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This Affiliate Agreement ("Agreement") is made as of this 29 day of November, 2022 ("Effective Date"), between GRAB MARKETING, LLC a company with its address located at 16192 Coastal Highway, Lewes, DE 19958 (the “Company”) and ("Affiliate"), a(n) , with its principal place of business located at . Company and Affiliate are each a “Party” and, collectively, are the “Parties” to this Agreement. The terms and conditions contained herein supplement and supersede all prior agreements entered into by and between Company and Affiliate.

  1. Company operates a technology platform whereby select and approved persons, hereinafter referred to as “Affiliates,” may elect to perform advertising and marketing services related to certain products available and generate expressions of interest in such products (commonly known as “leads”).;

  2. In order to participate in, or receive any, of the services offered or made available by Company through its technology platform, Affiliate has applied to become a member of the Company “Network,” and Company is willing to accept the application subject to the terms and conditions of this Agreement.

NOW therefore, in consideration of the above, and the mutual covenants and agreements contained in this Agreement, and for other good and valuable consideration, the receipt and sufficiency of which both parties acknowledge, the Parties, intending to be legally bound, do agree as follows:

  1. SCOPE
    1. Affiliate agrees that this Agreement will apply to all Services that Affiliate receives and/or participates in with Company, and to any Account that Affiliate may establish with Company. In the event of any conflict, the order of interpretation will be (1) this Agreement, and (2) any technical document respecting a particular service, such as an Insertion Order (IO). The terms of any such agreement are considered confidential and independent of this Agreement.

    2. Definitions:

      1. “Affiliate” means any person, including third-party marketers, who participates in an Affiliate Program, and registered with the Company via the affiliate signup process, responsible for advertising and marketing financial products, using varied digital assets and channels, for the purpose of 1) directing consumers to fill our online application at a website owned and operated by Company; or 2) collecting consumer data to post to Company’s ping tree.

      2. “Affiliate Network” means any person who provides another Person with Affiliates for an Affiliate Program or whom any Person contracts with as an Affiliate to Promote any good or service; and that enable affiliate, marketers and advertisers to conduct transactions through the distribution of digital assets and the use of tracking systems, where traffic and/or leads are generated and commissions are provided based on specific affiliate campaigns.

      3. “Affiliate Program(s)” means any arrangement under which any marketer or seller of services made available by Company through its technology platform, either directly or through an Affiliate Network.

      4. “Digital Assets” includes, but are not limited to, visual aids used to engage consumers and persuade them to complete an online application for a financial product, such as emails, banner ads, sidebar ads and pop-up ads.

      5. “Person” means a natural person, an organization or other legal entity, including a corporation, partnership, sole proprietorship, limited liability company, association, cooperative, or any other group or combination acting as an entity.

    1. In order to participate in any portion of the Services, the Affiliate may be required to provide identifying information (e.g. identification or contact details) to establish an account in order to access and use this Service. Affiliate may also be required to update registration information as part of the continued use of the Service. Affiliate agrees that any registration information given to Company will always be accurate, correct and up to date.

    2. By clicking “Create Account,” you further agree: (A) to the terms and conditions of this Agreement; (B) to be bound by this Agreement; (C) Acknowledge and agree that you have independently evaluated the desirability of participation in the Program and are not relying on any representation or statement other than that which is expressly set forth in this Agreement; (D) represent and warrant that you are lawfully able to enter into Agreements (i.e. you are not a minor); (E) you are and will remain in compliance with the terms of this Agreement and with all state and federal laws; and (F) if you are entering this Agreement on behalf of a legal entity, then you are authorized (i.e. as an agent of legal entity) and lawfully able to bind the legal entity.

    1. This Agreement and its Terms and Conditions are subject to change by Company at any time. Changes may include, without limitation, changes in the payout structure, payment procedures and other Services-related policies; provided, however, that: (i) any amendment or modification to provisions applicable to disputes will not apply to any disputes that arise before the applicable amendment or modification has been released; and (ii) any amendment or change to payment provisions under these Terms and Conditions will not apply prior to the date of release of the amendment or modification.

    1. Either party may terminate this agreement, at any time, and for any reason. Notice of termination may be made by US mail or by email. Upon termination, Affiliate will stop using the Service(s) immediately. All obligations pertaining to uncontested payments, unresolved disputes, limitation of liability, indemnity and confidentiality shall survive such termination, only to the extent and time reasonably necessary to resolve such disputes.

    2. Company reserves the right, in its sole and absolute discretion to immediately terminate Affiliate’s access to the platform at any time, without notice, should Company suspect fraud, identity theft, misrepresenting or assisting others in misrepresenting any material fact, expressly or by implication, and/or negligence in Affiliate’s business operations.

    3. Upon termination of this Agreement, any and all licenses and rights that may have been granted to each party by the other in connection with this agreement shall terminate immediately. Each party will return or destroy any and all Confidential Information that was exchanged between the parties, and if Company requests, the Affiliate must certify that all such Confidential Information belonging to Company was returned or destroyed in accordance with, and as so instructed, by Company.

    4. Any termination of this agreement will not affect any obligations that, by their nature, are intended to survive termination, including without limitation, obligations regarding payment, confidentiality and indemnification, which will survive for a period of one year from the date of termination.

    1. All payments generated pursuant to this Agreement will be paid in U.S. dollars. The initial payment to Affiliate may, in Company’s sole discretion, be delayed up to fourteen (14) days in order for Affiliate to undergo the appropriate due diligence required to properly vet Affiliate’s professional background and/or Affiliate’s advertising and marketing methods.

    2. Any payments made to Affiliate under this Agreement will be made electronically, under a Net 7 payment schedule. Company will compile, calculate and electronically deliver reports of all data transferred between the parties. Upon written request by Affiliate, Company may also provide additional data, as necessary, to demonstrate billing and compensation calculations. Any questions regarding the data provided by Company, or disputes regarding payments made, must be submitted in writing within five (5) business days of the reporting provided by Company, otherwise the information will be deemed accurate and accepted by Affiliate.

    3. Upon termination of this agreement and except where otherwise provided, all payments that are due to Affiliate will be paid during the next billing cycle.

    4. Company reserves the right, but is not obligated to, investigate invalid or questionable traffic and/or any of Affiliate’s advertising and marketing practices during the term of the relationship between the parties. Company will notify Affiliate of any investigations, and the outcome of the same. If Company suspects that Affiliate may have engaged in an action which violates Applicable Law or this Agreement, Affiliate agrees that they will cooperate fully with the Company investigation and will, within two (2) business days of request, tender to Company all information requested, as well as any additional information that may be relevant to its investigation.

    5. Affiliate must provide a unique valid Taxpayer Identification Number (TIN) or valid Social Security Number (SSN), or other appropriate identification documentation (to be determined on an individual basis by Company) to receive payment. Additionally, Affiliate must have a valid, completed Form W8 or Form W9, or other appropriate identification documentation (to be determined on an individual basis by Company) on file with Company. Company reserves the right to withhold any and all payments due if there are issues with this identifying paperwork.

    6. If Company fails to receive payment in full from a Network Party, it will have no payment obligation to Affiliate. Affiliate accepts all risks associated with non-payment by the Network Party, and explicitly acknowledges that Company is not a guarantor of any payment or other obligation of any Network Party. If a Network Party does not pay on time, Company may, in its discretion, notify Affiliate and offer assistance with respect to collection, but it is not contractually obligated to do so.

    7. In certain circumstances, to be determined by Company, in its sole discretion, may decide to pay Affiliate for any amounts owed by a Network Party if that Network Party does not pay timely. If Company decides to make such a payment to Affiliate, then Affiliate agree to assign all rights to future payments from that Network party to Company equal to the amount which Company has already paid to Affiliate.

    8. Further, and in addition to any other remedies available to Company under these Terms and Conditions, Company reserves the right to:

      1. decline to pay or otherwise compensate Affiliate for any clicks, leads, actions or traffic that is believed to have been generated using Fraudulent or Deceptive Means or in violation of Applicable Law;

      2. set off against any future payments owed to Affiliate or seek reimbursement or charge backs for clicks, leads, actions or traffic that is believed to be have been generated using Fraudulent or Deceptive Means, duplications or inaccuracies, technical errors, tracking discrepancies, and/or

      3. set off or seek reimbursement for any payments made in violation of these Terms and Conditions.

    9. Affiliate will be responsible for paying any and all applicable taxes (if any) due to all taxing authorities arising from, or in connection with, Affiliate’s participation in the Service.

    10. There will be no responsibility to tender payments to Affiliate for

      1. consumer information that is transmitted and sold after this agreement terminates;

      2. consumer information that does not satisfy the Consumer Data Guidelines,

      3. consumer information that is not recorded due to Affiliate’s error or intentional interference;

      4. any perceived instances of fraud, material misconduct, negligence, or any other action that would be deemed, in Company’s sole discretion, to breach this agreement.

    11. If Company determines that any Affiliate or Affiliate Network has engaged in or is engaged in acts or practices prohibited by law or this Agreement, either directly or through any Affiliate that is part of Company’s Affiliate Program, Company may, at its own discretion, halt processing of any payments or charges generated by the Affiliate or Affiliate Network, and immediately terminate the Affiliate or Affiliate Network.

    1. Any consumer data sent to the Platform must satisfy all of Company’s Consumer Data Guidelines in this subsection (“Guidelines”). Any data that does not comply with the Guidelines will be deemed invalid, for which no payment will be tendered to Affiliate, and Company will not use the data for any commercial purposes whatsoever.

      1. Delivery. The data must comply with all technical specifications communicated to Affiliate by Company. These specifications will be communicated from time to time, and Company reserves the right to change the aforementioned specifications should the Platform be modified/updated as necessary.

      2. Self-Generation. Information must be submitted directly to Affiliate by that Data Subject and may not be generated through the use of bots, fraudulent means, or any other method which may be deemed “spam”.

      3. Completeness. Any consumer data transferred must include all required fields as specified by the Technical Specifications and Affiliate may not use default values for any of those required fields.

      4. Data Integrity. Affiliate must ensure that the file includes only information that has been input by the Data Subject and must make commercially reasonable efforts to ensure that information provided is accurate. Consumer data may be rejected, or later invalidated, based an inability to verify the accuracy of certain information contained within the file. In addition, Affiliate must provide accurate timestamp and other identifying information that is required to determine the age of the data and any information that would allow Company to properly determine Data Integrity.

      5. Duplication. Duplicate files of consumer data may not be sent to Company within thirty (30) days of each other. To the extent that Affiliate has a high percentage of duplicates, Company reserves the right to extend the duplicate review period for whatever period Company deems necessary to complete a full and thorough investigation.

      6. Incentivized Leads. Affiliate may not provide any consumer data that may have been generated by misleading the Data Subject, or by providing the Data Subject a reason to believe that they will receive a prize, gift, payment or pecuniary benefit of any kind in exchange for their consumer data.


    Each party represents and warrants that:

    1. It has full power and authority to enter into this Agreement, which is legally binding, and the execution, delivery and performance of this Agreement will materially comply with all Applicable Laws, rules and regulations;

    2. Neither party currently uses, or will in the future use, any Fraudulent or Deceptive Means to perform this Agreement;

    3. On every consumer facing website at which data could be collected and/or processed, both parties will post a privacy policy and website terms and conditions of use, which will accurately describe data collection, storage and data sharing procedures, and will comply with all Applicable Law;

    4. The Data that is transferred pursuant to this Agreement will be current, accurate and complete; and will not contain any email addresses that were obtained through email harvesting or dictionary attacks, whether by Affiliate or by a third party;

    5. Each party shall, within five (5) business days of receipt, promptly applicable party, as the case may be, with any and all ‘do not contact’ and ‘unsubscribe’ notifications that it receives that are relevant to the Data provided pursuant to this Agreement;

    6. No adverse claim has been made against such party with regard to the Use, Collection or Processing of any such Data;

    7. Each party maintains suitable Records, in commercially reasonable detail, with respect to the Collection and Processing and Use of all such Data;

    8. Each party has obtained any necessary permission needed to Transfer all such Data, whether from the Data Subjects or from any Third Party from which such party has acquired such Data;

    9. Daily operations will not violate any other party’s intellectual property rights, and each party will be solely responsible for the development, operation and maintenance of its website, database, any and all materials that appear on websites, including without limitation:

      1. the technical operation of websites and all related equipment;

      2. creating and posting content, descriptions and references on websites;

      3. the accuracy and propriety of materials posted on their respective website;

    10. Each party recognizes and understands that the other will enter into agreements with, and will provide the Service to individuals and entities in direct competition with the other;

    11. During the term of this Agreement, and for a period of two (2) years after termination of this Agreement, neither party will use the other party’s content as a prospecting tool for purposes of soliciting any Network Party.

    12. With respect to marketing services and campaigns perform pursuant to this Agreement, each party represents and warrants that all such campaigns and marketing services:

      1. will be truthful, accurate and in compliance with all applicable laws;

      2. will comply with all applicable Campaign instructions and/or restrictions specified in the Campaign; and

      3. will not entail or promote any illegal activities of any kind;

    13. Marketing services will not include, or use paid or sponsored search results, or spyware or adware to promote any Campaign;

    14. No posting of any specific messages relating to services under this agreement or either party, or any Content or Campaign to newsgroups, chat rooms, bulletin boards, blog comments, or to any Internet site that utilizes social website internal email systems;

    15. Neither party will provide services under this Agreement via a website or link to other websites that contain any pornographic, racial, ethnic, political, software pirating or hacking, hate-mongering, or otherwise objectionable content;

    16. Each party will promote Campaigns strictly in accordance with the terms and conditions of this Agreement, including any and all restrictions placed on services by either party from time to time.

    17. No Content provided by one party to the other will be modified in any manner without the other party’s written consent.

    18. Affiliate will abide by any category, Campaign or sub-ID daily click or revenue caps as imposed by Company from time to time. For the avoidance of doubt, and notwithstanding anything to the contrary, Affiliate understands that Company may in its sole discretion decline to pay or otherwise compensate Affiliate for any clicks, leads or traffic in excess of such caps and Company shall not use the consumer data provided in excess of such caps for any non-internal or commercial reason whatsoever and shall not provide them for use by third parties.

    19. The product, service, or Internet web site that is advertised or promoted by each email Affiliate may send pursuant to this Agreement, is sufficient to qualify Affiliate as a "sender" under the CAN-SPAM Act, 15 U.S.C. § 7702(16)(A); and in accordance with the aforementioned regulation, any emails sent by Affiliate will contain a functioning unsubscribe link, Affiliate name, a valid postal mailing address and link to both Affiliate’s website and privacy policy;

    20. Upon request by Company, Affiliate shall provide date, time stamp, IP address and site ID (URL) for any express consent (opt-in), or any other identifying information requested by Company, obtained from any user in Affiliate’s database within 24 hours of such request.

      1. Affiliate Content Requirements. All marketing materials must: (a) use plain and intelligible language; (b) be easily legible (or, in the case of any information given orally, clearly audible); (c) specify the name of the advertiser; (d) be factually accurate; (e) easily legible (fonts and colors); (f) must include the name and postal address of the Affiliate; (f) must represent actual loans; and (g) not contain any potential misrepresentations. Where an advertisement includes a rate of interest or an amount relating to the cost of the credit whether expressed as a sum of money or a proportion of a specified amount, the advertisement also must: (d) include a representative example (including (i) the rate of interest, whether fixed, variable or both; (ii) the nature and amount of any other charge included in the total charge for credit; (iii) the total amount of credit; (iv) the representative APR; (v) the duration of the agreement (unless open-ended); and (vi) the total amount payable by the debtor and the amount of each repayment of credit (unless open ended)); and (e) specify a postal address at which the credit broker or advertiser may be contacted. Any direct marketing campaigns should only be made if the intended recipients likely to qualify for the product or service and reasonably able to obtain: (i) the products or services advertised, (ii) the interest rates advertised, (iii) other loan features offered. All advertising materials must clearly, prominently, and accurately describe any related services that are either optional or required to obtain certain terms.

      2. Company disclaims all warranties of any kind, whether express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose, noninfringement and title, and any warranties arising from a course of dealing, usage, or trade practice except as set forth herein.

      3. Affiliate owns or has the legal right to use and distribute all Media used within any advertising and marketing campaign; and said media complies with all Applicable Laws and does not contain or promote, nor link to, another website that contains or promotes, libelous, defamatory, abusive, violent, prejudicial, obscene, sexually explicit or illegal or illegally obtained content, in Company’s sole discretion;

      4. Affiliate shall not and shall not permit any third-party Sub-Affiliate or other user to, engage in any activity that violates the Advertising and Marketing Best Practices policy or any applicable Laws.

      5. Affiliate shall not engage in acts or practices that are likely to mislead consumers including but not limited to the following:

        1. Misrepresenting any material restrictions, limitations, or conditions;

        2. Misrepresenting any material aspect about the nature or terms of refund, cancellation;

        3. Failing to disclose clearly and conspicuously the following:

          1. any material connection, when one exists, between any user or endorser of any product, service, or program and any other person manufacturing, advertising, labeling, promoting, offering for sale, selling or distributing such product or service;

          2. if applicable, that the content of any website or other publication has not be authored by an objective journalist but is in fact an advertisement placed for compensation;

          3. if applicable, that the consumer will be subject to recurring charges for additional services unless and until the consumer takes specific steps to cancel those services; failing to, in connection with the advertising, promotion, marketing, offering for sale, sale, or provision of any services though an affiliate program;

      6. Affiliate will immediately notify Company if Affiliate is aware or has reason to be aware, of any complaint, litigation, or threatened litigation regarding Affiliate’s relationship with Company, including but not limited to, any complaint, litigation, or threatened litigation surrounding Affiliate’s advertising and marketing practices as a whole.

      7. Affiliate or Affiliate Network, prior to use or dissemination to consumers of any marketing materials, including, but not limited to, websites, emails, and pop-ups used by any Affiliate or Affiliate Network to advertise, promote, market, offer for sale, or sell any services contemplated under this agreement, provide Company with copies of all marketing materials to be used by the Affiliate or Affiliate Network, including text, graphics, video, audio, and photographs; for hyperlinks contained in marketing materials, each location to which a consumer will be transferred by clicking the hyperlink, including URL of any website . However, if Company shall only have access to affiliates only through an Affiliate Network, the Affiliate Network shall obtain and maintain the same information set forth above from each of those affiliates who are party of the affiliate program.

      8. Affiliate shall promptly and completely investigate any complaints that Company receives through any source to determine whether any Affiliate or Affiliate Network is engaging in prohibited acts or practices.

    1. Affiliate agrees to allow Company to use any means of monitoring activities used pursuant to this Agreement.

    2. During the Term of this Agreement, Company or their designated third-party auditor, may, upon no less than seventy-two (72) hours written notice, audit and inspect during normal business hours for compliance with (a) the terms of this Agreement and (b) law applicable to the work and services provided by Affiliate under this Agreement. The parties agree that any such audit and inspection shall be conducted in a manner that does not disrupt Affiliate’s normal operating procedures. Affiliate shall be responsible for any and all costs associated with said audit.

    3. If Company reasonably believes that there is the potential for data fraud or other non-compliance with this Agreement or Applicable Law, Company may freeze Affiliate’s account(s) and prohibit access to the platform pending the conclusion of Company’s investigation.

    4. Campaigns may be subject to additional rules, as set forth in the Campaign details, and promotion of a Campaign constitutes acceptance of those additional rules and agreement not to breach those rules, which are incorporated into this agreement by this reference. Violation of the additional rules in a Campaign shall constitute a material breach of this Agreement.

    5. Company may seek such refunds or setoffs at any time during this Agreement and for up to one (1) year following the termination of this Agreement.

    6. Company reserves any and all rights, civil and criminal, it may have against the Affiliate included in and independent of this Agreement for violation of this Agreement.

    1. Each party shall keep all Confidential Information strictly confidential for two (2) years from the date such party received the Confidential Information. All consumer data shall be considered confidential information and therefore, both parties must:

      1. restrict disclosure of Confidential Information to only employees who have a need to know (each a “Representative”) as necessary to perform the obligations and purposes for which the Confidential Information was disclosed;

      2. ensure that each such Representative keep such Confidential Information secure and confidential at all times understanding that such party will be solely responsible for any disclosure of Confidential Information by any of such party’s Representatives in violation of these Terms and Conditions; and

      3. use the Confidential Information received only for purposes directly related to the purposes of fulfilling obligations under this agreement and for no other purpose.

    2. Nothing contained in these Terms and Conditions will be construed as granting or conferring any rights, title or interest in or to any Confidential Information of either party. All Confidential Information will remain the property of the disclosing party and the parties agree to return all Confidential Information and any copies contain all or any portion of Confidential Information to the disclosing party immediately upon written request. Either Party will construe no disclosure of any Confidential Information under these Terms and Conditions to be a public disclosure of such Confidential Information for any purpose whatsoever.

    3. The information and services provided by each party are proprietary in nature and, by accepting these Terms and Conditions, each party acknowledges that it is a competitor of the other and agrees not to share any such information with any competitors of each other. Affiliate further agrees that monetary damages for breach of this Section 9 may not be adequate and that the disclosing party will be further entitled to injunctive relief, without the requirement to post bond.

    4. his Section will survive any termination of this Agreement for a period of two (2) years, or for as long as the Confidential Information in question remains a trade secret under applicable laws and regulations, whichever period is longer.

    1. Affiliate acknowledges and agrees that each party owns all legal right, title and interest in and to their respective Sites and Services, including any intellectual property rights that subsist in the Services (whether those rights happen to be registered or not, and where in the world where those rights may exist)

    2. Unless otherwise agreed in writing or necessary to offer a service contemplated herein, nothing in the Terms and Conditions gives the other party a right to use each other’s Marks or any Marks of a Network Party without prior express consent. If such party has been given an explicit right to use any of Marks in a separate written agreement, then use of such Mark will be in strict compliance with that agreement, any applicable provisions of the Terms and Conditions, any guidelines that either or both parties may require Affiliate to follow as updated from time to time.

    3. Affiliate understands and agrees that the availability of the Platform or Service does not operate to act as a waiver of any rights related to those items, and each party does not acquire any transfer of ownership rights to what the other party makes available through its respective Service or its Site.

    4. By using the Site you are granted a non-exclusive, non-transferable, revocable and limited license to access and use the Site and associated content in accordance with the Agreement. Registration through the Site shall confer no right to participate as a Company Affiliate. Once approved as an Affiliate, you shall be subject to the restrictions contained in the applicable Network Agreement regarding use of the Creative Materials, the Company. Network and other materials made available therein. Company may terminate this license at any time for any reason. You may use the Site for your own personal, non-commercial use. No part of the Site may be reproduced in any form or incorporated into any information retrieval system, electronic or mechanical. You may not use, copy, emulate, clone, rent, lease, sell, modify, decompile, disassemble, reverse engineer or transfer the Creative Materials, Site, any content featured therein or any portion thereof. Company reserves any rights not explicitly granted in the Agreement. You may not use any device, software or routine to interfere or attempt to interfere with the proper working of the Site Company Network. You may not take any action that imposes an unreasonable or disproportionately large load on Company infrastructure. Your right to use the Site is not transferable.

    5. Company shall have sole ownership of and full right to use any and all Leads and data generated by Affiliate in connection with this Agreement, throughout the term of this Agreement and beyond. Affiliate transfers full ownership and a proprietary interest in all Leads that are purchased and paid for by Company. Affiliate shall have no rights to any Leads. Affiliate shall have no right to use Leads other than as expressly stated in this Agreement or as expressly authorized by Company. in writing. Affiliate shall refrain from disclosing, selling, or otherwise distributing Leads purchased by Company. to any third parties. Without limiting the foregoing, Affiliate shall not: (i) transfer, export, display, forward, or otherwise share any such Leads to or with any third party; or, (ii) use any such Leads on Affiliate’s own behalf in any manner not expressly authorized by Company.

    6. For purposes of this Agreement, any partner, associate, contractor, representative, or agent of Affiliate that participates in or performs any activities for Affiliate as a part of the Network shall be deemed a “Sub-Affiliate.” Any and all Sub-Affiliates must be preapproved by Company. Without limiting the foregoing, any Sub-Affiliate is prohibited from using Company’s Creative Material on any website unless given prior written approval by Company. Company reserves the right to withhold or refuse approval of any Sub-Affiliate for any reason or no reason at all, and Company may revoke its approval of any Sub-Affiliate at any time, with or without notice, for any reason or no reason at all. All Sub-Affiliates must meet the same criteria for approval and must comply with the same obligations as required of the Affiliate under this Agreement. Affiliate shall be responsible for the acts and/or omissions of its Sub-Affiliates. Affiliate agrees to indemnify, defend and hold harmless Company and its directors, officers, shareholders, employees, agents and publishers from and against any and all third-party claims, actions, and suits, including reasonable attorneys’ fees and costs arising out of or related to the acts, errors, or omissions of the Affiliate, its Sub-Affiliates, and any of Affiliates or Sub-Affiliate’s directors, officers, employees, and agents.

    1. The exclusions and limitations contained in these Terms and Conditions are intended to exclude warranties and to limit or exclude liability to the maximum extent permitted by law.

    2. Each party expressly understands and agrees that use of the services and platform provided is at such party’s sole risk and that the service and platform provided are provided “as is, where is” and “as available”, with all faults. Neither party represents or warrants that use of the service or platform or any third party components and information (1) will meet requirements, (2) will produce the results or revenue sought, or (3) will be uninterrupted, timely, secure or free from error, or (4) will be accurate or reliable; or any encryption algorithms, associated keys and other security measures provided pursuant to the service will be secure or effective; or any defects in the operation or functionality of any software provided as part of the service will be corrected. All parties further expressly disclaim all warranties and conditions of any kind, whether express or implied, including but not limited to (1) quiet enjoyment, quality of information, security, reliability, timeliness, availability of backed up data, performance of service; and (2) implied warranties of merchantability, fitness for a particular purpose, non-infringement, and title. All parties agree that they will be solely responsible for any damage to their respective computer system or other device of loss of data that results from participation in the service and lead production. No advice or information, whether oral or written, obtained by from either party will create any representation or warranty not expressly stated in these terms and conditions.

    1. Under no circumstances will either party be liable to the other for: for any indirect, incidental, consequential, special, exemplary, punitive or other damages (including damages for lost profits or lost revenues (whether incurred directly or indirectly), any loss of goodwill or business reputation, any loss of data suffered, lost business opportunities, lost customers or loss of use, cost of procurement of substitute services, or other intangible loss), under any legal or equitable theory of liability, whether incurred by you or any third party, even if the party had been advised of their likelihood; or any loss or damage that may be incurred by such party , including but not limited to loss or damage arising from any reason.

    2. The limitations on liability in this section 12 will apply whether or not either party has advised of or should have been aware of the possibility of any such losses arising. The exclusions of warranty and limitations of liability set forth in this agreement are fundamental elements of the basis of bargain and the parties would not enter into any legal agreement to provide the service without agreement to these exclusions and limitations. Each party’s liability to the other shall not exceed $1,000.


    You agree to indemnify and hold Company, its parents, subsidiaries, and affiliates, and each of their respective members, officers, directors, employees, agents, co-branders and/or other partners, harmless from and against any and all claims, expenses (including reasonable attorneys’ fees), damages, suits, costs, demands and/or judgments whatsoever, made by any third party due to or arising out of: (a) your use of the Site, Creative Materials and/or Company Network; (b) your breach of the Agreement; and/or (c) any dispute between you and any Site-User, Affiliate, Advertiser, any third party or other entity. The provisions of this paragraph are for the benefit of Company, its parents, subsidiaries and/or affiliates, and each of their respective officers, directors, members, employees, agents, shareholders, licensors, suppliers and/or attorneys. Each of these individuals and entities shall have the right to assert and enforce these provisions directly against You on its own behalf.

    1. This Agreement shall be governed and construed in accordance with the law of the State of Delaware.

    1. Any controversy or claim arising out of or relating to this contract, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association in accordance with either (i) its Commercial Arbitration Rules or (ii) Arbitration Rules to be mutually agreed upon by the parties, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.

    2. The parties shall attempt in good faith to resolve any dispute arising out of or relating to this Agreement promptly by negotiation between executives who have authority to settle the controversy and who are at a higher level of management than the persons with direct responsibility for administration of this Agreement.

    3. All offers, promises, conduct and statements, whether oral or written, made in the course of the negotiation by any of the parties, their agents, employees, experts and attorneys are confidential, privileged and inadmissible for any purpose, including impeachment, in arbitration or other proceeding involving the parties, provided that evidence that is otherwise admissible or discoverable shall not be rendered inadmissible or non-discoverable as a result of its use in the negotiation.

    1. Force Majeure. Neither party will be liable or considered in breach of the Terms and Conditions on account of delay or failure to perform as required under the Terms and Conditions due to, arising or resulting from any causes or conditions that are beyond the reasonable control of the party which such party is unable to overcome through the exercise of commercially reasonable diligence (a “Force Majeure Event”). If any such Force Majeure Event occurs including, without limitation, acts of God, fires, explosions, telecommunications, Internet or network failure, results of vandalism or computer hacking, storm or other natural occurrences, national emergencies, pandemics, acts of terrorism, insurrections, riots, wars, strikes or other labor difficulties, or any act or omission of any other person or entity, each party to notify the other and use commercially reasonable efforts to minimize the impact of any such event.

    2. Notices. Any notice under this Agreement must be in writing and will be deemed to have been duly delivered if hand-delivered, mailed postage-prepaid to the respective address of each party set forth below, or to such other address as Company may designate, or sent by verified electronic mail to the contact information identified below:

      ADDR: 16192 Coastal Highway, Lewes, DE 19958
    4. No Waiver of Rights. Neither party waives enforce or any legal right or remedy which is contained in the Terms and Conditions by failure to act upon such right

    5. Signature. Both parties agree that electronic signatures shall have the same force and effect and will bind either party to this Agreement tin the same manner and to the same extent as a physical signature would do, in accordance with the Electronic Signatures in Global and National Commerce Act (“ESIGN”) to the extent applicable. Both parties also agree that this Agreement and all related documents are electronic records and that, as such, they may be transferred, authenticated, stored and transmitted by electronic means.

    6. Miscellaneous.

      1. Captions and section numbers are used in this Agreement for convenience only and may not be used in the construction or interpretation of this Agreement.

      2. Despite the possibility that one party may have prepared the initial draft of this Agreement or played the greater role in the physical preparation of subsequent drafts, the parties agree that neither of them shall be deemed the drafter of this Agreement and that, in construing this Agreement in case of any claim that any provision hereof may be ambiguous, no such provision shall be construed in favor of one party on the ground that such provision was drafted by the other.

      3. If any Section or provision of these Terms and Conditions, or the application of such Section or provision, is held invalid by any court of competent jurisdiction, applicable statute or rule of law, then such Section or provision shall be deemed automatically adjusted to the minimum extent necessary to conform to the requirements for validity as declared at such time and, as so adjusted, shall be deemed a Section or provision of this Agreement as though the amended language existed originally at the time entered this Agreement. If the invalid Section or provision is of such a nature that it cannot be so adjusted, then the Section or provision will be deemed deleted from this Agreement as though such Section or provision had never been included. In either case, the remaining Sections and provisions of this Agreement shall be interpreted so as to best reasonably affect the original intent of the parties.

    7. Relationship Between Parties: The parties are independent contractors, and nothing in this Agreement will create any partnership, joint venture, agency, franchise, sales representative or employment relationship between the parties.

    8. Succession: This Agreement will be binding on, inure to the benefit of and be enforceable against the parties’ successors and assigns.

    9. Assignment: Neither party may assign its rights or obligations under this Agreement without the prior written consent of the other party, which consent shall not be unreasonably withheld. Any assignment in violation of this provision is void ab initio. This Agreement shall be binding on each party's successors and permitted assigns.

IN WITNESS WHEREOF, the parties have executed this Agreement:

November 29, 2022

November 29, 2022






Effective March 1, 2021


We may modify this Agreement at any time at our sole discretion. If we decide to change this Agreement, we will post those changes on this Website. We encourage you to periodically review our Agreement to stay informed about our policies.


1. LICENSE GRANT. This Agreement provides You with a limited, non-exclusive, non-transferable, and non-sublicensable license to use the Website solely for your personal use or your internal business purposes.
2. LICENSE RESTRICTIONS. The foregoing license is limited. You therefore may not (i) use, copy, store, reproduce, transmit, distribute, display, rent, lease, sell, modify, alter, license, sublicense, or commercially exploit the Website (or any part thereof) in any manner not expressly permitted by this Agreement, (ii) reverse engineer, decompile, disassemble, translate, or create any derivative work of the Website (or any part thereof); (iii) access, link to, or use any source code from the Website (or any part thereof); or (iv) erase or remove any proprietary or intellectual property notice contained in or on the Website (or any part thereof). In addition, You acknowledge and agree that exceeding the scope of the license herein shall be a material breach of this Agreement and subject to the termination provisions set forth herein.
3. USER OBLIGATIONS. Subject to GRAB MARKETING, LLC’s right to monitor or audit compliance, You acknowledge and agree that it is solely your responsibility to maintain your compliance with the terms and conditions of this Agreement. By accessing or using the Website, You also agree to be responsible for and to abide by all applicable local, state, national, and international laws, regulations, rules, and guidelines with respect to your use of the Website. In addition, You agree to assume all responsibility for your use and the results of your use of the Website including meeting any requirements of your contracts with third parties or other persons.
4. PROPRIETARY RIGHTS. The contents of the Website, including all software, design, text, graphics, images, photographs, illustrations, audio and video material, artwork, databases, user interfaces, visual interfaces, sounds, artwork, presentations in any format, computer code (including html code), products, information, and documentation, as well as the design, structure, selection, coordination, expression, “look and feel,” and arrangement of the Website (collectively, “Material”) unless otherwise indicated, are owned, controlled, and licensed by GRAB MARKETING, LLC or its licensors. Any rights granted hereby are expressly licensed. GRAB MARKETING, LLC does not grant any implied right to You or any other person and does not transfer or assign any ownership or intellectual property interest or title in or to the Website (or any part thereof) to You or anyone else. Accordingly, Your unauthorized use of the Website (including any Material) may violate intellectual property or other proprietary rights laws as well as other laws, regulations, and statutes. The Website and Material is Copyright ©2021 GRAB MARKETING, LLC and/or its licensors. You must not alter, delete or conceal any copyright or other notices contained on the Website or Material, including notices on any audio/visual material You access, download, transmit, display, print or reproduce from the Website. You shall not, nor will You allow any third party (whether or not for your benefit) to reproduce, modify, create derivative works from, display, perform, publish, distribute, disseminate, broadcast or circulate to any third party (including, without limitation, on or via a third party website), or otherwise use, any Material without the express prior written consent of GRAB MARKETING, LLC or its owner if GRAB MARKETING, LLC is not the owner. GRAB MARKETING, LLC and all other names, logos, and icons identifying GRAB MARKETING, LLC and its products and services are proprietary trademarks of GRAB MARKETING, LLC (or its affiliates), and any use of such marks, including, without limitation, as domain names or account identifiers, without the express written permission of GRAB MARKETING, LLC is strictly prohibited. Other product and company names mentioned herein or on the Website may be the trademarks and/or service marks of their respective owners.
5. AFFILIATES. If You wish to become an Affiliate of GRAB MARKETING, LLC, You must complete one or more online sign up forms that request specific information from You, including, but not limited to, Your name, address, and phone number. Once You submit the form to GRAB MARKETING, LLC, GRAB MARKETING, LLC will decide whether to make You an offer to join Our Affiliate Network. Submissions to GRAB MARKETING, LLC are not offers, but merely solicitations of an offer. No Affiliate relationship is established between You and GRAB MARKETING, LLC until You sign a GRAB MARKETING, LLC Affiliate Agreement.
6. MOBILE SERVICES. The Website may include certain services that are available to You via your mobile phone or other mobile device if You have subscribed to them, including the ability to use your mobile device to receive and reply to messages from GRAB MARKETING, LLC and access certain other features (collectively, “Mobile Services”). Although GRAB MARKETING, LLC does not charge You for these Mobile Services, your mobile carrier’s normal messaging, data, and other rates and fees will still apply to your use of the Mobile Services. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your mobile carrier, and not all Mobile Services may work with all carriers or devices. Therefore, You are responsible for checking with your mobile carrier to determine if the Mobile Services are available for your mobile devices, what restrictions, if any, may be applicable to your use of the Mobile Services, and how much they will cost you.
7. FEEDBACK. GRAB MARKETING, LLC welcomes your feedback and suggestions about GRAB MARKETING, LLC’s products or services or with respect to how to improve the Website. But, by transmitting any feedback or suggestions and any related information, material, or other content (collectively, “feedback”) to GRAB MARKETING, LLC, You represent and warrant that such feedback does not infringe or violate the intellectual property or proprietary rights of any third party (including, without limitation, patents, copyrights, or trademark rights) and that You have all rights necessary to convey such feedback to GRAB MARKETING, LLC. In addition, any feedback received by GRAB MARKETING, LLC will be deemed to include from You a royalty-free, perpetual, irrevocable, transferable, non-exclusive right and license for GRAB MARKETING, LLC to adopt, publish, reproduce, disseminate, transmit, distribute, copy, use, create derivative works, and display (in whole or in part) worldwide, or act on such feedback without additional approval or consideration, in any form, media, or technology now known or later developed for the full term of any rights that may exist in such information, material, or content, and You hereby waive any claim to the contrary.
8. REPRESENTATIONS AND WARRANTIES. You represent and warrant to GRAB MARKETING, LLC that (i) You are at least the legal age of majority, (ii) You are authorized to enter into this Agreement, (iii) You will not use the Website or the Materials for any purpose or in any manner that violates any law, rule, ordinance, or regulation or infringes on the rights of GRAB MARKETING, LLC or any third party; (iv) any information or data provided to GRAB MARKETING, LLC by You will not violate any law, rule, ordinance, or regulation or infringe on the rights of GRAB MARKETING, LLC or any third party; (v) all information that You provide to Us in connection with the Website (e.g., name, e-mail address, and/or other information) is true and accurate; and (vi) You are authorized and able to fulfill and perform the obligations and meet the conditions of a user as specified herein.
10. LIMITATION OF LIABILITY. GRAB MARKETING, LLC shall have no responsibility to provide You access to the Website. You acknowledge and agree that GRAB MARKETING, LLC shall not be liable or responsible for any claim, damage, or loss resulting, directly or indirectly, from a cause beyond GRAB MARKETING, LLC’s control, including, but not limited to, offers or promotions made available on the Website, failure of electronic or mechanical equipment or communication lines, telephone or other connection problems, computer viruses, unauthorized access, theft, operator errors, severe weather, earthquakes, or natural disasters, strikes or other labor problems, wars, governmental restrictions, or any claim, damage, or loss arising out of transactions or interactions between You, third party merchants or anyone else. You specifically acknowledge that GRAB MARKETING, LLC shall not be liable for defamatory, offensive, or illegal conduct of any third party and that the risk of harm or damage from the foregoing rests entirely with You. MOREOVER, YOU AGREE THAT IN NO EVENT SHALL GRAB MARKETING, LLC BE LIABLE FOR ANY INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES, INCLUDING, WITHOUT LIMITATION, FOR LOST PROFITS, FOR LOST DATA, ARISING OUT OF OR IN ANY WAY CONNECTED WITH YOUR USE OF THE WEBSITE, OR FOR ANY INFORMATION OR MATERIALS AVAILABLE THROUGH THE WEBSITE, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF GRAB MARKETING, LLC HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. WITHOUT LIMITATION OF THE FOREGOING, TOTAL LIABILITY OF GRAB MARKETING, LLC FOR ANY REASON WHATSOEVER RELATED TO USE OF THE WEBSITE, RESULTS FROM USE OF THE WEBSITE, OR FOR ANY CLAIMS RELATING TO THIS AGREEMENT SHALL NOT EXCEED ONE THOUSAND DOLLARS ($1,000.00 USD), AS LIQUIDATED DAMAGES AND NOT AS A PENALTY EVEN IF GRAB MARKETING, LLC HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THIS LIABILITY, IF ANY, SHALL BE COMPLETE AND EXCLUSIVE.
11. INDEMNIFICATION. You agree to release, discharge, defend, indemnify and hold harmless GRAB MARKETING, LLC and its officers, directors, employees, agents, affiliates, third party information providers, licensors, contractors and others involved in the delivery of products, services or information through the Website (collectively, “Indemnified Parties”), arising from, in connection with, or relating to, any breach of this Agreement by You, including breaches arising from Your use of the information obtained through the Website. You agree that the Indemnified Parties will have no liability in connection with any such breach or unauthorized use, and You agree to indemnify any and all resulting loss, damages, judgments, awards, costs, expenses, and attorneys’ fees and litigation expenses of the Indemnified Parties in connection therewith. You will also indemnify and hold the Indemnified Parties harmless from and against any claims brought by third parties arising out of Your use of the information accessed through the Services or related website(s).
12. GOVERNING LAW. This Agreement has been made in and will be construed and enforced solely in accordance with the laws of the State of Delaware, U.S.A., as applied to agreements entered into and completely performed in the State of Delaware (without regard to conflict of law principles). The state or local courts in the State of Delaware will have exclusive jurisdiction and venue over all controversies in connection with this Agreement, and You hereby consent to such exclusive and personal jurisdiction and venue. Any claim You might have against GRAB MARKETING, LLC must be brought within two (2) years after the cause of action arises, or such claim or cause of action is barred. In addition, You agree to waive any right to a jury trial in connection with any action or litigation in any way arising out of or related to this Agreement and that each party has the right to seek attorneys’ fees in any proceeding. You also acknowledge and agree that any applicable state law implementation of the Uniform Computer Information Transactions Act (including any available remedies or laws) shall not apply to this Agreement and is hereby disclaimed. A printed version of this Agreement and of any related notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this Agreement to the same extent as other documents and records originally generated and maintained in printed form. Please contact GRAB MARKETING, LLC if You wish to receive a printed copy of this Agreement.
13. BINDING ARBITRATION. ANY CLAIM OR DISPUTE RELATING IN ANY WAY TO YOUR USE OF THE WEBSITE OR THIS AGREEMENT SHALL BE SUBMITTED TO CONFIDENTIAL ARBITRATION, except that either party may seek interim relief from any state or federal court in the party’s state of residence to protect the party’s intellectual property rights. ARBITRATION WOULD REMOVE YOUR RIGHT TO LITIGATE A CLAIM IN COURT OR TO HAVE A JURY TRIAL ON THAT CLAIM. OTHER RIGHTS THAT YOU WOULD HAVE IN COURT MAY NOT BE AVAILABLE IN ARBITRATION. IT IS IMPORTANT THAT YOU READ THIS PROVISION CAREFULLY BEFORE ACCEPTING THESE TERMS OF USE. The arbitration will be administered by the American Arbitration Association (“AAA”) under its then-current arbitration rules. If any AAA rule conflicts with these Terms of Use, these Terms of Use shall control. You can obtain procedures, rules, and fee information from the AAA at or 1-800-778-7879. Any participatory arbitration hearing that you attend shall take place in the state of Delaware. Delaware state law will apply during the Arbitration. The judgment upon the award rendered by the arbitrator shall be final and binding and may be entered in any court having jurisdiction. Unless inconsistent with applicable law, each party shall bear the expense of their respective attorneys’, experts’ and witness fees, regardless of which party prevails in the arbitration.
15. ENFORCEMENT. GRAB MARKETING, LLC wishes to maintain the Website as a helpful resource for all of its users. As it relates to GRAB MARKETING, LLC, You therefore have no reasonable expectation of privacy while using the Website because GRAB MARKETING, LLC reserves the right to view, monitor, and/or record activity on the Website (in accordance with applicable law) and to comply with government or court appointed authorities when necessary. Actual or attempted unauthorized use of the Website may also result in criminal and/or civil prosecution, including, without limitation, punishment under the Computer Fraud and Abuse Act of 1986 under U.S. federal law. You shall therefore not, nor shall You permit any third party to, disable, circumvent, or otherwise avoid any security device, mechanism, protocol, or procedure established by GRAB MARKETING, LLC for use of or with the Website. Moreover, You also acknowledge that any breach, threatened or actual, of this Agreement by You may cause irreparable injury to GRAB MARKETING, LLC and/or its licensors, such injury would not be quantifiable in monetary damages, and GRAB MARKETING, LLC and/or its licensors would not have an adequate remedy at law. You therefore agree that GRAB MARKETING, LLC and/or its licensors (or on their behalf) shall be entitled, in addition to other available remedies, to seek and be awarded an injunction or other appropriate equitable relief from a court of competent jurisdiction restraining any breach, threatened or actual, of your obligations under any provision of this Agreement. Accordingly, You hereby waive any requirement that GRAB MARKETING, LLC or its licensors post any bond or other security in the event any injunctive or equitable relief is sought by or awarded to GRAB MARKETING, LLC to enforce any provision of this Agreement.
16. PRIVACY. We respect your privacy and the use and protection of your personally identifiable information. Please see our Privacy Policy for important information and disclosures relating to the collection and use of your personally identifiable information in connection with your use of the Website.
17. TERMINATION. GRAB MARKETING, LLC also reserves the right at any time and on reasonable grounds, which shall include, without limitation, any reasonable belief of fraud, illegal activity, or actions or omissions that violate any term or condition of this Agreement, to terminate this Agreement with You (including any registered account) in order to protect its name, business, or goodwill and/or any other user. You acknowledge and agree that GRAB MARKETING, LLC shall have the sole right to determine in its reasonable discretion whether You are engaging in any unauthorized activity and/or violating any term or conditions of this Agreement. GRAB MARKETING, LLC shall also not be responsible or liable for any damages or loss, such as loss of sales or profits, as a result of any termination of this Agreement in accordance with this section. You may also terminate at any time by ceasing to use the Website. But, all applicable provisions of this Agreement will survive termination, as outlined below. Any licenses from GRAB MARKETING, LLC and any right to use the Website shall immediately cease upon termination of this Agreement. The provisions concerning feedback, GRAB MARKETING, LLC’s ownership rights, representations and warranties, warranty disclaimer, limitation of liability, governing law, enforcement, termination, and the miscellaneous terms will survive the termination or expiration of this Agreement for any reason.
18. DATA PROTECTION & SECURITY AGREEMENT. In addition to the other representations and warranties contained in this Agreement, you further represent that You will use commercially reasonable efforts to maintain the security of your websites and all Lead information, including without limitation as required by the following Data Protection and Security Standards.
Data Protection & Security Standards
  1. Definitions: In addition to any terms defined elsewhere in the Agreement, the following terms have the following meanings. Other capitalized terms used herein but not herein defined shall have the meaning set forth in the Agreement.

    1. "Personally Identifiable Information” shall mean any information that alone or in combination with other information, relates to a specific, identifiable individual person. By way of illustration and not limitation, Personally Identifiable Information includes individual names, personal identification numbers such as Social Security or Social Insurance Numbers, credit card numbers, home telephone numbers, home addresses, driver's license numbers, account numbers, personal email addresses, and vehicle registration numbers, as well as Nonpublic Personal Information as defined by Title V of the Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.) and any of its applicable implementing regulations. Specific information that can be associated with Personally Identifiable Information, such as a user ID or an e-mail address, shall also be Personally Identifiable Information. For example, an individual's age alone is not Personally Identifiable Information, but if such age were capable of being associated with a specific, identifiable individual, then such age would be deemed Personally Identifiable Information. Personally Identifiable Information also includes the fact that an individual has a relationship with GRAB MARKETING, LLC.

    2. "GRAB MARKETING, LLC-Owned Information" shall mean all client information lists, including any Personally Identifiable Information therein, provided by GRAB MARKETING, LLC to Purchaser.

  2. Data Security Standards

    1. At all times, Purchaser shall use its reasonable best efforts to comply with all applicable national, federal, state, and local laws, rules, and regulations of regulatory agencies relating to the protection of Personally Identifiable Information and privacy rights associated with the Personally Identifiable Information.

    2. Notwithstanding anything to the contrary contained in this Agreement and in addition to (and not in substitution for) Purchaser's other obligations hereunder, Purchaser shall, and shall cause its vendors, agents, representatives, and affiliates, to comply with the following Data Security Standards:

      1. Store Personally Identifiable Information for no other purpose than to facilitate the performance of Services under this Agreement, and for only so long as is necessary to facilitate any applicable lending transactions;

      2. Not disclose Personally Identifiable Information to any third party, including, without limitation, third party service providers, list managers, brokers, aggregators, and/or marketers;

      3. Not use and/or disclose Personally Identifiable Information for any purpose other than to facilitate the performance of Services under this Agreement;

      4. Purchaser shall use commercially reasonable best efforts to honor all consumer preferences, including but not limited to opt-out and opt-in requests, communicated to or received by Purchaser regarding the Personally Identifiable Information;

      5. To the extent that Purchaser receives instructions regarding communication preferences, including but not limited to opt-out and opt-in requests, associated with the Personally Identifiable Information, Purchaser shall communicate such preferences to GRAB MARKETING, LLC within seven (7) days;

      6. Maintain effective and commercially reasonable information security measures to protect the Personally Identifiable Information from unauthorized disclosure or use, including:

        1. Using and regularly updating anti-virus software or programs;

        2. Restricting access to the Personally Identifiable Information to a need-to-know basis;

        3. Restricting physical access to the Personally Identifiable Information;

        4. Conducting periodic audits of the security of its systems;

        5. Installing and maintaining firewalls to protect the Personally Identifiable Information from unauthorized access; and

        6. When destruction is required, destroying the data containing Personally Identifiable Information in accordance with global data security and privacy laws by employing commercially reasonable and secure methods that render the data unreadable, including but not limited to, cross-shredding of paper documents.

    3. Provide GRAB MARKETING, LLC with information regarding Purchaser's own data security standards upon the reasonable request of GRAB MARKETING, LLC;

    4. Change and update these Data Security Standards to remain consistent with material changes in standard industry practice and/or in response to reasonable requests by GRAB MARKETING, LLC; and

    5. Purchaser shall provide notice to GRAB MARKETING, LLC within twenty-four (24) hours of the discovery of any breach in the security of unencrypted Personally Identifiable Information whether that failure or breach is suffered by the Purchaser or a third party. Purchaser shall, and shall cause its vendors, agents, representatives, affiliates, and any other party to whom Purchaser may provide the Personally Identifiable Information under this Agreement, work with GRAB MARKETING, LLC to rectify any issues that may result, including providing (or providing access to) all non-confidential information relevant to such breach or necessary to verify the ability of the party responsible for the breach to prevent future data breaches in a manner consistent with this Agreement.

    6. Purchaser agrees to return to GRAB MARKETING, LLC all GRAB MARKETING, LLC-Owned Information in its possession within thirty (30) days of the termination of this Agreement and will not make or retain any copies of the GRAB MARKETING, LLC-Owned Information except as required to comply with any applicable legal or accounting record keeping requirement.

  3. Records. Purchaser and/or the Lenders to whom Purchaser provides Leads purchased under this Agreement will maintain for at least three (3) years its records, contracts, and accounts relating to each loan transaction using the Personally Identifiable Information, and will permit examination not more frequently than once per calendar year of that information upon reasonable request by GRAB MARKETING, LLC and during normal business hours by an auditor.

  4. System Security Standards. Purchaser shall use commercially reasonable best efforts to implement system security standards to protect the integrity of the systems with Confidential Information no less protective than the systems security standards set forth herein.

    1. Definitions. In addition to any terms defined elsewhere in the Agreement, the following terms have the following meanings. Other capitalized terms used herein but not herein defined shall have the meaning set forth in the Agreement.

      1. "Account" collectively refers to those elements of the System used to facilitate access of an end user to the System and associated with a particular User ID.

      2. "Electronic Storage Media" means any tapes, disk drives, cartridges, or other non-volatile storage medium.

      3. "Registration" means the process by which an individual is issued an account on the System.

      4. "Strong Password" means an eight-character password containing upper or lower case alphabetic characters, at least one (1) special character, and at least one (1) numeric character.

      5. "Support/Content Management User" means a user of the System(s) who will perform tasks to support, update, and maintain application-specific content and functionality specific to meeting the objectives of the Agreement including but not limited to graphical images, databases, reference documents, and web pages. Support/Content Management Users include but are not limited to Purchaser's support engineers and System support analysts.

      6. "System" collectively refers to the applicable hardware, software, facilities websites, and services used to provide the Services as such term is defined in the Agreement.

      7. "System Administrator" means a user of the System(s) who will perform tasks to the System(s) in order to meet the objectives of the Agreement including but not limited to account management, operating system support, disk space management, software upgrades, and system monitoring. System Administrators include but are not limited to Purchaser's System Administrator.

      8. "Two Factor Authentication" shall mean an authentication scheme which relies upon two factors such as something the user knows and something the user possesses for authentication. Examples include RSA's SecurID™.

      9. "User ID" means an identifier that uniquely identifies a user of a system.

  5. General Security.

    1. Unless specifically authorized by GRAB MARKETING, LLC, Purchaser must not use software or hardware tools that can break security mechanisms. Examples of such tools are those that facilitate illegal copying of copy-protected software, reverse engineering of code, discovery of secret passwords, deciphering of encrypted data, or monitoring of network traffic. Passwords, encryption keys, and any other information that may be used to weaken or circumvent the security controls described in this Agreement are confidential and must not be disclosed to any individual, unless such individual is otherwise authorized by GRAB MARKETING, LLC, following a security risk assessment performed by GRAB MARKETING, LLC, to access such information.

    2. The following changes to the policy settings listed below should be logged and reviewed: Password policies, Account lockout policies, Screen saver/display policy settings

    3. In addition, the following events must be logged: Domain policy changes, Domain trust changes, Audit log clearance, Security event log clearance, Audit policy changes

    4. The logs shall be readily available in order to facilitate quick reaction to a security threat or breach. Copies of logs shall be retained for at least three (3) months.

    5. GRAB MARKETING, LLC review of user accounts created for customer account support will be performed as part of the audit process. Purchaser is not required to have user requests approved by GRAB MARKETING, LLC's security team at the time of the request.

    6. To protect Confidential Information, after fifteen (15) minutes of keyboard and mouse inactivity, it shall be necessary for a user to log in to his or her service location workstation using his or her User ID and password before viewing any Confidential Information.

  6. Authentication and Authorization.

    1. Purchaser shall provide a unique User ID (Account) for each System Administrator and Support/Content Management User and persons performing tasks of these roles of the System subject to the following conditions:

      1. Authentication shall make use of Two Factor Authentication Technology.

      2. All accesses to the System shall be logged.

      3. Access logs to all network devices, servers, and other equipment necessary for this Agreement shall be maintained for a period of ninety (90) days where technically possible.

      4. The Registration and privilege assignment process shall be documented and made available to GRAB MARKETING, LLC prior to utilization of the service.

      5. Purchaser agrees to audit at least semi-annually the list of System Administrators and Support/Content Management Users and disable the access of those not required to accomplish the objectives of this Agreement.

      6. Internet access shall be over secured channels (example: SSL or SSH).

    2. Purchaser shall make available a unique User ID (Account) for each end user subject to the following constraints:

      1. Authentication shall make use of Strong Passwords.

      2. Password lifetime shall not be more than ninety (90) days.

      3. Purchaser must audit password policy compliance at least semi-annually and report any weaknesses to GRAB MARKETING, LLC.

      4. Purchaser must notify GRAB MARKETING, LLC of any compromised or suspected compromised passwords within twenty-four (24) hours of Purchaser becoming aware of such compromise.

      5. Internet access shall be over secured channels (Ex: SSL or SSH).

  7. Transmission and Storage of Confidential Information.

    1. Where the transmission of Confidential Information across any communication medium susceptible to interception by any party other than the sender or intended recipient(s) is required to fulfill the terms of the Agreement, Purchaser shall at a minimum employ, for the communication medium utilized, generally accepted encryption technologies to minimize the risk of interception and/or disclosure. Encryption shall include the following or higher/better:

      1. 112-bit shared private keys or 1024-bit public/private key (RSA) with encryption algorithms equal to or higher than 3DES, RC4 or IDEA

      2. Integrity-signed MD4 or SHA-1 hashes

      3. Non-Repudiation using digital signatures

    2. Where the storage of Confidential Information on any Electronic Storage Medium is required to fulfill the terms of this Agreement, Purchaser shall employ, for the medium utilized, generally accepted encryption technologies to minimize the risk of disclosure to those parties without an explicit need to know.

  8. Event Logging and Notification.

    1. Purchaser agrees to log the following system events:

      1. Login failures

      2. Administrative rights usage

      3. System Administrator and Support/Content Management User logins

      4. System shutdowns and restarts

    2. Purchaser agrees to retain such log information for a period of ninety (90) days from the date of the event and to make such log information available to GRAB MARKETING, LLC upon reasonable request.

    3. Logs shall be reviewed at a minimum on a weekly basis and anomalies shall be reported and action taken.

    4. Purchaser shall notify GRAB MARKETING, LLC within twenty-four (24) hours of Purchaser becoming aware of each of the following types of incidents relative to meeting the objectives of the Agreement:

      1. Virus infection

      2. Compromise of electronic security

      3. Compromise of physical security/theft of assets

      4. Unscheduled outage or system unavailability

  9. Security Patches and Virus Protection.

    1. Purchaser agrees to install and maintain virus protection software on any equipment utilized in meeting the objectives of the Agreement.

    2. Purchaser agrees to apply any vendor-provided virus definition updates within twenty-four (24) hours of availability from the virus software vendor.

    3. Where technically feasible, Purchaser agrees to, within fifteen (15) days of availability from the software or hardware vendor, apply any available critical security patches to any equipment utilized in meeting the objectives of the Agreement.

    4. Where technically feasible, Purchaser agrees to, within two (2) weeks of availability from the software or hardware vendor, apply any available critical security patches to any application software utilized in meeting the objectives of the Agreement.

  10. Access Restrictions. Purchaser agrees to limit physical access to the equipment utilized in accomplishing the objectives of the Agreement to those parties directly involved with maintaining or supporting the equipment. Purchaser shall limit access to any Confidential Information, and to any System documentation specific to the objectives of the Agreement, to those parties directly involved with meeting the objectives of the Agreement. Upon termination of the Agreement, any such Confidential Information or System documentation shall be destroyed or otherwise rendered unreadable.

  11. Equipment Sanitization. Purchaser agrees that upon expiration of the term of the Agreement or upon the replacement of any equipment utilized in meeting the objectives of the Agreement, Purchaser will return and render unreadable and unrecoverable all Confidential Information stored on any Electronic Storage Media before being redeployed for other uses of the Purchaser or, if being disposed of, before leaving the physical control of the Purchaser. This shall be done via seven pass extended character rotation or stronger destruction means to wipe Confidential Information from storage locations.

  12. Audits, Penetration Testing & Security Weaknesses.

    1. Purchaser agrees to perform the following audits and penetration tests with reasonable protection of Confidential Information and on-going service:

      1. A yearly independent third-party penetration test on Internet-facing networks and to resolve or mitigate any critical findings within three (3) months of the final report.

      2. A yearly internal security test/audit for physical and logical security weaknesses including operational systems/controls, networks, privacy, and personnel practices on all portions of the internal network containing or interfacing with Confidential Information on a yearly basis by an independent third party.

    2. Purchaser agrees to provide an appropriate GRAB MARKETING, LLC contact upon request with results of critical findings which are not able to be mitigated or resolved within three (3) months of either the external penetration test or internal audits.

    3. Purchaser agrees to ensure strict controls with limited access to auditing tools on Systems holding Confidential Information and that access to stated tools will be monitored and reviewed.

    4. Purchaser shall report to GRAB MARKETING, LLC, as quickly as possible, any and all indications of potential weaknesses involving Confidential Information for high security risk situations including, but not limited to, weak privileged access passwords or unencrypted customer/GRAB MARKETING, LLC password files.

  13. Extension of Protection.

    1. Purchaser agrees to ensure that protection (maintenance, transmission, and destruction) of Confidential Information extends to parties having access to Confidential Information either via physical or logical means when part of operational processes. Protection shall cover responsibilities, liability, procedures for protection, etc. These shall include but not be limited to:

      1. Protection of Information Privacy. Privacy information relating to the Services under this Agreement shall be handled in all material respects in accordance with all applicable local and federal governmental laws in both backups as well as production information. Transmission of privacy information to third parties for the purposes of fulfilling this Agreement will include specific extensions of privacy statements. Privacy information will not be transmitted to any party which is not an extension of this Agreement.

      2. Security Organization & Incident Management.

        1. Service interruptions shall be addressed in the manner set forth in the Agreement.

        2. If a formal security incident is declared, there shall be procedures defined to ensure that proper reporting of such incidents occur in a timely manner, activities are logged, and evidence gathering is performed in a manner supporting potential legal use, and that these incidents are brought to the attention of GRAB MARKETING, LLC.

        3. The information security organization shall ensure that policy ownership is at a level high enough to ensure enforcement and that appropriate ownership of policies, procedures and standards applies to all management, users, and administrators including contractors and third parties.

        4. The security policy shall state corporate management's security philosophy and goals through executive level commitment to maintain the privacy, integrity, and availability of all corporate and customer information and assets.

      3. Data Breach Notification Procedures. Purchaser shall maintain in place a process to monitor all access to Confidential Information and determine if security measures protecting Confidential Information have been breached. If Purchaser determines that access to Confidential Information has been breached or potentially breached, Purchaser shall immediately contain the breach to the extent possible and notify GRAB MARKETING, LLC of the type of breach (e.g., loss of a laptop, unauthorized system access). Purchaser shall work with GRAB MARKETING, LLC, in accordance with the direction set by GRAB MARKETING, LLC, in identifying the manner in which the data was compromised, the type of data that was compromised, the names of affected customers or employees, and whether any person acted purposefully to cause a data security breach. GRAB MARKETING, LLC shall be responsible for determining if notification needs to be provided to those affected or potentially affected by such breach, and whether notification needs to be provided to law enforcement. In the event of a data security breach, all requests from the press shall be directed to GRAB MARKETING, LLC, and Purchaser shall not communicate with any third party concerning the data security breach without the prior consent of GRAB MARKETING, LLC. Purchaser shall cooperate with GRAB MARKETING, LLC at all times in remedying a data breach and provide GRAB MARKETING, LLC with all information requested related to the breach or potential breach.

      4. Antivirus Patches and Updates. Purchaser shall install and monitor up-to-date antivirus software, configurations, and pattern files on all computing devices connecting to GRAB MARKETING, LLC's data/network. Antivirus software on such computers must be active at all times and not turned off, disabled, or unloaded. Purchaser shall ensure that antivirus pattern file updates will be automatically deployed to all devices connecting to GRAB MARKETING, LLC's network promptly after receipt of the pattern update files from GRAB MARKETING, LLC or the antivirus software vendor. Antivirus pattern file updating shall be considered normal operations and shall not require use of change protocols established by the Parties. GRAB MARKETING, LLC shall have the right to disconnect from data/network any of Purchaser's computing devices found not to have up-to-date antivirus software or pattern files, or for which antivirus software is improperly configured.

      5. Physical & Operations Security.

        1. Equipment shall be sited and protected to ensure reduced risks of interference and unauthorized access. Stated equipment protection shall include, but not be limited to:

          1. Caging, cabling, or other segregated means in secured areas

          2. Proper fire and water protection should be adequate

          3. Access to equipment shall be protected such that:

          4. Visitor access shall be only upon approval, signed-in and escorted by personnel approved for access.

          5. Use of key locks and/or passcodes as well as alarms and video inspection shall be used.

          6. Use of key locks, alarms, passcodes, biometrics, as well as video inspection shall be used.

          7. Biometrics may be used as deemed necessary by the Purchaser.

          8. Combinations/key locks shall be periodically changed and a documented list of authorized personnel with entry access available.

19. MISCELLANEOUS. The relationship between You and GRAB MARKETING, LLC is and shall be that of independent contractors and nothing in this Agreement shall be construed or used to create or imply any relationship of partners, joint ventures, or employer and employee. You may not assign or otherwise transfer this Agreement or the license granted hereunder or delegate any of your duties specified herein, in whole or in part, without GRAB MARKETING, LLC’s prior written consent. Any attempt of assignment, delegation, or transfer in violation of this Agreement shall be void, of no effect, and a material breach of this Agreement. Notwithstanding the foregoing, GRAB MARKETING, LLC may assign this Agreement in whole or in part. Moreover, GRAB MARKETING, LLC may delegate its rights and responsibilities or use contractors or agents to fulfill its obligations under this Agreement. Failure by GRAB MARKETING, LLC to insist on strict performance of any of the terms and conditions of this Agreement will not operate as a waiver of that or any subsequent default or failure of performance. In the event any provision of this Agreement is found by an arbitrator or court of competent jurisdiction to be invalid, void, or unenforceable, You agree that unless it materially affects the entire intent and purpose of this Agreement, the invalidity, voidness, or unenforceability shall affect neither the validity of this Agreement nor the remaining provisions herein, and the provision in question shall be deemed to be replaced with a valid and enforceable provision most closely reflecting the intent and purpose of the original provision. Headings are for convenience only and have no legal or contractual effect. This Agreement and GRAB MARKETING, LLC’s Privacy Policy, which is hereby incorporated by reference as if set forth fully herein, represent the entire agreement between You and GRAB MARKETING, LLC with respect to subject matter herein, and they supersede all prior or contemporaneous communications and proposals, whether electronic, oral, or written between You and GRAB MARKETING, LLC with respect to the Website. Any rights not expressly granted herein are reserved by GRAB MARKETING, LLC. Please note that GRAB MARKETING, LLC reserves the right to change the terms and conditions of this Agreement and by which the Website is extended to You by providing You in writing or electronically a copy of such revised terms (or notice thereof). GRAB MARKETING, LLC also has the exclusive right to provide updates, upgrades, or changes to, or to suspend, discontinue, or modify any aspect of the Website at any time. Your continued use of the Website following any such change to such Website will be deemed acceptance to be bound by any such change to this Agreement or the Website. If You have any questions about this Agreement, You may contact us via e-mail at:, toll-free at [PHONE NUMBER], by facsimile at [FAX NUMER], or in writing sent via certified mail to: GRAB MARKETING, LLC Attn: Compliance Department 4700 Millenia Blvd., Suite 270 Orlando FL 32839

Effective March 1, 2021

GRAB MARKETING, LLC Website Privacy Statement

GRAB MARKETING, LLC collects Personal Data to serve and communicate with you. This Privacy Statement explains how GRAB MARKETING, LLC collects, uses, and discloses your Personal Data and answers questions regarding privacy and security.

Part I. Collection, Use, and Sharing of Personal Data

California Consumers please visit MERLIN CREDIT REPAIR LLC’s California Privacy Policy.

1. Types of Personal Data GRAB MARKETING, LLC May Collect

This Privacy Statement explains our practices with regard to "Personal Data." Personal Data is any information that can be used to identify, locate, or contact you. It also includes other information that may be associated with such Personal Data. Examples of types of Personal Data:
  • Contact Data, such as your name, email address, mailing address, email address or phone numbers;
  • Transaction Data, including purchases, inquiries, and information about how you use the GRAB MARKETING, LLC websites and mobile applications;
  • Financial Account Data, such as your credit card number or Social Security number;
  • Geo-location Data, as may be transmitted to us by your smart phone or other location-aware devices; and/or
  • ob Applicant Data, such as your Contact Data, resume, previous work experience, education, transcript, driver’s license information, social security number or national identification number and information relating to references.

2. How GRAB MARKETING, LLC Collects Personal Data

In most cases, we collect Personal Data directly from you. We will ask you for Personal Data when you interact with us, such as registering on our websites, using any interactive features or applications, signing up to receive a newsletter or a rebate, participating in a savings program, making a direct purchase, or applying for employment. We may collect additional data from third party data suppliers who enhance our files or from social media sites such as Facebook, if you like our pages or join our communities.

If you interact with us online, we use cookies and other technological tools to collect data about your computer and your use of our website and applications. If you use a mobile application that GRAB MARKETING, LLC has developed, that application will inform you of the data that the mobile application collects and what information it may transfer to MERLIN CREDIT REPAIR LLC. We treat this data as Personal Data, only when it, or other data that is associated with it, can be used to identify you. For more information about cookies and other technologies, please see the “Cookies and Other Data Collection Technologies” below

3. How GRAB MARKETING, LLC Uses Personal Data

GRAB MARKETING, LLC may use your Personal Data for its business purposes, such as:
  • To respond to your requests for information, products, services, including managing your online accounts with us and providing warranty service for certain products;
  • To provide you with Your Free Credit Score as well as information about our products and services;
  • To provide you with marketing communications and offers for products and services, including to deliver advertising to you on this and other websites;
  • To administer promotional programs, such as sweepstakes, rewards, and rebate programs;
  • To determine if you are eligible for certain products, services, or programs
  • If you have a business or professional relationship with MERLIN CREDIT REPAIR LLC, to develop our business relationship with you;
  • If you apply for a job via our career center, to consider you for employment;
  • For our research and development efforts;
  • To anonymize data so that it is no longer Personal Data;
  • For product safety, such as adverse event reporting, or to communicate product safety information to you; and/or
  • For other everyday business purposes, such as payment processing and financial account management, product development, contract management, website administration, fulfilment, analytics, fraud prevention, corporate governance, reporting, and legal compliance

4. When and Why Personal Data Is Disclosed by MERLIN CREDIT REPAIR LLC

GRAB MARKETING, LLC will share Personal Data only in compliance with applicable laws and regulations. For example, we may share Personal Data as follows:
  • We may share Personal Data with your consent or as you direct.
  • We may share Personal Data with our affiliated companies and product co-promotion partners, which may only use Personal Data for the purposes listed herein.
  • We may share Personal Data with our service providers, who are bound by law or contract to protect Personal Data and only use Personal Data in accordance with our instructions or the agreements we have signed. For example, we may share Personal Data with vendors who provide data processing or fulfilment services for us.
  • We may also disclose Personal Data where needed to affect the sale or transfer of business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions.
  • We may also disclose Personal Data when requested under legal process or otherwise required by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
  • Please note that we may also disclose data about you that is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers. These reports do not contain any data that would enable the recipient to contact, locate, or identify you.

Part II. Social Media and Cookies

5. Cookies and Other Data Collection Technologies

When you visit our websites or use our mobile applications, we collect many different types of data by automated means, using technologies such as APIs, web services, scripts, cookies, pixels, tags, web beacons, browser analysis tools, and server logs.

We may collect data about the device you use to access our websites or services associated with our mobile apps, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country, region and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices used to identify and communicate with each other on the Internet. We may also collect data about the website you were visiting before you came to our website, and the website you visit after you leave our website. We may also use vendors, such as Adobe and Google, to place cookies and collect data to enable certain services we use, including advertising, visitor tracking, personalization, site analytics and security services, including reCAPTCHA, and the data may be disclosed to our vendors for these purposes.

Other data may be disclosed to vendors providing additional services integrated into GRAB MARKETING, LLC websites and mobile apps, including performance monitoring, user experience components such as user interface frameworks, images and web fonts, maps, and ecommerce functionality.

In many cases, the data we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Data. However, under some privacy and data protection laws, this data could be considered Personal Data. This Privacy Statement governs how we use this data when it is considered your Personal Data. For example, we use the data we collect about all website users, including IP address to optimize our websites and to understand website traffic patterns.

When you visit our websites, we may place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store data or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. Some of our websites may use Web Storage instead of cookies.

We have separated the cookies that we use on our websites and mobile apps into the following general categories: Functional Cookies, Analytics Cookies, Advertising Cookies, and Social Media Cookies.

Functional Cookies: Functional Cookies are automatically placed on your browser and may involve disclosure of data to our service providers. GRAB MARKETING, LLC websites use functional cookies, including Session Cookies, to support the functionality of our websites, such as storing user preferences or maintaining a temporary store of values entered into forms. Session cookies generally expire after a short period of time, while other functional cookies can be cleared by using your browser’s “Forget This Site” functionality or by clearing your browser’s history.

Analytics Cookies: Analytics Cookies are automatically placed on your browser. GRAB MARKETING, LLC websites and mobile apps collect analytics data to allow us to personalize and enhance your online experience, by analyzing repeat visits, user journeys through our websites, and user interaction with website elements. GRAB MARKETING, LLC websites use first-party cookies for these purposes, while our website analytics vendors, including Adobe and Google, may also place cookies in your browser to provide us with analytics services.

Certain GRAB MARKETING, LLC websites use Adobe Flash Cookies (also known as Local Shared Objects), Microsoft Silverlight, and similar technologies. Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. Flash Cookies (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. For more information about how to manage Flash Cookies and/or Silverlight Cookies, you should refer to those vendors’ privacy and data sharing statements.

Pixels and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixels or web beacons generate a notice to us of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

Third Party Advertising Cookies. We may use third party advertising companies to place our ads on other websites. One way we do so is by allowing network advertising companies and social media (“Network Advertisers”) with whom we work to place their own cookies on the browser of an individual who visits one or more of our sites and who clicks “accept” on the cookie consent banner on the site. This enables these Network Advertisers to place a cookie on your computer and to receive information (including for example your IP Address, internet tracking data, and advertising IDs) from that cookie that may include information about your visits to this and other websites. This data received by Network Advertisers allows them to measure advertising effectiveness and to provide advertisements on other websites about our goods and services that are tailored to you and that may be of interest to you on these other websites. These Network Advertisers may in turn disclose your cookie data to other network advertisers to allow these advertisers to display ads to you as well. Under CCPA these additional disclosures may be considered a sale of personal information.

To revoke your consent or opt-out after you have consented to the cookie consent banner, or to manage your cookie preferences, you can delete the cookies on your browser or use the cookie settings on your browser. All browsers are different, so visit the “Help” section of your browser to learn how to delete the cookies we set in your browser, including the cookie consent, and about cookie preferences and other privacy settings that may be available.

6. Social Media Cookies

GRAB MARKETING, LLC websites use social medial plugins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit our website and click “Accept” on the cookie consent banner, the operators of the social plugins and integrated social media platforms can place cookies on your computer, enabling those operators to receive information (including for example your IP address, internet tracking data, and advertising IDs) from those cookies on your computer that allow those operators to see that you have previously visited our site. If you are logged into a social media website (e.g., Facebook, Twitter) while browsing on our website, the social media plugins allow those social media websites to share data about your activities on our website with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allows you to see your friends’ Facebook activity on our website. GRAB MARKETING, LLCdoes not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

Part III. Other Important Information

7. Do-Not-Track Signals and Similar Mechanisms

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Websites linked to this Privacy Statement do not currently respond to these “do-not-track” signals.

8. Your Choices

You can always limit the data you provide to MERLIN CREDIT REPAIR LLC, but if you choose not to provide certain requested information, you may be unable to access some of the services, offers, and content on our websites. You can also limit the communications that GRAB MARKETING, LLC may send to you by following a simple opt-out process. Simply follow the instructions in our advertisement/promotional emails to opt-out of receiving future marketing communications.

Please note that even if you opt-out of promotional emails, we may still need to contact you with important transactional data about your account or your purchase. For example, even if you opt-out of advertisement/promotional emails, we will still send you a confirmation when you purchase something from our website, a notification of changes to, expiration of, or discontinuation of a program you are enrolled in, and product safety communications.

California Consumers should visit MERLIN CREDIT REPAIR LLC’s California Privacy Policy for the designated methods for making California Consumer Privacy Act data subject rights requests.

9. Data Security

GRAB MARKETING, LLC has implemented a data security program that contains administrative, technical and physical controls that are designed to reasonably safeguard your Personal Data from unlawful use and unauthorized disclosure. The security of information transmitted through the internet cannot, however, be guaranteed. We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet. You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of websites, applications, or other services. Any access to websites, applications, or other services through your user ID and password will be treated as authorized by you. To help protect your Personal Data, we may suspend your use of all or part of the websites, applications, or services, without notice, if we suspect or detect any security issues.

10. Disclosure to Subsequent Owner or Operator

If all or part of GRAB MARKETING, LLC is sold or merged into another entity, the data we have about you may be transferred to a third party as part of that transaction. We will try to assure that no Personal Data that is transferred will be used or shared in a manner inconsistent with this Privacy Statement without your consent. However, in the event of a sale or merger, your continued use of this site signifies your agreement to be bound by the privacy statement and other applicable terms of the subsequent owner or operator.

11. Consent to Processing in the United States and Elsewhere

This site is owned and operated by GRAB MARKETING, LLC in the United States, but the data you provide will be accessible to our affiliates, vendors, and suppliers in other countries. Furthermore, if you are visiting this site from another country, other than the United States, your communication with us will necessarily result in the transfer of data across international boundaries. The level of legal protection for Personal Data is not the same in all countries. However, we will take the security measures described in this Privacy Statement in an effort to keep your data secure. By using this site, you consent to the collection, storage, and processing of your data in the United States and in any country to which we may transfer your data in the course of our business operations.

12. Privacy Statements of Third Parties

This Privacy Statement only addresses the use and disclosure of data by MERLIN CREDIT REPAIR LLC. We may provide links to outside websites or advertisements for third parties that have their own privacy statements and data collection, use and disclosure practices. Our independent dealers, suppliers and business partners have their own privacy statements too. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with data or taking advantage of an offer or promotion.

13. Children’s Privacy

GRAB MARKETING, LLC websites and applications are not intended to attract children, and we do not knowingly collect any Personal Data from anyone under the age of 13. If you believe your child is using our website, please contact us so we can investigate and delete any data as may be appropriate.

14. Forums, Product Reviews and Other Public Areas

Our websites may contain forums and other areas where you can publicly post product reviews, communicate with others, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. You have no privacy rights in public postings. All the data you post will be accessible to anyone with Internet access, and any Personal Data you include in your posting may be read, collected, and used by others. For example, if you post your email address along with a product review, you may receive unsolicited messages. Please use caution when posting any Personal Data.

By submitting data to us online, you are sending it to the United States, where it will be subject to the protections afforded under US laws that may be different from the laws in your country and which your country may consider not to provide adequate privacy protections. If you do not agree that your submission of your application data will be governed solely by United States law, GRAB MARKETING, LLC will not accept your application.

15. Changes to this Privacy Statement

We will only use Personal Data in the manner described in this Privacy Statement in effect when the data was collected from you. However, we reserve the right to change the terms of this Privacy Statement at any time by posting revisions to our site. If we make any material changes to this Privacy Statement, we will either notify you or place a prominent notice on our website. If at any point, we decided to use Personal Data in a manner that is materially different from that stated at the time it was collected, you will be given a choice to allow or disallow any additional material uses or disclosures of your personally identifiable data, beyond that which was stated in this Privacy Statement at the time your data was collected.
Any portions of this policy are void to the extent they are prohibited by applicable law.

16. Social Security Number Protection Policy

GRAB MARKETING, LLC collects Social Security numbers in the ordinary course of its business. GRAB MARKETING, LLC has implemented reasonable technical, physical and administrative safeguards to help protect the Social Security numbers from unlawful use and unauthorized disclosure. All GRAB MARKETING, LLC workers are required to follow these established procedures, both online and offline. In particular:

Access to Social Security numbers is limited to those workers and service providers who have a need to access the data to perform tasks for MERLIN CREDIT REPAIR LLC. Social Security numbers are only disclosed to third parties in accordance with MERLIN CREDIT REPAIR LLC’s established Privacy Statement. We will only disclose Social Security numbers: (i) with those service providers, auditors, advisors, and/or successors in interest who are legally or contractually obligated to protect them, or (ii) as required or permitted by law.

17. How to Contact Us

Please contact us if you have any questions or comments about our privacy practices, your privacy choices, or this Privacy Statement. You can always reach us online at You can reach us via mail at the address below. If you send us a letter, please provide your name, address, email address, and information about the communication that you do not want to receive.

Attn: Compliance Department
4700 Millenia Blvd., Suite 270
Orlando FL 32839

California Privacy Policy (Privacy Notice)

Effective March 1, 2021

What is the scope of this Privacy Notice?

The California Consumer Privacy Act of 2018 (CCPA) gives certain consumers that reside in California (“California Consumers”) the right to know what categories of Personal Information GRAB MARKETING, LLC including our affiliated entities (referred to collectively as “GRAB MARKETING, LLC,” “we,” “our,” or “us”), collects about them and how and for what purposes we use and share that information. This California Privacy Policy (“Privacy Notice”) provides the information required under the CCPA and applies to both GRAB MARKETING, LLCs online and offline activities relating to California Consumers’ Personal Information. This Privacy Notice supplements GRAB MARKETING, LLCs Privacy Statement. As used in this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information includes, but is not limited to, the categories of Personal Information identified below if such information identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household.

What Personal Information may we collect, use and share about you and for what purposes?

If you are a California Consumer, the following table details what Personal Information we collect, use and share about you:
Categories of Personal Information Collected – We may collect these types of personal Information: Source(s) of Personal Information – Entities or individuals we may collect this information from: Representative Date Elements may include Purpose(s) for Collecting – How we could use this information: Categories of Third Parties – we may share or disclose this information to:
Contact Information You, Your authorized representatives, Third party data aggregators, Registration data Full name, nicknames or previous names; honorifics and titles; mailing address, email address, telephone number, mobile number, contact information, such as authorized users of your account To identify and communicate with you, send transactional messages, send marketing and promotional communications, personal out communications and provide customer service, process payments, market research, for our everyday business purposes Our affiliates, our service providers, third parties who deliver out communications, other third parties including government agencies as (as required by law)
Government issued identification numbers You, third parties such as consumer and credit reporting agencies Social security number, driver’s license number, passport number, other government issued identifiers as may be needed for compliance To identify you, maintain the integrity of our records, customer verification, security and risk management, market research, our everyday business purposes Our affiliates, our service providers, third parties including consumer reporting agencies, our lawyers, auditors, consultants, other third parties as required by law
Unique Identifiers When you interact with us using your New Image account number, third parties such as ad delivery companies who place cookies containing advertising New Image account number, system identifiers, device identifiers, advertising ID, online user ID To identify your device, for record-keeping, for metrics and analytics, track your use of services and website, for market research purposes, to send marketing and promotional communications, for our everyday business purposes Our affiliates, our service providers, third parties who assist with fraud prevention, detection and mitigation, our lawyers, auditors and consultants, other third parties as required by law
Relationship Information You, third parties that provide access to information you make publicly available Education information, professional information, preferences for being contacted To better understand you, design, develop, market, sell and improve services, send marketing and promotional communications, identify prospective customers, market research, for internal business purposes, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, our lawyers, auditors and consultants, other third parties required by law
Transaction and interaction Information You, third parties that process transactions for us Customer account information, marketing and add campaign data and history, customer service records, visitor logs To fulfill our business relationship with you, design and improve our services, market research, send marketing and promotional communications, for internal business purposes, risk management, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Inferred and Derived Information We may create inferred and derived data elements by analyzing our relationship and transactional information Propensities, attributes and/or scores generated by internal analytics and used for marketing and advertising Marketing and research, internal business, our every day business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, our lawyers, auditors and consultants, other third parties required by law
Online Technical Information You and from you computer or devices when you interact with our platforms, websites and applications; automatically via such technologies such as cookies, web beacons, when you visit our website or other website; third parties including computer security services and third party advertising network companies and social medial; we may also associate information with you using unique identifiers collected from your devices IPAddress, MAC address, SSIFs or other device identifiers, password, device characteristics, web server logs, application logs, browsing dat, viewing data, first party cookies, third party cookies, preference management including opt-in and opt-out management For system administration, information security, recordkeeping, market research, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, our lawyers, auditors and consultants, other third parties required by law
Financial Information You, payment processors and other financial institutions; consumer reporting agencies; third parties that provide security and fraud prevention services; we may infer financial information Bank account number, payment card information, credit reports, credit scores To fulfill our business relationship with you, recordkeeping, risk management, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Geolocation data We may collect this type of information automatically from your mobile device Precise location Provide information or services requested, information security, our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Children’s data We do not collect personal information directly from children under 16. N/A N/A Other third parties as required by law
Compliance Data You, third parties that help us conduct internal investigations; third parties such as consumer reporting agencies and data aggregators who conduct background screening for is Customer screening records, records relating to complaints and internal investigations, including compliance hotline reports, legal requests, records of privacy and security incidents Comply with applicable law, internal business purposes, and for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Everyday Business Purposes encompasses the Business Purposes (as defined in the CCPA) and the following related purposes for which personal information may be used:
  • To provide the information, product or service requested by the individual or as reasonably expected given the context in which with the personal information was collected (such customer credentialing, providing customer service, personalization and preference management, providing product updates, bug fixes or recalls, and dispute resolution)
  • For identity and credential management, including identity verification and authentication, system and technology administration
  • To protect the security and integrity of systems, networks, applications and data, including detecting, analyzing and resolving security threats, and collaborating with cybersecurity centers, consortia and law enforcement about imminent threats
  • For fraud detection and prevention
  • For legal and regulatory compliance, including all uses and disclosures of personal information that are required by law or for reasonably needed for compliance with company policies and procedures, such as anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines, as well as for compliance with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
  • To exercise or defend the legal rights of GRAB MARKETING, LLC and its employees, affiliates, customers, contractors, and agents.
  • To comply with applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws.
  • For corporate audit, analysis and reporting,
  • To enforce our contracts and to protect against injury, theft, legal liability, fraud or abuse, to protect people or property, including physical security programs
  • To de-identify the data or create aggregated datasets, such as for consolidating reporting, research or analytics,
  • To make back-up copies for business continuity and disaster recovery purposes, and
  • For corporate governance, including mergers, acquisitions and divestitures.

Targeted Advertising Disclosure – When You Consent to the Cookie Consent

We use third party advertising companies to place our ads on other websites. One way we do so is by allowing network advertising companies and social media (“Network Advertisers”) with whom we work to place their own cookies on the browser of an individual who visits one or more of our sites and who clicks “accept” on the cookie consent banner on the site. This enables these Network Advertisers to place a cookie on your computer and to receive information (including for example your IP Address, internet tracking data, and advertising IDs) from that cookie that may include information about your visits to this and other websites. This data received by Network Advertisers allows them to measure advertising effectiveness and to provide advertisements on other websites about our goods and services that are tailored to you and that may be of interest to you on these other websites. These Network Advertisers may in turn disclose your cookie data to other network advertisers to allow these advertisers to display ads to you as well. Under CCPA these additional disclosures may be considered a sale of personal information To revoke your consent or opt-out after you have consented to the cookie consent banner, or to manage your cookie preferences, you can delete the cookies on your browser or use the cookie settings on your browser. All browsers are different, so visit the “Help” section of your browser to learn how to delete the cookies we set in your browser, including the cookie consent, and about cookie preferences and other privacy settings that may be available.

Does GRAB MARKETING, LLC “Sell” Your Personal Information?

GRAB MARKETING, LLC does not sell Personal Information of California Consumers and will not sell this information unless we modify this Privacy Notice and take the additional steps required under the CCPA.

What are your rights?

If you are a California Consumer you have certain rights with respect to GRAB MARKETING, LLCs use and disclosure of your Personal Information:
  • Right of Access | Right to Notice. You have the right to request from us:
    • the categories of Personal Information we have collected about you, the categories of sources from which the Personal Information is collected, the business purpose or commercial purpose for collecting the Personal Information, the categories of third parties with whom we share Personal Information, the categories of Personal Information we have shared and the reasons we shared it.
    • a copy of the specific pieces of Personal Information we have collected about you in the preceding 12 months.
  • Right to Deletion You have the right to request that GRAB MARKETING, LLC delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the Personal Information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right Not to Be Subject to Discrimination
Should you exercise any of your privacy rights as a California Consumer, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, for example where you have requested or consented to our services that use your Personal Information to provide the service, we may not be able to provide a service if you choose to delete your Personal Information. To exercise any of these rights, or to designate an agent or authorized representative to act on your behalf, you can contact us through our designated CCPA processes by email us at or by going to our CCPA Data Subject Rights Management System to submit an electronic form. When you submit a Data Subject Rights request through one of these designated methods, we will use the information you submit and the information we have in our systems (or through the systems of our Service Provider if we use a Service Provider) to try to verify your identity and to match the personal information we have collected about you, if any, to your identity. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we cannot validate your identity, we will attempt to contact you to inform you of this issue.

How do you contact us if you have any questions or concerns?

If you have any questions regarding this Notice, you can contact GRAB MARKETING, LLCs US Privacy Office at Please submit all data subject rights requests through our designated methods either by going to our CCPA Data Subject Rights Management System or by emailing us at This Privacy Notice was last updated March 1, 2021.
In our ongoing effort to provide reliable and transparent services to all users of our Site, grab markets strives to abide by the Online Lenders Alliance’s (“OLA”) Best Practices, the industry’s leading guidelines for online lending and marketing. As an active OLA member, we work hard to ensure that all third party affiliates we associate with comply with these Best Practices, as it is our responsibility to police our affiliates for their compliance.

Below is an overview of OLA Best Practices that we require our affiliates to follow in their business activities and marketing practices. Please contact your Account Manager or grab markets Compliance Department if you have any questions.

Advertising and Marketing Best Practices Guidelines:

  • Never engage in activities that are unfair, abusive, or deceptive.
  • All advertisements and representations should be truthful, accurate, and reflective of the products and/or services actually provided.
  • Clearly and conspicuously disclose to your site users that the owner of the Site (i.e. you) is not a lender and does not make lending decisions. Inform consumers that the owner of the Site is a loan-matching service or referral service that may match the consumer with a participating lender.
  • Clearly and conspicuously disclose that you cannot guarantee a loan or loan amount, or that the consumer will be matched with a lender.
  • Do not advertise that a loan can be approved despite bad credit/no credit or that no credit check will be run. Inform users that that some lenders may conduct credit checks through credit bureaus or other providers of credit information.
  • Do not advertise that faxing is not required. Inform your site users that some lenders require faxing.
  • Only advertise for credit terms that are actually available. Do not advertise that loans can be taken out for more than $1,000.
  • Do not make inaccurate or misleading representations concerning how long it will take before cash is available to the consumer. Inform consumers that their funds may be available as soon as the next business day. Do not say cash will be available within “one hour” or “same day.”
  • If you include testimonials on your site, make certain those testimonials are actual statements by real consumers and users of your site. This must be verifiable.

Terms to Avoid:

  • Bad Credit ok
  • 100% Approval
  • 100% Secure
  • Guaranteed
  • Pre-Qualified/Pre-Screened/Pre-Approved
  • X% interest
  • X Number of Payments
  • X Payment Period
  • Down Payment
  • Instant/Instantly
  • Immediate/Immediately
  • Automatically
  • Apply/Application
  • Within Minutes
  • Within Hours
  • Within One Hour
  • Matched/Match You
  • Same Day
  • $1000 or more
  • Our Loans/Our Payday Loans
  • No Faxing
  • No Credit Check
  • Most Favorable
  • Lowest Rate/Lowest Fee
  • Best Rate/Best Lender/Best Loan/Best Possible
  • Get Matched to the Best Lenders with Great Rates
  • We Find You the Best Lender

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