Last modified: March 2022

GPARENCY LLC (“GPARENCY” or “we,” “us,” “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our website www.gparency.com or our mobile applications (together, our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information, as well as your rights concerning such information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Website. By accessing or using this Website, you agree to this Privacy Policy. This policy may change from time to time so please check here periodically. Your continued use of this Website after we make changes is deemed to be acceptance of those changes.

Information We Collect About You and How We Collect It

We may collect information from you in the following ways:

• Directly from you when you provide it to us;
• Automatically as you navigate through the Website; or
• From third parties, for example, our business partners.

1. Information You Directly Provide to Us

We may collect certain categories of information when you voluntarily provide it to us, which may include:

• Account Registration. When you register to use our Website, we may collect your name, mailing address, email address, phone number, username, and password.
• Contact Information. When you reach out to us with a general inquiry or to provide us with feedback on the Website or our services, we may collect your name, email address, and phone number.
• Billing Information. To process your payments we may collect your credit card number, expiration date, bank account information, billing address, and similar information.
• Credit Information. In order to provide you with our services and evaluate your credit worthiness, we may need to collect your employment-related information, credit card information, billing address, social security number, or other financial information including a credit report.
• Personalization Information. To provide you with relevant information we may collect your geo-location, property type (e.g. condo, single family, etc.), marital status, income, property value, desired loan amount, and similar information that will help us curate your options and preferences.

1. Information We Automatically Collect

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Device Information. When you interact with our Website, we may automatically collect information about the computers, phones, and other devices you are using (e.g. IP address, WiFi information, device attributes, operating system version, etc.).
• Usage Information. So that we may understand and improve on the user experience and functionality of the Website, we may collect information about how you interact with the Website such as mouse movements, clicks, keystrokes, the date of your visit, the time spent on pages of the Website, or other actions.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, please refer to allaboutcookies.org.
• Web Beacons. Pages of our the Website [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We currently do not honor Do Not Track signals from internet browsers; when a universal standard for processing them emerges, we will follow it.

Note that third-party sites that are linked to the Website may set cookies or other technologies to collect information about your use and interaction with their websites or content. We do not have access to, or control, over such third-party data collection.

How We May Use Your Information

We may use information that we collect about you for the following:

• To provide you with personalized information about our services, pricing, and loan options.
• To create and maintain your account, including expiration and renewal notices.
• To provide you with our services.
• To receive and respond to your inquiries and client service requests.
• To process payments and prevent transactional fraud.
• To notify you about changes to our Website, policies, or any services we offer or provide through it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To better understand your experience with and improve our Website and services.

Disclosure of Your Information

We may disclose your personal information as follows:

• To contractors, service providers, and other third parties we use to support and/or improve our business.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or investigate potential violations of our Terms of Service (and other agreements, including for billing and collection purposes).
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of GPARENCY, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Security and Retention

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or through our services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

We will keep your personal information as long as reasonably necessary to fulfill the purposes for which it was collected. In some circumstances we may retain your personal information for longer if and when required (e.g. legal, tax, or accounting requirements).

Links to Other Sites

The Website may contain links to other sites for your convenience only. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the applicable privacy policy of these third-party websites. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to us or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information to us or on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at connect@gparency.com.

Additional Rights for California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA)  may provide you with additional rights regarding our use of your personal information. As a resident of California you may have some or all of the following mechanisms to control your information:

• Accessing Your Information You may request, up to 2 times each year, that we disclose to you the categories and specific pieces of information that we have collected about you.
• Deleting Your Information. You may request that we delete any personal information that we have collected from or about you.

In accordance with the CCPA, in addition to the details described above, we make the following disclosures:

• We collect the following categories of personal information: identifiers/contact information, commercial information, financial information, internet or other electronic network activity information, location, and any inferences drawn from the foregoing.
• We disclose the following categories of personal information for our business purposes: identifiers/contact information, financial information, internet or other electronic network activity information, location, and any inferences drawn from the foregoing.

You may exercise your California privacy rights by emailing connect@gparency.com. We will handle verified requests to access, correct, or delete your information within forty-five (45) days unless the request is unusually extensive or complex, in which case we will inform you of the expected timeline for handling your particular request. We do not discriminate against any California residents who exercise any of their rights described in this Privacy Policy

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

connect@gparency.com or via our number at 732.719.3010.