Privacy Policy

This Privacy Policy (“Policy”) describes the Personal Information collected by or on behalf of Vontive, Inc. (“Company,” “we,” “us,” or “our”) from you and through our websites, including our member portals and any website that links to this Privacy Policy (collectively “Sites”), and how we use, share, and protect that Personal Information. We will modify this Policy to reflect changes we make in our processing of Personal Information, and all such modifications will be effective immediately upon posting to the Sites. 

If you use our Sites, you must comply with our Term of Use (“Terms”) found at https://www.vontive.com/legal/termsofservice

When you or your business contracts with us for the purchase of our products or services, or applies for a loan, the collection, use, and sharing of any information collected is governed by the contracts between Company and you or your business.  Those agreements will control if they conflict with this Policy.

1. Personal Information We Collect

This section describes the categories of Personal Information we collect and the categories of third parties with which we share the Personal Information. 

Prospective Customers: We may collect interest and demographic information for marketing purposes, using third parties who supply information about prospective customers, such as lead buy partners and data brokers.

All Users of the Sites ("Users"): We may collect device, usage, and activity information, as well as non-precise location information for security, system administration, marketing, and improvement purposes, in order to provide the Sites to Users. Data is collected by analytics providers and indirectly by observing Users’ activities and behavior while using the Sites, and may be stored by third-party analytics providers and behavioral advertisers.

Users Whose Activities Express Interest in Our Products or Services: We may collect interest and demographic information for marketing purposes. Data is collected by analytics providers and indirectly by observing Users’ activities and behavior while using the Sites, and may be stored by third-party analytics providers and behavioral advertisers.

Users and Other Individuals Who Apply for a Financial Product or Service, Including a Mortgage: We collect the following information: name and contact information, user-selected credentials (email address and password), business affiliation and information for affiliated business, application information, including purpose of application, guarantor information, residency information, asset information, and liquidity information, financial information, such as bank statements or other banking information, credit information, and identification. We do so to determine your eligibility for the requested financial product or service, to verify your identity and business affiliation, and for customer service and marketing purposes. Data is collected directly from Users, indirectly from agents of individuals seeking to apply for financial products or services on such individuals’ behalf, from third parties that provide information about creditworthiness, and from third parties that verify User-provided information. This information may be shared and verified using third parties that provide and/or compile information about creditworthiness, such as credit bureaus and consumer reporting agencies or verify User-provided information, and other financial institutions with which we work.

Users Who Pay an Appraisal Deposit in Connection With Their Application for a Financial Product or Service: We collect information about the payment transaction to confirm receipt of the deposit from our payment processing partner.

Users Who Provide Feedback or Send Us a Message Using the Sites, Including Users Who Use Our Sites’ Live Chat Features and Users Who Interact With Us on Social Media: Names and contact information, along with the contents of messages may be collected, in order to review, respond, and take responsive action, to improve our business and the Sites, and for marketing purposes. This is collected directly from Users, and shared with the third party providers or live chat capability or applicable social media companies.

Users Who Apply for Employment With Us: We collect the following information: name and contact information, professional qualification information, including work experience, educational credentials, licenses, certifications, and references, work eligibility information, and equal employment information in order to evaluate the application for employment. This information is may be collected directly from Users, from third parties who verify professional qualification information, to the government, for equal opportunity reporting, payroll and benefits administration, and other administration of the employment relationship. This may be shared with third parties who verify professional qualification information.

Live Chat Conversations

‍If you use a chat feature on our Sites, we will collect all text and other data that you submit via that chat feature. If you use a chat feature while signed into your account, we may link the submitted data to your account. The information you share while using the chat feature may be shared with the third parties who provide and operate the live chat.

2. Disclosure of Personal Information

In addition to the sharing with the third parties described in the table above, we may also share your personal information with:  

• Employees and Professional Advisors. We may share Personal Information with our employees and professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.
• Processors/service providers. We share your personal information with third parties that provide services to us. We engage these kinds of third parties with contracts that require them to use your personal information only to deliver the services for which we have engaged the third party, and as required by law. These third parties provide business, professional, administrative, or technical support functions for us, such as payment processing, billing, data storage, quality assurance, and marketing. 
• Legal compliance recipients. We disclose personal information to the courts, the government, law enforcement agencies, litigants, and similar recipients when required by law. 
• Affiliates. We may disclose members’ personal information to our affiliates. 
• Successors. We may disclose personal information associated with a part of our business to a buyer, potential buyer, or other successor to our business.

We also may disclose personal information to third parties with your consent or at your direction.

3. Children's Information

The Sites are not directed at children under 18 years of age. We do not knowingly collect, use, or share Personal Information from children under 18. If a parent or legal guardian learns that their child provided us with Personal Information without their consent, we invite them to contact us so we can delete such Personal Information.

4. Personal Information Security and Retention

We use commercially reasonable technical and organizational appropriate security and encryption for the type of Personal Information processed to help secure Personal Information against loss, misuse, and alteration. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

You understand that no data transmission over the internet or device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee its security, and you provide Personal Information at your own risk.

We retain personal information for as long as necessary for the purposes for which we use it, or longer if required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal information:

• retention periods established under applicable law;  
• industry best practices;
• whether the purpose of processing is reasonably likely to justify further processing;  
• risks to individual privacy in continued processing;  
• applicable data protection impact assessment;  
• information systems design considerations/limitations; and 
• costs associated with continued processing, retention, and deletion.

5. Access from Outside the United States

If you access the Sites from outside the United States, please be aware that Personal Information will be processed in the United States. If we transfer information to the United States, we will do so in accordance with applicable law.

6. Analytics and Advertising Technologies

We use various third-party tools to analyze how Users interact with our Sites and to reach prospective customers.

6.1 Session Replay and User Experience 

We use Session Replay and User Experience Analytics Providers to record and analyze user sessions to improve our platform’s functionality and troubleshoot technical errors.

• Privacy Protections: We have configured these services to automatically mask and exclude sensitive data fields—including Social Security Numbers, passwords, bank account numbers, and other government-issued identifiers —from all recordings. This ensures that our engineering team can analyze user experience without accessing your most sensitive personal information.

6.2 Advertising and Analytics Pixels & Server-Side Integration 

We use industry-standard tools—including browser pixels and server-to-server APIs—to measure the effectiveness of our advertisements and optimize our reach on Digital Advertising and Social Media Platforms.

• Hashed Data Sharing: When you interact with our application or lead forms, we may transmit de-identified (hashed) identifiers—such as your email address, phone number, name, or ZIP code—to our advertising partners. This hashing process protects your plain-text information while allowing these platforms to match your activity with your existing account profile to improve ad relevance and conversion accuracy. This data is only shared with partners who are contractually bound to maintain its confidentiality.
• Cross-Context Advertising: We use these technologies to build audiences and optimize our marketing based on your interactions with our Sites. Certain advertising partners may use first-party cookies to build retargeting audiences from our site visitors.
• Your Options: You can limit this data collection through the privacy and ad settings within your respective third-party accounts. While our Sites do not currently respond to automated browser signals like Global Privacy Control (GPC), we provide a manual process to opt-out of the "sharing" of your information for these purposes as described in Section 9.

6.3 Website Traffic Analytics Service Providers

We use Website Traffic Analytics Service Providers to monitor site performance through the use of cookies and similar tracking technologies. This data is used in an aggregated, de-identified manner to understand broad user trends rather than to profile individual borrowers.

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7. Third-Party Websites and Services

The Sites may incorporate, link to, or be linked to third-party websites or services that we do not control. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

Our Blog. If you subscribe to or read our blog, please be advised that our blog is hosted by a third-party provider. Any information collected from you when you visit our blog, and the terms governing your use of the blog, are subject to the third party’s privacy policy and website terms posted on that site.

Online Behavioral Advertising. We use third parties for interest-based behavioral advertising services. These third parties may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including the Sites) over time and across different websites. These advertisements may appear on the Sites and on other websites. These advertisements may also be sent to you via email. In particular, we may use Google Ads to serve ads across various websites. Google collects data about your visits to the Sites to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google,  customize your ad preferences, or  limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Sites.

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Note that changing your settings with individual browsers or ad networks may not carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting out of targeted advertising does not opt you out of all ads, just those targeted to you.

Google Analytics. We use Google Analytics to collect and process information about your use of the Sites. Google uses this information to provide us with reports that we use to better understand and measure how Users interact with our Sites.

We may also implement additional add-on services to Google Analytics, such as:

• Demographics and Interest Reporting, which gathers information such users’ age, gender, and interests based on their purchasing and other online activities. This is done by tracking users across websites and across time.
• Remarketing with Google Analytics, which uses user behaviors on our Sites to help us identify users for our remarketing campaigns.
• Google Display Network Impression Reporting, which provides us information about how often our ads are shown. 

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

Google Maps. The Sites may contain maps provided by Google Maps or other third parties for your convenience. We and these third parties may collect data about how you interact with the maps. For example, Google may collect usage data on maps embedded on the Sites. Even if you do not interact with the maps, Google may still collect certain information about your interactions with our Sites if you are signed into your Google account when accessing our Sites. Please see Google’s Privacy Policy for more information.

Video.  The Sites may contain videos and embedded content provided by Company and other parties, including visible content and/or feeds scripts embedded in the Sites’ code. Company and such other parties may collect data about how you interact with such content. For example, YouTube may collect usage data on videos embedded on the Sites. Even if you do not watch videos, YouTube may still collect certain information about your interactions with our Sites if you are signed into your YouTube account or Google account when accessing our Sites.  YouTube, LLC is owned by Google. Please see Google’s Privacy Policy for more information. 

8. Corrections & Update Your Personal Information

To correct or update your Personal Information as it exists in our records, please contact us using the contact information below in the last Section of this Policy. You may update some of your information within your account.

9. E-mail and Text Messages

If you provide your email address to us, you understand that we may send you emails, including marketing emails. You may opt-out of marketing emails by using the unsubscribe link in the email or contacting us at privacy@vontive.com with “Unsubscribe” in the subject line. Similarly, if you provide your mobile phone number to us, you agree to receive account-related text messages. If you choose to opt in to receiving marketing-related text messages, you may receive such messages. To opt out of text messages, text “STOP” in reply to any such message. To opt out of other communications (e.g., postal marketing and telemarketing), please contact us as set forth below. Opting out of marketing communications does not opt you out of all communications from us, such as account-related communications. Message and data rates may apply to any text messages that you agree to receive.

10. California Residents

This section describes the rights available to California residents under the CCPA. Vontive extends these same rights and protections to all our U.S. customers.

10.1 Information We Collect and Share

In the preceding 12 months, Vontive has collected and disclosed the following categories of information for a business purpose:

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Vontive only uses and discloses Sensitive Personal Information for the specific business purposes necessary to provide our services (e.g., underwriting and identity verification) and does not use such information to infer characteristics about consumers for other purposes.

10.2 Your Rights and Choices

You have the right to request that we disclose what personal information we collect, use, and share, and the right to request the deletion or correction of your personal information. We will use commercially reasonable efforts to correct inaccurate information once verified.

Verification & SLA: To exercise these rights, email privacy@vontive.com. We track all requests via a centralized Jira ticketing system. We will verify your identity (e.g., via account login or secure document upload) and aim to complete verified requests within our internal 96-hour service standard.

Financial Service Exemptions: As a financial services provider, Vontive is exempt from deletion requests regarding information necessary to complete your loan transaction, comply with legal record-keeping obligations (e.g., BSA/AML or state lending laws), or protect against fraud (Civ. Code § 1798.105(d)).

10.3 "Sale" or "Sharing" of Personal Information 

Vontive does not sell your personal information for money. However, we use services that help deliver interest-based ads across third-party platforms to you (see Section 6), which may be considered "sharing" under California law.

How to Opt-Out: You may exercise your right to opt-out of this sharing through any of the following methods:

1. Browser-Based Tools: Adjust the settings within your browser or third-party accounts as described in Section 6.
2. Direct Request: Email privacy@vontive.com with the subject line 'Opt-Out of Sharing'.
3. Toll-Free: Call us at 833-747-3927.

We will process and confirm your request within our 96-hour service standard. We are working to implement technical support for Global Privacy Control (GPC) signals. In the meantime, California residents may submit a manual opt-out request to stop the sharing of their personal information by the email or phone listed above.

10.4 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

11. Contact Us

If you have questions or concerns regarding this Privacy Policy or our processing of Personal Information, or if you wish to make any request to exercise legal rights associated with your Personal Information, contact us at:

Vontive, Inc
Attn. Legal Department
1000 2nd Ave

Suite 2500

Seattle, WA 98104

help@vontive.com

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