Third Floor Technology, INC.
PRIVACY POLICY
Last Updated Feb 6, 2022
Welcome to the website (the “Site”) of Third Floor Technology, Inc. (“Third Floor Technology,” “Third Floor,” “we,” “us,” or “our”). Third Floor Technology provides Mortgage-as-a-Service solutions to the mortgage industry (collectively, including the Site [and any related mobile applications], the “Service”).
The Service is directed towards our customers and potential customers. It should not be used for personal, family, or household purposes. We treat all personal information covered by this Privacy Policy as pertaining to individuals acting as business representatives, rather than in their personal capacity.
This Privacy Policy explains what personal information we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any personal information to Third Floor Technology, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.
1. PERSONAL INFORMATION COLLECTION
Personal Information You Provide: We collect the following categories of personal information from you:
- Identification Information: We collect your name, email address, phone number, and mailing/billing addresses.
- Financial Information: Our payment processor(s) will collect the financial information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers.
- Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.
- Commercial Information: We may retain a history of the products you browse and/or purchase using the Service.
- Social Media Information: We maintain a social media presence on platforms like Instagram, Facebook, Tiktok, Twitter, and LinkedIn (“Social Media Pages”). When you interact with us on social media, we may receive personal information that you provide or make available to us based on your settings, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. [We may also receive information from social media platforms if you link your social media accounts with your Third Floor Technology account. The type of information we receive depends on your settings with the relevant platform, but may include things like your handle and followers list.]
Internet Activity Information: When you visit, use, and interact with the Service, the following information may be created and automatically logged in our systems:
- Device Information: The manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the Service. The information we collect may vary based on your device type and settings.
- Usage Information: Information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We use Google Analytics, a web analytics service provided by Google LLC (“Google”) to help collect and analyze Usage Information. For more information on how Google uses this information, click here.]
- Location Information: We may derive a rough estimate of your location from your IP address when you visit the Site.
- Email Open/Click Information: We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
The following technologies may be used to collect Internet Activity Information:
- Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Personal Information We Process on Behalf of Our Customers: In order to provide the Service, we process names and contact information relating to employees and customers on behalf of our customers. We process that data, including any personal information contained within it, pursuant to our agreements with our customers. We have no direct relationship with the individuals whose personal information we process in the course of providing our Service to our customers. If you are such an individual and have questions about the processing of your personal information or want to exercise one of your privacy rights, please contact the customer that you interact with directly.
Derived Information: We may infer your preferences for mortgage services based on the personal information we collect about you.
2. PERSONAL INFORMATION USE
Your personal information is used for the following purposes:
Service Delivery, including to:
- Provide, operate, maintain, secure and improve the Service;
- Create, maintain, and authenticate your account;
- Process transactions through our third party payment processors;
Communicating with You:
- to send you updates about administrative matters such as changes to our terms or policies; and
- provide user support, and respond to your requests, questions and feedback.
Service Improvement, including to:
- improve the Service and create new features;
- personalize your experience; and
- create and derive insights from de-identified and aggregated information.
Marketing and Advertising: We and our advertising partners may use your personal information for marketing and advertising purposes, including:
- Direct Marketing: To send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via postal mail, email, telephone, text message, and other means.
- Interest-Based Advertising: We engage advertising partners, including third party advertising companies and social media companies, to display ads on the Service and other online services. These companies may use cookies and similar technologies to collect information about your interaction over time across the Service, our communications, and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to our or similar users (known as a “lookalike audience”) on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Limit Online Tracking section below.
Compliance and Protection, including to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- Audit our compliance with legal and contractual requirements and internal policies; and
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
3. PERSONAL INFORMATION SHARING
Our Sharing: We do not sell, rent, license, or lease your personal information to third parties. However, in certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:
- Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with service providers, including hosting services, cloud services, and other information technology services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your personal information.
- Professional Advisors: We may share personal information with our professional advisors such as lawyers and accountants where doing so is necessary to facilitate the services they render to us.
- Business Transfers: If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
- Legal Requirements: We do not volunteer your personal information to government authorities or regulators, but we may disclose your personal information where required to do so for the Compliance and Protection purposes described above.
4. PERSONAL INFORMATION RETENTION
We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.
5. NOTICE TO CALIFORNIA RESIDENTS
Where provided for by law and subject to any applicable exceptions, California residents may have the following rights:
- Know. You can request to know the categories of personal information that Third Floor Technology has collected about you, the business purpose for collecting your personal information, the categories of sources from which the personal information was collected, whether Third Floor Technology has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information (we provide this information in the Personal Information Collection, Use, and Sharing sections above);
- Access. You can request access to the specific pieces of personal information that Third Floor Technology has collected about you;
- Delete. You can request that we delete the personal information we collected from you; and
- Opt out. You can instruct businesses that sell your personal information to stop doing so – Third Floor Technology, however, does not sell personal information.
If you would like to exercise any of these rights, or want an alternative form of this Privacy Policy, please contact us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you authorized the agent to submit the request. We will not treat you differently for exercising your rights.
6. CHILDREN
Our Service is not directed to children who are under the age of 16. Third Floor Technology does not knowingly collect personal information from children under the age of 16. If you believe that a child under the age of 16 provided personal information to Third Floor Technology please contact us and we will delete that information.
7. LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by Third Floor Technology, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
8. SECURITY
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information. You use the Service at your own risk.
9. PERSONAL INFORMATION PROCESSING IN THE U.S.
Third Floor Technology is headquartered in the United States. By using our Service, you understand and acknowledge that your personal information will be transferred from your location to our facilities and servers in the United States, where data protection laws may be less protective than those in your jurisdiction.
10. YOUR CHOICES
Update or Correct Personal Information: You can contact us and request any updates or corrections needed to keep your personal information accurate, current, and complete.
Opt Out of Marketing Communications: You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in any marketing communication we send you. Please note, however, that you may continue to receive communications as described in the Communicating with You section after opting out of marketing communications.
Limit Online Tracking: Here are some of the ways you can limit online tracking:
- Block Cookies: Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Use the following links to learn more about how to control cookies and online tracking through your browser:
- Firefox; Chrome; Microsoft Edge; Safari
- Limit the Use of Advertising ID: You may be able to limit use of your mobile device’s advertising ID for interest-based advertising purposes through your device’s settings.
- Use Privacy Plug-Ins or Browsers: You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt out of Google Analytics.
- Advertising Industry Opt-Outs: You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance
- Network Advertising Initiative
- Platform Opt-Outs. The following advertising platforms offer opt-out features that let you opt out of use of your information for interest-based advertising:
- Google opt-out
- LinkedIn opt-out
- Microsoft opt-out
Note that the above opt-out mechanisms are specific to the device or browser on which they are exercised. You will need to opt out on every browser and device that you use.
Do Not Track. We currently do not respond to "Do Not Track" or similar signals. Learn more about "Do Not Track" here.
11. CHANGES TO THE PRIVACY POLICY
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Service or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and the practices described in it.
12. CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@thirdfloor.ai.