Interactive Mortgage Privacy Policy

Last Updated: January 8, 2021

This Privacy Policy explains the practices of Winnpointe Corporation dba Interactive Mortgage (hereinafter referred to as “Interactive Mortgage”, “Company,” “we,” or “us”) with respect to how we collect, use, disclose and secure information in connection with the Interactive Mortgage website at www.interactivemortgage.com (“Website”) and Interactive Mortgage’s lending and social networking service or related services (“Service”).

We may change this Privacy Policy at any time in our sole discretion by posting all changes to this Policy on this page and will indicate at the top of the page the modified Policy’s effective date. If we make any material changes to this Privacy Policy, we will notify you by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Collecting Your Information

We may collect information about you when conducting our business, including when you contact us, seek information from us, or use our website. The information that we collect may include, but is not limited to:

- Your name, address and other contact details;

- social security, driver’s license, or tax identification number;

- account information, assets, transaction and/or income information, materials necessary to verify personal information (e.g., copies of passports or utility bills);

- demographic information, such as age, gender, date of birth, nationality, place of birth, and other information (including potentially sensitive information) that may be derived from the information and documentation that we collect; and,

- website usage and device information, such as browser type, operating system, referring or exit web pages, and the Internet Protocol (IP) address of your computer.

We may supplement the personal information you submit to us with information from third-party sources. For example, if permitted under applicable law, we may supplement your information with address standardization data to verify the address you have entered is actually your address.

When you visit the Website or use our Service, we (or our service providers) may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include the type of device you use, operating system, the device identifier (or "UDID"), your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our Website, and other available information. We may also collect information about your use and interaction with the Website, our mobile application, or our Service. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account.

Tracking, Use of Cookies, Web Beacons and Similar Tracking Devices

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Website. We do not link the information we store in cookies to any personally identifiable information you submit while on the Website.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” menu.

We employ (and/or our third-party advertising partner employs) a software technology called clear gifs (sometimes known as web beacons or web bugs), that help us better manage content on the Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Most browsers are initially set to accept cookies and similar devices. You can set your browser to notify you when you receive a cookie or similar device, giving you the chance to decide whether or not to accept it. (For some web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies or similar devices will probably not be able to access those pages or the related products and services.)

Information from Minors

This website is not intended for use by minors under the age of 16. We do not intend to collect personal information from children under 16 years of age. If we learn that we have collected this information from a child under the age of 16, we will promptly take all reasonable steps to delete the data from our system.

Using Your Information

We may use the information we collect for the following purposes:

- Legal and everyday business purposes: Your personal information may be used to provide the Service, administering the relationship between us (including communications and reporting), monitoring and analyzing our activities. Your personal information may also be processed to comply with our policies and applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, compliance, or responding to subpoenas, court orders or other requests for information from regulatory, supervisory, law enforcement or judicial agencies).

- For marketing purposes: We may use information that we collect to market products and services that may be of interest to you.

- To protect our interests: To protect the rights and property of Interactive Mortgage and others, including to enforce our agreements, policies, and any applicable terms and conditions.

- With your authorization or for other purposes permitted by law: Your personal information may be shared with or processed by certain persons with your consent, upon your instruction, or for any purposes permitted by applicable law.

We may aggregate and/or de-identify the data we collect so that we are no longer able to personally identify an individual. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including our business partners and other third parties.

If you are a current Interactive Mortgage customer, please see our Financial Privacy Notice for a comprehensive explanation of how we collect, use and share your personal information and what you can do to limit the use and sharing of your information.

Sharing Your Information

We may share the information we collect with the following parties:

- With vendors and service providers who perform functions on our behalf, who may only use the information as is reasonably necessary to carry out their work on our behalf or comply with applicable law.

- With affiliates and as part of joint marketing campaigns with other financial companies, to the extent permitted by law.

- With third parties as necessary, in our sole discretion, to protect the rights and property of Interactive Mortgage and others, including to enforce our agreements, policies, and any applicable terms and conditions.

- As required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

In addition to the sharing described in this Privacy Policy, we may share your information with third parties whenever you consent to or direct such sharing, or as otherwise permitted by applicable law.

Personal information may be disclosed or transferred to our affiliates and as part of, or during negotiations of, a merger, consolidation, sale of company assets or equity, financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Interactive Mortgage.

Protecting Your Information

We maintain administrative, technical and physical safeguards designed to protect the security, confidentiality and integrity of your personal information. However, no information transmitted over the internet is 100% secure. To protect the confidentiality of such personal information, you should not divulge your password to anyone. You are responsible for all uses of the Website and Service by any person using your customer ID and password. Please advise us immediately if you believe your password has been compromised. Please note that any information you submit by email may not be secure, so please do not send any sensitive information or materials in or attached to any email to Interactive Mortgage. Interactive Mortgage will never request that you submit sensitive information over email; please report any such requests purporting to originate from Interactive Mortgage to us at info@interactivemortgage.com.

Third Party Websites

The Website may contain links to other websites that we believe may be of convenience to you. For example, Interactive Mortgage may have relationships with various service providers whose services are available to you from the Website, from websites that are linked to the Website, or in connection with the Service. The privacy policy applicable to that website, and not this Privacy Policy, will govern the collection, use, disclosure and security of information collected through those third party websites.

Please note that any information, photos, contact information, email addresses, videos, and other content you post to your social networking profile or to any public bulletin board, blog, chat room or other forum is available to all persons accessing that location. Information shared on those websites be available to all persons accessing these venues, and such information may be read, collected or used by others for any purpose, including sending you unsolicited messages.

Choices Regarding Your Information

You may use this CCPA Request Form to make requests regarding Interactive Mortgage’s use of information about you.

Notice Concerning Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. At this time, we do not recognize or respond to DNT signals. You can learn more about Do Not Track here.

California Collection Notice

If you are a California resident, California law requires us to provide you with some additional information regarding how Interactive Mortgage collects, uses, and shares your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Please note the CCPA’s scope excludes personal information covered by certain financial services-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA) and California Financial Information Privacy Act (FIPA). Our separate Financial Privacy Notice that is provided to investors applies to this excluded data and has been provided to our fund investors.

Depending on how you interact with our website and services, we may collect the following categories of information from you, in addition to the information we collect in connection with providing financial products and services:

- Identifiers (such as your name and contact information, IP address, and mobile device identifiers);

- Internet usage information (such as browsing history and use and interaction with our website).

This information is used and disclosed for the various business purposes and to the categories of third parties described in the “How We Use and Share Information” section of the privacy notice, above.

Your California Privacy Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

- Provide you with the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom     we shared personal information.

- Provide you with access to and/or a copy of certain personal information we hold about you.

- Delete certain personal information we have collected from you.

You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we may need certain information to provide services to you or for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use some of our services.

Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us through our CCPA Request Form  or by sending us an email at info@interactivemortgage.com. You may need to provide additional information to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or power of attorney, signed by you, for the agent to act on your behalf. You must email this authorization to info@interactivemortgage.com. You will still need to verify your identity directly with us.

Additional Information for California Residents

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months. We do share certain information and allow parties to collect certain information about your activity, for example through cookies, as explained in the Sharing Your Information and the Tracking, Use of Cookies, Web Beacons and Similar Tracking Devices sections.

Contacting Interactive Mortgage

If you have questions regarding our Privacy Policy or if you believe that Interactive Mortgage has not complied with this Privacy Policy with respect to your personal information, please contact us at info@interactivemortgage.com. If you are reporting non compliance with this Privacy Policy, in your e-mail or letter, please describe in as much detail as possible (but without disclosing any sensitive information about you or third parties) the ways in which you believe that the Privacy Policy has not been complied with.