Privacy Policy

Personal information we collect

Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name and email address.
• Application data, such as your first and last name, email address, mailing address, phone number, home address, estimated home valuation, and other information you provide when you submit a prequalification request or application for one of our financial products.
• Communications data about our communications with you, including when you contact us through the Service, social media, email, text messages, or otherwise, including the date, time, and contents of the message, and the email addresses, phone numbers (and carrier name), and social media handles from which your messages are sent.  
• Transactional data pertaining to your transactions with us, including information about any financial products we provide you. 
• Relationship data, such as the personal information of relatives or third parties that you provide to us.
• Financial data, such as your stated income, credit score and credit history, and financial account numbers.
• Government identification data, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
• Survey data, including information you share when you choose to participate in a survey. We recommend that you read any instructions, terms, or rules applicable to the survey before participating.

We may also collect other data not specifically listed here and will use it as described in this Privacy Policy or as otherwise disclosed at the time of collection.

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Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, and other publicly available sources.
• Private sources, such as data licensors. 
• Marketing partners, such as joint marketing partners.
• Third-party services, such as financial institutions from which you authorize us to retrieve your information for use in connection with our review of your application for our products or services,  which may include your address and Social Security Number, account balances, transaction history, and length of relationship with the third party.

‍Automatic data collection. 

We, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, Bluetooth, LTE, 3G) and location data that can be derived from it, general location information such as city, state, or geographic area that can be derived from your IP address.
• Online activity data, such as pages or screens you viewed, your search terms, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails, forwarded them, or clicked links within them, and other functional information on Service performance (like diagnostics and crash logs).

• Location data, including the general location associated with your IP address or, when you authorize the Service to access it.

Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened or that certain content was viewed or clicked. 
• Chat technologies, which enable the chat features that you can use to communicate with us through the Service. We and the third parties that provide these features may access and use the data described in the automatic data collection section described above, and will monitor and record your chats, for the purposes described in this Privacy Policy. When you use these features, you should assume you are not communicating with a human unless we specifically confirm that you are.‍
• Session replay services, which employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. For example, we use session replay services provided by PostHog. You can learn more about PostHog at https://posthog.com/privacy and any data PostHog collects in their “Cookies, tracking technologies and Do Not Track” section of PostHog’s Privacy Policy.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

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Service delivery and operations.  We may use your personal information to:

• provide, operate, and improve the Service and our business;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages, as well as and responding to your requests, questions, and feedback;
• administer and communicate with you about surveys in which you choose to participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and improve our support capabilities, including to perform quality assurance monitoring of support calls and to train support personnel.

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Marketing and advertising.  We, our service providers, and our third-party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications via mail, email, or (as permitted by law) text messages and may personalize these messages based on your needs and interests.  You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
• Targeted advertising.  Our third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the Automatic data collection section above) with the Service, our communications, and other online services over time and with different browsers and devices, and use that information to serve online ads that they think will interest you and measure their effectiveness. We may also share contact data about our users with these companies to facilitate targeted advertising to those or similar users on other online platforms. 

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Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.  As part of these activities, we may create aggregated, de-identified, and/or anonymized data from personal information we collect.  We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you.  We may use this aggregated, de-identified, or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

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Compliance and protection.  We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); 
• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
• enforce the terms and conditions that govern the Service; and 
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.  

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Cookies and other technologies. The Service employs cookies and other technologies to facilitate the purposes for which we use personal information:

• Service delivery and operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and authenticating you into the Service, and to enhance the performance and functionality of our services.
• Interest-based advertising. To facilitate interest-based advertising as described above. 
• Research and development. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails and advertisements. For example, we use Google Analytics cookies for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Artificial Intelligence. We, our service providers and the third parties we work with may use artificial intelligence (AI) and machine learning technologies, including generative AI, to facilitate the processing of personal information described in this Privacy Policy.

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California Privacy Notice 

This notice describes our collection, use, and disclosure of personal information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to their personal information. For purposes of this notice, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. For example, the CCPA exempts information covered by our U.S. Consumer Privacy Notice or handled in accordance with the Fair Credit Reporting Act. 

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Your privacy rights. If you’re a California resident, you have the following rights under the CCPA:

• Right to know. You can request information about the categories of personal information that we have collected; the categories of sources from which we collected personal information; the business or commercial purpose for collecting, sharing and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared, or disclosed for a business purpose.
• Right to access. You can request a copy of certain personal information that we have collected about you.
• Right to deletion. You can request that we delete personal information that we collected from you.
• Right to correction.  You can request that we correct inaccurate personal information that we have collected about you.
• Right to opt-out.   You can request to opt-out of disclosures of your personal information that constitute “selling” or “sharing” of your personal information as defined in the CCPA. Our use of the targeted advertising services described above may constitute “sharing” of your personal information but we do not otherwise sell personal information.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

You may submit requests to exercise your right to know, access, deletion, and correction by submitting an online request here or calling us at (855) 245-3614. You may submit a request to opt-out by clicking “Your Privacy Choices” at the bottom of our webpage and following the instructions or enabling the Global Privacy Control (GPC) from your browser. Learn more at the Global Privacy Control website: https://globalprivacycontrol.org. Your request to opt-out will apply only to the browser and the device from which the request is submitted.

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The rights described above are not absolute, and in certain cases, we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Identity verification. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to provide identifiers we can match against information we may have collected from you previously, confirm your request using the email or telephone number stated in the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.

Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

Information practices. The following describes our practices currently and during the past 12 months:

• Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in the Privacy Policy. 
• Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.
• Retention.  We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  The length of time we retain particular categories of personal information is determined based on whether it is sufficient to achieve such purposes.  When we no longer require the personal information, we may either delete it, anonymize it, or isolate it from further processing.
• De-identified data. We maintain and use de-identified information without attempting to re-identify it except to test whether our de-identification processes comply with applicable law.
• Children. We are required to inform you that we have no actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.
• Collection and disclosure. The chart below describes the personal information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose it.  The terms in the chart refer to the categories of information and third parties detailed above in the Personal information we collect section. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to professional advisors, law enforcement and government authorities, and business transferees as described above in the How we share your personal information section of this Privacy Policy.