Privacy Policy

This Privacy Policy was last updated on September 1, 2017

Welcome to point.com! This Privacy Policy applies to point.com (and any subdomains thereof) (the “Site”), which is owned, operated, licensed, and controlled by Point Digital Finance, Inc., a Delaware corporation (together with its related, affiliated or subsidiary companies, “Point”, “we”, or “us”). This Site has been created to provide information about our company and our home equity marketplace and related services (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This privacy policy describes how Point collects and uses the personal information you provide on our Site. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Your privacy and the protection of your sensitive personal information are important to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information. In addition to this Privacy Policy, you are subject to additional policies, such as our Terms of Use, Credit Report Policy, and Consent to Electronic Communications and Electronic Signatures (collectively, the “Point Policies”), that may be posted on the Site from time to time. All terms from such Point Policies are hereby incorporated by reference. You also have certain rights under the Fair Credit Reporting Act, a summary of which can be found here.

IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY AND THE OTHER POINT POLICIES, DO NOT USE THE SITE.

If you have any questions, complaints or suggestions regarding our Privacy Policy or practices, please contact us at [email protected].

CHANGES TO PRIVACY POLICY

The Services and our business may change from time to time. As a result, at times it may be necessary for Point to make changes to this Privacy Policy. Point reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

INFORMATION WE COLLECT

When you interact with us through the Services, we may collect personal data and other information from you, as further described below:

Personal Data That You Provide Through the Services

We collect personally identifiable data, including financial information (“Personal Data”) from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, apply for a Point product or use certain Services. Most of the collection occurs when you register with the Site to apply for a Point product.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Point and the authorized third parties referred to herein located in the United States.

We will retain your Personal Data as long as your account is active or as needed to provide you the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Point may still need to keep certain personal details of customers to ensure that systems reflect your preferences even if a customer has chosen to opt out of allowing Point to use that customer’s personal details for marketing purposes. Point may keep records of any transaction a customer enters into on the Site for a minimum of seven years from the end of Point’s relationship with the customer. Point may keep other information about a customer only to the extent necessary to comply with applicable laws and to further legitimate business needs.

Other Information: Non-Identifiable Data

Point uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant Point and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy. If you choose to become a Point customer, Point may continue to access, transfer, and store your data using Plaid for the duration of your agreement.

When you interact with Point through the Services, we receive and store certain personally non- identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Point may store such information itself or such information may be included in databases owned and maintained by Point affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, IP addresses, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Services, we may use a technology called “cookies”. A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Point or its service providers send cookies when you surf our Site or sites where Point ads appear, make purchases, request or personalize information, or register yourself for certain Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features; if cookies are not accepted, most features of our Site will not be available to you. Point does not store passwords or any other information about a visitor without a Point account in a cookie that would identify them, locate them, and determine their preferences or their financial activity.

Other Information: Aggregated Personal Data

In an ongoing effort to better understand and serve the users of the Services, Point often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Point may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Point may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the Site, including if users browse the Site across multiple devices such as a home computer and mobile device, and enhance your experience when you use the Service. Your continued use of the Site indicates your consent to our use of Google Analytics. If you wish to opt out from Point’s use of Google Analytics go to https://support.google.com/analytics/answer/181881?hl=en for instructions on installing the Google Analytics opt-out browser add-on. For more information on how Google uses this data, go to http://www.google.com/policies/privacy/partners/.

OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION

Point uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Point and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. Point and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us at [email protected]. If Point intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION

Point is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

YOUR CHOICES

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

EXCLUSIONS

This Privacy Policy does not apply to any Personal Data collected by Point other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Point through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, blogs, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Point shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

CHILDREN

Point does not knowingly collect Personal Data from minors under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a minor under the age of 18 has provided Personal Data to Point through the Services, please contact us at [email protected], and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Point (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Point endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

INTEGRATION SOCIAL NETWORKING SERVICES

One of the special features we may offer with the Service is to enable you to log in to various social networking services like LinkedIn or Facebook (“Social Networking Service(s)”) via the Services. By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and Point shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

TELL-A-FRIEND AND OTHER USER REFERRAL ACTIVITIES

Users may choose to refer friends to the Site via email.

If this referral occurs independently of our Site or a partner’s site, we do not track the referral other than as a unique page view. Since we do not collect any information from the referring party or the recipient of the external email referencing our site, we do not capture or store any information about either party. If friends refer each other to our Site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities that contributed to the referral. Our users can also refer friends to the site by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular Point product request, and the sender will not know whether you are an applicant, investor or customer. The information collected in this process is only kept long enough to monitor whether the referral program is achieving the desired results in terms of attracting new visitors to the site and converting them into applicants. Again, these are messages initiated by friends of the recipients, and the recipients will not be added to any mailing list or contacted by Point apart from this referral process, which may include invitation reminders. In the case where a bonus is offered to a member in return for the referral, Point will only retain the information about the referred parties to properly credit the account of the member initiating the referral. The information is not used for any other purpose.

Your friend may contact us at [email protected] to request that we remove this information from our database.

SECURITY

Point takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. All data entered into the Point site is encrypted using industry-standard 128-bit AES cipher and transported over secure TLS protocols. TLS allows sensitive information such as social security numbers to be transmitted securely. Your information is unreadable to anyone except Point. Additionally, Point does not store the login details of your linked accounts, such as usernames and passwords. No one at Point has access to the login details of your linked accounts.

Despite our efforts, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Point via the Internet.

You can take several precautions to protect the security of your computer and Personal Data:

OTHER TERMS AND CONDITIONS

Your access to and use of the Services is subject to the Terms of Use.

ACCESS TO INFORMATION; CONTACTING POINT

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about Point’s Privacy Policy or the information practices of the Services at [email protected].