Updated: November 1, 2021
This Policy describes how we collect, use, store, protect and disclose Personal Information we obtain from you when you visit the websites that we own or control (today or in the future), including https://getattune.com (collectively, the “Sites”), you use the mobile applications we own or control (today or in the future) (collectively, the “Applications” or “Apps”), and when you use any services we provide through the Sites or the Apps (collectively, with the Sites and the Apps, the “Services”). You can access the Sites in many ways, including from a computer or mobile phone, and this Policy will apply regardless of the means of access. This Policy also governs the use of Personal Information we obtain from you from any third party site or application that you authorize to provide to us Personal Information. Please be aware that ATTUNE cannot control the privacy policies or practices of sites or companies that we do not own or control and cannot control the actions of people we do not employ or manage.
I. Information We Collect
Information We Collect From You
In order to use some of our Services, we ask you to provide certain Personal Information and in some cases require you to register for an account. If you do not provide the Personal Information requested, you may not be able to benefit from our Services if the requested information is necessary to provide you with the applicable Services or we are legally required to collect it.
When you register for an account, we may access and collect the Personal Information you provide, such as your name, contact information (including your mailing and billing addresses), e-mail address, social security number, date of birth, phone number, username and password. We may also collect from you information, which may constitute Personal Information, included in such things as your mortgage statements, tax returns, paystubs, bank statements, work histories, education records, resumes, and any other documents, records or sources of information that you upload to our Services. We may also ask for additional Personal Information including your mobile phone number and your credit or debit card number or other financial account numbers. We will also collect and maintain information about all transactions associated with your accounts.
Some of our Services involve the collection and storage of financial and related information, such as (1) outstanding loans or other financial obligations, financial account balances, payment histories, account activity, and other information that may be contained in statements or other reports relating to your debts and assets, (2) information from consumer reporting agencies and other sources, such as your credit bureau reports, collection agency reports or other communications, and other information relating to your payment histories, creditworthiness, annual income, and/or ability to satisfy your obligations, and (3) your income range. This information will only be collected if applicable to your use of the Services and will be collected, used, stored and/or shared in accordance with this Policy.
When you use some of our Services, you may choose to provide certain information directly to us to request more information about our Services or for other reasons. We will collect, use, store and/or share such information, which may include Personal Information, consistent with this Policy.
Information Collected from Joint Applicants
If you are using the Services with another person to apply jointly for a loan or other financial services product, you and your co-applicant may choose to provide information, including Personal Information, for your application using a single joint account or multiple individual account(s). If joint applicants choose to utilize a single account, they will have access to all information supplied by users of the same account to complete that application, including Personal Information. Such joint applicants will have the ability to view, print, transmit, save, and/or edit the information associated with the joint account, including Personal Information. Access may continue for as long as the joint applicants utilize the joint account.
Information Collected From Third Parties
We may collect your Personal Information from third party affiliates or business partners such as social media sites, ad networks, analytics providers, loan officers, borrowers, real estate agents or insurance agents. If you are a borrower and you have instructed your loan officer, real estate agent or insurance agent not to provide us with Personal Information, you may not be able to use certain features of our Sites or utilize our products or services.
If you are a borrower, we may also collect other information about you from loan officers, real estate agents or insurance agents that utilize our products and services, which does not necessarily constitute Personal Information, including, but not limited to (1) income range, (2) appraised value of your property, (3) statistics about your property, (4) property purchase price, (5) loans you may have, (6) expenses related to your property, (7) information about your use of the Sites, (8) your insurance pertaining to your property, and (9) information related to your credit history.
Information Automatically Collected
When you use our Services, our servers automatically record information that your browser or device sends whenever you visit a website or utilize an application. This information may include your IP address, the type of device you are using, the internet service provider or mobile carrier you are using, your device identifiers, your mobile telephone number, your geographic location and your activities within the Services, including the links you click, the pages or screens you view, your session time, the number of times you click a page/screen or use a feature of the Services, the date and time you click on a page or use a feature and the amount of time you spend on a page or using a feature.
Like many websites, our Sites also use “cookie” technology to collect additional website usage data and to improve the Sites and our Services. A cookie is a small data file that we transfer to your computer’s hard disk. A session cookie enables certain features of the Sites and is deleted from your computer when you disconnect from or leave the Sites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Sites. We may use both session and persistent cookies to better understand how you interact with our Sites, to monitor aggregate usage by our uses and web traffic routing on our Sites, and to improve our Sites and Services. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all of the services or functionalities of the Sites.
We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or after you visit our Sites, the pages or other content you view or otherwise interact with on our Sites and the dates and times that you visit, access or use our Sites. We may also use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on or forwarded a message, to the extent permitted under applicable law.
Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
Information Collected by Third Parties
Links to Other Websites
Sites may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer or mobile device, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third party sites or services to which links or access are provided through our Sites. We encourage you to read the privacy policies or statements of the other websites you visit.
II. How We Use The Information We Collect
We may use the information we collect for non-marketing purposes including: (1) validating your identity; (2) sending you push notifications or e-mails to provide you with alerts and updates about your account and our Services; (3) processing your transactions; (4) conducting statistical or demographic analysis; (5) complying with legal and regulatory requirements; (6) customizing your experience with the Services; (7) protecting and defending ATTUNE and its affiliates against legal actions or claims; (8) preventing fraud; (9) debt collection; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other government agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; (12) improving customer service; (13) providing you the features and functionalities associated with the Services; (14) any other purposes for which we obtain your consent; and (15) for other business purposes permitted under applicable law (collectively, “Non-Marketing Purposes”).
With your advance consent, we may use the Personal Information we collect for our own marketing purposes including notifying you of special promotions, offers and events via push notifications, email and other means, including SMS messaging, subject to compliance with applicable laws. We may also link Personal Information (including your name, mobile phone number, and email address) with non-personal information (including Personal Information automatically collected as described in this Policy) and use such information for our own marketing purposes.
IF YOU PROVIDE A CELL PHONE NUMBER AND EXPRESSLY CONSENT TO RECEIVE SMS MESSAGES FROM ATTUNE, YOU EXPRESSLY CONSENT TO RECEIVING SMS MESSAGES FROM ATTUNE FOR THE PURPOSE FOR WHICH YOU CONSENTED TO RECEIVE MESSAGES. ALTHOUGH THERE IS NO FEE ASSOCIATED WITH THIS SERVICE, YOUR CARRIER MAY CHARGE YOU FOR EACH MESSAGE YOU RECEIVE IN ACCORDANCE WITH YOUR CALLING PLAN. YOU AGREE THAT WE ARE NOT RESPONSIBLE IN ANY WAY FOR SUCH CHARGES. IF YOU DO NOT WISH TO CONTINUE TO RECEIVE ANY SMS MESSAGES VIA YOUR MOBILE DEVICE, YOU MAY OPT-OUT AT ANY TIME BY CONTACTING US AT firstname.lastname@example.orgOR BY TEXTING “STOP” IN RESPONSE TO A SMS MESSAGE YOU RECEIVE FROM ATTUNE. FAILURE TO OPT-OUT CONSTITUTES YOUR CONSENT TO CONTINUE TO RECEIVE THESE SMS MESSAGES UNTIL YOU ELECT TO OPT-OUT.
We may also use information in the aggregate to understand how our users as a group use the Services provided on our Applications. ATTUNE will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes without providing you notice.
III. Who We Share Personal Information With
For business purposes, we may share certain Personal Information we receive from and about you, and about your transactions with us, with our affiliates and certain third parties. Doing so allows us to provide the Services you request. If you are a borrower, we will share your Personal Information to provide you with our Services and with your lender, real estate agent and/or insurance agent. If you are a lender or representative of a lender, we will share your Personal Information, as necessary to provide you or your employer’s anticipated borrowers with our Services, with borrowers, real estate agents and/or insurance agents. Finally, if you are a real estate agent or insurance agent, we will share your Personal Information as necessary to provide your existing or prospective clients with our Services.
We may also share your Personal Information with the following third parties:
Third Party Service Providers
Your Personal Information may be shared with or collected by third party service providers who provide us with services, including, but not limited to, facilitating mailing information and services, data hosting or processing, credit card processing, or processing or fulfilling transactions. We require these third party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.
Referred Service Providers
Data Access Providers
We may provide anonymized information to third parties. Any anonymized information we provide to third parties is not considered Personal Information and is not subject to the terms of this Policy.
Sale of our Business; Bankruptcy
Compliance with Laws and Law Enforcement
ATTUNE cooperates with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect the property and rights of ATTUNE or a third party, to protect ATTUNE against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Services and any equipment used to make the Services available, or to comply with applicable law.
Some of our Services allow you to communicate and collaborate with other users of our Services through the mortgage process. As a result, depending on your use of our Services, we may provide your Personal Information to other users of the Services that you interact with or otherwise authorize us to provide your Personal Information to.
IV. Managing Your Personal Information
You may decline to share certain information with us, in which case, we may not be able to provide you some of the Services we offer. To protect your privacy and security, we reserve the right to take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.
With your advance consent, you may receive mailings or emails from us with news or other information on events, products, services, discounts, special promotions, upcoming events or other offers from us or on our behalf. If at any time you wish to stop receiving emails or mailings from us please send us an email to email@example.com we will remove you from our mailing list.
Alternatively, for email communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth in email messages from us. Your unsubscribe request or email preferences change will be processed promptly, though this process may take several days. During that processing period, you may receive additional emails from us.
Marketing/Joint Marketing Opt-Out
If you wish to opt-out of receiving solicitations from us, or do not want us to share your Personal Information with ATTUNE’s affiliates or partners for marketing purposes, including real estate agents or insurance agents, you may email us at firstname.lastname@example.org.
We will support your ability to access, correct, and delete your Personal Information. If we have obtained your Personal Information from your financial institution or other third party, we may confirm your request through them. For assistance with exercising your choices, or if you have any questions about your choices, please contact us at email@example.com.
ATTUNE is committed to protecting the security of the Personal Information you provide to us and that we collect about you. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information that you provide to us. Our safeguards vary based on the sensitivity of the information that we collect and store. Additionally, our Services are designed to comply with the laws applicable to the highly regulated financial services industry. This includes utilizing practices and measures that are designed to comply with the requirements for safeguarding, using and protecting personal information as set out in laws such as the Gramm-Leach-Bliley Act of 1999 and the Real Estate Settlement Procedures Act.
Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet. Your information may be intercepted without our consent, collected illegally and used by others without your consent. We cannot guarantee the security of any information you disclose online, and you do so at your own risk. We recommend that you change your password periodically. You are responsible for maintaining the security of your account username and password. If you believe that your account username and/or password have been stolen or been made known to others, it is your responsibility to immediately contact us at firstname.lastname@example.org change your password. We are not responsible if someone else accesses your account through information they have obtained from you.
As a matter of security and privacy, any and all access to your account (if any) will automatically be terminated after sixty (60) days of inactivity with respect to your account. All Personal Information stored by ATTUNE with respect to your account will be stored, and may be shared or used, by ATTUNE in accordance with this Policy.
VI. Underage Persons
The Services are for use by persons who are at least 18 years of age. If you are younger than 18, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of Personal Information via the Services from persons underage, pursuant to applicable law and regulations. We do not knowingly collect or allow the collection of Personal Information via the Services from persons under the age of 13. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information, you may contact us at email@example.com ask us to remove your child’s Personal Information from our systems.
VII. International Users
The Sites and Apps are only intended for residents of the United States. If you are not a resident of the United States, please do not provide us with any Personal Information.
VIII. Disclaimer – California and Nevada State Law Privacy Rights
This notice does not apply to employment-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals.
The California Consumer Privacy Act (the “CCPA”) affords those who reside in the State of California certain rights as a data subject. If you are a resident of the State of California, we encourage you to read and learn about those rights on your own, but the following will help you to begin to understand them:
- Access: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information.
- Erasure: In some cases, you may have the right to request that we erase your Personal Information in our possession.
- Data Portability: This allows you to request a copy of your Personal Information that we may have and transfer that information to someone else without any interference from us. In some cases, you may be able to request that we transfer your Personal Information directly to a third party on your behalf. We will verify any third party that purports to represent you prior to providing them a copy of your Personal Information.
- The CCPA further provides California residents the right to direct us not to sell your personal information. WE DO NOT SELL YOUR PERSONAL INFORMATION.
We will not discriminate against you for exercising any of your CCPA rights.
The categories of Personal Information that we collect from California residents are described in Section I, and include identifying, contact, financial, relationship, transactional, and identifiable Internet information. The purposes for which we process Personal Information is described in Section II, above, and include servicing you, our clients, and business partners; overseeing and completing transactions; preparing, delivering, maintaining, and otherwise providing our goods and services; supporting and improving of our goods and services; setting up and maintaining user accounts; providing you with customer service, measuring and understanding the effectiveness of our goods and services, complying with laws and regulations; and communicating offers for goods and services subject to your opportunity to opt out of direct marketing communications or market research inquiries.
In addition, California’s “Shine the Light” law permits you to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.
To make a request regarding any of these rights or to ask questions or provide comments about this Privacy Notice for California Residents, please contact us at firstname.lastname@example.org. You may also call us at [INCLUDE TOLL FREE PHONE NUMBER], or write us at:
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: email@example.com. However, please know we do not sell data triggering that statute’s opt-out requirements.
IX. Changes to this Policy
We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions by placing notice of the revised Policy on our website or any place through which you access the Services. Your continued access or use of the Services following any amendments to the Policy constitutes your acceptance of the Policy as amended. It is your sole responsibility to monitor our website for changes to the Policy.
X. Contact Us