Privacy Policy

1. Data Controller

FullRTR (“we,” “us,” or “our”) is the data controller responsible for the processing of personal information described in this policy.

2. Information We Collect

We may collect the following categories of information:

• Business contact information (names, email addresses, phone numbers)
• Account and financial data related to MCA agreements
• Merchant business information (business name, EIN, revenue data)
• Communication records related to account resolution
• Website usage data (pages visited, time on site, browser type)
• Cookie consent preferences

3. Purpose of Data Processing

We process personal information for the following purposes:

• Providing pre-collections and account resolution services
• Conducting outreach to merchants on behalf of funders
• Negotiating and structuring settlement agreements
• Providing real-time reporting and data room access to authorized funders
• Maintaining records of resolution activities for compliance purposes
• Improving our website and user experience
• Responding to inquiries and communication requests

4. Legal Basis for Processing

We process personal information based on one or more of the following:

• Contractual necessity: Processing required to fulfill our service agreements with funders and merchants.
• Legitimate interest: Processing necessary for our business operations, including account management and reporting.
• Consent: Where you have given explicit consent, such as cookie preferences or contact form submissions.
• Legal obligation: Processing required to comply with applicable laws and regulations.

5. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected:

• Active account data: Retained for the duration of the resolution process and any active settlement monitoring.
• Completed resolution records: Retained for up to 7 years after completion to comply with financial record-keeping requirements.
• Website analytics data: Retained for up to 26 months.
• Contact inquiries: Retained for up to 2 years after last communication.

6. Data Sharing and Third Parties

We do not sell, rent, or trade personal information. Information may be shared in the following limited circumstances:

• Between resolution parties: Account information is shared between the directly involved funder and merchant only to the extent necessary for resolution.
• Service providers: We may use third-party tools for website hosting, analytics, and communication. These providers process data on our behalf under contractual obligations.
• Legal requirements: We may disclose information when required by law, subpoena, or legal process.

7. Data Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. Access to account data, data rooms, and reporting tools is restricted to authorized representatives only.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate personal data.
• Right to erasure: Request deletion of your personal data, subject to legal retention requirements.
• Right to restrict processing: Request limitation of how we process your data.
• Right to data portability: Request your data in a structured, commonly used format.
• Right to object: Object to processing based on legitimate interests.

9. How to Exercise Your Rights

To exercise any of the above rights, please submit a written request to ben@fullrtr.com. Include your full name and sufficient detail for us to identify the data in question. We will respond within 30 days of receiving your request. We may request additional verification to confirm your identity before processing.

10. Cookies

For detailed information about the cookies we use, please refer to our Cookie Policy.

11. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated to active partners. The date at the top of this page indicates when this policy was last revised.

12. Contact

For questions or concerns about this Privacy Policy or your personal data, contact us at ben@fullrtr.com.