I. Unlock Technologies, Inc.
Unlock Technologies, Inc. (“Unlock” or “We” or “Us”) provides real estate finance products to homeowners (“Products”). Our Products allow existing homeowners to tap into the equity of their homes. Additional privacy rights and notices will apply if you are a California resident. See the section below called Your California Privacy Rights for more information about your fights under California law. A different privacy policy applies if you request or receive a financial product or service from or through us. See our GLBA Privacy Notice for more information about how we collect and disclose nonpublic personal information about you and other consumers.
II. Overview
The purpose of this Privacy Policy (“Policy”) is to provide individuals (“You”) with information about how We collect, protect, use, and disclose Your personal information through our website (“Site”). We maintain our Site and provide services through them for your information and communication purposes, as well as for purposes associated with the marketing of our products and services (“Services”). This Policy also explains how we collect personal information that you may provide when you visit, use or interact with us online, and through our ads displayed through online services operated by us or non-affiliated third parties. In addition, this Policy explains how we may use or share personal information collected to provide our Services to you and for advertising purposes.
If you do not agree with our policies and practices, your choice is not to use our Site. By using our Site, you agree to the terms and conditions of this Policy.
Our Sites and Services are intended for use only by United States residents, while located in the United States. If you are not a United States resident, or are located in a country other than the United States, you may not use our Site or request and obtain Services from us through our Site.
This Policy applies to Unlock and to our subsidiary Unlock Partnership Solutions, Inc. We work with third party providers that are contractually obligated to comply with our policies for protecting information. However, if you visit or access one of these third party provider sites or mobile apps, please review the online privacy policies that apply to the third party provider’s site or mobile app to understand the specifics of how your online personal information may be collected, used and shared.
This Policy is in force as of the Effective Date listed above and supersedes all prior versions.
III. Updates to this Policy
We may update this Policy at any time. Any changes to this Policy will be posted at the following link: http://www.unlock.com/legal. We encourage You to review this Policy regularly to ensure that You remain up to date on Our privacy practices. If we change the Policy on this Site and you continue to use it, you agree that your continued use of the Site will mean you have accepted all of the changes described in our updated Policy.
IV. Linking To Other Sites
We may provide links to non-affiliated third parties. If you follow links to any site that is not affiliated with or controlled by Unlock, you should review their privacy and security policies and other terms and conditions, because the policies of those third parties may be different from those that apply to our Site. We do not guarantee and are not responsible for the privacy or security of these third party sites or for the accuracy, completeness, or reliability of information found on those other sites.
V. Children
Our Site is not intended to be used by anyone under the age of eighteen (18) (“Minors”), and we do not knowingly collect and/or use personal information of Minors through Our Site. If you are a parent or guardian and believe that we inadvertently collected personal information of a Minor, without parental consent, please contact us immediately at: hello@unlock.com. We will then delete such information
VI. Information That We Collect through Our Site
We collect personal information from You through Our Site in order to provide You with Our Products.
We collect the following categories of personal information through the Site, which may be collected directly by Us or through other sources:
- First and last name
- A home or other physical address, including street name and name of a city or town
- An e-mail address
- Telephone Number
- Social Security
- IP Address
We collect such personal information through our Site by:
- Information You Provide to Us
- Information Collected Through Technology
- “Cookies”, ”Web Beacons”, ”Pixel Tags”
- Email-based Information Tracking
- Geolocation Data
- Third Party Services
VII. How We Use and Share Your Personal Information which is Collected through Our Site
We use Information collected through our Site to: (i) to operate the Site and provide You with Our Products; (ii) to respond to Your requests and inquiries; (iii) to contact You and to communicate with You about Your use of Our Products; (iv) to notify You about important changes to Our Products, such as updates or revisions to this Privacy Policy, security announcements or other similar messages; (v) to review Site usage and operations and to improve the content and functionality of the Site and Our Products; (vi) to provide You with information and materials about Our Products, including marketing and promotional offers from us, as well as non-affiliated third party sites; (vii) to address problems with Our Products; and (viii) to protect the security or integrity of Our Products and Our business.
Except as otherwise expressly provided in this Privacy Policy, Unlock will only share Your Information: (i) as required or permitted by law or regulation or as We believe in good faith that disclosure of such Information is reasonably necessary to: (1) satisfy any applicable law or regulation, (2) to respond to claims and/or to comply with a judicial proceeding, court order, or legal process served on Us, (3) to protect and defend Our rights or property, and/or the rights or property of Our customers or third parties, as permitted by law, (4) to detect, prevent, or otherwise address fraud, security or technical issues; or (5) to enforce Our Terms of Use; (ii) among our affiliates and subsidiaries; (iii) with Our service providers that conduct various services on Our behalf in order to provide You with Our Products, and those service providers will be permitted to obtain only the Information they need to deliver the service. For example, We may use third party service providers to host the Site or to operate various features available thereon, such as sending and managing email, analyzing data, and providing search results; (iv) to fulfill the purpose for which your personal information is provided; (v) with your consent; (vi) to conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as party of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users and consumers are among the assets transferred; and/or (vii) any other purpose we disclosed when obtaining the personal information.
VIII. How We Protect Your Personal Information
We take securing Your personal information seriously. We use security measures that comply with federal and state laws to protect personal information from unauthorized access and use. We cannot ensure or warrant the security of any Information You transmit to us and You provide all Information via the Site at Your own risk. We will never ask You to send Your password or other sensitive information to us in an email, though We may ask You to enter this type of information on the Site. If You are sharing a computer with anyone You should always log out before leaving a website or service to protect access to Your Information from subsequent users. Unlock routinely conducts information security audits to ensure your data is protected. We maintain oversight of our third party providers in an effort to maintain that personal information remains confidential and secure.
IX. Online Tracking and Cookies
Unlock uses cookies, which are small text files, stored locally on Your computer that help store user preferences. Cookies may be html files, or other technology and other, similar products which track Your use of Our Site when You use Our Products. We collect different types of information through a variety of types of cookies
Necessary Cookies
Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our Website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account to access the content.
Functionality cookies
Functionality cookies let us operate the Website and Services in accordance with the choices you make. For example, we will recognize your username and remember how you customized the Website and Services during future visits.
Analytical cookies
These cookies enable us and third party services to collect aggregated data for statistical purposes on how our visitors use the Website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the Website.
Social media cookies
Third party cookies from social media sites (such as Facebook, Twitter, etc.) let us track social network users when they visit or use the Website and Services, or share content, by using a tagging mechanism provided by those social networks. These cookies are also used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our and social networks’ privacy policies. We will not collect or share any personally identifiable information from the user.
In addition, third parties may collect information about your online activities over time and across different websites when you use Our Site.
Some modern web browsers contain a “Do Not Track” setting. However, there is currently no industry standard regarding the meaning of “Do Not Track” and what, if anything, websites should do in response. As a result, We may not respond to “Do No Track” requests. However, most browsers and mobile devices allow You to change Your settings to provide You with: (i) a notification when/if cookies or other tracking technologies are being used; and (ii) an option to choose whether or not to accept/allow the use of cookies or other tracking technologies. Most browsers also allow You to disable or delete existing cookies or to automatically reject future cookies. Please be advised that disabling cookies may limit your ability to use Our Site.
X. Third party data sharing
Some companies may offer aggregation websites and services that allow you to share data with them to consolidate your account information from different sources, so you can view it in one location or perform actions related to your accounts using their services. To do this, a third party may request you to authorize access to your Unlock account by providing your Unlock username and passcode or by providing your information-sharing consent directly to Unlock. Please be careful about using these third parties and keep the following details in mind if you choose to use these third party service providers: (a) the third party may access, on your behalf, detailed and personally identifiable information about you, about your accounts, transactions, and relationships with us, and about the Services you obtain from and through us; (b) you should use caution and ensure the third party has appropriate policies and practices to protect the privacy and security of any personal information you provide or to which they are gaining access; (C) use of your information by the third party is governed by your agreement with them, not by any agreement you have with us; (d) we are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your username and passcode; (e) if you share your username and passcode or other information about your accounts with others, we will consider your decision to share this information with others to mean that you have authorized any transaction or action that is initiated using the access information you provided; and/or (f) if you decide to revoke the authority you have given to a third party, we strong recommend that you change your passcode to ensure that the third party cannot continue to access your account.
XI. Notices to California Residents
The information in this section only applies to California residents.
A. Your California Privacy Rights
A. Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as Shine the Light Law”), if you are a resident of California, you may request certain information about disclosure of personal information about you during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at (1230 W. Washington St., Suite 310, Tempe, AZ 85288).
If you are a California resident, the California Consumer Privacy Act, as modified by the California Privacy Rights Act (collectively, the “CCPA”, along with subsequent clarifying CCPA legislation, implementing regulations, and other California privacy laws, provides you certain rights and choices regarding how we collect, share, use, and protect your “personal information” as information that identifies, relates, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
We do not disclose “sensitive personal information.”
Exceptions
Certain information that we collect may be exempt from the CCPA because it is considered public information or covered by financial privacy laws, such as the Gramm-Leach Bliley Act, the California Financial Information Privacy Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act, or may be exempt for other legitimate business purposes.
We collect the following categories of “personal information” or “sensitive personal information” for the purposes outlined in this Privacy Policy.
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, employment, employment history, bank account number, or any other financial information.
Some personal information included in this category may overlap with other categories. |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
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| D. Biometric information. | We do not collect biometric information. |
| E. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
| F. Geolocation data. | Physical location or movements. |
| G. Sensory data. | Audio recordings of customer calls. |
| H. Professional or employment-related information. | Current or past job history or performance evaluations. |
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contract that describes the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
You have the right, at any time, to request that your personal information not be sold or shared. We will not sell or share the personal information of anyone we know is under 16 years old.
In the preceding 12 months we have not sold any category of personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right To Correct
The right to correct any inaccurate personal information that is maintained about the consumer.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
- Calling us at 1-800-560-3450
- Emailing us at privacy@unlock.com
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. Your authorized agent may make a request on your behalf after verifying their identity and providing a valid power of attorney given to your authorized agent pursuant to applicable state law where you reside. If you have not provided your authorized agent a power of attorney we may require you or your agent to take additional steps to permitted by law to verify that your request has been authorized, to verify your identity and that of the authorized agent, and that you have given permission to your authorized agent to submit a request on your behalf.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Providing personal identifiers we can match against information we may have collected about you previously
- Confirming your request by email or telephone call to the email address or phone number stated in your request
- Providing government identification
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at privacy@unlock.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
Do Not Sell My Personal Information
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.