Privacy Policy

Privacy Statement
Effective as of March 30, 2012 

Clayton Holdings LLC ("Clayton") understands that you care how information about you is used and shared, and we appreciate your trust that when you visit our website at (the “Website”). We will handle any information you provide in compliance with our Privacy Statement as set forth below. This Privacy Statement is part of the Terms and Conditions for using the Website. By visiting the Website you are accepting the practices described in the Privacy Statement. This Privacy Statement applies only to information that you provide to Clayton through this Website.

Through the Website, Clayton only collects the personal information that you voluntarily provide. You may browse the Website without having to reveal any personal information (though some sections, primarily those restricted to clients (“Clients”) and authorized users (“Users”), may require submission of personal information).

Clayton does not collect personally identifying information about you except when you specifically and knowingly provide it. As with many advanced Internet sites, the Website uses “cookies” to enhance the functionality of the Website and to make transactions and other activities more convenient and efficient for Clients and Users. A “cookie” is a small text file stored locally on the computer used to access the Client account, and contains information relating to a Client’s past use of the Website.

Information We Collect by Automated Means

When you visit, we collect certain information by automated means, using technologies such as cookies, web server logs and web beacons.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or device or to store information or settings in your device. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website. In conjunction with information gathered through cookies, our web servers may receive and store certain types of information whenever you access our site, such as the date and time of connection, Internet Protocol (IP) addresses (the location of your computer or network on the Internet), browser type, Internet service provider, the web page from which you came to the site, the exit web page, the software used to access the web server, and number of clicks you made on the site. 

Clayton  may use information collected through automated means for market research, data analytics, and system administration purposes, such as to determine whether you have visited us before or are new to the site. We also may use this information to target custom content and ads to you on this and other websites, including as described in the Interest-Based Advertising section below.

Interest-Based Advertising

Certain information about your activities online is being collected on our site for use in providing advertising tailored to your individual interests. You may choose whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.

You may see certain ads on other websites because we participate in advertising networks administered by third parties. These networks track your online activities over time by collecting information through automated means, including through the use of the technologies described in the "Information We Collect By Automated Means" section above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our website, such as the pages you have viewed. This collection and ad targeting takes place both on our website and on third-party websites that participate in the ad network, such as sites that feature advertisements delivered by the ad network. This process also helps us track the effectiveness of our marketing efforts.

To learn more about ad networks, including how to opt out, click here.

In the following instances, Clayton may ask you to provide certain personal information in order to access certain areas of the Website: 

(i) Registration Information: Clayton may require Clients and Users of the Website to provide certain information, including name, company, title, email address, phone number, and mailing address, which Clayton will use to verify that Client or User meets the minimum criteria for accessing Services through the Website. There is no Website directory; contact information and other Client-specific information is used only internally by Clayton to operate the Website and to communicate with Clients. Client-specific information is available to other Clients only to the extent expressly authorized by a Client in the context of a particular transaction.

(ii) Transactional Information: Information relating to Client transactions, such as contact information, loan pool value, transaction type, and transaction amount, will remain confidential, and will be used by Clayton for the purpose of monitoring transaction activity, or to maintain, upgrade, and repair the Website. Transaction information will only be disclosed to other Clients who are a party to a particular transaction, or as otherwise required by contract, law, or regulation.

(iii) Technical and Usage Information: To operate the Website, enhance its functionality, and ensure that Client transactions and communications are convenient, dependable and secure, Clayton may collect, store and use technical and Website usage information relating to a Client’s or User’s activities on the Website. Such information includes the Internet Protocol (“IP”) address from which a Client or User accesses the Website, which is used only internally by Clayton as required for server operation and other technical uses, and is not disclosed to Clients or third parties.

(iv) Client Communications: Clayton may use Client contact information, such as e-mail addresses, to communicate with Clients regarding available transactions, to notify Clients of changes in Website functionality and features, product and service updates, patches, policy changes, billing and other activities relating to a Client’s use of the Website.

At certain points on the Website you may have the opportunity to contact us and request information from us. In that process we may ask that you provide certain personal information, such as your e-mail address, your name, your organization, your postal address and your telephone and fax numbers. The information that you provide is used to forward requested documentation or to contact you with information about the services in which you have expressed an interest. Once you have voluntarily chosen to provide your personal information to Clayton through this Website, the information is stored by Clayton, and we may furnish this information to third-party service providers for the purpose of sending you the documentation that you request. We do not authorize these service providers to use this information for any other purpose. You can always choose not to provide personal information through the Website. A decision not to provide such information may preclude you from using certain services offered on the Website.

Clayton may use internally the information you furnish to us to better serve you. Clayton may also use such information to analyze trends, administer the Website, track Users' movement, and gather demographic information. Clayton reserves the right to use non-personal aggregated information for other business purposes.

Clayton, through the Website, may provide links to sites maintained by third parties ("Third Party Sites"). We may partner with some of those Third Party Sites to provide specific services. When a User signs up for these services, we may share names, and other contact information that is necessary for the Third Party Site to provide those services. Clayton does not operate or control any of the Third Party Sites, and is not responsible for the content, functionality, accessibility, privacy policies or other practices of such Third Party Sites.

Affiliates of Clayton may have access to information provided by you through the Website. When they do, they are required to protect this information in a manner that is consistent with this Privacy Statement. Clayton does not knowingly market to children. We recognize the importance of protecting children's identities and privacy.

Clayton takes precautions to protect the information of visitors to the Website. It takes technical, administrative, and physical steps to protect against unauthorized access to information collected through the Website. All such information is handled within Clayton and is not disclosed to third parties except as indicated in this Privacy Statement. As communication technology evolves, Clayton may from time to time, review and revise its data protection practices.

If Clayton is sold or disposed of, whether by merger, sale of assets, or otherwise, any data collected by Clayton through the Website or personal information that you have voluntarily provided to Clayton through the Website may be furnished to the purchaser or successor in interest.

Clayton reserves the right to disclose any information if such action is necessary (a) to conform to the requirements of law or to comply with legal process or subpoena served on Clayton, (b) to protect and defend the legal rights or property of Clayton, the Web Site or its Clients, or (c) in an emergency, to protect the health and safety of its Clients or the general public. Clayton further reserves the right to release any information concerning any Client if that Client participates (or is reasonably suspected of participating) in any illegal activity, even without a subpoena, warrant, or other court order. Finally, Clayton reserves the right to cooperate with law enforcement agencies in identifying those who may be using our servers or services for illegal activities, and to report any suspected illegal activity to law enforcement agencies for investigation or prosecution.

Clayton reserves the right to change this Privacy Statement. If Clayton decides to change its Privacy Statement, it will post the revised Privacy Statement here. Such revised Privacy Statement will become effective upon posting. Your access and use of the Website after such posting shall be deemed acceptance of such revised Privacy Statement.

If you have questions or concerns about Clayton's application of this Privacy Statement or if you would like to inform Clayton about changes in your personal information (such as your address) you may e-mail us.