Effective Date: May 1, 2021.
Company customers should also refer to their license agreement and other customer agreements, which may provide additional terms governing their use of our Services.
THE INFORMATION WE COLLECT
When you visit our Websites, the Company collects a variety of information from and about you, your devices, and your interaction with the Company’s Services. We also collect information about users of our Services and obtain information from third parties (including our customers’ borrowers and from service providers) in the course of providing our Services to customers. This information includes:
- Information You Provide in Services Inquiries. When you express an interest in obtaining information about the Company’s Services through the Websites or our sales teams, request to contact sales, use our “Contact Us” or similar features, sign up for an event or webinar, or download certain content from our Websites, we ask you to provide your name, title or job level, company, address, email address, telephone number, or username and/or password.
- Registration Information. When you register to use one of the Company’s Services or for one of our events, such as our Experience user conference, we may collect certain information from you to contact you and provide our Services to you, including your name, email address, title or job level, company, address, telephone number, emergency contact information, and other information that we need for your attendance, such as dietary preferences and physical or ADA accessibility needs.
- Event Attendance. If you attend an event, we may require a photo ID or other form of identification prior to admission and/or to confirm registration and scan your attendee badge or require registration or sign in as you access sessions or events, which will provide us with your name and address information provided during registration. Exhibitors and sponsors at the event also may, with your consent, scan your attendee badge or track your visit to their virtual site to obtain your name, title or job level, company, address, email address, and telephone number for future contact.
- Usage Information. Like other websites and online services, we collect standard technical information when you visit our Websites and/or use our Services, including unique device identifiers, internet protocol (IP) addresses, browser types, internet service providers (ISPs), the number and duration of page visits and the number of clicks.
- Personal Information Collected as a Third Party Service Provider. When we collect information as a third party service provider, we do so solely to provide our Services to our customers, namely lenders and mortgage brokers. In the course of delivering our Services, our systems receive information about our customers’ borrowers (which may include personal information), which is provided by our customers. We process this information on the behalf of our customers. Our customers are responsible for providing notice and obtaining appropriate consents to collect data from their borrowers and to provide it to us as their service provider. You should refer to our customers’ privacy notices and/or contact them directly to understand how your personal information will be collected, used, and shared.
- Transactional Information. The Company, as a service provider, may also collect and process transactional information relating to the loan transactions or other events occurring through our Services. This transactional information is collected to enable us to provide and enhance our Services, to enable the services provided by third parties (including, for example, determinations of qualification for loans or the interest rates to be applied to loans), and to enable us to comply with various legal obligations.
- Messaging Services and Other Communications. The Company enables users of certain of our Services to communicate with each other and/or their consumers through those Services using messaging services like text, chat or email. As a service provider, we collect and process this information to enable our customers to communicate and collaborate. This communications information is collected solely to enable the Company to provide its Services and, to the extent applicable, to enable the services provided by third parties.
HOW WE USE INFORMATION
We use information we collect through our Services in a variety of ways to provide our Services and to operate our business, including the following:
- To Provide our Services. We use the information that we collect (i) to operate, test, maintain, fix, and provide features of our Services; (ii) to provide services and information that you request; and (iii) to provide support to customers, users, and site visitors.
- To Improve, Analyze, and Personalize our Services. We use the information that we collect (i) to understand and analyze usage trends and preferences; (ii) to monitor and analyze the effectiveness of our Services; (iii) to enhance and improve our Services and develop new products, services, features, and functionality; (iv) to personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our Services, and (v) to provide customized content and information.
- To Contact You. We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including important product updates and marketing or promotional communications relating to our Services or events. You have the ability to opt out of receiving marketing or promotional communications by updating your preferences in our Subscription Center or as described below.
- To Plan and Manage Events. We use the information that we collect for event planning and management, including registration; attendance; where permitted, connecting you with other event attendees; and/or to contact you further about relevant events and Services. Any information you provide about emergency contacts, dietary preferences, or accessibility requirements is used solely for your safety and health purposes.
- Aggregate, De-identified Data. We aggregate and de-identify data collected through our Services and use it for purposes such as creating and publishing reports about the use of our Services, including users’ interests, usage patterns, and borrowing and loan origination trends.
- Other Uses of Your Information. We also use your information to detect, investigate, and prevent fraudulent transactions and other illegal activities, manage the security of our Services, diagnose technical problems, and comply with legal obligations. Please note that there may be other uses for certain information of yours, which we would describe to you when we collect the information.
HOW WE SHARE INFORMATION
- With Service Providers. When we engage a service provider to help us provide and support our Services, we may need to give them access to the information reasonably necessary for them to provide their service. We allow them to use the information only to perform the service we have contracted them to perform. Further, we vet all service providers carefully and address the safeguarding and proper use of your information in our service provider contracts.
- With Our Customers. Any transactional information collected by our customers through the Company’s Services may be available to their customer account administrators or other customer account managers, and may, at the direction of our customers, be shared with third parties as necessary for our customers’ loan origination and management purposes. The Company’s customers may use certain information they collect through our Services for marketing or promotional communications, subject to any appropriate or necessary consents and their own privacy policies.
- In Aggregated, De-Identified Form. We may make certain aggregated, de-identified non-personal information that cannot reasonably be used to identify you publicly available to available to third parties for various purposes, including (i) for compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, usage patterns, and borrowing and loan origination trends.
- With Experience Conference Exhibitors and Sponsors. We may share your information, namely your name, job title, company, and email and physical addresses with certain exhibitors and sponsors of our Experience Conference. If you are a California resident, you may decline from the sharing of your information for this purpose at the time you register for the event or in your Experience Conference registration preferences by selecting the “Do Not Sell My Personal Information” button. Under some state laws, this disclosure may be considered a “sale” of information. Except for this limited instance associated with the Company’s annual user conference, we do not sell any of your information.
- Compliance with Laws and Law Enforcement; Protection of Our Rights. We may disclose your information (including your personal information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of our Websites or Services, (d) to protect the property, rights, and safety of the Company, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third party claims or allegations.
- Subject to Consent. We may share your information in other ways if you have asked us to do so or have given consent. For example, with your consent, we post user testimonials that may identify you.
INFORMATION FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”) took effect on January 1, 2020. The CCPA grants new rights to California residents regarding their personal information, including:
- The right to know what categories and specific pieces of personal information have been collected, used, shared or sold (if any);
- The right to know the purposes for which the information is used;
- The right to delete personal information, where not excepted by law; and
- The right to opt-out of the sale of their personal information.
OUR POLICY CONCERNING CHILDREN
Our Websites and Services relate to the U.S. real estate market and are intended for use by adults ages 18 or older. We do not knowingly collect any personal information from minors and minors should not use our Websites or our Services at any time.
PRIVACY POLICIES OF LINKED SITES
Our Websites and Services may contain links to other websites. We are not responsible for the privacy practices or the content of such sites and third parties. If you have any questions about what information these other sites and third parties collect, how they use it, and with whom they share it, you should contact them directly.
HOW TO ACCESS AND UPDATE YOUR INFORMATION
You can access and update the information that you have provided to us as follows:
- You may contact us at firstname.lastname@example.org and request to review, amend or delete your personal information collected by us through the Websites, email, or telephone sales contacts if you have not chosen to obtain services from the Company.
- If you have an Encompass account, you can review and make changes to certain personal information, company information, and other data within the “Settings” menu of Encompass. We require that you keep your contact information current and accurate.
- For certain information we collect, including account information, we may provide you with the opportunity to delete this information from our records. Please note that not all information we collect or that is created through our Services may be deleted.
- You may opt-out of receiving marketing emails at any time by following the steps to “unsubscribe” described in the footer of our marketing emails or by adjusting your preferences in our Subscription Center. Your opt-out will become effective in 10 days or less.
- If you are a customer and choose to terminate your relationship with the Company, you may be permitted under your agreement with the Company to obtain a copy of the data in your account. Please refer to the terms of your license agreement with the Company for further information.
ICE Mortgage Technology, Inc.
4420 Rosewood Dr., Suite 500
Pleasanton, CA 94588
Attn: Legal Department