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Privacy
Policy

Last Updated: August 30, 2021

INTRODUCTION

This Privacy Policy describes the information PollyEx, Inc. (“Polly”, “our”, “we” or “us”) processes and collects about you as a visitor to www.polly.io including any subdomain thereof and other websites that we operate and that link to this Privacy Policy (collectively, “Websites”), as a customer or authorized user of our products and services (collectively, “Services”) and as a registrant of one of our events. This Privacy Policy details how we will use the information provided and with whom we may share the information. This Privacy Policy also describes your choices and rights related to the information that is provided to or collected by us.

Polly customers should also refer to their written agreement(s) with us, which may provide additional terms governing the use of our Services. Unless we define a term herein, all capitalized terms used in this Privacy Policy will have the same meanings as in our Terms of Service (“General Terms”).

SCOPE OF THIS PRIVACY POLICY

In this Privacy Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity.

This Privacy Policy applies to our Websites, which may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

This Privacy Policy applies to our “Users”, which is a company, firm or entity who entered into an agreement for the use of our Services or an individual added as an authorized user in an account for which we provide Services. Users are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as all privacy policies, agreements or other obligations, relating to information about Users’ borrowers (which may include personal information) provided to us in connection with the use of our Services. If you are an individual who interacts with a User using our Services, then you will be directed to contact our User for assistance with any requests or questions relating to your personal information.

We may transfer personal information to companies that help us provide our Services, including cloud hosting and storage services companies. Transfers to such companies are governed by the written agreement(s) with our Users.

We collect and process personal information under the direction of our Users and have no direct relationship with individuals whose personal information we process in connection with our Users’ use of our Services. If you are an individual who interacts with a User using our Services (such as a customer of one of our Users) and would either like to amend your contact information or no longer wish to be contacted by one of our Users that use our Services, please contact the User with whom you interact. If you are unable to contact the User or need assistance contacting the User, use the information in the “Contact Us” section below.

THE INFORMATION WE COLLECT

When you visit our Websites, we collect a variety of information from and about you, your devices and your interaction with our Services. We also collect information about Users and obtain information from third parties in the course of providing our Services to Users. The categories of information we collect depend on whether you are a User or a visitor and the requirements of applicable law. This information includes:

Information You Provide in Your Communications with Us. When you express an interest in obtaining information about our Services through the Websites or our sales teams, request to contact sales, use our “Contact Us” or similar features, sign up for an event or webinar, download certain content from our Websites or participate in surveys, we may collect certain information from you to contact you and provide our Services to you, including your name, title or job level, company, address, email address, telephone number or username and/or password.

Account and Event Registration Information. When you register to use our Services or for one of our events, we may collect certain information from you to contact you and provide our Services to you, including your name, email address, title or job level, company, address, telephone number, username and/or password.

Usage Information. We may automatically collect certain information when you visit our Websites and/or use our Services, including unique device identifiers, internet protocol addresses, browser types, internet service providers, the number and duration of page visits and the number of clicks and other information about how you use the Services. Information we collect may be associated with accounts and other devices. In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.

Personal Information Collected as a Third Party Service Provider. In the course of delivering our products and services, we receive information about Users’ customers (which may include personal information on Users’ borrowers) which is provided by Users. Users are responsible for providing notice and obtaining appropriate consents to collect data from their borrowers and to provide it to us as their service provider. You should refer to our Users’ privacy notices and/or contact them directly to understand how your personal information will be collected, used and shared. We also collect aggregated data and information on Users’ customers (such as investors or borrowers) when such data and information is provided to us. We may also collect information about Users and their customer transactions with us or others relating to the Services.

Transactional Information. Polly, as a service provider, may also collect and process transactional information relating to the loan transactions or other events occurring through our Services. This transactional information is collected to enable us to provide and enhance our Services, to enable the services provided by third parties and to enable us to comply with various legal obligations.

Information from Polly Partners. As a user of our Services, you can obtain various services from our partners. These services include offerings from partners who directly have engaged us and also from your service provider contacts. If you select a Polly partner provider during the use of our Services, we may collect (and share with the partner) the relevant information about the mortgage loan, property, borrower or credit report so the partner may provide its services to you. We also may share certain information about our Users such as name, address, telephone number and name of individual acting as the User with the partner. If you wish to transact with a service provider who is not a Polly partner, such third party service provider’s privacy policy and terms of service will apply to your transactions, and we have no control over or responsibility for the information sent or other communications between you and the third party service provider.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.

o Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. If you do that, however, the Services may not work properly.

o Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

o Analytics. We may also use Google Analytics and Refinitiv to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit here. You can opt out of Google’s collection and Processing of data generated by your use of the Services by visiting here. For more information on Refinitiv, please visit here.

Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, we may collect information about you from that third-party application that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business and Services.

HOW WE USE YOUR INFORMATION

We use your information in a variety of ways to provide our Services and to operate our business, including to:

Provide our Services. We use the information that we collect to (i) operate, test, maintain, fix and provide features of our Services, (ii) provide services and information that you request, (iii) communicate with and provide support to Users and visitors to our Websites and (iv) process payment for our Services.

Improve, Analyze and Personalize our Services. We use the information that we collect to (i) understand and analyze usage trends and preferences, (ii) monitor and analyze the effectiveness of our Services, (iii) enhance and improve our Services and develop new products, services, features and functionality, (iv) personalize our Services and (v) provide customized content and information.

Contact You. We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including important product updates and marketing or promotional communications relating to our Services or events. You have the ability to opt out of receiving marketing or promotional communications by contacting us.

Aggregate De-identified Data. We aggregate and de-identify data collected through our Services and may use it for our business purposes such as creating and publishing reports about the use of our Services, including Users’ interests, usage patterns and borrowing and loan origination trends.

Other Uses of Your Information. We may use your information (i) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (ii) to enforce our agreements, policies and General Terms, (iii) to protect the security or integrity of our Websites or Services, (iv) to protect the property, rights, and safety of Polly, our Users or the public from harm or illegal activities, (v) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person or (vi) to investigate and defend ourselves against any third party claims or allegations. Please note that there may be other uses for certain information of yours, which you consent to or are described to you when you provide or we collect the information.

HOW WE SHARE INFORMATION

We may share your personal information as follows:

With Service Providers. When we engage a service provider to help us provide and support our Services, we may need to give them access to the information reasonably necessary for them to provide their service. We allow them to use personal information only to perform the service we have contracted them to perform.

With Our Customers. Any transactional information collected by our Users using our Services may be available to their account administrators or other account managers, and may, at the direction of our Users, be shared with third parties as necessary for our Users’ loan origination and management purposes. Users may use certain information they collect through our Services for marketing or promotional communications, subject to any appropriate or necessary consents and their own privacy policies.

In Aggregated, De-Identified Form. We may make certain aggregated, de-identified non-personal information that cannot reasonably be used to identify you publicly available to third parties for various purposes, including (i) for compliance with various reporting obligations, (ii) for business or marketing purposes or (iii) to assist such parties in understanding our Users’ interests, usage patterns and borrowing and loan origination trends.

Compliance with Laws and Law Enforcement; Protection of Us or Others. We may disclose your information to a third party (i) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (ii) to enforce our agreements, policies and General Terms, (iii) to protect the security or integrity of our Websites or Services, (iv) to protect the property, rights, and safety of Polly, our Users or the public from harm or illegal activities, (v) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person or (vi) to investigate and defend ourselves against any third party claims or allegations.

In Significant Business Transactions. Your information, including personal information, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy or receivership in which information is transferred to one or more third parties as one of our business assets. In addition, we may share your information with our affiliates under common ownership or control for uses as described in this Privacy Policy.

Subject to Consent. We may share your information in other ways if you have asked us to do so or have given consent.

INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) took effect on January 1, 2020. The CCPA grants rights to California residents regarding their personal information, including:

• the right to know what categories and specific pieces of personal information have been collected, used, shared or sold (if any);

• the right to know the purposes for which the information is used;

• the right to delete personal information, where not excepted by law; and

• the right to opt-out of the sale of their personal information.

This Privacy Policy describes what categories of information we collect, for what purposes we use it, and with whom we share it. If you would like to exercise your rights under the CCPA to request what specific pieces of personal information we have about you or for deletion of your information or to opt out any sale of your information, you may contact us at support@polly.io or as noted below and include, at a minimum, your first and last name and email so we may verify you and process your request. If your request pertains to one or more of our Users, we will promptly notify those Users so that they can fulfill your request. For more information, refer to the “How We Share Information” section above. Your privacy is important to Polly and we will not discriminate against you if you choose to exercise your privacy rights under the CCPA.

COMMUNICATIONS PREFERENCES

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or contact us using the information below.

RETENTION OF YOUR PERSONAL INFORMATION

We store personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by making a notice available to you through the Services or sending an e-mail to you.

OUR POLICY CONCERNING CHILDREN

Our Websites and Services relate to the U.S. real estate market and are intended for use by adults ages 18 or older. We do not knowingly collect any personal information from minors, and minors should not use our Websites or our Services at any time.

LINKED WEBSITES AND SOFTWARE DEVELOPMENT KITS

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. If you have any questions about what information these other sites and third parties collect, how they use it, and with whom they share it, you should contact them directly. We may use third party APIs and software development kits as part of the functionality of our Services. For more information about our use of APIs and software development kits, please contact us as set forth below.

INTERNATIONAL VISITORS

Our Websites and Services are hosted in the United States and are intended for use in connection with the U.S. real estate market. If you choose to use them from outside the U.S., your personal information may be transferred to, stored, and processed in the United States where our servers are located and our systems are operated. The data protection laws of the U.S. may differ from those in your country. By using the Websites and Services, you consent to your information being transferred to Polly and third parties with whom we share information as described in this Privacy Policy. If you are located in the European Economic Area, you may have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. If we update this Privacy Policy, we will update the “effective date” at the top of this policy. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect. We encourage you to periodically review our Privacy Policy and any notices to stay informed.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy including to submit a consumer request under the CCPA or unsubscribe from marketing communications, please contact us by email at support@polly.io or write to us at:

Polly
Attn: Privacy Officer
548 Market Street, Suite 25656
San Francisco, CA 94104

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