TurboDSCR, ("TurboDSCR," "we," "us," or "our") generates, markets, and
distributes consumer and business financing inquiries ("leads") by collecting Personal
Information from individuals seeking financing and sharing or selling that Personal Information
with participating lenders, brokers, financing providers, and other partners. This Privacy
Policy ("Policy") describes how we collect, use, disclose, sell, share, and protect Personal
Information obtained from users ("you") through the website at NationCapital.com and any related
or linked to landing pages or inquiry/request forms (collectively, the “Site”), and any
services, transactions, or other interactions you may have with us (collectively, the
“Services”). It applies to Personal Information we collect through your use of the Site or
Services.
This Policy forms part of the Terms of Use that govern your use of and access to the Site and
Services. Please read both this Policy and the Terms carefully. By accessing or using our Site
or Services, you agree to our use of your Personal Information consistent with our Terms of Use
and this Privacy Policy. If you do not agree with our Terms of Use or this Privacy Policy, you
must refrain from using our Site or Services.
We may update this Policy periodically. The “Last Updated” date at the top of this Policy
reflects the date of any updates. Continued use after changes constitutes acceptance of the
revised Policy.
1. What Information is Subject to this Policy?
A. Personal Information
“Personal Information” refers to any information, in any form, about an
identified or identifiable individual or household, including an individual or
household whose identity may be inferred or determined from such information.
We may collect the following categories of Personal Information: full name; email
address; mobile and/or landline telephone number; current mailing or residential
address; subject property address; property type; estimated AS-IS property
value; purchase price (where applicable); requested loan amount; loan purpose;
estimated monthly rental income; estimated annual property taxes; estimated
annual insurance; estimated HOA dues; estimated debt-service-coverage ratio
(DSCR); estimated loan-to-value (LTV); occupancy designation; entity vs.
individual borrower status; entity name; citizenship/residency status (where
requested); a credit-score band verified through a soft credit pull at intake;
preferred timeline to close; consent acknowledgments and TCPA disclosure
responses; IP address; submission timestamp; provenance metadata (including
TrustedForm, Jornaya, or equivalent consent certificate where available);
traffic-source/campaign parameters (UTM data); browser type; operating system;
device identifiers; access times; referring URLs, and Site-interaction data
collected automatically through cookies and similar technologies.
B. Sensitive Personal Information
“Sensitive Personal Information” is a more sensitive subset of Personal
Information (e.g. social security numbers, financial account credentials,
precise geolocation, etc.). We do not knowingly collect, process, use, or share
any Sensitive Personal Information.
C. What is Non-Public Personal Information (“NPI”)?
NPI is non-public information collected by financial institutions under the
Gramm-Leach-Bliley Act (“GLBA”) and certain state laws, including information
consumers provide to obtain financial products/services, transaction results, or
information obtained in connection with providing financial products/services.
D. What is not Personal Information?
Personal Information does not include publicly available information;
de-identified or aggregated consumer information; or information exempted from
applicable state privacy laws, including information collected or processed
solely to comply with legal or regulatory obligations.
2. Do we collect NPI?
TurboDSCR may be considered a financial institution, finder, service provider, or
other GLBA-regulated entity with respect to certain products, services, activities, or
information and certain of the information we collect may, in turn, constitute NPI
subject to the GLBA.
As a result, some or all of our collection, use, disclosure, and processing of
information may be subject to the GLBA and other applicable financial privacy laws. In
certain jurisdictions, TurboDSCR itself may be wholly or partially exempt from
otherwise applicable state privacy laws because of its status as a GLBA-regulated
entity. In other jurisdictions, only certain categories of information—such as nonpublic
personal information ("NPI") subject to GLBA—may be exempt from applicable state privacy
laws, while other information remains subject to those laws.
To the extent information is subject to GLBA or otherwise exempt from applicable state
privacy laws, such information will be governed by our GLBA
Privacy Notice and applicable financial
privacy laws. Information that is not subject to GLBA, including certain website usage
information, cookie data, analytics data, advertising-related information, and
information relating to commercial or business-purpose financing activities, may remain
subject to this Privacy Policy and applicable state privacy laws.
3. Sources of Personal Information
We obtain Personal Information from three principal sources: (a) Personal Information you
submit voluntarily, for example through any forms on the Site or by telephone or email;
(b) Personal Information generated automatically when you interact with the Site; and
(c) Personal Information from third parties, including credit-reporting agencies, the
lead-generation sources or partners from whom we may acquire inquiries, advertising
platforms, and our service providers.
4. Purposes for Collecting Your Personal Information
We may collect and use your Personal Information for any of the following purposes:
- Communicate with you, including responding to your inquiries or request for
information;
- Provide the Services, including by pre-qualifying you for certain financial products
and services and identifying and matching you with lenders, finance companies, or
investors;
- Ensure safety, security, fraud prevention
- Personalize your experience
- Conduct marketing and advertising
- Manage and improve the Site or Services
- Meet legal, regulatory, and compliance obligations and enforce our rights
- Conduct analytics, auditing, research, and monitor trends and usage to improve our
offerings
- Evaluate or conduct mergers, acquisitions, restructurings, or other business
transfers
- As otherwise agreed and approved by you.
5. Who do we share your Personal Information With?
This section is important and describes the core part of our business. As a lead
generator, the nature of our business requires that we disclose, sell, and share (as the
terms “sell” and “share” are defined by applicable state privacy laws, including the
California Consumer Privacy Act, as amended) the Personal Information you provide, to
and with third parties in order to provide the Services you requested through the Site
(i.e. to be connected with financial institutions and lenders for a potential loan or
mortgage) and/or for cross-context behavioral advertising.
A. Sharing or Selling with Lead Buyers
When you submit an inquiry through our Site, your information may be disclosed,
sold, licensed, rented, transferred, or otherwise made available to one or more
lenders, brokers, financing providers, investors, lead buyers, and marketing
partners so they may evaluate your inquiry and contact you regarding financing
opportunities in exchange for monetary or other valuable consideration, such as
referral or participation fees. The full list of third parties to whom we may
sell or share your Personal Information is available here. We will not share or
sell your Personal Information with more than four (4) lead buyers.
B. Sharing with Our Affiliates Including LeedWallet
We may share your Personal Information with our affiliated company(ies) under
common ownership and control with TurboDSCR, including but not limited to
LeedWallet. LeedWallet operates a lead distribution and marketing platform that
assists in matching consumer inquiries with interested lenders, brokers,
financing providers, investors, and other lead purchasers and marketing
partners. To provide the Services, LeedWallet may receive, review, market,
distribute, disclose, sell, license, or otherwise make available the Personal
Information you provide through the Site to up to four (4) lead buyers so they
may evaluate your inquiry and contact you regarding potential financing
opportunities.
C. Third Parties Receiving Data
Unless otherwise disclosed at the time of collection, TurboDSCR and its
affiliates, including LeedWallet, will limit distribution of your Personal
Information to no more than four (4) participating lead buyers, cumulatively, in
connection with a single inquiry. Once your Personal Information has been
provided to a lead buyer or other third party, that recipient may use and
process your Personal Information in accordance with its own privacy practices
and applicable law.
D. Categories of Third Parties To Whom We Share/Shall Personal Information.
We may disclose, sell, or share your Personal Information to and with:
- Lead Buyers and Marketing Partners including lenders,
finance
companies, private investors, and other capital providers who may evaluate
your inquiry
and contact you with offers;
- Service Providers and Processors that perform functions on
our behalf,
such as soft
credit pulls, identity verification, hosting, analytics, communications,
consent
documentation (e.g., TrustedForm and Jornaya), payment processors, and other
third party
providers each of whom are contractually limited to using the information
only to
perform those functions;
- Advertising Partners, in connection with the online
advertising
described in our Cookies
Policy;
- Affiliated Companies under common control with us,
including but not limited to LeedWallet;
- Successor Entities in connection with a corporate
transaction; and
- Legal Personnel, including government authorities, our
attorneys, law enforcement, courts, and regulatory bodies when legally
required or to protect rights
6. How do we use and share your Personal Information?
In the past twelve (12) months, we have collected and shared Personal Information for the
following purposes and with the following third parties:
| Category | Source Collected From | Purpose for Collection and Use | Sharing with Third Parties for Business Purpose | Third Parties to Whom Personal Information was Sold/Shared |
|---|
| A. Identifiers. A real name, alias, postal address, unique personal identifier,
online
identifier,
Internet Protocol address, email address, account name, Social
Security
number,
or
other similar identifiers. | - Directly from you
- Automatically from your browser or device
- From third parties
| - Communications
- Provide Services
- Safety and security
- Personalize your experience
- Marketing
- Manage and improve the Site and Services
- Legal or compliance
- Research
- Business transactions
- As agreed by you
| - Lead Buyers and Marketing Partners
- Service Providers and Processors
- Advertising Partners
- Affiliates and Successor Entities
- Legal Personnel
| - Lead Buyers and Marketing Partners
- Advertising Partners
- Affiliates
|
| B. Personal information categories listed in the California
Customer
Records
statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical
characteristics or
description, address, telephone number, employment, bank account
number,
credit
card number, debit card number, or other financial information.
Some personal information included in this category may overlap
with other
categories
| - Directly from you
- Automatically from your browser or device
- From third parties
| - Communications
- Provide Services
- Safety and security
- Personalize your experience
- Marketing
- Manage and improve the Site and Services
- Legal or compliance
- Research
- Business transactions
- As agreed by you
| - Lead Buyers and Marketing Partners
- Service Providers and Processors
- Advertising Partners
- Affiliates and Successor Entities
- Legal Personnel
- Business affiliates and partners
- Legal Personnel
- Ad servers
| - Lead Buyers and Marketing Partners
- Advertising Partners
- Affiliates
|
| C. Protected classification characteristics under California
or federal
law. Age (40 years or older), race, color, national origin,
citizenship, marital
status, physical or mental disability, sex (including gender,
gender
identity,
gender expression, pregnancy or childbirth and related medical
conditions),
sexual orientation, veteran or military status, genetic
information
(including
familial genetic information). | - Directly from you
- Automatically from your browser or device
- From third parties
| - Communications
- Provide Services
- Safety and security
- Personalize your experience
- Marketing
- Manage and improve the Site and Services
- Legal or compliance
- Research
- Business transactions
- As agreed by you
| - Lead Buyers and Marketing Partners
- Service Providers and Processors
- Advertising Partners
- Affiliates and Successor Entities
- Legal Personnel
- Business affiliates and partners
- Legal Personnel
- Ad servers
| - Lead Buyers and Marketing Partners
- Advertising Partners
- Affiliates
|
| D. Commercial information. Records of personal property, products or services purchased,
obtained, or
considered, or other purchasing or consuming histories or
tendencies. | - Directly from you
- From third parties
| - Provide Services
- Safety and security
- Marketing
- Legal or compliance
- Research
- Business transactions
- As agreed by you
| - Lead Buyers and Marketing Partners
- Service Providers and Processors
- Advertising Partners
- Affiliates and Successor Entities
- Legal Personnel
| - Lead Buyers and Marketing Partners
- Advertising Partners
|
| E. Biometric information. Genetic, physiological, behavioral, and biological
characteristics, or
activity
patterns used to extract a template or other identifier or
identifying
information, such as, fingerprints, faceprints, and voiceprints,
iris or
retina
scans, keystroke, gait, or other physical patterns, and sleep,
health, or
exercise data. | | | | |
| F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s
interaction
with a
website, application, or advertisement, | - Automatically from your browser or device
| - Communications
- Provide Services
- Safety and security
- Personalize your experience
- Marketing
- Manage and improve the Site and Services
- Legal or compliance
- Research
- Business transactions
- As agreed by you
| - Lead Buyers and Marketing Partners
- Service Providers and Processors
- Advertising Partners
- Affiliates and Successor Entities
- Legal Personnel
| - Lead Buyers and Marketing Partners
- Advertising Partners
|
| G. Geolocation data. Physical location or movements. | | | | |
| H. Sensory data. Audio information (including voice recordings). | | | | |
| I. Professional or employment-related
information. Current or past job history or performance evaluations. | | | | |
| J. Non-public education information (per the Family
Educational Rights
and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part
99)). Education records directly related to a student maintained by an
educational
institution or party acting on its behalf, such as grades,
transcripts,
class
lists, student schedules, student identification codes, student
financial
information, or student disciplinary records. | | | | |
| K. Inferences drawn from other Personal
Information. Profile reflecting a person’s preferences, characteristics,
psychological
trends,
predispositions, behavior, attitudes, intelligence, abilities,
and
aptitudes. | - Directly from you
- Automatically from your browser or device
- From third parties
| - Communications
- Provide Services
- Safety and security
- Personalize your experience
- Marketing
- Manage and improve the Site and Services
- Legal or compliance
- Research
- Business transactions
- As agreed by you
| - Lead Buyers and Marketing Partners
- Advertising Partners
- Affiliates and Successor Entities
| - Lead Buyers and Marketing Partners
- Advertising Partners
|
| L. Sensitive Personal Information Any information that reveals a consumer’s SSN, driver’s license
number, or
passport number, account credentials, precise geolocation,
racial and ethnic
origin, religious beliefs, biometric data, personal information
concerning a
consumer’s health or sex life or sexual orientation, as well as
contents of
mail, e-mail and text messages | | | | |
In the preceding twelve (12) months, we have disclosed the following categories of
Personal
Information to the third parties listed above for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records Personal Information categories.
- Category C: Protected classification characteristics under California or federal
law.
- Category D: Commercial Information.
- Category F: Internet or Other Similar Network Activity
- Category K: Inferences Drawn from Other Personal Information
In the preceding twelve (12) months, we have shared the following categories of Personal
Information
for marketing or cross-context behavioral advertising purposes:
- Category A: Identifiers.
- Category B: California Customer Records Personal Information categories.
- Category C: Protected classification characteristics under California or federal
law.
- Category D: Commercial Information.
- Category F: Internet or other similar network activity
- Category K: Inferences Drawn from Other Personal Information
7. Your Privacy Choices and State Privacy Rights
If you live in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa,
Kentucky,
Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island,
Tennessee,
Texas, Utah, or Virginia, Oklahoma, Vermont, or Louisiana, you may have the rights
and/or choices
described in this section:
- Right to access: The right for a consumer to access from a
business/data controller the information or categories of information collected
about a consumer, the information or categories of information shared with third
parties, or the specific third parties or categories of third parties to which the
information was shared, including, where required by applicable law, the specific
third parties to whom your Personal Information has been disclosed; or, some
combination of similar information. In some states you may have the right to make a
request up to twice in a 12-month period free of charge. If requests are excessive,
repetitive, or manifestly unfounded, we may charge a reasonable fee or decline to
act on the request as permitted by applicable law.
- Right to correct: The right for a consumer to request that
incorrect or outdated Personal Information be corrected but not deleted.
- Right to Delete: The right for a consumer to request deletion of
Personal Information about the consumer under certain conditions.
- Right to Confirm Processing: The right to confirm whether we are
processing your Personal Information.
- Right to opt out of certain processing: The right for a consumer to
restrict a business’s ability to process certain types of Personal Information about
the consumer, such as the right to opt out of sharing of Sensitive Personal
Information or profiling, where applicable.
- Right to opt out of targeted advertising: The right to opt out of
the use of your Personal Information for targeted or cross-context behavioral
advertising.
- Right to portability: The right for a consumer to request Personal
Information about the consumer be disclosed in a common file format.
- Right to opt-out of sales or sharing: The right for a consumer to
opt out of
the sale of Personal Information about the consumer to third parties.
- Right to limit the use of Sensitive Personal Information: You may
have a right to limit our use of Sensitive Personal Information for any purposes
other than to provide the Services or goods you request or as otherwise permitted by
law. As noted in Section 1.B, we do not knowingly collect or process your Sensitive
Personal Information.
- Right against automated decision making: A prohibition against a
business making decisions about a consumer based solely on an automated process
without human input. We do not engage in automated decision making.
- Right to opt out of profiling: The right to opt out of profiling in
furtherance of decisions that produce legal or similarly significant effects
concerning you, where applicable. While we may use Personal Information for
analytics and targeted advertising, we do not engage in profiling.
- Right to appeal: Where a controller declines to take action
regarding a consumer's request to exercise any privacy right, the controller must
allow the consumer to appeal the decision and provide instructions on how they may
request an appeal.
- Right to withdraw consent: You have the right to withdraw consent
at any time, without affecting the lawfulness of processing based on your consent
before its withdrawal.
- Right of Non-Discrimination: You have a right to exercise your
rights under this section free of discrimination. We will not discriminate against
you in any way if you choose to exercise your rights under this section.
Please Note: These rights do not extend to Personal Information
that is exempted from your state’s applicable privacy laws. For NPI and other
information exempted from state privacy laws under the GLBA, please see our Gramm-Leach-Bliley
Act
Privacy Policy for more information about how we use and process your
information and your rights.
8. How do you opt out of data sharing/sale?
A. Opt Out Request Form
You may opt out by clicking the “Do Not Sell or Share My
Personal
Information” link in the footer of our website.
B. Universal Opt Out Mechanism
We honor Global Privacy Control (GPC) and other opt-out signals as requests to:
- Opt out of Personal Information sales
- Opt out of sharing for targeted advertising
- Limit use of Sensitive Personal Information, where applicable
We process recognized universal opt-out signals in accordance with applicable
state privacy laws.
Your opt-out applies only to the specific browser/device sending the signal.
Renew if you switch devices/browsers or clear cookies.
C. Personal Information Shared with Third Parties
Opt-out requests apply prospectively only and do not affect Personal Information
you provided before opting out that was already shared with applicable third
parties in accordance with this Policy. If we have already shared your Personal
Information with third parties, their use of that information is governed by
their own privacy policies and opt-out procedures, for which we are not
responsible. To opt out or exercise your rights with respect to information
already shared with third parties, please follow the instructions in those third
parties’ applicable privacy policies.
9. How do you make a request to exercise your rights or choices?
A. How to make a Request
To exercise your rights or to make an inquiry, please visit our Data Request Form
or you can contact us using any of the methods listed in the Contact Us section.
We may verify your identity before processing requests. Verification information
is used only for verification, security, or fraud-prevention and deleted after
processing.
B. Our Response to Requests
We will process all opt out requests as soon as reasonably practical and in
accordance with applicable law.
For all other requests, we will confirm receipt of your request within 10
business days. In general, we will respond within 45 days of our receipt of your
request. If we need more time to respond, we will let you know the reason for
the additional time and may take up to another 45 days to respond.
C. Authorized Agents
You may designate an authorized agent to exercise your rights on your behalf. We
require verification of the agent's authority and may require attestation under
penalty of perjury. Without power of attorney, we also require you to verify
your identity.
D. What to do if you disagree with our decision
If we deny your request, you may appeal by contacting us (see Contact Us section)
with your name, email, request type, appeal reason, and original request
reference. We will respond to appeals within the time required by applicable
law. In most cases, we will respond within forty-five (45) days of receiving
your appeal. Our response will explain the action taken or not taken. If your
appeal is denied, we will provide instructions on how you may submit a complaint
to the applicable state Attorney General.
Cookies, Tracking, and Online Advertising
We use tracking technologies ("Cookies") including cookies, pixels, and
tracking scripts to collect, store, and track information about you and your use of the Site
or Services. Our use of cookies may constitute a “share” or “sale” for cross-context
behavioral advertising purposes under applicable state privacy laws, including the
CCPA/CPRA.
A. Cookies Explained
We may use the following tracking technologies on our Site or in providing the
Services:
- Cookies: Small text files stored on your device for months;
deletable through browser settings. Cookies can be stored on your device for
months, but you can choose to delete cookies stored on your device at any
time through your browser settings.
- Pixels/Web Beacons: Tags on web pages/emails recording
activities; stop tracking when you navigate away. We may also allow some
third parties to place web beacons on our Site or in our communications.
Pixels are not stored on your device and will stop tracking you once you
navigate away from the Site.
- Tracking Scripts: Small piece of code, typically in
JavaScript, monitoring user behavior, such as page visits, time spent on
pages, clicks, and device information. Tracking scripts usually work with
cookies to monitor website users across sessions.
B. Cookie Classifications
Cookies are classified by their purpose (their primary function on the website)
and generally fall into one or more of the following categories:
- Essential: Required for the Site to function. You cannot
disable these.
- Targeted Advertising: Deliver targeted ads and measure
effectiveness.
- Personalization: Remember preferences (such as your
username, language,
or the region you are in) and provide enhanced features.
- Analytics: Understand Site performance and visitor
interactions.
We use cookies for all of the above purposes.
C. How We Use Third Party Cookies
We may also use third party cookies or analytics tools for the following
purposes:
- Third Party Analytics Tools: We use third party analytics
tools to
collect information about how consumers use our platforms. This information
is collected
in aggregated form only. Some third party analytics tools, such as Google,
allow you to
control your privacy preferences across all websites by allowing you to
download an
extension for your browser.
- Third Party Ad Servers: We may use other third-party
tracking technologies (“Ad Servers”) to either re-target relevant
advertising about our products or services, or enable third parties to serve
their ads and monitor users’ responses to their advertisements. Ad Servers
may re-direct you to other websites not associated with us. The use of Ad
Servers may be considered a “sale” or “sharing” under certain data
protection laws. Ad Servers have their own privacy practices, we do not
control these third parties’ use of cookies, or how they manage the
information they gather through them. You should review the privacy policies
of other websites you visit or link to from our Site to understand how these
other websites use cookies and how they use the information they collect
through the use of cookies on their own websites.
D. Blocking, Disabling, or Opting Out of Cookies
You may have choices about the collection of information by cookies we use on the
Site.
- Manage your cookie preferences: Clicking on the “Cookies
Preferences” link (looks like a picture of a cookie, in the lower left hand
corner of the Site) and selecting the cookies you wish to disable. You
cannot disable essential cookies. Disabling cookies may impact your ability
to use all of the features and functionality of the Site.
- Browser Settings: Most browsers allow you to reject cookies
by default. You may also be able to delete our cookies as soon as you leave
the Site. Disabling cookies may impact your ability to use all of the
features and functionality of the Site.
- Google Ad On: For Google Analytics, you may download an
Opt-out Browser Add-on. Please note that the Add-on does not prevent
information from being sent to us. To learn more about the Add-on tool for
Google Analytics, click here.
- Subscribe to Opt-Out Lists: Some advertisers and service
providers that perform advertising-related services for us and for third
parties may participate in the self-regulatory programs. See the below links
to learn more:
- Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for
Online
Behavioral Advertising, visit http://www.aboutads.info/choices/, and
http://www.aboutads.info/appchoices.
- Network Advertising Initiative (“NAI”), see
http://www.networkadvertising.org/choices/.
- Request to Opt-Out Of The Sale Or Sharing Of Personal
Information by either submitting the Data Request Form or
following the instructions in the “How Do You Opt Out of Data Sharing?”
section.
Do Not Track Signals: Some browsers allow you to turn on Do Not
Track signals (DNTs), which sends a signal to the websites you visit telling
those sites that you do not wish to allow third-party cookies. There is no
standard technology at this time for companies to receive these signals. Our
Site does not currently consistently respond to DNTs received from web browsers.
11. What is de-identified or aggregate data and how do we use such data?
"De-identified data" cannot reasonably be linked to a particular person.
"Aggregate data" shows high-level trends without linking to
individuals.
We may de-identify and aggregate data for business purposes, including improving the
Services, security, analytics, and reporting. We maintain such data in de-identified or
aggregate form and do not attempt to re-identify it except as legally permitted. Third
parties receiving such data commit to maintaining it in de-identified or aggregate form.
12. Data Security
We use commercially reasonable administrative, technical, and physical safeguards
designed to protect Personal Information from unauthorized access, misuse, or
disclosure. No method of transmission or storage is completely secure, however, and we
cannot guarantee absolute security. You transmit Personal Information to us at your own
risk.
13. Children's Privacy
The Site and Services are not intended for users under the age of eighteen (18), nor do
we knowingly
collect, retain or share information in connection with the Site or Services from
children under the
age of 18.
With respect to children under the age of thirteen (13), we do not knowingly collect
information from
children under 13. Visit the Federal Trade Commission website for more information about
the
Children’s Online Privacy Protection Act (COPPA).
If you believe that we have received information from a child or other person who is not
of a
majority age in their relevant jurisdiction, please contact us using the information
listed in the
“Contact Us” section below and we will take all reasonable efforts to remove the
information.
14. Do we use or process Personal Information outside the country where the data was
originally
collected?
We may send Personal Information to servers outside your country. By using the Site and
Services, you
consent to transfer and processing in other countries. Data protection laws may differ
from your
country of residence. We take steps to ensure secure treatment in accordance with our
Terms and this
Policy.
15. Data Retention
Unless you request deletion, we retain Personal Information for as long as necessary to
fulfill the purposes described in this Policy. We consider amount, nature, sensitivity,
risk of harm, processing purposes, and legal requirements when determining retention
periods. Lead inquiries are generally retained for as long as necessary to document
consumer consent, maintain transaction records, comply with legal obligations, resolve
disputes, enforce agreements, and support audit and compliance functions.
16. Third-Party Websites
Our Site may include links to websites or services operated by third parties that are not
affiliated with us. A link to a third party’s site does not necessarily mean that we
endorse it or that we are affiliated with it. We do not exercise control over
third-party sites. These third parties have their own privacy policies and practices,
which we encourage you to review, as we do not control and are not responsible for their
content, security, or handling of Personal Information. Review their privacy policies
when linking.
17. Other information about your privacy
We generally act as a “controller” of your Personal Information. Lead buyers, lenders,
brokers, investors, and certain affiliated entities receiving your information may act
as independent businesses/controllers and are responsible for their own privacy
practices. You are responsible for any Personal Information you choose to share
publicly, whether through the Site or any third-party platforms.
18. Communications by Phone, including Call and SMS/MMS, and Marketing Consent
By providing your phone number, you are providing your express written consent to receive
phone calls and text messages (SMS/MMS/other) from us (including our service providers
or vendors sending communications on our behalf or at our direction) and lead buyers.
Calls and texts may be placed using equipment which may qualify as an automatic
telephone dialing system or other similar technology and or using a
prerecorded/artificial voice message. Calls and texts will only be placed for both
informational purposes (e.g. relating to your account or to respond to your requests)
unless you have provided your prior express written consent to receive marketing calls
or texts. Your consent to marketing calls/texts is not required to purchase any
products, goods, or services from us. You understand and agree that you are consenting
to calls/texts even if you have previously listed yourself on any state or federal
Do-Not-Call List. Message frequency varies. Message & data rates may apply. Reply HELP
for assistance, STOP to cancel.
By using the Site and Services, you understand and agree that we are a lead generator
that connects interested borrowers with interested lenders. When you submit a request
through any web forms available on the Site or by telephone, email, or otherwise, you
understand that in order to provide the Services you requested, we must share or sell
your Personal Information, including the contact information that you provide, so that
interested financial institutions and lead buyers can contact you to discuss your
request. We will only share your consent to receive calls or text messages with third
parties when you have provided prior express written consent to receive communications
from those third parties at the time you provide your phone number.
For additional details regarding our communications with you, please see the Terms
at Section
If you have provided consent to receive communications from us by phone, we will not
share or sell that consent to any third party without your prior express written
consent.
To Nevada Consumers
We are providing you this notice pursuant to state law. You may be placed on our internal
Do Not Call List by requesting that we cease calling you by contacting us directly and
making such request in writing by using the contact information provided in Section 20.
Nevada law requires that we also provide you with the following contact information:
Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington
St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail:
BCPINFO@ag.state.nv.us.
19. Changes to This Policy
We may modify this Policy at any time. Changes supersede previous policies. Updates will
be posted with a revised "Last Updated" date. Check frequently for updates. Where
required by applicable law, we will notify you of any material changes (including
changes to how we share and/or sell your Personal Information) to this Policy by email
and/or account notice. For changes to how we collect, use, process, or share personal
data, we’ll provide opportunity to consent or opt out as required by applicable law, and
such changes will not apply retroactively without your consent.
20. State Specific Disclosures
California – Shine the Light Law
California residents have the right to request certain details about how their Personal
Information is shared with third parties and, in some cases, affiliates for direct
marketing purposes. We may from time to time elect to share certain Personal Information
about you with third parties for those third parties’ direct marketing purposes. If you
are a California resident, you may obtain the categories of Personal Information shared
and the names and addresses of third parties that received Personal Information for
their direct marketing purposes during the preceding calendar year. You may make this
request by contacting us using the information provided in the Contact Us section. Such
request must include “California Privacy Rights Request” in the first line of the
description and include your name, street address, city, state, and ZIP code. To help us
determine if this right applies to you, we may ask that you attest to the fact that you
are a California resident and provide a current California address. Please note that we
are only required to respond to one request per customer each year.
California and Vermont
We automatically treat accounts with Vermont and California billing addresses as if you
requested we not share information with nonaffiliated third parties and limit
information shared with affiliates. If we disclose information about you to
nonaffiliated third parties with whom we have joint marketing agreements, we will only
disclose your name, address, other contact information, and information about our
transaction and experiences with you.
21. How to Contact Us
If you have any questions or concerns about us, the Site, the Services, this Policy, the
Gramm-Leach-Bliley Privacy Policy, or to exercise your rights or choices, please contact
us:
Data Request Form
