Our Commitment to Privacy

At A Plus Mortgage LLC (“we,” “our,” or “us”), safeguarding your privacy is of utmost importance. This Privacy Policy outlines how we gather, store, process, share, and employ data that identifies or relates to you (referred to as “personal information”) and covers our use of cookies and similar technologies. This policy pertains to our websites and the services we provide. Before using our websites or services, please ensure you have thoroughly read and understood the principles outlined in this Privacy Policy.

A Plus Mortgage LLC serves as the data controller for the personal information we collect about you.

Personal Information We Collect and How We Use It

We collect personal information from individuals who are our direct customers, as well as individuals who are employees, agents, or representatives of our business customers. Throughout this Privacy Policy, these individuals are referred to as “you.”

We gather your personal information when you voluntarily provide it directly to us, such as when you register for an account, fill out a form, correspond with us via our websites, phone, email, or other means, subscribe to our mailing lists or newsletters, respond to surveys, or use various features of our services. If you choose not to provide personal information, we may be unable to offer our services or respond to your requests adequately.

Please refer to Annex 1 for details on the categories of personal information we collect and how we use it. This annex also lists the legal basis for processing this information, the categories of recipients who may receive the information, and our policies on retention periods.

We also automatically collect personal information indirectly regarding how you access and use our services and information about the device you use for this purpose. Annex 2 provides information on the categories of personal information collected automatically and how we utilize this data.

We may link or combine the personal information you provide with the information we collect automatically. This enables us to offer you a personalized experience regardless of how you engage with us.

Moreover, we may anonymize and aggregate the personal information we collect, including data about your subscribers, website visitors, or customers. This anonymized information may be used for purposes such as system testing, research, data analysis, service improvement, and product development. We may also share this anonymized information with third parties.

Customer Data We May Process

During the provision of our services, we may process information about individuals who are subscribers, website visitors, or customers of our customers. This data is referred to as “Customer Data.” Please refer to the privacy policy of the relevant customer for information regarding Customer Data, and direct any related inquiries to them.

Marketing and Advertising

With your consent, we may contact you from time to time with relevant information about our services. Most of these messages will be sent via email. To tailor these messages, we may use the personal information we collect about you. You have the option to opt out of receiving such messages by clicking the unsubscribe link in the footer of our emails. Please note that non-promotional messages related to your account, such as account verification, updates to service features, or security notices, cannot be opted out of.

Storage and Transfer of Your Personal Information

We implement appropriate technical and organizational measures to protect your personal information from accidental or unlawful destruction, loss, alteration, or damage. All personal information we collect is stored on secure servers, and electronic transactions on our website are protected by SSL encryption technology. When you create an account on our services, you are responsible for maintaining its security, as outlined in our Terms of Service.

The personal information we collect may be transferred to and stored in countries outside your jurisdiction, where we and our third-party service providers operate.

Your Rights in Respect of Your Personal Data (EU Users)

If you are located in the EU, you have certain rights regarding your personal information, including:

• Right of Access and Portability: You have the right to access and receive your personal information.
• Right to Rectification: You can request the correction of inaccurate or incomplete personal information.
• Right to Erasure: In certain circumstances, you can request the erasure of your personal information.
• Right to Restriction: You can request the restriction of processing your personal information in certain situations.
• Right to Object: You have the right to object to the processing of your personal information, including for direct marketing purposes.

If you wish to exercise any of these rights, please contact us using the contact details provided at the end of this Privacy Policy. You also have the right to lodge a complaint with your local data protection authority.

Cookies and Similar Technologies

We use various tracking technologies, including cookies, Flash objects, web beacons, and others, to automatically collect information about how you access and use our services, as well as information about your device. Please see Annex 2 for details on the categories of personal information collected automatically and how we use this information. You can typically manage your cookie settings in your browser’s options or preferences menu.

Third-Party Data Collection and Interest-Based Advertising

We engage in interest-based advertising and work with third-party advertising companies to display targeted advertisements based on your browsing history. We may share a common account identifier with these partners to identify you across devices. Please be aware that we may not be able to respond to Do Not Track signals from your browser at this time.

Links to Third-Party Sites

Our websites may contain links to third-party websites. Please note that these websites have their own privacy policies, and we do not accept responsibility for their policies. We encourage you to review the privacy policies of these websites before providing them with any information.

Our Policy Towards Children

Our services are intended for use by adults, and we do not knowingly collect personal information from children under the age of 13. If you become aware that your child has provided us with personal information, please contact us so we can take appropriate steps to remove the information and terminate any account created by your child.

Changes to this Policy

We may update this Privacy Policy periodically. When we make significant changes to the policy, we will update the “last modified” date at the end of the document. Changes to this policy take effect when posted on this page.

Notice to You

If we need to provide you with information for legal, marketing, or other business-related purposes, we will use the most appropriate means to contact you, typically via email or by posting notices on our websites. This does not affect your ability to opt out of specific types of contact, as described in this Privacy Policy.

Contacting Us

If you are based in the USA, our representative is A Plus Mortgage LLC (USA) Ltd, with a registered address at 1635 W Wise Road, Ste 9, Schaumburg, IL 60193. Regardless of your location, you are welcome to reach out with questions, comments, or requests related to this Privacy Policy. You can contact our Data Protection Officer at either privacy@APlus.Mortgage or loans@APlus.Mortgage, depending on how you are using our services.

This Privacy Policy was last modified on 07 March 2019.

Annex 1 – Personal Information We Collect When You Use the Services

Categories of Personal Information

1. Contact Information and Basic Personal Details:

• Includes your full name, phone number, postal address, email address, and zip code.

How we use it:

• Communication with you, such as sending statements, invoices, news, alerts, and marketing communications.
• Handling inquiries and complaints related to our services.
• Authentication purposes.
• Creating customer accounts and facilitating the operation, maintenance, and provision of service features.

Legal basis for the processing:

• Necessary for the performance of a contract and to take steps before entering into a contract.
• Our legitimate interests, including administering services, marketing, and communication with users.
• Compliance with legal obligations.

2. Website, Business, and Marketing Information:

• May include company website, IP address, email list size, e-commerce software, email marketing software, product usage data, demographic information, data about third-party services, and other business-related details (e.g., Facebook ad spend, industry, business goals).

How we use it:

• Operating, maintaining, and providing service features.
• Identifying relevant advertising and marketing activities.

Legal basis for the processing:

• Necessary for the performance of a contract and to take steps before entering into a contract.
• Our legitimate interests, including administering services and marketing.

3. Payment Information:

• Details such as credit card information, account information, billing address, and related data.

How we use it:

• Facilitating payment for service usage.
• Detecting and preventing fraud.

Legal basis for the processing:

• Necessary for the performance of our contract with you.
• Our legitimate interests, including fraud detection and prevention.

4. Correspondence and Comments:

• Recording comments and opinions when you contact us directly via email, phone, mail, message boards, blogs, online forms, or quality surveys.

How we use it:

• Addressing your questions, issues, and concerns.
• Improving our services.
• Determining products and services that may interest you.
• Sending news, alerts, and marketing communications according to your preferences.

Legal basis for the processing:

• Our legitimate interests, including communication with users and marketing.

5. All Personal Information Set Out Above:

• We use all the personal information we collect for various purposes, including preventing and detecting fraud, improving services and websites, and developing new products and services.

Legal basis for the processing:

• Our legitimate interest, including administering and improving services, websites, and our business.

Categories of Recipients

As required based on how we use the information, we may share your personal information with the following categories of recipients:

Service Providers and Advisors:

• Third-party vendors and service providers who perform services on our behalf, such as mailing or email services, tax and accounting services, payment processing, data enhancement, web hosting, and analytics.

Purchasers and Third Parties in Connection with Business Transactions:

• Personal information may be disclosed to third parties in transactions like mergers, sales of assets, reorganizations, financing, change of control, or acquisition of our business.

Law Enforcement, Regulators, and Other Parties for Legal Reasons:

• Disclosure may be necessary by law or when we reasonably believe it’s essential to comply with legal requirements, enforce our Terms of Service, protect the security of our services or websites, or safeguard rights, property, or personal safety.

Retention Period

We retain your personal information for no longer than necessary for the purposes outlined in accordance with our legal obligations and legitimate business interests.

Annex 2 – Personal Information Collected Automatically

Categories of Personal Information

1. Information About How You Access and Use the Services:

• Includes details such as the website you came from and the one you go to when leaving our websites, the frequency and duration of your service usage, your interaction with emails (opens, clicks), device use (e.g., multiple devices), and other actions within the services.

How we use it:

• Tailoring services to your preferences.
• Determining relevant news, alerts, and products for marketing.
• Monitoring and improving services and business.
• Helping us develop new products and services.

Legal basis for the processing:

• Our legitimate interests, including personalizing services, improving services, marketing, communication, and fraud detection.

2. Information About Your Device:

• Details about the device you use to connect to the services, including type, unique identifying numbers, operating systems, browsers, applications, server information, Internet service provider, mobile network, and IP address.

How we use it:

• Enabling services presentation on your device.
• Operating, maintaining, and providing service features.
• Monitoring and improving services and business.

Legal basis for the processing:

• Our legitimate interests, including personalizing services, improving services, marketing, communication, and fraud detection.

Categories of Recipients and Retention Periods

Similar to Annex 1, the categories of recipients and retention periods for personal information collected automatically are based on the purposes of data collection and are consistent with our legal obligations and legitimate business interests.

Cookies and Similar Technologies

When using our service, reading our emails, or engaging with us through computers or mobile devices, we and our third-party service providers automatically collect information about your access and usage. We employ various tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar tools (collectively referred to as “tracking technologies”). This information is used to enhance your user experience, monitor and improve our websites and services, and serve other internal purposes.

Annex 2 outlines the categories of personal information we collect automatically and how we use it.

Our websites utilize cookies to distinguish you from other users. Cookies are code fragments that personalize our websites by storing your information, such as user IDs and preferences. These small data files are transferred to your device’s hard disk (e.g., computer or smartphone) for record-keeping purposes.

We employ the following types of cookies:

• Strictly Necessary Cookies: These are essential for the basic operation of our websites, including user authentication and preventing fraudulent use.
• Analytical/Performance Cookies: These cookies help us count and recognize visitors and track their movements on our websites. This data aids us in improving website functionality and ensuring users easily find what they’re looking for.
• Functionality Cookies: Functionality cookies are used to recognize you upon your return to our websites. This enables us to personalize content, greet you by name, and remember your preferences (e.g., language or region choice).
• Targeting Cookies: Targeting cookies record your website visits, viewed pages, and followed links. This information is used to make our websites and the displayed advertising more relevant to your interests. We may also share this data with third parties for these purposes.

We may collect analytics data or use third-party analytics tools like Google Analytics to measure traffic and usage trends. Google’s practices can be reviewed at https://policies.google.com/privacy/partners, and opt-out options can be found at https://tools.google.com/dlpage/gaoptout.

Additionally, we may collaborate with third-party partners to employ technologies, including statistical modeling tools, to identify and contact you across multiple devices.

While we strive to respect users’ privacy preferences, we are currently unable to respond to “Do Not Track” signals set by your browser.

Please note that you can typically change your cookie settings in most browsers. However, refusing cookies may limit your ability to use all the features of our websites. Instructions for managing cookies in various browsers can be found in the respective “options” or “preferences” menus, or in the browser’s “Help” section.

Deleting cookies does not remove non-cookie technologies like Local Storage Objects (LSOs), such as Flash objects and HTML5. Information about Flash objects, including privacy and storage settings, can be found on Adobe’s website. Various browsers may offer their own management tools for removing HTML5 LSOs.

Third-Party Data Collection and Interest-Based Advertising

We participate in interest-based advertising and work with third-party advertising companies to serve targeted advertisements based on your browsing history. We allow third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our websites and mobile apps over time. They may display ads on our services, other websites, apps, or services you use, and across various devices you employ. This information is often gathered through cookies or similar tracking technologies that recognize the device you are using and collect data like clickstream information, browser type, and visit timestamps.

We may share a common account identifier, such as an email address or user ID, with our third-party advertising partners to identify you across devices.

This data helps us and our third-party partners show you online advertisements that are more relevant to your interests. It also aids in providing advertising-related services such as reporting, attribution, analytics, and market research.

Please be aware that some opt-outs may not work unless your browser accepts cookies. If you delete cookies, modify your browser settings, switch browsers or devices, or use a different operating system, you may need to opt-out again.

Links to Third-Party Sites

Our websites may occasionally contain links to and from third-party websites. Please be aware that these websites have their own privacy policies, and we do not accept any responsibility or liability for their policies. We recommend reviewing the individual policies before submitting any information to those websites.

Our Policy Towards Children

Our services are intended for adults, and we do not knowingly collect personal information from children under 13. If you become aware that your child has provided us with personal information, please contact us so we can take steps to remove such information and terminate any accounts your child may have created.

Changes to this Policy

We may update this Privacy Policy periodically, so we encourage you to review it from time to time. Material changes to this Privacy Policy will be indicated by updating the “last modified” date at the end of this Privacy Policy. Changes become effective when posted on this page.

Notice to You

If we need to provide you with information for legal, marketing, or other business-related purposes, we will choose the most suitable way to contact you, typically via email or by placing a notice on our websites. However, you can still opt out of certain types of contact as described in this Privacy Policy.