Assumable Technologies Inc., dba RetroRate (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at retrorate.com (the “Site”) and online services (“Services”). For the avoidance of doubt, this Privacy Policy applies equally to Lenders and Borrowers as defined in the Terms of Use, although based on the nature of the Services.
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Questions; Contacting Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following email:
RetroRate
Attn: Legal Department
[email protected]
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User Consent. By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.
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A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 18. If a child under 18 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 18, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 18, please contact us at [email protected].
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A Note to Users Outside of the United States. If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
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Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information, including financial information, about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
- Information You Provide to Us.
- We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, professional title, company name, phone number, and password when you create an account to log in to our network (“Account”).
- If you use our Services on your mobile device, including through our Application(s), we may collect your phone’s unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either reinstall the Application(s) or deactivate GPS on your mobile device.
- Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you post Content, including financial information and documents relating to you, on our Site, the information contained in your posting will be stored in our servers and other users who you have designated and invited to use the Services will be able to see such content, depending on the permissions determined by us.
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Information You Provide to Third-Party Accounts. The Services allow users to sign into their RetroRate account through their Google or Microsoft user accounts (“Third-Party Accounts”). If you choose to connect your Third-Party Accounts to your Account, you are allowing the Services to access your information and you are agreeing to the terms of use that govern such Third-Party Account in your use of the Services. Any information that we collect from your Third-Party Account may depend on the privacy settings you have for that Third-Party Account, so please consult the applicable privacy and data practices. You have the option to disable the connection at any time by logging into your Account through the Site or Application and going to “Settings”.
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Information Collected via Technology.
- Information Collected by Our Servers. To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
- Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
- How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
- Mobile Services. We may also collect non-personal information from your mobile device if you access our Services through a mobile phone. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location and information about the type of device you use.
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Information Collected through the RetroRate Extension. The RetroRate VHS browser extension ("Extension") operates only on specific real estate listing websites: including but not limited to Zillow, Redfin, and Realtor.com. When the Extension is active on one of these websites, it displays a visible overlay on the page showing assumable loan information sourced from our proprietary database of assumable loan data. We do not extract, scrape, or collect listing content from these third-party websites. The overlay is visible at all times while you are on a supported page, so you can always see when the Extension is operating.
- Information about your use of the Extension. We collect information about your interactions with the Extension, including:
- When you open, expand, collapse, minimize, or navigate within the Extension's overlay
- Which tabs, features, or information panels you view within the Extension
- Your interactions with calculators, sliders, and other tools within the Extension
- Clicks on Extension buttons, links, or calls to action, including requests to our concierge service
- Whether the Extension successfully displays assumable loan information on a given page
- Information about your browsing activity on supported real estate websites. While the Extension is active on a supported website, we observe limited information about your browsing activity on that site, including:
- The URL of the listing page you are viewing (used to identify the property and retrieve the assumable loan data we have independently sourced for it)
- How long you spend on the listing page and how far you scroll
- Whether you return to the same listing page in later sessions
- Actions you take on the listing page that are visible to the Extension, including clicks on page elements such as photo galleries, save/favorite buttons, tour requests, agent contact forms, offer-related buttons, and similar calls to action
- The number and sequence of listings you view within a browsing session
- We do not collect the content of the listings themselves (such as listing descriptions, seller information, or agent names) from these websites, and we do not collect the content of any forms you submit on these websites.
- Technical and device information. We also collect standard technical information, including your browser type and version, operating system, approximate location derived from IP address (typically to the metro or ZIP-code level, not precise GPS), and a randomly generated Extension identifier used to associate your activity across sessions without identifying you personally.
- What we do not collect. We do not collect your name, email address, phone number, or other directly identifying information through the Extension unless you voluntarily provide it (for example, by contacting our concierge service or creating an account). We do not collect passwords or payment information. We do not access pages on websites other than the supported real estate websites where the Extension is designed to operate.
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Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.
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Location Information. If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.
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Use of Your Personal Data
- General Use. In general, Personal Data you submit to us from through our website, mobile apps or browser extension is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Site and Services;
- operate and maintain the Services you request;
- improve the quality of experience when you interact with our Site and Services;
- produce internal analytics and insights about demand for assumable mortgages, which we may use to inform our business strategy, product decisions, and business development conversations with prospective partners
- detect, prevent, and address technical issues, fraud, and abuse
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- send information or promotional materials related to our Services and for other marketing purposes of Company.
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Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
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Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
- Third Parties Designated by You. When you use the Services as a Client, the Personal Data you provide will be shared with your Agent. Such third parties will have limited access to your Personal Data and Anonymous Data, based on permissions set by us, which are based on a need to know. Depending on the type of access granted to such third parties, they may also be permitted to edit the information you have provided to us.
- Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.
- Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
- Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
- Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
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Third Party Websites. Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
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SMS Privacy. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
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Your Choices Regarding Information. You have several choices regarding the use of information on our Service:
- Email Communications. We may periodically send you free newsletters and e-mails that directly promote the Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
- Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
- Stopping Data Collection: You can stop all data collection at any time by stopping use of our site, or uninstalling our Extension through your browser's extension settings. You may also request access to, correction of, or deletion of information we hold about you by contacting us at [email protected].
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Security of Your Personal Data. Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your Personal Data, Company cannot guarantee its absolute security.