Privacy Policy

Sphinx Consultants LLC (“Sphinx,” “we,” “us,” or “our”) respects your privacy and is committedto protecting your personal information. This Privacy Policy explains how we collect, use,disclose, and safeguard your information when you visit our website, access our consumerportal, or otherwise interact with us (collectively, the “Service”). By using the Service, youconsent to the practices described in this Privacy Policy. If you do not agree with our practices,please do not use the Service.

1. Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked withyou (“Personal Information”). The categories we collect include:

• Identifiers: Name, postal address, email address, telephone number, online identifiers, IPaddress, and account credentials.
• Financial and Debt-Related Information: Debt account details, balance information,payment history, bank account or payment card data, and credit-related data.
• Internet or Electronic Activity: Browsing history, interaction data, and information collected automatically through cookies, pixels, server logs, and similar technologies.

We collect this information directly from you, from the Debt Accounts we service, fromthird-party sources such as credit bureaus, prior creditors, service providers, and automaticallythrough your use of the Service.

2. How We Use Your Information

We use the collected Personal Information for the following business and commercial purposes:

• To provide, maintain, and improve the Service, including allowing you to view andmanage Debt Accounts and make payments;
• To process payments and communicate with you regarding your accounts;
• To respond to your requests, disputes, or validation inquiries as required by applicablelaw (including the FDCPA);
• To send you important notices, administrative messages, and, where permitted,marketing communications;
• To detect, prevent, and address fraud, security issues, and illegal activity;
• To comply with legal obligations, respond to subpoenas, court orders, or regulatoryrequests;
• To conduct analytics, research, and internal reporting; and
• For any other purpose with your consent or as otherwise permitted by law

3. How We Share or Disclose Your Information

We do not sell your Personal Information in the traditional sense. We may disclose yourPersonal Information to third parties that perform services on our behalf, affiliates and businesspartners within our corporate group or in connection with a corporate transaction, legal andregulatory authorities when required by law, and credit reporting agencies as permitted or required in connection with Debt Account servicing.

4. Cookies, Tracking Technologies and Opt-Out Rights

We use cookies, web beacons, pixels, server logs, and similar technologies to collect informationabout your browsing activities, preferences, and interactions with the Service. Thesetechnologies help us recognize your browser and remember your preferences, analyze trendsand usage statistics, personalize your experience, and improve the security and functionality ofthe Service. You may disable certain cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of the Service.

5. State Rights

Some states, including California, Colorado, Connecticut, Montana, Oregon, Texas, Utah andVirginia, provide additional privacy protections for its residents. If you are a resident of one of these states, you have the right to:

• Know what Personal Information we have collected about you and how it is used andshared;
• Request deletion of your Personal Information;
• Correct inaccurate Personal Information;
• Opt out of the “sale” or “sharing” of your Personal Information;
• Limit the use and disclosure of your Sensitive Personal Information; and
• Receive equal service and pricing without discrimination for exercising your rights.

To submit a verifiable request, contact us using the information in Section 10. We will verifyyour identity before fulfilling most requests. You may use an authorized agent to submit arequest on your behalf, subject to our verification procedures. We respond to verified requests within the time required by law. You may appeal any denial of your request as provided in ourresponse.

6. Security of Your Information

We implement reasonable administrative, technical, and physical safeguards designed toprotect your Personal Information from loss, misuse, and unauthorized access, disclosure,alteration, and destruction. These measures include encryption for sensitive transmissions andaccess controls. However, no method of transmission over the internet or electronic storage is100% secure. Therefore, while we strive to protect your information, we cannot guarantee itsabsolute security

7. Children's Privacy

The Service is not directed to people under the age of 18. We do not knowingly collect PersonalInformation from people under 18. If we learn that we have collected Personal Informationfrom someone under 18 without verifiable parental consent, we will take steps to delete thatinformation as soon as possible. If you are a parent or guardian and believe we may havecollected information about your child, please contact us using the information in Section 10.The Service is not designed for or targeted at individuals under 18. We do not knowingly solicitor collect Personal Information from children under 18. If we become aware that we havecollected such information, we will delete it promptly

8. International Users and Data Transfers

Our Service is hosted in and operated from the United States. If you access the Service fromoutside the United States, your information may be transferred to, stored, and processed in theUnited States or other countries where our service providers operate. These countries may havedata protection laws that differ from those in your jurisdiction. By using the Service, youconsent to the transfer of your information to the United States. We take appropriate safeguards to protect your information during such transfers where required by law.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices,technology, or legal requirements. When we make material changes, we will notify you byposting the revised policy with a new “Effective Date,” sending an email to the addressassociated with your Account, or through other reasonable means. Your continued use of theService after the effective date of any revised Privacy Policy constitutes your acceptance of thechanges.

10. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Mail: Sphinx Consultants LLC, 16192 Coastal Highway, Lewes, DE 19958.
Email: info@sphinx.com
Phone: (405) 206-7067