1. SCOPE

This Privacy Policy applies to personal information processed by us through our website and web applications, and other online services, including but not limited to our website (https://lenderprice.com/) and our Broker Marketplace web application  and the related product, pricing, eligibility engine web application and website widgets, and all data, content, features, products, and services made available therein by Company (collectively, the “Services”).

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

 A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

• Information You Provide Through Interactions With the Services. We may collect information when you access and use the Services, including in connection with creating an account or registering for the Services. This information may include, without limitation, your full name, title, company affiliation, email address, mailing address, phone number, password, company website or URL, NMLS IDs (individual and company), and any other information you voluntarily choose to provide through use of the Services, including when messaging us through the Services or emailing us. We may also collect personal information about other individuals that you (in your capacity as a mortgage broker for your clients) voluntarily submit through the Services, such as information you submit in connection with receiving lender pricing results and loan availability information for your clients, including client name, FICO score, property type, loan type, property purchase price, loan amount, and loan ID number. You are solely responsible for obtaining all necessary consents and authorizations from your clients to share client data with us and lenders via our Services. We process your client data solely as a service provider to provide you the requested Services and do not sell or use it for any independent purposes. You are solely responsible for complying with all applicable privacy, consumer protection, and financial services laws and regulations related to such client data and for responding to privacy requests from your clients.

• Payments and Financial Information. We may collect certain financial information when you choose to make a purchase or subscribe to a feature or service of ours that requires a fee. To complete such purchase or subscription, you will be required to provide your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and other similar payment data or information (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment processors pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Payment Information in connection with your purchases or subscriptions. By providing your Payment Information, you acknowledge and agree to use of such information by the third-party payment processor for purposes of processing your payment to us.

• Your Communications with Us. We may collect personal information, such as your name, email address, phone number, or mailing address, and content of communications when you request information about our Services, request customer or technical support, or otherwise communicate with us.

• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.

• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

• Social Media Information. We may have pages on social media sites like LinkedIn, Facebook, and X. When you interact with our social media pages, we may collect personal information that you elect to provide to us, such as your contact details.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services.

For example, we may log your geolocation data and internet or other electronic network activity information such as Internet Protocol (IP) addresses, mobile carrier, unique device identifier, device model, operating system type, browser type, browser history, browser language, links clicked, pages you viewed, how long you spent on a page, access times and information about your use of and actions on the Services as follows:

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as our third-party service providers, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

• Cookies. Cookies are small text files placed in device browsers or mobile devices that store preferences, facilitate and enhance your experience, and collect information about site visits, web page traffic, and online behavior.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a small graphic or piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us or our third-party service providers to record, for example, that a user has visited a particular page, clicked a link, and their other online behavior such as mouse and scroll movements and clicks. We may also include web beacons in emails and, where permitted, texts to understand whether messages have been opened, acted on, or forwarded.

Our and our third-party service providers’ uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services and applications and tools that are required to identify irregular website/app behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

• Performance Related. This includes Technologies to assess and improve the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

• Functionality Related. This includes Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

• Analytics. We and our third-party service providers use Technologies and other third-party tools (such as Google Analytics) to process analytics information on our Services and understand how you use our Services. These tools help us evaluate usage of the Services, compile statistical reports on activity, and improve the functionality and user experience of the Services.

• Social Media Platforms. Our Services may contain Technologies and social media buttons or features from social media platforms such as LinkedIn, Facebook, and X (that might include widgets such as the “share this” button or other interactive mini programs). These Technologies and features may collect your IP address, which page you are visiting on our Services, and may set a cookie or other related Technologies to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

 C. Information Collected from Other Sources

We may obtain personal information about you from other sources, including through third-party services and organizations such as social networks you choose to connect with or interact with through our Services, business partners with whom we may jointly be offering products or services, or analytics providers.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services or the products and services of the lenders whose loan products are listed in the Services, as described below.

A. Provide Our Services

We use personal information to provide you with our Services, such as:

• Managing your information and accounts;

• Enabling you to use and providing you with our Services;

• Operating and maintaining the Services;

• Providing access to certain areas, functionalities, and features of our Services;

• Enabling you to communicate with us;

• Processing and verifying your purchases in our Services;

• Answering requests for customer or technical support; and

• Communicating with you about your account, purchases, activities on our Services, and policy changes.

B. Administrative Purposes

We use your personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring and analyzing use of and interest and engagement in our Services;

• Improving, upgrading, or enhancing our Services;

• Developing new products and services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions and other compliance activities;

• Enforcing our agreements and policies; and

• Complying with our legal obligations.

 C. Marketing and Advertising Our and Lenders’ Products and Services

We may use personal information to analyze our user base, products and services, and trends and traffic and to provide you with content and advertisements about our products and services and the products and services of lenders whose loan products are listed in the Services. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include through the Services, email campaigns, and other non-targeted advertising.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below or use unsubscribe links in emails you have received (for opting out of email communications). If you opt out, we may still send you non-marketing communications. Non-marketing communications include, for example, emails about your accounts, purchases, and our other business dealings with you.

D. Other Purposes

We also use personal information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

• De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information or other analyses we create.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We do not sell personal information in exchange for monetary consideration.

We disclose personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share personal information are described below.

• We may share your personal information and the personal information of your clients that you have shared with us with lenders in order to provide the pricing results and loan availability information you have requested for your clients. Lenders use this information to evaluate loan eligibility and may retain such information in accordance with their own privacy policies. You are solely responsible for obtaining all necessary consents and authorizations from your clients to share client data with us and lenders via the Services. We encourage you to review and read the privacy policies of any lenders with whom you choose to engage.

• Service Providers. We may share personal information with our third-party service providers who use that information to help us in operating, providing, improving, or promoting our Services and/or who create, deliver and assess our advertising or marketing campaigns. This includes service providers that provide us with IT support, hosting, cloud services, data security services, database platforms, web analytics, development services, marketing services, payment processing, email, telephone, and other communication software, customer service, and other related services that facilitate our delivery of pricing solutions.

• Business Partners. We may share your personal information to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.

• Social Media. We may share your personal information with social media platforms, such as LinkedIn, Facebook, and X, when you choose to use certain features or tools available on our Services that enable you to connect to a social media account or to share inspiration and other content on social media.

• Affiliates. We may share your personal information with our affiliates.

• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

 B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law, law enforcement, national security requests, and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, personal information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

D. Disclosures With Your Consent

We may share personal information to external parties for other purposes pursuant to your consent or at your direction.

E. Disclosures of De-identified and Aggregated Information.

We may share de-identified and/or aggregated information that does not reasonably identify you or any other individual. This type of information no longer constitutes personal information and may be used or disclosed without restriction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction and grant-related emails regarding Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our legal terms or this Privacy Policy).

• Text Messages. Text messages are only sent for multi-factor authentication purposes for securing your account in the Services.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain browsers and mobile operating systems. Please note that we do not respond to or honor DNT signals or similar mechanisms that automatically communicate your choice not to be tracked online.

• Technologies. You may stop or restrict the placement of certain Technologies on your device or remove them by adjusting your preferences as your browser or device permits or by opting out through our Services or opting out via third parties as otherwise available. However, if you opt-out or adjust your preferences, our Services may not work properly. Please note that with respect to Google Analytics, Google has an opt-out browser add-on available to prohibit sending site activity information to Google Analytics. However, the Google Analytics opt-out browser add-on does not prevent data from being sent to our site. Visit https://tools.google.com/dlpage/gaoptout for more information on how to opt out.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);

• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of your personal information;

• Request Restriction of or Object to our processing of your personal information; and

• Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF PERSONAL INFORMATION

We take steps to ensure that personal information is treated securely and in accordance with this Privacy Policy. We employ industry standard security measures and have taken appropriate administrative, technical, and physical safeguards to protect the personal information you provide to us from unauthorized access, use, disclosure, alteration, or destruction. We also require our third-party service providers and partners to maintain appropriate safeguards.

The safeguards we use include, but are not limited to:

• In-Transit Encryption: We utilize Transport Layer Security (TLS 1.2 or higher) to encrypt data transmitted between our servers and users.

• At-Rest Encryption: We use AES-256 Bit Encryption to protect data stored on our servers.

• Access Controls: Access to personal information is restricted to authorized personnel who need the information to perform their duties. All personnel are subject to confidentiality obligations and follow strict access protocols.

• Ongoing Security Review: We regularly assess the adequacy of our security measures using both internal and external resources.

When we process client data on behalf of brokers, we do so in accordance with the brokers’ instructions and applicable service provider obligations under laws such as the Gramm-Leach-Bliley Act (GLBA), where applicable.

Unfortunately, no system is 100% secure, and we cannot ensure or warrant the absolute security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

This Supplemental California Privacy Notice only applies to our processing of personal information of residents of California under the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”).

The CCPA provide residents of California with the right to know/right to access what categories of personal information Company has collected about them and whether Company disclosed that personal information for a business purpose in the preceding 12 months. Such residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Personal Information” above, respectively.

“Sales” or “Sharing” of Personal Information under CCPA. Company does not “sell” personal information or “share” personal information for cross-contextual behavioral advertising purposes nor do we have actual knowledge of any “sale” or “sharing” of personal information of minors under 16 years of age.

Profiling and Targeting Advertising Under CCPA. Company does not engage in profiling of you in furtherance of decisions that produce legal or similarly significant effects. Company also does not engage in cross-context behavioral advertising as defined under the CCPA.

Additional Rights for California Residents Under CCPA

• Right to Know/Access and Data Portability: The right to request that we disclose to you the personal information we collect, use, or disclose about you, and information about our data practices as well as the right to obtain a copy of your personal information.

• Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.

• Right to Request Deletion: The right to request that we delete any or all of your personal information that we have collected from or about you, subject to certain exceptions. Please note that we may not delete your personal information if it is necessary to:

• • Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Right to Opt-Out of “Sale” or “Sharing” of Personal Information: The right to opt-out of the “sale” or “sharing” of your personal information as those terms are defined under the CCPA. We do not “sell” personal information or “share” personal information for cross-contextual behavioral advertising.

• Right to Opt-Out of Profiling: The right to opt-out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in profiling of you in furtherance of decisions that produce legal or similarly significant effects.

• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

• Rights Relating to Sensitive Personal Information. You may choose to provide us with certain information that is considered “sensitive” under CCPA, including but not limited to, financial account information and login and credentials. We only use or disclose this information as necessary to:

• • provide the Services to you;
  • to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions;
  • to ensure the physical safety of natural persons;
  • for short-term, transient use;
  • to perform services on behalf of the business, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
  • to verify or maintain the quality or safety of our products, and to improve, upgrade, or enhance the products or features offered by the business; and
  • to collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

By providing such information to us, you consent and agree that we may store, process, use, and disclose such information to provide the Services and as set out above or as otherwise allowed by CCPA. We do not process sensitive personal information for the purposes of inferring characteristics about a consumer.

Exercising Your Rights. If you are a resident of California and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent

Appeals. You may have the right to appeal a decision we make relating to requests to exercise your rights under applicable CCPA. To appeal a decision, please send your request to us at the contact information set forth in “Contact Us” below.

Your Other California Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes and the identify of those third parties. Please note that we do not share your personal information with any third parties or affiliates for their direct marketing purposes.

10. CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. We ask that minors (under the age of 18) not download or use the Services.

If you are a parent or guardian and believe your child has provided personal information to our Services without your consent, please contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

11. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you if required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect. We encourage you to periodically review this page for the latest information on our privacy practices.

12. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Cre8tech Labs, Inc. dba Lender Price

33 S. Catalina Ave., Suite 101
Pasadena, CA 91106
Telephone: (626) 486-0171
Email: legal@lenderprice.com
Website Form: https://lenderprice.com/contact-us/