribution, email list management services, advertising, certain product functionalities, customer support, web hosting, customer data management and enhancement, fulfillment services (e.g., companies that fill product orders or coordinate mailings), research and surveys, data analysis and email service.
• We reserve the right to transfer any and all information that we collect from Site users to an affiliate or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
• Law enforcement; emergencies; compliance; other purposes permitted by law. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose personal information to others as we believe appropriate (a) to comply with legal process; (b) to respond to governmental requests; (c) to enforce our Terms of Use; (d) to protect the rights, privacy, safety or property of ConsumerInfo.com, Inc., our affiliated companies, you or others; (e) to permit us to pursue available remedies or limit the damages that we may sustain; and (f) for any other purpose permitted by applicable law.
• Aggregate, Non-Personal, or De-identified Information. We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personal, de-identified, or anonymous information we collect with third parties, including affiliates to develop and deliver targeted advertising on our Site and on the websites of third parties. If you would prefer that we do not utilize cookies with your website experience, or would prefer to restrict the use of cookies with network advertising partners, please see the “Your Choices” section below.

3. Removal of Your Personal Information.  If you provide Direct Funder, LLC written notice of your request to remove your Personal Information, we will endeavor to remove it as quickly as possible.  You understand that any such removal is only intended to result in the removal of your Personal Information from Direct Funder, LLC’s own records, but will not result in, nor will your request create an expectation of, any removal of any information about you from the Available Information.
4. Other Information. Direct Funder, LLC may store, and you authorize Direct Funder, LLC to store, your Credit Card and/or Sensitive Information solely for its purposes. Direct Funder, LLC will not share your Credit Card and/or Sensitive Information for any purposes, unless Direct Funder, LLC first obtains your prior written consent to do so.
5. Aggregate Information. Notwithstanding anything in this Privacy Policy to the contrary, Direct Funder, LLC may use any information you provide, when aggregated with others’ information, to provide trend analysis of market segments, business growth patterns, or any other trending information. In such event, Direct Funder, LLC will not use any personally-identifying information you have provided in any manner which will divulge you or your business in such trending analysis. Further, Direct Funder, LLC may use your information to provide case studies, provided you cannot and will not be able to be identified in such event.
6. Use and Sharing of Your Personal Information.
7. a)Direct Funder, LLC may use your Personal and Non-Personal Information to create and maintain your account, to personalize your experience, to complete administrative and internal communications, to fulfill purchases of our products and services, to transfer in the event of a merger or similar event (in which transferring information would enable a smooth transition to continue fulfillment of requested products and services), and to send periodic e-mail communications relating to the Service, such as purchase receipts, account confirmations, and customer service correspondence.  Direct Funder, LLC may provide your e-mail address and other Personal and Non-Personal information outlined in this Privacy Policy to a third party service, including without limitation any of the Subsidiaries  solely for the purpose of marketing third party services to you, delivering phone, text and e-mail and marketing communications, preventing fraudulent transactions, delivering products and services requested by you or required in order to fulfill products and services requested by you, however, Direct Funder, LLC will first endeavor to obtain your authorizing signature to do so before transmitting your information. Such third parties may include, without limitation: Direct Funder, LLC; Viet Von; Vietvon.
8. b)You understand and agree Direct Funder, LLC may monitor usage on the Website and the Services and may share your use of the Website and Services with law enforcement agencies and officials in response to inquiries or if Direct Funder, LLC has reason to believe your use of the Website and Services is for an unlawful purpose.  Direct Funder, LLC may share your use of the Website and/or Services as required by law, a court order, a subpoena or other court proceedings, or as Direct Funder, LLC determines is necessary or advisable to protect its interests.
9. c)Direct Funder, LLC may use your Personal Information to improve the Website and the Services. Direct Funder, LLC may share Internet protocol addresses used to access the Website with designated third parties to prevent and detect fraud.  Direct Funder, LLC may use services and technologies provided by other companies to assist Direct Funder, LLC in understanding your use of the Website.  Your Personal Information may be available to such third parties to the extent that their technology collects such information for Direct Funder, LLC’s use.  Direct Funder, LLC reserves the right to transfer your Personal Information to any successor in interest to all or some portion of the Direct Funder, LLC business.

If you wish to cease receiving marketing-related e-mails from third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.

SECURITY MEASURES

We have security measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem as soon as possible.

LINKS

The Site may contain links to third-party websites. These linked sites are not under our control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by us. If you provide any personal information through any such third-party website, your transaction will occur on the third party’s website (not the Site) and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

LOCATION

We control and operate the Site from the United States, and the Site is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

YOUR CHOICES

• Direct Funder, LLC Emails. If you prefer not to receive emails from us about offers and Promotions please unsubscribe via the unsubscribe link in an email, or contact us.
• You have the ability to prohibit being served an advertisement based on cookie technology from certain companies. We may utilize reputable third-party vendors to serve advertisements. If however, you are not comfortable with cookies, you can adjust the settings within your browser to further prohibit being served a cookie. Please see the browser’s instructions to perform this task. Additionally, the Network Advertising Initiative (NAI) has developed an opt-out tool with the express purpose of allowing consumers to “opt-out” of the targeted advertising delivered by its member networks. We may share anonymous or de-identified information with such member networks for the purposes of delivering targeted advertising; however you may visit the NAI opt-out page and opt-out of this cookie tracking if you do not wish to receive targeted advertising.
• Changing information. Corrections or updates to your information including your email address, phone number, mailing address, credit card information or password reminder phrase can be made by calling one of our representatives to have them update the information within your account. For your protection, our representatives may request supporting documents before making any changes or updates to your membership information.

7. Children’s Privacy.
8. a)    The Website and the Services are directed to people who are at least 18 years old.  Direct Funder, LLC does not knowingly collect Personal Information from anyone under the age of 18.  If you are aware that Direct Funder, LLC has collected Personal Information from someone under the age of 18, please alert Direct Funder, LLC via the contact information found on our Site, and the information will be removed from our system as soon as reasonably possible.
9. b)    Direct Funder, LLC does not knowingly aggregate or provide information about people under the age of 18.  You are only authorized to use the Website and the Service, or to provide Direct Funder, LLC your information if you are at least 18 years old.
10. Contacting Direct Funder, LLC.If you have any questions regarding this Privacy Policy, please email us atinfo@FundwiseCapital.com.
11. Changes to this Privacy Policy.  Direct Funder, LLC may change this Privacy Policy from time to time in its discretion.  Privacy Policy changes will be posted on the Website and become effective as of the time of change.