1.0 Our Commitment to Privacy
a. Reverse Mortgage Assist respects the importance of consumer information security and personal privacy. Further, Reverse Mortgage Assist is committed to handling a consumer’s information in a secure environment. Therefore, we have made it a critical focus to protect the confidentiality and security of the personal information you provide us.
2.0 The Information We Collect
a. We or our preferred partners/vendors may collect two types of information: Personally, Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII).
b. PII - PII is information that identifies a specific user of the Services and is provided by the user.
c. When you engage in certain activities on the Services, such as when you register to use the Services, you may be asked to provide certain information about yourself that we will collect and store. This information may include, but is not limited to: first and last name, physical address, email address, phone number and other information specific to the product you have expressed interest in.
d. Depending on what activity you are engaged in, some of the information that may be requested will be identified as mandatory or as voluntary.
e. If you do not wish to provide the mandatory information for a particular activity, you will not be permitted to engage in that activity.
f. You do not have to engage in the activities in which we ask you to provide such information. But if you choose to do so, additional information may be requested, such as your first and last name, gender, email address or date of birth.
g. We log Internet protocol (IP) server addresses for system administration purposes and catalog traffic patterns through the Sites. This information may or may not be linked to a consumer’s personal information at our discretion.
h. Non-PII: Non-PII is information that identifies your computer and its navigational patterns through the Services (but not a specific user).
i. We may automatically collect Non-PII information when you visit the Services, through the use of a variety of tools including cookies (small text files that are stored on a user’s computer for record-keeping purposes and which contain information about that user’s computer), or other available data analysis or collection technologies.
3.0 How We Use and Share Information
a. We use the information we collect to (a) provide, maintain, and protect the Services; (b) notify you of promotions, special events, new services and special offers, for example, through e-mails; (c) tailor our product offerings, customer service and overall experience; (d) improve the content, operation, appearance and utility of the Services; (e) conduct surveys, research and evaluations; (f) troubleshoot and resolve disputes; (g) gather demographic data and (h) accomplish other administrative tasks.
c. Cross-Device Advertising and Tracking: Reverse Mortgage Assist may collect and use the above mentioned data for cross-device advertising purposes. This process allows consumers to experience a personalized, informative advertisement that targets specific product interests over multiple devices. The information may also be used for analytics, and reporting purposes such as an advertisement effectiveness and overall campaign success.
Reverse Mortgage Assist may implement cross device advertising and tracking through two methods:
1. We may use a deterministic approach which may identify and track consumers across devices through identifying characteristics such as a consumer login account. This information may also be used to connect data across different devices.
2. We may also use a probabilistic method which may identify and track consumers through an IP address and the utilization of cookies. This information may also be used to connect data across different devices.
These methods allow information about your use of websites or applications on your browser or device to be combined and used with information from your other browsers or devices. I.e. Your tablet and cell phone. This enables delivery of advertisements or informational data to your multiple devices.
d. Push Notifications/Alerts: We may use push notifications and alerts to notify you of services and/or products that you have expressed interest in on multiple devices. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we may need to collect certain information about your device such as operating system and user identification information. You may opt-out of push notifications or alerts through your browser settings.
e. Third Parties: When you register with the Sites, you explicitly authorize us to share your information with our preferred partners/vendors so that they may contact you via email, SMS, telephone and/or direct mail. Specifically, at registration you agree to receive autodialed or prerecorded calls (including to mobile numbers) and texts and emails from Reverse Mortgage Assist and its affiliates, partners, and vendors to the phone numbers (including mobile numbers) and email addresses you provide to Reverse Mortgage Assist today or in the future and to any phone numbers or email addresses subsequently associated with you by Reverse Mortgage Assist or its affiliates or
marketing partners, affiliates or vendors. You understand and agree that your consent is not a condition, directly or indirectly of a purchase.
Your information, including your PII, may be sold to preferred partners/vendors. We may also sell your information, including your PII to other affiliated companies, and with other trusted vendors and business partners. Some business partners include companies who provide business services to us or on our behalf, such as to market products or services to you, monitor Services activity, help to maintain our customer database, and administer e-mails, surveys or other contests.
f. Opt-Out: If you decide that you are no longer interested in receiving SMS or email communications from us, you may follow the instructions in our SMS or emails to unsubscribe from our email list or by emailing us at: email@example.com. If you wish to opt-out of disclosure and to be excluded from our mailing list, please email us at: firstname.lastname@example.org. As to communications from our preferred partners/vendors, affiliated companies, trusted vendors and business partners, please follow the instructions to opt-out in those entities’ communications.
g. Legal Compliance/Other Information Disclosure: We also reserve the right to disclose your information in good faith as required by law, in response to legal process including law enforcement requests, and with any person or entity that may acquire all or any part of our business or assets, in connection with any change in control of us, and where needed to prevent fraud and to protect the safety, property, or legal rights of users of the Services or our affiliates. We may also disclose your information to manage and protect our information technology infrastructure and security. We may also disclose your information for any other purpose with your consent. We may share non-PII at any time for any purpose.
4.0 Unsubscribe, Opt Out or Revoke
in the subject line. PLEASE NOTE: Data collected may be sold or transferred to our preferred partners/vendors which takes place immediately in real-time. Should you decide to unsubscribe, opt-out or revoke consent, your
data may have already been sent to our preferred partners/vendors. We cannot revoke your information from a third party if it has already been sold. We will remove your PII from our internal programs and further
communication from Reverse Mortgage Assist will cease. We will notify any third parties of removal of your information as well.
5.0 Third Party Information Collection/”Do Not Track”
With respect to Ad Servers: To try and bring you offers that are of interest to you, we have relationships with other companies that we allow to place ads on our Site. As a result of your visit to our Site, ad server companies may collect information such as your domain type, your IP address and clickstream information. For further information, consult the privacy policies of the companies representing the ads or http://www.google.com/privacy_ads.html.
Third parties with whom we partner to provide certain features on the Site or to display advertising based upon your web browsing or application activity use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
“Do-Not-Track” is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to Do-Not-Track signals. If you wish to limit the collection of information by us or third party partners to provide you with advertising based upon your website browsing activities and interests, you may click [http://preferences-mgr.truste.com] to opt out. To opt out of targeted advertising on your mobile device, iOS users can click here: https://support.apple.com/en-us/HT205223 to learn how to limit ad tracking and Android users can click here: https://support.google.com/ads/answer/2662922?hl=en to learn how to opt out of interest-based ads. Please note that opting out of interest-based/targeted advertising does not limit all advertising. You
will continue to receive generic advertisements.
6.0 Privacy Policies of Third Parties
c. We are not responsible for the policies or practices of third parties.
7.0 Editing and Requesting Your Information
a. We will permit you to change your profile settings. Even after you remove your information from your profile, copies of your information may remain viewable elsewhere to the extent it has been shared with others or it was copied or stored by other users. We may also be required to retain your information by law or for legitimate business purposes, such as to prevent identity theft or other misconduct.
b. We will permit you to request a copy of your PII that we have collected about you by emailing us at email@example.com.
c. You can also correct factual inaccuracies in this information by emailing us at firstname.lastname@example.org.
8.0 Storage and Security
a. We will retain PII, including user location information, only as long as our business needs require. We will then destroy or render unreadable any such information upon disposal.
b. We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse and alteration of your information under our control.
c. Depending on site requirements, we may employ Secure Sockets Layer (SSL) encryption technology to transmit data between a consumer’s browser and our web server. To use our websites, a consumer will need an SSL-capable browser such as MS Internet Explorer 4.0 (or higher) or Netscape Navigator 4.0 or higher.
d. We require that preferred partners/vendors handle consumer information under confidential conditions.
e. Notwithstanding such security measures, please be aware that no security measures are perfect or 100% secure, and we cannot guarantee the security of any information transmitted to or from the Services.
f. Although we have agreements and vetting procedures in place for third parties, we are not responsible for the actions of any third parties that may receive any such information.
g. You should note that the security of your personal information also depends on you. Please do not communicate any information to us through unsecured channels, such as when you are in public areas. Where we have provided you or you have chosen a password, access code, or similar security feature, you must keep the password, access code or security feature confidential. Please do not share your password with anyone. If you believe your password or account has been compromised, please contact us immediately at email@example.com.
9.0 Minors and Privacy Issues
a. Children’s Online Privacy Protection Act- This site is intended to be used by people the age of 18 and older. We do not knowingly allow any users under the age of thirteen to use our service. However, if you become aware of the existence of a user who is under the age of thirteen, or that an individual under thirteen has provided their information to us, contact us immediately with details at firstname.lastname@example.org. If you have been reported as being below thirteen by another person, we may request that you verify your age to us, including providing us a copy of your photo ID as a condition of your continued use of our service.
b. No part of the Services is designed to attract anyone under the age of 18.
c. Children under the age of 18 may not use the Services.
d. If you are a parent or guardian and believe that your child under the age of 13 has provided personal information to us, you may contact us to request this information be deleted.
10.0 Specific Industry Disclaimers
a. Financial Services-Please note that we are not a mortgage lender, debt service, debt settlement, real estate company, insurance agent, auto sales company or automotive warranty organization. This is not, and is not intended to be, any type of application for any financial product.
i. Our sites use short forms which enable you to be matched with one or more companies within our network. In order to be contacted, a consumer must complete a financial services request by completing an application located on one of our sites.
ii. Once you have completed this expression of interest (or information request form), your information will be sent to our participating companies. Our application technology will match a consumer with one to four companies within our network.
iii. We will share your information with our preferred partner, Secure Rights. You agree to share your information with Secure Rights and up to 4 of its Premier Partners and for them to contact you (including through
automated means; e.g. autodialing, text and pre-recorded messaging) via telephone, mobile device (including SMS and MMS) and/or email, even if your telephone number is currently listed on any state, federal or corporate Do Not Call list. Specifically, at registration you agree to receive autodialed or prerecorded calls (including to mobile numbers) and texts and emails from Reverse Mortgage Assist and its affiliates, partners, and vendors to the phone numbers (including mobile numbers) and email addresses you provide to Reverse Mortgage Assist today or in the future and to any phone numbers or email addresses subsequently associated with you by Reverse Mortgage Assist or its affiliates or marketing partners, affiliates or vendors. You understand and agree that your consent is not a condition, directly or indirectly of a purchase.
iv. In most cases, a company will contact a consumer regarding requests within 24 hours. There is no fee charged or billed to a consumer by us for the above service.
v. A company may utilize a consumer’s information submitted at one of our Sites. In addition, a company may use this information to evaluate a consumer’s eligibility, process an application or initiate and close a transaction. Many companies have proprietary privacy policies regarding dissemination of personal information.
vi. Licensed organizations are subject to Federal and State laws and regulations or their practices. We have no direct control over information handling practices within our network. However, we require companies within our network to refrain from disclosing confidential consumer information to third parties that are not affiliated with the application process.
11.0 ARBITRATION AGREEMENT AND CLASS ACTION WAIVER
BY ACCESSING AND/OR USING ANY REVERSE MORTGAGE ASSIST WEBSITES OR SERVICES, YOU AGREE TO THESE TERMS AND CONDITIONS OF THIS ARBITRATION AGREEMENT. DO NOT USE REVERSE MORTGAGE ASSIST SERVICES OR SUBMIT ANY CONTACT INFORMATION IF YOU DO NOT AGREE TO THESE TERMS.
THIS AGREEMENT IS BINDING TO ARBITRATE ALL CLAIMS. YOU AGREE THAT DISPUTES BETWEEN YOU AND REVERSE MORTGAGE ASSIST WILL BE RESOLVED BY BINDING, INDIVIDUAL ARBITRATION AND YOU WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION.
THIS AGREEMENT PROVIDES THAT ALL DISPUTES BETWEEN YOU AND REVERSE MORTGAGE ASSIST WILL BE RESOLVED BY BINDING, INDIVIDUAL ARBITRATION AND NOT IN COURT OR BY JURY TRIAL. IF A DISPUTE IS ARBITRATED, YOU GIVE UP YOUR RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR CLASS MEMBER ON ANY CLASS CLAIM YOU MAY HAVE AGAINST REVERSE MORTGAGE ASSIST INCLUDING ANY RIGHT TO CLASS ARBITRATION OR ANY CONSOLIDATION OF INDIVIDUAL ARBITRATIONS.
Review this section carefully. This arbitration provision limits your and Reverse Mortgage Assist’s ability to litigate claims in court and you and Reverse Mortgage Assist each agree to waive your respective rights to a jury trial or a state or federal judge. You agree that you will not file any lawsuit against us in any state or federal court.
We strive to never have a dispute, but if we do, you and we agree to try for 60 days to resolve it informally.
If no resolution results from this informal process, you and we agree to binding individual arbitration before the American Arbitration Association (“AAA”) under the Federal Arbitration Act (“FAA”), and not to sue in court in front of a judge or jury. As an alternative, a neutral arbitrator will decide and the
arbitrator’s decision will be final except for a limited right of appeal under the FAA. Class action lawsuits, class wide arbitrations, private attorney-general actions, and any other proceeding where someone acts in a representative capacity aren’t allowed. Nor is combining individual proceedings without the consent of all parties.
You agree that the Arbitrator will have sole and exclusive jurisdiction over any dispute you have with us. The Federal Arbitration Act allows for the enforcement of arbitration agreements and governs the interpretation and enforcement of the agreement to arbitrate.
If any provision of this Arbitration Agreement is found to be invalid or unenforceable, then that specific provision shall be of no force and effect and shall be severed, but the remainder of this Arbitration Agreement shall continue in full force and effect.
No waiver of any provision of this Arbitration Agreement will be effective or enforceable unless recorded in a writing signed by the party waiving such a right or requirement.
Such a waiver shall not waive or affect any other portion of this Agreement. This Arbitration Agreement will survive the termination of your relationship with Reverse Mortgage Assist.
d. If a change would authorize the use of your PII for a new or materially different purpose, then we will send you an email notification. It is your responsibility to ensure that we have a current, working email address on file for you.
13.0 Contact Information
b. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov.
Date last revised: July 27, 2017