This Privacy Policy describes how Real-Finity Mortgage, LLC (“Real-Finity Mortgage,” “we”, “us”) collects and processes Personal Information.

Please read this Privacy Policy carefully.  When you submit information to us, you consent to the processing of your information as described in this Privacy Policy. 

1. SCOPE

This Privacy Policy applies to rfm.io and all websites and mobile apps owned and operated by Real-Finity Mortgage on which this privacy policy is displayed (such websites and apps referred to hereafter as the “Website(s)” or “Site(s)”, whether individually or collectively, or collectively as “Services”) as well as Real-Finity Mortgage affiliates.

This Privacy Policy does not apply to information that is collected offline or by any third-party websites or services that you access through the Services. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.. 

2. CHANGES TO THIS PRIVACY POLICY

The Effective Date of this Privacy Policy is set forth at the top of this webpage.  As we add new features to the Services, we may amend this Privacy Policy.  If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you in advance through the Services.  Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy.  The amended Privacy Policy supersedes all previous versions.

3. INFORMATION WE COLLECT

We collect information about you to help us serve your financial needs, to provide you with quality products and services and to fulfill legal and regulatory requirements. We consider non-public information about you in our possession to be personally identifiable information, even if you cease to be a customer. The personally identifiable information we collect about you may include among other things:

• Identifying information, such as your name, age, address, phone number and social security number and photo
• Employment information
• Financial information such as your income, assets and liabilities, as well as information about your savings, investments, insurance and business.
• Information for fraud detection and prevention

We may also collect information such as demographic data, data about your online activity, and other information that is not used to identify you.

4. HOW WE COLLECT INFORMATION

Information provided by you: We collect information from you when you enter it or otherwise provide it in connection with an inquiry into our Services. This information could be provided via applications, online forms, over the phone, or via other means in which you interact with our Services.

Information from third parties: Information is collected from credit bureaus, lead generators and other partners who may have data on your financial profile, home, or other demographic information.

Information from cookies and other tracking technologies: We use cookies, web beacons, and similar technologies to record your preferences, track the use of our Site and collect information. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Sites may not function properly.

Through Publicly Available Sources: We may collect personal data from publicly available sources, such as government records or public review websites, to supplement the personal data identified above.

5. HOW WE USE INFORMATION

We may use your information in accordance with applicable laws, such as:

• Providing customer support, processing transactions, and responding to your inquiries;
• Sending you important information and updates regarding sites, products and services; 
• Delivering marketing communications that we believe may be of interest to you, including, advertisements or offers tailored to you 
• For business purposes, including data analysis, audits, developing and improving products and services, enhancing the site, identifying usage trends and determining the effectiveness of promotional campaigns; 
• For risk control, fraud detection and prevention, compliance with laws and regulations, and accordance with other legal process and law enforcement requirements; 
• For any other purposes that we may specifically disclose at the time you provide or we collect your information; and 
• Operate, provide, improve, and maintain our sites and services and offer tailored content.The Services are protected by copyright, trademark, and other US and foreign laws. These Terms do not grant you any right, title, or interest in the Services, others’ content in the Services, or Real-Finity trademarks, logos and other brand features.

6. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive.  A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

How We Use Data Collection Technology: Data Collection Technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, measuring the success of marketing campaigns, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud.

The Services use the following cookies:

• Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer.
• Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
• Functionality cookies, which are used to recognize you when you return to the Services.

We also use Google Analytics which is a Google service that uses Data Collection Technology to collect anonymous information about use of the Services and report website trends.  Google Analytics does not identify individual users.  We may use an enhancement to Google Analytics called “Demographics and Interest Reporting,” through which Google provides us with information about our users’ demographics (e.g., age, gender) and interests. This information, which Google may collect by tracking a user’s behavior across third-party websites, helps us to learn more about our users.  You can learn about Google’s practices in connection with this enhanced tracking and opt out of it by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. 

We also may use other Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device.  You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including Real-Finity Mortgage, do not respond to DNT signals. 

7. HOW WE SHARE INFORMATION

Real-Finity Mortgage may share personally identifiable information collected via the Services as follows:

• Service Providers: We share personally identifiable information about you, as required or permitted by law, with third parties, such as service providers who assist us in the in the administration, processing, servicing, and sale of your loan. These third parties may include among others, title companies, appraisers, insurance companies, real estate companies, fraud detection services, underwriting services, processing services, printing companies, software providers, marketing services, and purchasers of loans. Our policy is to require third party service providers to enter into confidentiality agreements with us, prohibiting them from using any personally identifiable information they obtain for any other purpose other than those for which they were retained or as required by law.
• Corporate Transaction: We may share and transfer personally identifiable information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Real-Finity Mortgage or any affiliated company (in each case, whether in whole or in part).
• When Required by Law:  Applicable law may require Real-Finity Mortgage to disclose your personally identifiable information: (i) to comply with applicable legal or regulatory obligations, (ii) to respond to a subpoena, warrant, court order, or other legal process, (iii) as part of an investigation or request from law enforcement or a governmental authority, or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law).
• Other Lawful Disclosures: We also share information (i) if disclosure would mitigate Real-Finity Mortgage’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of Real-Finity Mortgage, users, customers, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; (v) to respond to an emergency; and (vi) with your mortgage lender, as permitted. 

Real-Finity Mortgage may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Anonymized Information”).  Real-Finity Mortgage shares Anonymized Information with third parties and does not limit third parties’ use of the Anonymized Information.

8. COMMUNICATIONS FROM OUR SITE

When you submit an application and/or create a profile on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and confirmation of successful submissions of loan requests and portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personally identifiable information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us by clicking the unsubscribe link or emailing us at info@rfm.io (and including the word “unsubscribe” in your email request to us).

9. UPDATING YOUR PERSONAL INFORMATION

If you wish to access or update your personal preferences, please contact us as outlined under the Contact Us section. If you are an existing Real-Finity Mortgage customer, and you wish to access or update your personal preferences online, you can register and/or log in at _________. We will comply with your request within a reasonable time frame and within the time limits established by applicable law.

10. NOTICE TO CALIFORNIA RESIDENTS

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Please visit our Privacy Policy for California residents for more information.

11. LINKS TO OTHER WEBSITES AND SERVICES

The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it.  If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours.  This Privacy Policy does not apply to any personal information that you provide to these other websites and services.

12. NOTICE TO INTERNATIONAL VISITORS

We are headquartered in the United States and the Services are intended for users in the United States and controlled and operated from the United States.  We process and store personal information in the United States where privacy laws may not be as protective as in your place of residence.  If you are using the Services from outside of the United States, by providing your personal information to us, you consent to the transfer of your personal information to the United States for processing consistent with this Privacy Policy.

13. PROTECTION OF PERSONAL INFORMATION

We take precautions intended to help protect information that we collect and store.   Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services.  Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.

Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password-protected or secure areas of the Services. Access to the Services through your user ID and password will be treated as authorized by you.  Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution.  We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.

If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

14. CHILDREN’S PRIVACY

The Services are not directed to or intended for use by minors.  Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.

QUESTIONS OR COMMENTS

We welcome your questions or comments.  Please contact us at info@rfm.io