Privacy Policy | Neat Capital

Privacy Policy

Effective Date: June 1, 2016

This Privacy Policy explains the practices of Neat Capital Inc. (“Neat Capital,” “we,” or “us”) regarding the collection, use, and disclosure of information we receive through our website at www.neatcapital.com (“Website”) and in connection with Neat Capital’s mortgage lending service or related services (“Service”). This Privacy Policy applies to personal information we collect from you and from third parties both online and offline. This Privacy Policy does not apply to information that may be collected by any third-party websites, services or applications, even if they are accessible through our Service. When you use our Service, you agree that we may collect, use, and share information as described in this policy. If you do not consent to this policy, then you should not use our Service or provide us with any personal information.

To the extent that this Privacy Policy conflicts with any separate notices we provide you in connection with a mortgage loan, or any separate consent you provide in a promissory note or other mortgage loan document, such separate notice(s) and/or consents control.

Changes in Privacy Policy

This notice describes Neat Capital’s Privacy Policy in effect as of the date indicated above. The current version of our Privacy Policy is always posted on our Website. We reserve the right to change this Privacy Policy at any time. We will provide notice of changes by indicating on the Privacy Policy the new effective date of the Policy. In some situations, we may provide you with advance notice of changes to this Privacy Policy and an opportunity to reject such changes. If you object, the changes will not become effective with respect to your information, but your ability to use our Service may be terminated or impaired.

Collecting Personal information

We may collect personal information about you from you and from third parties. As used in this Privacy Policy, “personal information” means information that specifically identifies you or reasonably could allow someone to identify or contact you. Personal information includes, but is not limited to, your name, address, telephone number, email address, social security number, driver’s license number, payment or identity verification information, financial institution account numbers, and employment information.

Personal information does not include anonymous or aggregated information or other information that cannot reasonably be used to identify you. For example, we may use aggregated data for purposes such as helping us understand trends and user needs to improve our Service. Personal information also does not include demographic information unless it is linked with your personal information. Demographic information is anonymous information, which may include your age, date of birth, income, gender, geographic area, hobbies or interests. We may at times link demographic information with your personal information, such as to customize content or services according to your interests and preferences or to verify your identity. In cases where demographic information is linked with your personal information, such demographic information is also subject to this Privacy Policy.

This section of our Privacy Policy describes the various circumstances under which we collect your personal information.

     ·  Loan Application Process

Neat Capital may collect personal information when you use the Service. When you apply for a loan with us, Neat Capital will ask you to create an account. You will be asked for basic personal information, as well as employment and financial information. You will also be asked to consent to Neat Capital obtaining a credit report, which we will use to help us assess your creditworthiness and your ability to repay a loan. We may collect additional personal information during discussions between you and our mortgage loan professionals. We may also collect information from various third parties to process or underwrite your loan. These third parties may include, for example, credit reporting agencies, employers, attorneys, financial advisors, banks, lenders, other financial institutions, title insurers, insurance companies, data verification services, and software providers. We may also collect personal information when you submit a form indicating interest in the Services or provide feedback to us.

     ·  Visits to the Website

Neat Capital also collects information about people who visit our Website, whether or not they apply to use our Service, as further explained below.

To improve our Service and the Website and provide more convenient, relevant experiences to our customers, we and our vendors may use “cookies” and similar devices to track your activities. A cookie transfers a small amount of data to your browser by servers within the domain and is only read by the server that gave it to you. We may use session cookies and persistent cookies to alert us when you have logged into your account and to tell us when you interact with the account. Session cookies are deleted when you log out from the Service, while persistent cookies remain from session to session. We may also use cookies to monitor aggregate usage, web traffic routing, and to customize and improve our Service.  You may change your browser options to stop accepting cookies. If you do not accept cookies, you may not be able to access some or all of our Service.

We and third-party vendors may use web beacons to track when a web page or email has been viewed, to deliver or communicate with cookies, to monitor visitors to our Service and the effectiveness of our advertising. A web beacon embeds a small transparent gif image in an HTML page or email. A similar analytics function may be used by which a product, service or functionality may send data to a server when a set of user-initiated events occur (such as after clicking a button on the Website or in an email). This function is similar to a cookie because it tracks your visit, and the data is only read by the server that receives the data. It is different than a cookie because it is not browser-based and does not store any data on your computer. While Neat Capital uses cookies and similar devices to track your use of the Website and the Service, such as the number of downloads and how many users we receive daily, and while our web servers automatically log the IP/Internet address of your computer, Neat Capital does not generally use this information to identify you personally. However, if you expressly provide consent for the Website or the Service to “remember” you when you log into your account, we will store that unique identifier on a cookie on your computer and link that unique identifier to your account. As a result, we will track your navigation path around the Website and the Service.

When you access our Website or the Service through a mobile device, we may also collect unique identifiers, caller ID data, location-based data, and similar information. Neat Capital will obtain your consent prior to collecting any location-based information. If you give your consent, we may use your location information to improve and personalize the Service for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

When you use the Website, Neat Capital may also collect certain information about your computer to facilitate and evaluate your use of the Website and the Service. For example, we may log information such as browser type, operating system, referring or exit web pages, the Internet Protocol (IP) address of your computer, pages or features of our Service browsed and the time spent on those pages, links on our Service a user clicked, and other data. We may on occasion supplement the personal information you submit to us with information from third-party sources. For example, if permitted under applicable law, we may supplement your personal information with address standardization data to verify the address you have entered is actually your address.

     ·  Advertisements on Other Websites

We place and track advertisements on third-party websites. Like many advertisers, we advertise our products and services, and we contract with third parties to place advertisements, on websites not affiliated with us where we think the advertisements are likely to be most relevant. Similar to the features on our Website, these advertisements may contain cookies or other mechanisms that allow tracking of your response to our ads. We and our contracted third parties track and report performance of our advertising and marketing campaigns by using cookies, web beacons, and other similar technology, which may be used to collect and store information about user visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site. No personal information is stored during this process.

     ·  Posts on Our Website

Our Website may also provide you the opportunity to post personal information, photographs, videos, and other content, such as to your social networking profile, through messaging functionality on the Website, or to a public bulletin board or blog, chat room or other forum on the Website. If you choose to share your information, your profile may be generally available on the Website. Any content you post to our Website is done at your own risk, and Neat Capital bears no responsibility for any such content or any liability for any claims arising out of such content. You should also be aware that any personal information you use on our blog can be used, read, or collected by other users of the blog and could be used to send you unsolicited messages. We are not responsible for personal information you choose to submit in the blog or any other area of the Website.

     ·  Financial Institution Data

The Service uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant Neat Capital and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

Using Personal Information

In general, we use personal information to determine whether you are qualified to receive a loan from us and at what rate, to inform you about other information and services we think will be of interest to you, to facilitate your use and our administration and operation of the Website and the Service, to learn more about and improve the Website and the Service, and for the purpose for which the information was provided.

We reserve the right to use information collected through cookies, web beacons, and similar tracking technologies for any lawful purpose, including user authentication, to enable security features, to help us detect malicious activity, to understand your communication preferences, to assist you in filling out web-based forms and applications, to advertise on our Website and on third-party websites, to monitor Website and Service performance, and to research products, features and services. We may also engage third-party vendors to engage in any of the foregoing actvities, to track and analyze anonymous or aggregated information from people who visit our Website, and to monitor the effectiveness of our advertising.

Sharing Personal Information

We only share your personal information with unaffiliated third parties as permitted or required by law. We may engage third-party providers to help us administer the Service (including processing, underwriting, closing, servicing, or selling your loan) and to assist us with our business operations. These third parties include, but are not limited to, title companies, appraisers, credit reporting agencies, fraud prevention services, employment verification services, insurance companies, underwriting services, processing services, printing companies, software providers, marketing services and purchasers of loans. When we share your personal information with vendors and service providers who perform functions on our behalf, we require that they keep your information confidential and secure, and that they use it only as reasonably necessary to carry out their work or comply with applicable law. When we sell a loan to a third-party financial institution, we may share your personal information only in relation to the sale and subsequent servicing of your loan.

We may share your personal information with affiliates and as part of joint marketing campaigns with other financial companies. We may also share your information in an aggregated, non-identifying form to comply with government regulatory and licensing requirements, for industry research and analysis, demographic profiling, and similar purposes. In addition, personal information may be disclosed or transferred to to third parties as part of, or during negotiations of, a merger, consolidation, sale of company assets (including by way of bankruptcy) or equity, financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Neat Capital. Finally, Neat Capital also may share your personal information to enforce our legal rights, to stop any activity that we believe may be illegal, unethical, or legally actionable, to respond to legal claims (including subpoenas), and in connection with government inquiries, examinations, enforcement actions, and other efforts by government officials or private parties to enforce and comply with the law.

Opting Out

In certain situations, you may have the opportunity to opt out on Neat Capital’s collection or sharing of personal information. Please note that in such case, you may not be able to access some or all of the features of our Service. If you do not want us to share your personal information with third parties for direct mail marketing, or if you do not want us to send you offers or promotions through direct mail, please send an email to help@neatcapital.com with “Direct Mail Opt-Out” in the subject line. If you do not want to receive emails regarding offers or promotions, please unsubscribe using the instructions provided in such emails. Even if you opt out of certain services, we may still contact you by phone, email, and direct mail as reasonably necessary to provide the Service you have requested.

Protecting your Personal Information

We maintain administrative, physical and technical safeguards designed to protect the security, confidentiality and integrity of your personal information. These safeguards include policies and procedures designed to control access to customer files and security programs and measures including use of passwords, firewalls, and virus detection software. Access to the personal information you provide online in connection with registering yourself as a user of the Website or of the Service is restricted through a password and unique customer ID selected by you. This password is hashed and encrypted. To protect the confidentiality of such personal information, you should not divulge your password to anyone. You are responsible for all uses of the Website and Service by any person using your customer ID and password. Please advise us immediately if you believe your password has been compromised. In addition, your personal information resides on servers or in areas of facilities that only selected Neat Capital personnel and contractors have access to.

We encrypt all data you submit to us through the Website, which reduces the chance that unauthorized parties may view such information during transmission to Neat Capital. Neat Capital diligently investigates and implements new technologies to improve the security of its customer data. PLEASE NOTE THAT NO TRANSMISSION OF INFORMATION OVER THE INTERNET IS COMPLETELY SECURE. NEAT CAPITAL DOES NOT GUARANTY THE SECURITY OR CONFIDENTIALITY OF PERSONAL INFORMATION TRANSMITTED OVER THE INTERNET. WE EXPRESSLY DISCLAIM ANY EXPRESS OR IMPLIED WARRANTIES OR DUTIES TO THAT EFFECT. TO THE EXTENT THAT ANY APPLICABLE LAW IMPOSES ON NEAT CAPITAL A DUTY WITH RESPECT TO TRANSMISSION OF YOUR INFORMATION OVER THE INTERNET, YOU ACKNOWLEDGE AND AGREE THAT NEAT CAPITAL SHALL BE CONSIDERED TO HAVE MET SUCH DUTIES UNLESS WE ENGAGED IN WILLFUL MISCONDUCT. Please also be aware that any information you submit by email may not be secure.

How We Respond to Do Not Track Signals

We do not respond to “do not track” signals or similar mechanisms where a visitor to the Website requests that we disable the collection of information about the visitor’s online activities, including navigation around the Website and the Service. We may also permit third parties to collect information on the Website, and they may also not respond to “do not track” signals.

Personal Information Collected by Third Parties

Personal information that is not collected on the Website or in connection with the Service is not generally subject to this Privacy Policy. The Website may contain links to other websites which may collect personal information. For example, we may have relationships with various service providers whose services are available to you from the Website, from websites that are linked to the Website, or in connection with the Service. Typically, these providers offer services that Neat Capital customers might find useful, such as those you may use in conjunction with Service. Those providers may require you to provide personal information to use their services. In such cases, the privacy policy applicable to that website, and not this Privacy Policy, will govern the collection, use, disclosure and security of your personal information.

Personal Information of Children

We do not intend to collect personal information from children under 13 years of age. If we learn that we have collected this information from a child under the age of 13, we will promptly take all reasonable steps to delete the data from our system.

Contacting Neat Capital

If you have questions regarding our Privacy Policy or if you believe that Neat Capital has not complied with this Privacy Policy with respect to your personal information, please contact us at help@neatcapital.com. If you are reporting noncompliance with this Privacy Policy, in your e-mail or letter, please describe in as much detail as possible (but without disclosing any sensitive information about you or third parties) the ways in which you believe that the Privacy Policy has not been complied with.