Online Privacy Policy

Depending on the relationship we have with you, in the last 12 months we may have disclosed the following categories of personal information in ways that could be broadly deemed a “sale” for purposes of the CCPA: (i) Identifiers; (ii) Categories of personal information described in Cal. Civ. Code Section 1798.80(e); (iii) Protected classification characteristics under California or federal law; (iv) Biometric information; (v) Internet or other similar network activity; (vi) Geolocation data; (vii)Sensory data; and (viii) sensitive information.

Depending on the relationship we have with you, in the last 12 months we may have “shared” the following categories of personal information for purposes of cross-context behavioral advertising: ) Identifiers; (ii) Categories of personal information described in Cal. Civ. Code Section 1798.80(e); (iii) Protected classification characteristics under California or federal law; (iv) Biometric information; (v) Internet or other similar network activity; (vi) Geolocation data; (vii)Sensory data; and (viii) sensitive information.

In the preceding twelve (12) months, we have disclosed the following categories of personal information to the third parties listed above for a business purpose:

• ■Category A: Identifiers.
• ■Category B: California Customer Records personal information categories.
• ■Category C: Protected Classifications
• ■Category E: Biometric Information
• ■Category F: Internet or other similar network activity.
• ■Category G: Geolocation data.
• ■Category H: Sensory data
• ■Category L: Sensitive Personal Information

We collect the above information through the following means and technologies:

1. Contacting Reserve My Loan. You can contact us with questions or comments. In order to communicate with us, you must provide certain Personal Information. By communicating with us for these purposes, you may provide us with your email address and other Personal Information. In these instances, we use any information you provide to us for the purposes for which you submit the information.
2. Questionnaires, Quizzes, and Surveys. We may allow you to participate in surveys, quizzes, questionnaires, and other information-gathering mechanisms, which we may post on the Website or otherwise provide to you from time to time. You are free to choose whether you participate in any such survey, quiz, or questionnaire. We may ask that, in addition to providing your responses, you also provide Personal Information. In these instances, we use any information that you provide to us for the purposes for which you submit the information. We may also add your Personal Information to your customer profile, as well as for advertising and marketing purposes. Survey, quiz, and questionnaire information may be used for the purposes of monitoring or improving our Business. As further set out in Section 13 (Your Choices Regarding Your Personal Information; Opting Out), please understand that you will not be allowed to “opt out” of formal notices related to our Business, such as the operation of the Website, and legal, and other related notices concerning your relationship with us.
3. Newsletters. You may choose to sign up to receive optional communications from us. In addition, if you have previously provided us with your email address, then we may choose to send news, bulletins, marketing materials, or other information to you. We will use Personal Information to determine which communications may interest you, and to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 13 (Your Choices Regarding Your Personal Information; Opting Out).
4. Submitted Content. As further set out below, we may provide you with the ability to submit content to us for our internal use or to submit content to us for public consumption (collectively, “Submitted Content”). If you include any Personal Information relating to others in your Submitted Content, then you represent that you have full permission and authority to do so.
5. Submitted Content Provided to Us for Internal Use. We may provide you with the ability to submit Submitted Content to us (either directly or through a third-party service), and we may also provide content to you, in order for us to better provide Services. For example, we may allow you to provide us with feedback related to our Business. If you provide us with such Submitted Content, we will protect it in accordance with this Privacy Policy.
6. Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your computer or mobile device from a website or a mobile application and stored on your hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website or a mobile application upon future visits. We may include cookies on our Website, and use them for a variety of purposes, such as to recognize you when you return to our Website and to remember your preferences. You may set your browser or mobile device so that it does not accept cookies. Cookies may need to be enabled, however, if you wish to access certain personalized features of the Website.
7. IP Addresses; Logs. We may automatically receive and record information in our server logs from your browser or mobile device, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser or mobile device operating system, referrer addresses, and other generally accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes.
8. Tags. We may use so-called “pixel tags” – small graphic images (also known as “web beacons” or “single-pixel gifs”) – to tell us what parts of our Website have been visited or to measure the effectiveness of searches you perform on our Website. Pixel tags also enable us to send email messages in a format that you can read and they inform us whether emails have been opened. Pixel tags also help us ensure that our messages are of interest to you.
9. Click-Throughs. We may send email messages, which use a “click-through URL” linked to content related to our Business. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We may track this click-through data to help determine interest in particular topics and to measure the effectiveness of our customer communications.
10. Configuration. In order to determine whether your computer or mobile device is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, the presence of any software that our Website may require to operate with your computer or mobile device, or other third-party software on your computer or mobile device.
11. Other Uses. In addition to the uses specifically identified in this Section 9 (How We Collect this Information), there may be instances where you request information or other Services from us that are not described in this Privacy Policy. In that instance, we will use Personal Information that you submit in order to provide such information or Services to you.
12. Provision of Personal Information Offline. We may ask you to provide us with Personal Information when you speak with us on the phone, or otherwise interact with us offline (“Offline Personal Information”). If you provide Offline Personal Information to us, we will strive to provide you with either verbal and/or written notice of this Privacy Policy so that you can review it. For the avoidance of doubt, we treat any Offline Personal Information that you provide to us as Personal Information under this Privacy Policy.

We use the information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with the terms of this Privacy Policy. More specifically, we use the information we collect for the following purposes:

• ■To provide you with the Services you request and to communicate with you regarding our Services;
• ■To use, and to allow you to provide us with, Submitted Content.
• ■To respond to your inquiries;
• ■To customize and enhance your use of our Website, such as by personalizing your experience with us;
• ■To provide communications that might interest you, including marketing messages and to inform you of services that we think would be appealing to you, whether the services are provided by us or by others, and whether the services are available via us or a third party;
• ■To perform analytics, quality control, market research, and to determine the effectiveness of our Services and promotional campaigns, to improve our current Services, and Website, and develop new services;
• ■To perform internal administration, auditing, operation, and troubleshooting; and
• ■To disclose the information to third parties as permitted or in accordance with your consent.

In addition to the uses specifically identified above, there may be instances where you request information and Services from us that are not described in this Privacy Policy. In our discretion, we can use information that you submit in order to provide such information and Services.

We may also use the information that we collect as we believe to be necessary or appropriate for certain essential purposes, including:

• ■To comply with applicable law and legal process;
• ■To respond to requests from public and government authorities, including public and government authorities;
• ■To detect, prevent, or investigate potential security incidents or fraud;
• ■To facilitate the functionality of our Website;
• ■To enforce our terms and conditions;
• ■To protect our operations;
• ■To protect our rights, privacy, safety or property, security and/or that of you or others; and
• ■To allow us to pursue available remedies or limit the damages that we may sustain.

We value your privacy, and we disclose the information we collect only in the manner set out below

1. Marketing. Subject to your communications choices explained herein, we may use your Personal Information to send you marketing communications. Company may also share your Personal Information with third parties for their own direct marketing purposes, including in connection with Corporate Transactions (defined below) absent your consent (which may be by means of the third-party interactions described herein). This information gathering, and the subsequent transfer of information that could occur between or among contracted parties could be considered the “transfer,” “sale,” or “sharing” of information as defined under the CCPA and similar state analogues.
2. Your Disclosure or Consent. As more fully described herein, your activities on the Service may, by their nature, result in the sharing of your Personal Information with third parties and by engaging in these activities you consent to that sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not the Company.
3. Our Service Providers. We may engage certain Service Providers to perform functions on our or their behalf. These functions may include, without limitation, maintaining our Website, collecting information, responding to and sending email or other messages, data analysis, and other functions useful and critical to our Business. In this capacity, we may provide Service Providers with Personal Information, Online Activity Information, and Anonymous Information as applicable. We will seek to only provide our Service Providers, if any, with the bare minimum of information necessary to perform their required functions.
4. Legal Process. We will reveal your Personal Information only to the extent we reasonably believe that we are required to do so by applicable law.
5. Corporate Transactions. We shall be entitled to transfer information that we collect (including Personal Information) to a third party in connection with or in contemplation of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personal Information with protections that are compatible with those set out in this Privacy Policy.

We may also participate in advertising to keep the public apprised of our Services and associated content. As further set out below, we may use the information you shared with us to provide you with advertising or promotions based on your interaction with our Business.

1. Use of Anonymous Data for Advertising. Like many companies, we may utilize targeted banners and ads and may display these to you when you are on other websites and mobile applications. We do this using a variety of digital marketing networks and ad exchanges in addition to using a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks. The banners and ads that you may see displayed will be based on information we hold about you, such as your previous use of our Website. This may include your search history on our Website, the content you read on our Website, or banners or ads you have previously clicked.
2. Advertisers Use of Anonymous Data for Advertising. Additionally, we may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages. These ads may be provided, in some cases, by a third-party ad service provider or advertiser (collectively, “Advertisers”). Additionally, Advertisers may place or utilize their own cookies on your browser and may use Anonymous Information about your visit to our Website. If an Advertiser requests that you provide Personal Information to it or otherwise accept its cookie on your browser, please be aware that the Advertiser’s use and collection of this information and use of any cookies will be governed by its privacy policy or other relevant agreement, and not our Privacy Policy. We recommend that you review the Advertiser’s privacy policy before providing Personal Information. You may choose not to receive targeted advertising from certain ad networks, data exchanges, marketing analytics, and other service providers as indicated at: http://www.aboutads.info/choices/.

Our Website may include links to third party websites offering services that augment those services offered by us. Those third parties determine their own data handling practices – any information that you submit to third parties is not governed by this Privacy Policy.

We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law.

1. Our Retention of Data. We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you, if any; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
2. Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

1. Unsubscribing to Marketing Communications. If you no longer wish to receive bulletins, updates, or other marketing-related materials from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in the Contact Us section below.
2. Access, Deletion, and Do-Not-Sell Requests. You may have certain rights regarding the information we collect and share with third parties. To exercise those right, please visit our Do-Not-Sell/Data Requests Page.
3. Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your Sensitive Personal Information, if any, as defined under applicable law and we will treat that request as a revocation of your consent for us to collect and process your Sensitive Personal Information and will delete your Sensitive Personal Information (subject to any exemptions available under applicable law).

We will process requests to Limit Use of Sensitive Personal Information within 15 business days subject to any applicable exceptions and extension permitted by law.
You may exercise your Right to Limit Use of Sensitive Personal information by contacting us at privacy@reservemyloan.com You may also designate an authorized agent to act on your behalf as described on the Limit Use of Sensitive Personal Information Request Page.

Specifically, we provide the following rights with respect to your Personal Information:

1. Copies of Personal Information. You may request a copy of the following: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling (if applicable) the Personal Information; (iv) the categories of third parties with whom we share Personal Information; and (v) the specific pieces of Personal Information we have collected about you.
2. Deletion of Personal Information. You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes consistent with the terms under which it was collected.
3. Do-Not-Sell Requests. You may request that we do not share or sell your Personal Information with third parties to be used for purposes not described in this Privacy Policy. The California Consumer Privacy Act refers to this as a “Do Not Sell” request. We only seek to share or otherwise transfer Personal Information with service providers and others described above for purposes identified in this Privacy Policy. Please note, however, that Online Activity Information or Anonymous Information collected by service providers providing pixels or other third-party technologies on our Website could potentially be used by those service providers for their own purposes, some of whom may be able to associate such information with you based on other information they have collected independently (not from us). We will endeavor to block such sharing upon request.
4. Submission of Requests. You can submit any of these requests by e-mailing us at privacy@reservemyloan.com or by visiting the Do-Not-Sell/Data Requests Page. You may authorize another person (your “Agent“) to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it or advise you of an exemption.
5. Response to Requests. Please be advised that we will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable, and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please email us at privacy@reservemyloan.com or contact us as provided in the Contact Us section below.
6. Anonymous Information. We will not delete Anonymous Information from our database other than in the regular course of business, and nothing in this Privacy Policy restricts our use of Anonymous Information.

Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONAL INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 16. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html. If you believe we have inadvertently collected or stored such personal information, please contact us so it can be deleted.

This Privacy Policy must be read in conjunction with our Terms of Use, and the provisions of our Terms of Service are incorporated herein. To the extent the Terms of Use conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

The following provisions of this Section 16 (Notice of Privacy Rights to California Residents) apply if you are a California resident.

1. Shine the Light Law. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.
2. California Consumer Privacy Act. We make the following disclosures regarding the California Consumer Privacy Act:
3. No Financial Incentives. We do not provide a financial incentive or a price or service difference to individuals in exchange for the retention or sale of their Personal Information. We may send offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. We do not offer financial incentives to deter consumers from making such requests and will not discriminate against any consumer for exercising their privacy rights, including those provided by applicable law.

We will endeavor to report consumer request metrics when they become available.

If you have any questions about our privacy practices, including in connection with the California Consumer Privacy Act, please email us at privacy@reservemyloan.com or contact us as provided in the Contact Us section below.

If you have a suggestion on how we can improve our Services or complaints you would like us to address, please contact by email us at privacy@reservemyloan.com or contact us as provided in the Contact Us section below. If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.

From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in applicable law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Website and/or notifying you of the change via the Website, email, or other methods. Your continued use following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy. If you do not agree with any changes to our Privacy Policy, please contact us using the information set forth in the Contact Us section below.

If you have any questions about this Privacy Policy or your dealings with us, please contact us at privacy@reservemyloan.com or write to us at:

Reserve My Loan Mgmt, LLC
251 Little Falls Drive, Wilmington, DE 19808

PLEASE PRINT AND RETAIN A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS.