Privacy Policy

Personal information we collect

The personal information we collect may include:

• Contact Data, such as your first and last name, email and mailing address, and phone number.
• Account Data, such as username and password.
• Financial Data, such as information about your assets, refinancing applications or history, and income.
• Closing Data, such as any information contained in closing documents you upload to the Online Services.
• Professional Data, such as job title, company and employment history.
• Automated Data, such as device and network identifiers and information about your online activity (please see the “Automated Data Collection” section below for more detail).
• Other Data you choose to provide to us, such as through communications with us over our Online Services.

Automatic Data Collection

We and our service providers may automatically obtain information about you, your computer or mobile device, and your interaction over time with the Online Service, 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, language settings and device carrier.
• General location data, for example, as inferred from network data or device settings.
• Online activity data, such as pages or screens viewed, search history, online services visited before browsing to the Online Service, navigation paths between pages or screens, information about activity on a page or screen, access times and duration of access.

Tracking 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, credentials, and login status as they navigate a site.
• Local storage technologies, like HTML5, which provide cookie-equivalent functionality but can store 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 was accessed or opened, or that certain content was viewed, clicked or forwarded.
• Session replay technology, which enables us to collect, on a real-time basis, information on how you use and navigate the Online Service (e.g., mouse movements, how you scroll through the Online Service).

How we use your personal information

We may use your personal information for the following purposes:

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

• provide and operate our Online Service and other products and services;
• process your requests and transactions;
• establish and maintain your account on the Online Service;
• communicate with you about the Online Service and our other products and services, provide customer support, and respond to your requests and feedback;
• understand your needs and interests, and personalize your experience with the Online Service and our communications; and
• fraud prevention and security.

Research and development. We may use your personal information for research and development purposes, including to develop, analyze and improve our Online Service and other products and services, create aggregated or de-identified data, and perform analytics.

Marketing. We may use your personal information for marketing purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests.

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

• comply with applicable laws, lawful requests, and legal process;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance;
• enforce our policies and terms; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

In addition to the other uses included in this section, we may use the tracking technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Online Service, such as remembering selections as you navigate and remembering whether you are logged in.
• Functionality. To enhance the performance and functionality of our Online Service.
• Analytics. To help us understand user activity on the Online Service, including how users move around the Online Service or interact with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout. We also may use third-party session replay services that record users’ interactions with the Online Service.

How we share your personal information

We may share your personal information for the purposes identified in this Privacy Policy with (1) our affiliates; and (2) service providers that perform certain services on our behalf (e.g., analytics, email delivery, and information technology). In addition, we may share your information with entities providing or brokering loan offers relevant to your inquiries or business.

We also may disclose personal information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to share or transfer any personal information we have about you in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business (including in the event of a divestiture, restructuring, reorganization, dissolution or liquidation).

Your Choices

In this section, we describe the choices available to you.

Opt-out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Online Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. We do not respond to legacy “Do Not Track” signals received from browsers.

Other sites and services

The Online Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We maintain administrative, technical and physical safeguards designed to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. We protect your personal information as described in this Privacy Policy.

Children’s privacy

The Online Service is not intended for use by anyone under 18 years of age. If we learn that we have collected personal information through the Online Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Online Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

How to contact us

If you have questions about this Privacy Policy, please contact us at privacy@easecapital.com.