Privacy Policy
Effective date: 2024/02/01
At Homium, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your Personal Information. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of Homium's Services is at all times subject to our Terms of Use, which in corporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Homium’s website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
What does this Privacy Policy cover?
This Privacy Policy covers how we treat Personal Information that we gather when you access or use our Services. “Personal Information” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or“personal data” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage and may not cover certain categories of Personal Information protected by industry-specific privacy laws such as the Gramm-Leach-Bliley Act (the “GLBA”). Privacy notices as required by the GLBA shall be provided separately, such as in your borrower packet.
Personal Information
Categories of Personal Information We Collect
Generally, we only collect the Personal Information about website visitors or marketing leads, investors, lenders, originators, and borrowers. The following charts below detail the categories of Personal Information that we collect and have collected over the past 12 months, based on your interaction with us. Please note that multiple charts may apply to you, depending on your relationship with us:
WEBSITE VISITORS OR MARKETING DATA
If you interact with our Services, visit our website, or otherwise reach out to us, we will collect the following personal data about you:
· Email address
· Phone number
· Advertising Partners
· Business Partners
· Device ID
· Domain server
· Type of device/operating system/browser used to access the Services
· Analytics Partners
· Referring webpage/source through which users accessed the Services
· Statistics associated with the interaction between device or browser and the Services
· Analytics Partners
· Analytics Partners
· First and last name
· Email address
· Phone number
· Company
· Analytics Partners
INVESTORS
If you apply to be an investor with us, we may collect the following personal data about you:
· Email address
· Phone number
· Mailing address
· Business Partners
· Driver’s license number
· State identification card
· Passport number
· Proof of address, authorization letter, organization chart, entity foundation documents
· Business Partners
· Business Partners
· Business Partners
· Zip codeGender
· Business Partners
· A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
· Personal data revealing citizenship or immigration status
· Business Partners
LENDERS AND ORIGINATORS
If you represent any lender applying to be or approved to participate in the Homium Lending program, we may collect the following information about you and your organization:
· Business name
· Business email address
· Business phone number
· Business mailing address
· Originator ID
· Business Partners
· Advertising Partners
· Originator IDs are published to the blockchain (public)
· Business contact information
· Primary contact information
· Any other business information required on our Homium Lender Application
· Business Partners
· Business Partners
· Title
· Last 4 digits of social security number
· Percentage of ownership
· Business Partners
· Business Partners
BORROWERS
If you seek information about our Services or apply for a loan, we may collect the following information about you, in accordance with the privacy notice provided in your borrower packet:
· Email address
· Phone number
· Mailing address
· Business Partners
· Account type
· Financial institution
· Account number
· Business Partners
· Zip code
· Gender
· Race
· Ethnicity
· Marital Status
· Job title
· Job history
· Race or ethnic origin
· Personal data revealing citizenship or immigration status
· Personal information concerning a consumer’s sex life or sexual orientation
· Job title
· Job history
Categories of Sources of Personal Information
We collect Personal Information about you from the following categories of sources:
You
When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
- Through Cookies(defined in the “Tracking Tools and Opt-Out” section below).
- If you use a location-enabled browser, we may receive information about your location.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
Public Records
- From the government or other sources.
Business Partners
- Securitize
- Banking partners
- Loan Servicers
- Originators
Third Parties
Vendors
- For example, we may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
Our Commercial or Business Purposes for Collecting Personal Information
Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
Marketing the Services
- Marketing and selling the Services.
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Homium or the Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, Homium or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.
How We Disclose Your Personal Information
We disclose your Personal Information to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Information. For more information, please refer to the state-specific sections below.
Service Providers.
These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Document service providers.
- Direct marketing service providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- Payment processors.
- Title, closing, and escrow service provider.
Analytics Partners.
These parties provide analytics on web traffic or usage of the Services. They include:
- Companies that track how users found or were referred to the Services.
- Companies that track how users interact with the Services.
Business Partners.
These parties partner with us in offering various services. They include:
- Businesses that you have or may develop a relationship with, such as
- Securitize, whose privacy policy you can find https://securitize.io/privacy-policy
- Originators, such as Guild Mortgage whose privacy notice you can find https://www.guildmortgage.com/privacy-notice/
Parties You Authorize, Access or Authenticate
Third parties you access through the services.
Affiliates
We may share Personal Information we collect with our affiliates, including our investors, Homium Mutual Benefit Corporation and Homium Asset Corporation, in connection with our Services and our business.
Legal Obligations
We may share any Personal Information that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Information” section above.
Business Transfers
All of your Personal Information that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Information
We may create aggregated, de-identified or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time. As of now, we only place necessary or essential cookies on our website. These cookies are necessary for our website to function.
Generally, you can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or“options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Data Security
We seek to protect your Personal Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Information and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Information about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Information. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Information, why we collected the Personal Information, and the sensitivity of the Personal Information. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
- We retain your profile information and credentials for as long as you have an account with us.
- We retain your payment data for as long as we need to process your investment, loan, or software subscription.
- We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
- We maintain records as required by applicable law.
Personal Information of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Information about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Information to us, please contact us at customerservice@homium.io.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at customerservice@homium.io.
Access
You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. In response, we will provide you with the following information:
- The categories of Personal Information that we have collected about you.
- The categories of sources from which that Personal Information was collected.
- The business or commercial purpose for collecting or selling your Personal Information.
- The categories of third parties with whom we have shared your Personal Information.
- The specific pieces of Personal Information that we have collected about you.
If we have disclosed your Personal Information to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Information shared with each category of third party recipient. If we have sold your Personal Information over the past 12 months, we will identify the categories of Personal Information sold to each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Information that we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, we may need to retain your Personal Information to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Information involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Information we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Information, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Processing of Sensitive Personal Information Opt-Out
If you are a California resident, please note that we only collect your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations and we do not collect or process such information with the purpose of inferring any characteristics about California residents.
Personal Information Sales and Sharing
We will not “sell” or “share” your Personal Information (as such terms are defined under the CCPA) and have not done so over the last 12 months. To our knowledge, we do not sell or share the Personal Information of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.
Exercising Your Rights under the CCPA
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, specifically: your name and email address, or if you have used SecuritizeID to login to Homium, your SecuritizeID username, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Email us at: support@homium.io
- Send a request in writing to: Homium Inc., c/o Privacy, 15260 Ventura Blvd, Suite 1040, Sherman Oaks, CA 91403
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Other State Law Privacy Rights
California Resident Rights
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 customerservice@homium.io.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at customerservice@homium.io with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.
Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
- customerservice@homium.io
- Homium, Inc. c/o Privacy, 15260 Ventura Blvd, Suite 1040, Sherman Oaks, CA 91403