Privacy
Policy

Last Updated on September 2nd, 2024

ETHOS Lending, Inc. (“ETHOS”, “we” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at ethoslending.com (“Website”) and online services made available through the Website (“Services”).

Questions; Contacting ETHOS; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at:

User Consent. By submitting Personal Data through our Website and Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy. In addition, by registering for an account and submitting such Personal Data, you represent that any co-borrower agrees to the terms of this Privacy Policy, and that you have the permission of such co-borrower to provide his or her Personal Data as necessary.

International Users. Please note that our Website and Services are provided in the U.S. and intended for U.S. residents. As such, they are governed by U.S. law. If you use our Website or Services, your Personal Data will be subject to U.S. law and processed in the U.S. or in other countries, and you agree to this processing.

Types of Data We Collect. We collect Personal Data and Anonymous Data, as described below. “Personal Data” includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual. When we use the term “Anonymous Data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create Anonymous Data from the Personal Data that we receive about you and other individuals whose Personal Data we collect. Anonymous Data might include analytics information and information collected by us using cookies. We make Personal Data into Anonymous Data by excluding information that makes the data personally identifiable to you.

Information You Provide to Us.

• We may collect Personal Data from you, such as your first and last name, e-mail address, phone number, username and password when you create an account to log in to our network (“Account”). As a borrower, by registering an Account, you can save information such as loan documents for later review and update.
• We also collect other types of Personal Data that you provide to us voluntarily, such as your marital status, social security number, location and value of property related to requested home financing, current and estimated mortgage payments, financial information about your assets and income, employment history, liabilities, credit scores, and other information necessary to perform a credit check, determine loan eligibility, and/or otherwise process loans. We will only use this information to provide the Services to you and as described in the Privacy Policy. You are not required to provide us with this information; however, if you do not provide us with such information, we may not be able to provide you with the Services you request.
• If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
• When you participate in one of our surveys, we may collect additional profile information.
• We may also collect other Personal Data that is not specifically listed here, which will be used in accordance with this Privacy Policy.

Information Collected via Technology.

• To make our Website and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to prevent fraud, analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Website or the Services again, it will recognize you and the information could then be used to provide you with other information appropriate to your interests. In the case of suspicious activity, we may link IP addresses to Personal Data for the purpose of securing and safeguarding that Personal Data.
• Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your special interests and needs. We may also collect details about your interactions with emails that we may send you, including the links on which you click and your interactions with our linked sites.
• We use Google Analytics to help analyze how users use the Website. Google Analytics uses Cookies to collect information such as how often users visit the Website, what pages they visit, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve our Website and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Website, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Information Collected from Third Parties.

• We may receive additional information about you from third party partners, including credit reporting agencies and lenders, and combine it with other information that we have about you.
• If you are listed as a co-borrower on a loan, we may collect information about you from a registered user who has an Account with the Services in order to process the loan.

Use of Your Personal Data

• In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
  • facilitate the creation of and secure your Account on our network;
  • provide improved administration of our Website and Services;
  • perform a credit check through a credit reporting agency and generate a credit profile;
  • provide the Services you request, including identifying borrowers’ (and co-borrowers’) maximum buying power, generating pre-approval letters and loan options, processing loans, and facilitating communications between borrowers and lenders about loan applications;
  • improve the quality of experience when you interact with our Website, and Services;
  • send you a welcome email and/or text message to verify ownership of the e-mail address provided when your Account was created;
  • send you administrative e-mail or text notifications, such as security or support and maintenance advisories;
  • provide you with alerts and updates regarding your loan options and/or loan status; and
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of ETHOS.
• We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial, feedback or comment. If you make any comments on a blog or forum associated with our Website, you should be aware that any Personal Data you submit there can be read, collected or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to submit in these blogs and forums.
• We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Website navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

Third Parties Designated by You. When you use the Services, the Personal Data you provide will be shared with the third parties that you authorize to receive such information. For example, the relevant anonymized information may be shared with various lenders to be matched with loan programs to provide you with options.

Third Party Service Providers. We may provide your Personal Data to (i) third party service providers to provide you with the Services that we offer you through our Website; (ii) credit reporting agencies to perform credit checks, (iii) potential lenders to evaluate your eligibility for pre-approval for a loan, to secure and/or service a loan; and/or (iv) other service providers who assist in qualifying, processing, and closing your loan; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to ETHOS.

Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”) for the purposes set out in this Privacy Policy.

Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), ETHOS may disclose Personal Data if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on ETHOS; (iii) to protect or defend the rights or property of ETHOS or users of the Website or Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Third Party Websites. Our Website may contain links to third party websites or services. When you click on a link to any other website or location, you will leave our Website and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:

Email Communications. We will periodically send you free newsletters and emails that directly promote the use of our Website or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.

Changing or Deleting Your Personal Data. All users may review, update, correct or delete the Personal Data in their Account by contacting us or by editing their settings via the Services. If you completely delete all of your Personal Data, then your Account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Security of Your Personal Data. ETHOS is committed to protecting the security of your Personal Data. We use a variety of advanced security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while ETHOS uses reasonable efforts to protect your Personal Data, ETHOS cannot guarantee its absolute security.

Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here www.ethoslending.com/privacy-policy and we will change the “Last Updated” date above.

California Consumer Privacy Act Privacy Notice. This privacy notice supplements the general privacy policy notice of ETHOS Lending, Inc., dba “ETHOS Lending”, NMLS #1533336, an Equal Housing Lender, licensed by the Department of Real Estate Corporation Mortgage Loan Originator Endorsement, DRE #02103430, which can be found at https://ethoslending.com/privacy-policy/.

This supplemental privacy policy applies solely to consumers who reside in the State of California (“you”). ETHOS Lending adopts this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

The CCPA was passed by the State of California in 2018 and provides California residents with the following rights over their personal information: (a) the right to access, transfer, edit and delete their personal data with a verifiable consumer request; and (b) the ability to opt out of certain data-processing practices. In addition, California residents have the right to: (a) know what information is being collected about them; (b) know if their personal information is sold or disclosed, and to whom; (c) say “no” to the sale of personal information; and (d) equal service and price, even if they exercise their privacy rights under the CCPA.

You should consult this Privacy Policy regularly for any changes.