Effective Date: March 9, 2022
We may modify this Policy at any time. All changes will be effective immediately upon posting to the Sites. Material changes will be conspicuously posted on the Sites or otherwise communicated to you.
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 you / your business and Company, including any policies provided to you by Company at such time. Those agreements will control if they conflict with this Policy.
If you elect to provide information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you as an individual (“Personal Information”), we will collect, use, and share such Personal Information pursuant to this Policy, contracts we have with you, and applicable law. We may collect the following categories of Personal Information and share them for a Business Purpose:
Identifiers: Examples include: a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Protected Classifications: Examples include: Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, sex (including gender, gender identity, veteran or military status.
Commercial Information: Examples include: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet Activity: Examples include: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Employment Information: Examples include: Professional or employment-related information.
Education Information: Examples include: Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Inferences: Examples include: Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
When you visit our Sites, apply for a mortgage, or otherwise purchase our financial products or services, we may collect the following types of information that you provide to us:
Your Account. In order to apply for a mortgage or purchase certain financial products or services, you must first establish an account with us. To create an account you must provide your name, email address, and create a password. This data is used to populate a profile within your account. Never share your password with anyone.
If you choose to apply for a mortgage within your online account, you must submit your name, home address, credit history, credit score, account balances, transaction history, business information, financing purpose, property type, loan request, available liquidity, U.S. residency status, owned properties, bank statements, additional guarantor information and other similar information requested from you at the time. You may also choose to link your bank account, which we use to evaluate and document your liquidity when reviewing your loan application.
Do not send us the Personal Information of any other person unless you have their consent to do so. When you send us another person's Personal Information, you are promising that you have all rights to do so.
When you open an account, request a loan or receive a loan, additional documentation and policies will apply which are provided to you at such time. Please see such additional documentation to learn more about what information we collect, and how we use and share information pertaining to our financial products and services.
When we receive your job application materials, either directly from you or from our service provider, we will only use and share those job application materials to evaluate your qualifications to work for us and our affiliates.
Marketing Communications; Email Opt-Out. If you provide your email address to us, you understand that we may send you emails, including marketing emails. We may use third-party providers to deliver communications to you. You may opt-out of marketing emails by using the unsubscribe link in the email or contacting us at email@example.com with “Unsubscribe” in the subject line. 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 business communications.
Feedback. When you provide comments or feedback about our Sites, products or services ("Feedback"), we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
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.
Account Activity. We may collect information about how you use (i) your online account, and (ii) the Site when you are logged into your account.
What are cookies and web beacons / pixel tags? A cookie is a small text file that our Sites saves onto your computer or device when you use the Sites that provides us certain information about your activities. Cookies allow the Sites to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
What type of information do Cookies collect? The Cookies on our Sites may collect information such as:
We may combine information from Cookies with other Personal Information.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Sites and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
First and Third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Sites that you are visiting (i.e. these Sites). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We may not have control over how a third-party uses information collected through third-party Cookies.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Sites. Not all features or functions of the Sites may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Sites.
Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.
We may also implement additional add-on services to Google Analytics, such as:
Online Behavioral Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.
To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily 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.
We obtain information about individuals from various third-party companies and public sources and we may combine that data with other Personal Information. This enhances our existing data about our users, improves our ability to contact you, and enhances our marketing capabilities. For example, we may collect information provided by lead buy partners, data brokers and credit bureaus. If your loan officer submits an application on your behalf, we may receive any of the information described in this Policy in order to evaluate your application and credit worthiness, and subsequently service any approved loan.
How We Use Personal Information. We use Personal Information for the following purposes:
As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.
Administration. We use Personal Information for administrative purposes, such as to inform our business strategies and to understand the Sites’ demographics and user preferences.
Sites Management. We use Personal Information for Site management such as troubleshooting problems, auditing, fraud detection, debugging, quality control, to pre-populate information on the Sites, improving the content and functionality of the Sites, statistical and other analyses of the Sites, and to customize the Sites to you and our users.
Advertising and Communications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services or programs, to notify you of new features on our Sites, to notify you of changes to our Terms or this Policy, and for other similar communications.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites.
Mortgage Applications. When you apply for a mortgage or loan through our Sites, we use that information to evaluate your application and liquidity, verify the information you submit and check your credit score. When you provide us your bank account information, we use that information to determine and document your liquidity. Please see your mortgage application documentation and agreements for more information on our use of that information.
We may share Personal Information with the following parties, in compliance with applicable laws:
Employees and Affiliates. We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.
Financial Institutions. We may share mortgage and loan information with financial institutions with whom we do business.
Credit Bureaus and/or Consumer Reporting Agencies. We may share Personal Information with credit bureaus and/or consumer reporting agencies. For example, late payments, missed payments, or other defaults on your account(s) may be reflected in your credit report and/or consumer report.
Third-Parties and/or Service Providers. We may share Personal Information with third parties and/or service providers that provide services for us. For example, we may share Personal Information with vendors to help us host and manage the Sites; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide public relations; provide email services; provide data processing; support or provide the security of the Sites; provide, or help us provide, financial services and due diligence on the loans we consider.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Company or any other party.
Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.
Change in Ownership. In the event Company is the subject of a change of control or in the event the Sites change ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent or prospective owner(s), including with respect to any related due diligence.
Other. We may share Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Company is the sole and exclusive owner of such de-identified and aggregated information, including if Company de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.
Children. The Sites is not directed at children under 13 years of age. We do not knowingly collect, use, or share Personal Information from children under 13. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
We are active on social media, including Medium and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our Social Media pages any comments or content that you post on our Social Media pages.
Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. 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 the security of Personal Information and you provide Personal Information at your own risk.
If you access the Sites from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by other jurisdictions.
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.
If you sign-up to receive text messages from us, we may send you recurring SMS text messages to the mobile phone number(s) you provided, whether manually or using an automated telephone dialing system.
We may send you texts or calls regarding your account, the products and services we provide and other promotional texts. You are not required to consent to receive text messages in order to receive products or services from us and you can opt-out at any time. Regarding text messages, you may text "STOP" to stop and "HELP" for help to the number that sent you such message. Message and data rates may apply.
The terms in this Section only apply if you are a California resident.
In the last 12 months we have not sold your Personal Information and we currently do not sell Personal Information. You have the right to opt-out of the sale of your Personal Information by businesses subject to the CCPA.
Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.
Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by emailing us at firstname.lastname@example.org.
If you have questions or concerns regarding this Policy, contact us at:
Attn. Legal Department
101A Clay St. #101
San Francisco, Ca, 94111