Effective date: 2018/11/08
What Information does Homium collect?
Information You Provide to Us:
We receive and store any information you knowingly provide to us. Certain information may be required to register with us or to take advantage of some of our features. For example, through the registration process, uploads of documents, and/or through your account settings, we may collect the following Personal Information of the borrower/loan applicant, Investor/Market Maker, Lender/Originator, Escrow/Closing Agent or Trust/Homium Mutual Benefit Corporation
- full legal name,
- business or personal address
- email address,
- phone number,
- proof of identity (e.g., driver’s license, passport, or government-issued identity card),
- U.S. Social Security Number or other government identification number,
- bank account details and/or credit card numbers,
- other personal, commercial and/or taxpayer or government identification information (e.g., whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various know your customer (“KYC”) or anti-money laundering (“AML”) obligations, such as under the U.S. Bank Secrecy Act (“BSA”)), and
- association licenses such as real estate licenses
Because our Services may interact with the blockchain, the following information may be published on the Ethereum blockchain as part of a completed smart contract transaction:
- zip code of the property of the loan,
- Amount of the loan,
- Home appraised value at the time of loan,
- Combined loan to value,
- Loan identification number within both the Homium and third party’s database,
- Originator’s license number
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by contacting us at [firstname.lastname@example.org].
Information Collected Automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Cookies: “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. Our advertising partners may also transmit cookies to your browser or device, when you click on ads that appear on the Services. Also, if you click on a link to a third party website or service, a third party may also transmit cookies to you. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our website or Services. We’ve provided a quick summary of some of the cookie types we and our service providers use on the Services, but for more information about cookies, visit http://www.allaboutcookies.org/.
- Essential Cookies: Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Services. Disabling these cookies will make certain features and services unavailable.
- Functional Cookies: Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies: Performance/analytical cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the website, what pages visitors view on our website and how long visitors are viewing pages on the website. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Service’s content for those who engage with our advertising.
- Retargeting/Advertising Cookies: Retargeting/advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Information Collected From Other Websites and Do Not Track Policy
Will Company Share Any of the Personal Information it Receives?
We may share your Personal Information with third parties as described in this below:
Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, other than information on the blockchain (please see section “What about my privacy when I use digital assets and blockchains?” below), we never disclose de-identified information to a partner in a manner that would identify you as an individual.
Service Providers: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use cryptocurrency wallet services to enable users to store, send and receive digital currency, exchange services to fill orders to buy, sell or exchange digital currency, blockchain services to conduct, manage and confirm financial transactions, custodians for digital assets to facilitate custody and movement of digital currency assets, banks and escrow agents to custody client funds and facilitate Automated Clearing House transactions, third-party data providers to verify and calculate the value of real property, cyber security services to perform audits, multi-factor authentication services to help provide mobile application security, identity verification services to perform know your customer and anti-money laundering checks and to work to prevent fraud, bank Application Programming Interfaces to link bank accounts and provide account and routing information, bank account verification services to confirm your bank account balances prior to approving a transaction, or payment processing companies to receive and process your credit card transactions for us. Unless we tell you differently, our service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
User Profiles and Submissions: Certain user profile information, including your name, location, and any video, document, or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What about my privacy when I use digital assets and blockchains?
Due to the nature of the services, certain information may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data from such networks.
What Personal Information can I access?
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- name and password
- email address
- user profile information, including images and documents you have uploaded to the site
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email@example.com].
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [firstname.lastname@example.org].
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. For example, we may require certain personal information from users because applicable law requires us to collect this information to open an account, add a payment method or execute a transaction.
You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. [You may request deletion of your account by contacting us at email@example.com. Some information may remain in our records after your deletion of such information from your account. Because we are subject to various legal, compliance and reporting obligations, including BSA or national AML requirements, we are required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if necessary to comply with our legal obligations or to resolve disputes. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to [firstname.lastname@example.org], and we will try to resolve your concerns.