Effective as of January 1, 2023.
California Residents: See the California privacy notice below for important information about our collection, use, and disclosure of your personal information as well as your California privacy rights.
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name and email address.
- Application data, such as your first and last name, email address, mailing address, phone number, home address, estimated home valuation, and other information you provide when you submit a prequalification request or application for one of our financial products.
- Communications data about our communications with you, including when you contact us through the Service, social media, email, text messages, or otherwise, including the date, time, and contents of the message, and the email addresses, phone numbers (and carrier name), and social media handles from which your messages are sent.
- Transactional data pertaining to your transactions with us, including information about any financial products we provide you.
- Relationship data, such as the personal information of relatives or third parties that you provide to us.
- Financial data, such as your stated income, credit score and credit history, and financial account numbers.
- Government identification data, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
- Survey data, including information you share when you choose to participate in a survey. We recommend that you read any instructions, terms, or rules applicable to the survey before participating.
Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:
- Public sources, such as government agencies, public records, and other publicly available sources.
- Private sources, such as data licensors.
- Marketing partners, such as joint marketing partners.
- Third-party services, such as financial institutions from which you authorize us to retrieve your information for use in connection with our review of your application for our products or services, which may include your address and Social Security Number, account balances, transaction history, and length of relationship with the third party.
Automatic data collection.
We, our service providers, and our business partners may automatically log information about you, your computer, or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, Bluetooth, LTE, 3G), and location data that can be derived from it, general location information such as city, state, or geographic area that can be derived from your IP address, and precise geolocation of your device when you authorize our mobile application to access it in your device’s settings.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails, forwarded them, or clicked links within them.
- Location data, including the general location associated with your IP address or, when you authorize the Service to access it, your device’s precise location.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
- Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened or that certain content was viewed or clicked.
Session replay services, which employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. For example, we use session replay services provided by Hotjar. You can learn more about Hotjar at https://www.hotjar.com/legal/policies/privacy/ and how to tell Hotjar not to collect your data at https://www.hotjar.com/policies/do-not-track/.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide, operate, and improve the Service and our business;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- administer and communicate with you about surveys in which you choose to participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions, and feedback.
Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications via mail, email, or (with your consent) text messages and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified, and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified, or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
Cookies and similar technologies. The Service employs cookies and similar technologies to facilitate the purposes for which we use personal information:
- Service delivery and operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and authenticating you into the Service, and to enhance the performance and functionality of our services.
- Interest-based advertising. To facilitate interest-based advertising as described above.
- Research and development. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails and advertisements. For example, we use Google Analytics cookies for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
How we share your personal information
- Affiliates. Our corporate parent, subsidiaries, and affiliates.
- Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as mail delivery, hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).
- Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
- Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
- Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above or as otherwise permitted by law.
- Business transferees. Parties (and their respective advisors) to business transactions or proposed transactions involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Hoom (including, in connection with insolvency, bankruptcy or similar proceedings). Personal information may be also transferred to such parties in connection with due diligence preceding such transactions or as part of the transfer of assets/interests that occur when the transactions close.
In this section, we describe the rights and choices available to all users. California residents can find additional information about their rights below.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email or by emailing us at email@example.com. Please note that changes requested of us may not be effective immediately, and until such changes take effect, you may still receive or not receive promotional communications from us. If you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message.
Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, certain features of the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Blocking web beacons. Most browsers allow you to configure your device to prevent images that would include web beacons/clear GIFs from loading. To do this, follow the instructions in your particular browser settings.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google offers opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
- Google: Opt-out (https://adssettings.google.com/)
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: optout.aboutads.info.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do not track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals unless we explicitly indicate otherwise. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.
We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please email us at firstname.lastname@example.org. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
How to contact us
Mail: Hoom Inc., 1325 Denlyn St., Novato, CA 94947
California Privacy Notice
This notice describes our collection, use, and disclosure of personal information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to their personal information. For purposes of this notice, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. For example, the CCPA exempts information covered by our U.S. Consumer Privacy Notice or subject to the Fair Credit Reporting Act.
Your privacy rights. If you’re a California resident, you have the following rights under the CCPA:
- Right to know. You can request information about the categories of personal information that we have collected; the categories of sources from which we collected personal information; the business or commercial purpose for collecting, sharing and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared, or disclosed for a business purpose.
- Right to access. You can request a copy of certain personal information that we have collected about you.
- Right to deletion. You can request that we delete personal information that we collected from you.
- Right to correction. You can request that we correct inaccurate personal information that we have collected about you.
- Right to opt-out. You can request to opt-out of disclosures of your personal information that constitute “selling” or “sharing” of your personal information as defined in the CCPA.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
You may submit requests to exercise your right to know, access, deletion, and correction by submitting an online request here or calling us at 415-707-0976. The rights described above are not absolute, and in certain cases, we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Identity verification. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into an online account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email, or telephone account stated in the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.
Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months:
- Sales and sharing of personal information. Our use of the interest-based advertising services described above may constitute “sharing” of your personal information from which you have the right to opt-out. That is because these services use our users’ personal information (specifically, the contact data, device data and online activity data described above in Personal information we collect) to show you ads they think may interest you on other online services. You can request to opt-out of this “sharing” of your personal information by clicking “Do Not Share My Personal Information” at the bottom of our webpage. Your request to opt-out will apply only to the browser and the device from which you submit the request. You can also enable the Global Privacy Control (GPC) to opt out of the “sharing” of your personal information for each participating browser system that you use. Learn more at the Global Privacy Control website: https://globalprivacycontrol.org. We do not “sell” personal information as defined by the CCPA and have no actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.
- Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.
- Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. The length of time we retain particular categories of personal information is determined based on whether it is sufficient to achieve such purposes. When we no longer require the personal information, we may either delete it, anonymize it, or isolate it from further processing.