Last Updated: February 18, 2020
This website, www.homelendingpal.com (the “Site”), is owned and operated by Home Lending Pal (collectively “Home Lending Pal, Inc.,” “we,” “us,” or “our”).
This Policy may be supplemented or amended from time to time by “privacy notices” posted on this Site. These Privacy Notices provide a level of detail that we cannot provide in this more general description of our website privacy practices. For example, certain pages of this Site may contain Privacy Notices providing details about the Personal Information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.
Types of Information We Collect
Information You Volunteer. Home Lending Pal collects the Personal Information you and others knowingly and voluntarily provide when you use this Site. For example, we collect the Personal Information you submit when you sign up for our news alerts, submit any registration information, connect to bank accounts or contact us with questions.
Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your Web browser. This information typically includes your IP address, the identity of your Internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. Please check your browser if you want to learn what information your browser sends or how to change your settings.
Cookies and Similar Technologies. We use “cookies” and other Web technologies to collect information and support certain features of this Site. For example, we may use these technologies to:
- collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page;
- support the features and functionality of this Site—for example, to save you the trouble of re-entering information already in our database or to prompt the settings you established on previous visits; and
- personalize your experience when you use this Site.
Generally, the information we collect using these Web technologies does not identify you personally. If, however, you have created a user identity, for example, by registering to be a Home Lending Pal user, we may link the information we collect using these Web technologies to other information that identifies you personally.
Generally, if you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.
Information from your mobile device. If you access the mobile version of this Site, we may automatically collect certain information from or about your mobile device. The types of information we may collect include the type of device you use, your device’s unique ID, the IP address of your device, your device’s operating system, the type of mobile Internet browsers you use, and information about the way you use our mobile application(s) and this Site.
We will always maintain our commitment to protecting your privacy
Let us be specific. Here’s what we may collect:
|CATEGORY OF PERSONAL INFORMATION||COLLECTED AND REQUIRED TO PROVIDE OUR SERVICES||SOLD TO THIRD PARTY (WE WILL NEVER DO THAT)||WE MAY SEND IT TO ONE OF OUR SERVICE PROVIDERS|
|Document uploads, audio and video recordings||✔||✖||✔ included in smart contracts|
|Bank account login||✔ Simulate underwriting||✖||✖|
|Home(s) of interest||✔ Simulate underwriting||✖||✖|
|Biometric information (such as voice and handwriting recognition)||✖||✖||✖|
|Characteristics of protected classifications (e.g., age, gender, race, ethnicity, physical or mental handicap, etc.)||✔|
Age, gender, race
Analytics providers, industry regulators
|Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies)||✖||✖||✖|
|Credit card number||✖||✖||✖|
|Debit card number||✖||✖||✖|
|Driver’s License Number / State ID||✔ optional upload to remain anonymous||✖||✔|
Third-Party Authentication (not lender)
|Electronic network activity (e.g., browsing history)||✔ |
Only on our website / apps
|Email address||✔||✖||✔ Anonymized unless you give access|
Third-Party Authentication (not lender)
Third-Party Authentication (not lender)
|Geolocation data||✔||✖||✔ Analytics providers|
|Tax information||✔||✖||✔ included in smart contracts|
|Identifiers (e.g., name or alias)||✔||✖||✔|
Third-Party Authentication (not lender)
|Credit Report Details||✔||✖||✖|
|Smart Contracts||✔||✖||✔ Only parties you give access|
|National origin, citizenship, immigration status||✖||✖||✖|
|Online identifier (e.g. IP address)||✔||✖||✔ Analytics providers|
|Other financial information||✔ Sometimes to help you with underwriting||✖||✔ included in smart contracts|
|HeLP Token (Encrypted Financial Profile)||✔||✖||✔ Anonymized unless you give access|
|Postal address||✔||✖||✔ included in smart contracts|
|Signature||✖||✖||✔ included in smart contracts|
|Social Security Number||✔ Only used for soft FICO pull||✖||✔ included in smart contracts|
|Telephone Number||✔||✖||✔ Anonymized unless you give access|
In addition to the cookies Home Lending Pal delivers to your computer through this Site, certain third parties may deliver cookies to your computer for a variety of reasons. Home Lending Pal does not have access to, nor control over, the cookies of third-party service providers or advertisers.
How We Use Personal Information Collected Through This Site
Generally, we use the Personal Information we collect through this Site:
- to provide the information, products and services you request;
- to better understand your needs and interests;
- to provide you with a personalized experience when you use this Site;
- to provide you with effective customer service;
- to improve the Content, functionality and usability of this Site;
- to contact you with information and notices related to your use of this Site;
- to contact you with special offers and other information we believe will be of interest to you;
- to invite you to participate in surveys and provide Feedback to us (with “Feedback” meaning the Content you post on or through this Site that is specifically about how we can improve this Site and the products and services we make available through this Site).;
- to improve our products and services;
- to improve our marketing and promotional efforts;
- for security, credit or fraud prevention purposes; and
- for any other purpose identified in any other notice or agreement between you and us.
Please see below for information about the choices you have about the ways we use your Personal Information.
Use of Aggregated and De-Identified Information
We may use information gathered through this Site to create a compiled, aggregate view of its audience and visitors’ usage patterns. We use aggregated and/or de-identified information to operate our services and to better understand our audience as we develop new products and services. We may also share aggregated and/or de-identified information with our third-party service providers and/or investors. Aggregate and de-identified information is not personally identifiable.
Use of Survey Information
From time to time, we may post a survey on this Site or we may send you a questionnaire or survey. We compile statistical information from the responses to our surveys. These statistics are not personally identifiable. They help us understand the needs and preferences of the groups we serve, improve the Content and functionality of this Site and other websites owned by Home Lending Pal, and improve the products and services of Home Lending Pal and its service providers.
In General. We respect your right to make choices about the ways we collect, use, and disclose your Personal Information. Discussed above are choices you have about delivery of cookies through this Site and about our collection of location information. In addition, we may ask you to indicate certain choices at the time we collect your Personal Information. For example, at the time you give us your contact information, we may provide to you an opportunity to choose (via “opt out” or “opt in”) whether you receive certain communications from us and/or our business partners. We will also include an “unsubscribe” link in each electronic newsletter or promotional email we send to you, and you can always text STOP to stop receiving SMS text messages from us.
Previously Expressed Preferences. You may change previously expressed preferences regarding how we use your Personal Information. If you have registered with this Site, you may be able to change certain privacy preferences through your account settings. Otherwise, if at any time you wish to be taken off our mailing lists, please contact us using the information provided above. Once we have the information we need, we will remove you from our mailing lists as you have requested. Please give us a reasonable amount of time to honor your request.
How to Access, Update or Correct Your Personal Information
If you have registered with this Site, you may be able to access, update, or correct your Personal Information through your account settings. Otherwise, you may need our help. If you wish to access, update, or correct your Personal Information, please contact us using the information provided in this Policy. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.
Steps We Take to Safeguard your Personal Information
We maintain reasonable administrative, physical, and technological measures to protect the confidentiality and security of Personal Information you submit on or through this Site. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your Personal Information will not be disclosed, misused or lost by accident or by the unauthorized acts of others.
How We Share Your Personal Information With Others
Third–Party Vendors. We may share Personal Information collected through this Site with other third-party vendors who act for or on behalf of Home Lending Pal. For example, we may share Personal Information with companies that provide web hosting or email services for our business. These third-party vendors may need information about you to perform their functions.
Business Negotiations. We may contemplate, for strategic or other reasons, selling, buying, affiliating with, merging, or otherwise reorganizing with one or more third parties. In negotiating with a third party about entering into such an arrangement, we may need to disclose your Personal Information. In such cases, we will take reasonable measures to protect the Personal Information we disclose, for example, by requiring a prospective purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the Personal Information.
Business Transfers. Your Personal Information may be transferred to a successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization. If such a transfer occurs, the successor organization’s use of your Personal Information will still be subject to this Policy and the privacy preferences you have expressed to us.
As Described in a Privacy Notice. We reserve the right to disclose your Personal Information as described in any Privacy Notice posted on the Web page where you provide that information. By providing your personal information on that Web page you will be consenting to the disclosure of your personal information as described in that Privacy Notice.
Children under the Age of Thirteen
This Site is not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted Personal Information on or through this Site without the consent and supervision of a parent or guardian, please contact us using the information provided below.
California Privacy Rights
Under California Civil Code Section 1798.83, a California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
How We Deal with “Do Not Track” Signals
Certain browsers may allow you to request that websites not track your activities over time and across third party websites or other online services by sending “do not track” signals to commercial websites like the Site. We DO follow the “do not track” directions provided by your browser.
Links to Other Sites
This Policy May Change
This Policy describes Home Lending Pal’s current policies and practices with regard to the Personal Information we collect through this Site.
For your convenience, whenever this Policy is changed, we may alert you by posting a notice on our home page. We will also update the “effective date” at the top of this Policy. If we have your email address, we may also attempt to email you with notice that the Policy has changed.