Reali Loans - Security Policy

Effective date: January 1, 2020

Reali, Inc., together with its affiliates, including Reali Loans, Inc., Reali Escrow, A Non-Independent Broker Escrow, and BBYS, LLC (collectively referred to as “Reali,” “we,” “our,” or “us”), provide real estate and financial services for home buyers and sellers (“our customers”).  Our Privacy Notice (“Privacy Notice”) is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you.

SCOPE

This Privacy Notice applies to personal information processed by us in our business, including on our websites, mobile applications (“apps”), and other online and offline offerings (collectively, the “Services”).

By visiting the websites, using or downloading our apps, or otherwise using any of our Services, you agree that your personal information will be handled as described in this Privacy Notice. Your use of our Services, and any dispute over privacy, are subject to this Privacy Notice and our Terms of Service including its applicable limitations on damages and the resolution of disputes. The Reali Terms of Service are incorporated by reference into this Privacy Notice.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with our Services, and the requirements of applicable law.

Information You Provide to Us

Account Creation.  When you create an account with us on our website or mobile apps, we collect information such as your name, email address, phone number, user name, and password.

Loan Application.  When you apply for a loan or request related information such as mortgage rates, we may ask you to create an account and provide proof of your identity.  In this case, we may collect identity information including your phone number, Social Security number, date of birth, address, employment history, employment status, employer, passport details, and driver’s license number.  We may likewise collect financial information such as your household income and expenses, financial account details, payment card information, outstanding debt, mortgage preapproval documentation, and other information related to funding availability.

Property Information.  Through the Services you can submit information about properties you identify, such as properties you view, save, or seek to sell or buy.  In this case, we may collect information including addresses, prices, photos, and other information about the properties. In addition, we may collect information about the appointments you schedule, offers you place, counter or accept, and property notes you make.  We associate the property information with your account.

Your Communications with Us.  We collect personal information from you such as email address, phone number, or mailing address when you request information about or use our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job or otherwise communicate with us.

Interactive Features.  We may offer interactive features related to buying and selling homes.  These features allow you to perform tasks such as calculating your estimated Reali Rebate if you are buying a home, calculating your estimated savings if you are selling a home, utilizing the Reali Price Predictor, finding a home, scheduling a home visit, talking, messaging or scheduling an appointment with one of our licensed real estate, mortgage, or escrow professionals.  We may collect the information you submit or make available through these interactive features.

Our Services may also include features allowing you to provide property details, reviews, comments, pictures, and other publicly-accessible information that we associate with your account.  The Services may additionally include publicly-accessible blogs, forums, social media pages, and private messaging features. By using such features, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.  Any content you provide via these features will be considered “public,” may be available to other users of the Services, and is not subject to the privacy protections referenced herein. By using these features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.

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.

Registration for Sweepstakes or Contests.  We may run sweepstakes and contests.  Contact information you provide may be used to inform you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law.  In some jurisdictions, we are required to publicly share information of winners.

Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

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

Job Applications. We may post job openings and opportunities on the Services.  If you reply to one of these postings by submitting your application, resume and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment.

Information Collected Automatically

Automatic Data Collection.  We may collect certain information automatically when you use the Services.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of  your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services.  Information we collect may be associated with accounts and other devices.

Cookies, Pixel Tags/Web Beacons, and Analytics Information.  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies.  Cookies are small text files placed in device browsers to store their preferences.  Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons.  A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services.  The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  • Analytics.  We may also use Google Analytics and other service providers to collect and process analytics information on our Services.  For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.  You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Information from Other Sources

Third-Party Services and Organizations.  We may obtain information about you from other sources, including through third party services and organizations.  We may collect information about your identity and finances from third parties. For example, we may receive information about you from a third-party identity verification service.  We may also receive information about your funding availability from a third-party financial institution. In addition, if you access our Services through a third-party application, such as a social networking site, third-party login service or other website, we may collect information about you from that third-party that you have made available via your privacy settings or have otherwise consented to disclose. In addition, we may receive information about you from a third-party through which you have expressed interest in buying or selling a home and consented to sharing of your information for that purpose.

Third-Party Property Information.  We may collect information about properties from third parties.  This information may include photos, location, price and sales transaction details, tax records, and appraisals.  This third party property information may relate to properties you identify, and may be associated with your account.

HOW WE USE YOUR INFORMATION

We use your personal information for a variety of business purposes, including to:

Provide the Services or Requested Information, such as:

  • Fulfilling our contract with you, including facilitating real estate and lending transactions and otherwise providing our Services;
  • Evaluating your application for loan pre-approval;
  • Providing services specific to the escrow process;
  • Providing you with tailored content, including location-customized content and other personalized information involving the Services;
  • Managing your information;
  • Processing payment and/or other financial information to facilitate your use of the Services;
  • Responding to questions, comments, and other requests;
  • Providing access to certain areas, functionalities, and features of our Services; and
  • Answering requests for customer or technical support.

Serve Administrative Purposes, such as:

  • Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Measuring interest and engagement in our Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Carrying out audits;
  • Communicating with you about your account, activities on our Services and Privacy Notice changes;
  • Preventing and prosecuting potentially prohibited or illegal activities;
  • Enforcing our agreements; and
  • Complying with our legal obligations.

Marketing Our Products and Services.  We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.  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 as set forth below.

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.

Automated profiling.  We, as well as third parties with whom we interact to provide the Services, may use technologies to engage in automated decision making or profiling.  We will not use these technologies to make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology.  For more information, please contact us as set forth below.

De-identified and Aggregated Information Use.  We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.  De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Share Content with Friends or Colleagues.  Our Services may offer various tools and functionalities.  For example, we may allow you to provide information about your friends through our referral services.  Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

How We Use Automatic Collection Technologies.  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services.  Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related.  We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  • Functionality Related.  We may use 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, interests, or past items viewed;
  • Advertising or Targeting Related.  We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Cross-Device Tracking.  Your browsing activity may be tracked across different websites and different devices or apps.  For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop.  To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

Notice Regarding Third Party Websites, Social Media Platforms and Software Development Kits.  The Services may contain links to other websites, and other websites may reference or link to our website or other Services.  These other websites 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. Visiting these other websites or applications is at your own risk.

Social media buttons such as the Facebook “Like” and “Share This” buttons (other interactive mini-programs) may be on our site.  These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly.  These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the companies providing the features.

We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services.  APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.  For more information about our use of APIs and SDKs, please contact us as set forth below.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Service Providers.  We may share any personal information we collect about you with our third-party service providers.  The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment, loan, and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.

Business Partners.  We may provide personal information to business partners to provide you with a product or service you have requested, to provide you with information in which you may be interested, or for research and analytics purposes.  We may also provide personal information to business partners with whom we jointly offer products or services.

Affiliates.  We may share personal information with our affiliated entities.

Advertising Partners.  Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day).  These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”  If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

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

Disclosure in the Event of Merger, Sale, or Other Asset Transfer.  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, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

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.

YOUR CHOICES

General

You may have the right to object to or opt out of certain uses of your personal information.

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-related emails regarding products or 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 the Services or updates to our Terms or this Privacy Notice).

Mobile Devices

We may send you text messages/SMS and telephone calls in order to respond to you, provide you with information and notices about your account or the Services, and provide you with marketing materials; if you have given us your consent. You can opt out of these text messages, at any time, by replying STOP to any text message from Reali.

We may also send you push notifications through our mobile application.  You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.  With your consent, we may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asphttp://www.youronlinechoices.eu/https://youradchoices.ca/choices/, and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

YOUR PRIVACY RIGHTS

For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.

For a list of the categories of personal information we have collected from consumers in the past 12 months, the categories of sources from which we have collected the personal information, the business or commercial purpose for collecting the personal information, the categories of third parties with whom we share the personal information, and the categories of personal information shared for business purposes, please click here.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law; and (viii) not be discriminated against by us for exercising your privacy rights. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

DATA RETENTION

We store the personal information we receive as described in this Privacy Notice 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.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the 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 the 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 the Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.  If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

CALIFORNIA SHINE THE LIGHT LAW

The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Notice from time to time in our sole discretion.  If there are any material changes to this Privacy Notice, we will notify you as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

Attn: Legal Department

Reali, Inc.

777 Mariners Island Boulevard, Suite 210
San Mateo, CA 94404
1-844-447-3254
legal@reali.com