The Personal Information We Collect

We collect Personal Information about you directly from you and from third parties, and automatically through your use of our Sites or Services.

The Personal Information we collect does not include:

• Personal Information we reasonably believe you or a third party have made publicly available;
• deidentified or pseudonymous data that cannot be attributed to you and is stored separately from other data that could be used to identify you;
• Personal Information covered under other laws such as financial information protected by state and federal laws; and
• Personal Information collected in an employment or commercial context.

1. Personal Information We Collect Directly from You

   The Personal Information we collect from you depends on how you use our Sites and Services, but generally includes the following categories:

   • Contact information such as name, address, email, and phone number.
   • Employment and professional-related information such as company name, organization type, company address, and job title.
   • Electronic signatures such as the name of an individual signing documents.
   • Payment or financial information such as credit or payment card information.
   • General location information that can be determined from IP addresses.
   • Demographic information such as sex, gender, race, ethnicity, and age.
   • Information you provide via our chat features including transcripts of conversations with our customer service representatives.

2. Personal Information We Collect from Third Parties

   We collect the Personal Information listed below in our capacity as a service provider to our customers. Our customers are primarily financial organizations and we do not sell nor market services to individual consumers. In the course of delivering our Services, our systems receive Personal Information from our customers about our customers’ customers (e.g., borrowers, consumers). We process this information on behalf of our customers in order to provide them with our Services. Personal Information that our customers provide to us, and Personal Information our systems receive on their behalf, remains the data of those customers. We do not sell it, we do not use it for our own marketing, and we do not disclose it except as described in this Policy or as our customers direct. Our customers are responsible for providing notice and obtaining appropriate consents to collect Personal Information from their borrowers and to provide it to us as their service provider. If you are a borrower, you should refer to our customers’ privacy notices and/or contact them directly to understand how your Personal Information will be collected, used, and shared.

   • Contact information: in some instances, lenders and other business customers may allow you to access our Sites and Services through Single-Sign-On. In these cases, we collect your contact information and login credentials from the business with which you have an account.
   • Transactional information: if your lender uses our Services in connection with ICE Mortgage Technology’s Encompass, we may process information about the relevant loan, property, or borrower.

   We store the Personal Information that we receive from third parties with other Personal Information that we collect from you. For information about how third parties may use and disclose your Personal Information, including any information you make public, please consult their respective privacy policies. We have no control over how any third party uses or discloses the Personal Information they collect about you.

3. Personal Information We Collect Automatically

   We automatically collect Personal Information about visitor use of our Sites through cookies and other technologies, including: domain name, language information, country or region information, general location information, browser type, operating system, name and version, pages viewed and activities conducted, links clicked, IP address, length of session, the referring URL for the Sites, device name and model.

   To the extent permitted by applicable law, we combine this information with other information we collect about you, including your Personal Information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Our Purposes for Processing Personal Information

We process your Personal Information for the following purposes:

• Operating Services and Sites and Providing Related Support. To provide and operate our Sites and Services, communicate with you about your use of the Sites and Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, and for similar service and support purposes.
• Responding to Requests. To respond to your inquiries, fulfill your orders and requests, and consider your request or application (e.g., if you have submitted a resume or other application information online or by email, we will use it as part of the application review process).
• Analyzing and Improving Services, Sites, and our Business. To better understand how users access and use the Sites, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, and to develop services and features.
• Personalizing Experiences. To tailor content we may send or display on the Sites, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
• Aggregate and De-Identified Insights. We may use de-identified and aggregated data, and publicly available data, for analytics, product development, and to understand how our Services perform. We do not disclose Personal Information to affiliates, partners, or other third parties for these purposes. Where we process or disclose de-identified data, we include contractual terms to prevent re-identification of data and we commit not to attempt to re-identify it.
• Protecting Our Legal Rights and Preventing Misuse. To protect the Sites and our business operations; to prevent, and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Privacy Policy.
• Complying with Legal Obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Business Transfers. To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping, and legal functions.
• Training our Customer Service Representatives and Auditing our Customer Service Practices. We retain our chat sessions for history, training, and audit purposes.
• Customer Satisfaction and Marketing Surveys. With your permission, we may request information from you to assist us with improving our services and content that we provide through our Sites and Services.

The Parties with Whom We Share Personal Information

We may disclose the categories of Personal Information with the following parties:

• Service Providers. We may disclose Personal Information we collect with our service providers or agents who perform functions on our behalf. These service providers may include IT service providers, help desk providers and payment processors.

• Business Customers. Limited transactional information collected by our customers through the Company’s Services may be available to their customer account administrators or other customer account managers, and may, at the direction of our customers, be shared with third parties as necessary for our customers’ loan origination and management purposes. The Company’s customers may use certain information they collect through our Services for marketing or promotional communications, subject to any appropriate or necessary consents and their own privacy policies.
• Public Authority/Agency. We may disclose your Personal Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, and terms of service, (c) to protect the security or integrity of our Websites or Services, (d) to protect the property, rights, and safety of the Company, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.

Our Purposes for Sharing Personal Information

We may disclose information to the parties listed in Part III above for the following purposes:

• Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We may disclose your Personal Information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect You, Us, and Others. We disclose your Personal Information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Sites or Services. We may combine this information with other Personal Information we collect from you (and our third-party service providers may do so on our behalf). For more information on the types of Personal Information we collect through these technologies, please see the section above titled “Personal Information We Collect.” For resources and instructions on how to disable tracking technologies, see the section below titled “Tracking Choices.”

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites and Service. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Sites and Services. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Sites and Services.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you may be able to change your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, Pixel Tags, and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (e.g., web beacons or pixel tags), in connection with our Sites and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics. We use automated devices and applications, such as Google Analytics and Microsoft Bing, to evaluate usage of our Sites. We also may use other analytic means to evaluate our Sites. We use these tools to help us improve our Sites’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons, to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-Out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Third-Party Links. Our Sites and Services may contain links to third-party Sites. Any access to and use of such linked Sites is not governed by this Policy, but instead is governed by the privacy policies of those third-party Sites. We are not responsible for the information practices of such third-party Sites.

Tracking Choices

We do not serve advertising on our Sites, we do not participate in third-party ad networks, and we do not use Personal Information for interest-based or cross-context behavioral advertising. The tracking technologies described above are used only to operate our Sites and Services and to understand how our Sites are used.

If you wish to prevent cookies from tracking your activity on our website, you can set your browser to block certain cookies or to notify you when a cookie is set. If you block cookies, certain features on our website may not work. To prevent your Site usage data from being used by Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on at https://tools.google.com/dlpage/gaoptout.

Additional Privacy Information for Certain Jurisdictions

Note that these rights only apply to Personal Information that we collect and process under the terms of this policy. In our capacity as a service provider to other businesses, we may collect or process other Personal Information as reasonably necessary to provide our services. This Personal Information is not subject to the rights outlined below.

1. Rights of Nevada Consumers

   Nevada residents have the right to opt-out of the sale of “Personally Identifiable Information,” which is defined as a natural person’s first name or first initial and last name in combination with their Social Security Number, driver’s license number, identification card number, account number, credit card number, debit card number, in combination with any required security code, access code, or password that would permit access to that person’s financial account. However, we do not sell Personally Identifiable Information, so an opt-out mechanism is not required.

2. Rights of California Consumers

   Under the California Consumer Privacy Act (“CCPA”), California residents have the right to receive certain disclosures regarding our processing and sharing of “Personal Information,” as defined under the CCPA.

   Right to Access: With respect to the Personal Information we have collected about you in the prior 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions):

   • Categories of Personal Information about you we have collected;
   • The sources from which we have collected that Personal Information;
   • Our business or commercial purposes for collecting, selling, or sharing that Personal Information;
   • The categories of third parties to whom we have disclosed that Personal Information; and
   • A copy of the specific pieces of your Personal Information we have collected.

   Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information.

   Right to Delete: Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you. California consumers who are registered users of the Sites and under 18 years of age may request the removal of content or information they posted on the site. We will remove such content or information when we are required to do so by law. To request the removal of content or information you posted on the Sites, you may contact us as described below. Please note that even if we remove the content or information that you posted, we cannot prevent further use or disclosure of that content or information by others once you have shared it publicly.

   Right to Opt-Out of Sale: Under the CCPA, a “sale” includes disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration. We do not sell Personal Information, and we do not share Personal Information for cross-context behavioral advertising. Personal Information that we process in the course of providing our Services belongs to our business customers; we use it only to provide the Services to them and only as they direct.

   Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section.

   Authorized Agent: You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf.

   Right to Know: The chart below describes the categories of Personal Information we collect, the categories of sources from which the Personal Information is collected, our purposes for processing each category, whether we sell or share Personal Information, whether we have disclosed Personal Information for a business purpose in the last 12 months, the categories of recipients.

   Identifiers: Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and/or email address.

   Commercial information: Including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

   Categories Collected in the Last 12 Months	Categories of Sources	Purposes for Processing	"Sold"	Disclosed for a Business Purpose	Categories of Recipients
   Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and/or email address.	From you; from third parties; automatically	Providing our Services Improving our Services In support of our general business operations Responding to inquiries Protecting our rights and responding to legal requests/obligations	No	Yes	Our business customers, and service providers acting on our behalf. We may collect account name, Social Security Number, driver’s license number, passport number, or other similar identifiers on behalf of our business customers.
   Commercial information: Including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	From you		No	No
   Geolocation data: Precise location information about a particular individual or device.	Automatic collection through our Sites	Providing our Services Improving our Services In support of our general business operations	No	No
   Internet or other electronic network activity information: Including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.	Automatic collection through our Sites	Providing our Services Marketing Improving our Services	No	No
   Professional or employment-related information: Such as your job title and the name of your employer.	From you; from third parties.	Providing our Services.	No	No
   Protected classifications: We collect some information that is considered a protected classification under California/federal law (e.g., your gender, date of birth, citizenship, marital status, and disability status).	From you	Providing our Services Responding to inquiries In support of our general business operations Protecting our rights and responding to legal requests/obligations	No	No
   Sensitive Personal Information: In limited circumstances, we collect Social Security Numbers.		Providing our Services Responding to inquiries In support of our general business operations Protecting our rights and responding to legal requests/obligations	No	No

3. Rights of Virginia Consumers

   Under the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the VCDPA, as well as certain rights with respect to our processing of such Personal Data.

   We may share de-identified information about individuals with third parties for any reason. We commit to maintaining and using de-identified data without attempting to re-identify a Virginia consumer except as permitted by law.

   Right to Correction: To correct inaccuracies in your Personal Data, considering the nature of the Personal Data and the purposes of the processing of your Personal Data.

   Right to Deletion: To delete Personal Data provided by or obtained about you.

   Right of Portability: To obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller or business where the processing is carried out by automated means.

   Right to Opt-Out of Sale: Under the VCDPA, a “sale” includes disclosing or making available Personal Information to a third party in exchange for money. We do not “sell” Personal Information under this definition, so an opt-out mechanism is not required.

   Right to Opt-Out of Significant Profiling: To opt-out of the processing of your Personal Data for decisions that produce legal or similarly significant effects. We currently do not process Personal Data to make decisions with significant effects on consumers.

   Our Right to Refuse Your Request: We may deny your request if (1) we are not reasonably capable of associating your request with the Personal Data or it would be unreasonably burdensome for us to associate your request with the Personal Data; (2) we do not use the Personal Data to recognize or respond to you specifically or associate the Personal Data with other Personal Data about you; and (3) we do not sell the Personal Data to any third party or otherwise voluntarily disclose the Personal Data to any third party other than a processor, except as otherwise permitted under Virginia law.

   Right to Appeal: If we decline to take action regarding your request, we will notify you and provide our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.

Children

Our Services are not designed for children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information from our systems. We do not knowingly collect or sell Personal Information of consumers under 16 years of age as of the date of this Privacy Policy.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites and/or Application.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at: