Last Updated: August 30, 2021
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.
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.
• 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.
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
SECURITY OF YOUR INFORMATION
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.
Attn: Privacy Officer
548 Market Street, Suite 25656
San Francisco, CA 94104