Privacy Policy

Ainectra, Inc. ("Company," "we," "us" or "our") operates the TheLoanOfficer website located at theloanofficer.io and TheLoanOfficer mobile software application (collectively, the "Platform"). This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy (the "Websites");
• Software applications made available by us for use on or through computers and mobile devices (the "Apps");
• Our social media pages and apps located (collectively, our "Social Media Pages");
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the "Services."

We will update this Privacy Policy as described under "Updates to this Privacy Policy" below.

The Platform serves two types of users:

We may collect the following categories of personal information about you:

• Account information, identifiers and customer records information. When you create an account, we collect identifiers and customer records information, such as your name, email address, and your password.
• Consumer application information. If you are a Consumer, when you submit a match request, we collect identifiers and customer records information, such as your loan preferences, property information, and financial information.
  Self-reported credit score range (optional). You may optionally self-report an estimated credit score range (e.g., 620–659). This information is provided by you, is not obtained from any consumer reporting agency, and is not a "consumer report" under the Fair Credit Reporting Act. See Credit Information below.
• Subscriber professional information. If you are a Subscriber, we collect business and professional information, including your NMLS registration number and related licensing details.
• Uploaded documents and extracted data. You may upload documents to the Platform. Our AI tools extract and summarize data from those documents. See Artificial Intelligence Features in the Terms of Service.
• Payment and commercial information. When you purchase a paid subscription, we receive payment-related information from our third-party payment service provider (see Third Party Payment Provider below), such as your subscription status, plan, last four digits of your card, card brand, and billing event information.
• Usage data and internet or other network activity information. We collect information about how you interact with the Services, such as the pages or features you use, the time and duration of your sessions, device information, log data, analytics information, and other usage information.
• Device and connection information. We may automatically collect technical information about your device and connection, such as IP address, browser type, operating system, and approximate location derived from your IP address.
• Communications, feedback and other information you provide. When you contact us for support or otherwise communicate with us, we receive your message and the contact information you provide. When you provide feedback on recommendations or other features of the Services, we collect that feedback. We may collect this information directly from you, automatically from your device as you use the Services, and from third-party providers.

We and our service providers collect personal information in a variety of ways, including:

• Through the Services. We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, contact customer service, or make a purchase.
• From Other Sources. We receive your Personal Information from other sources, for example, other users, our service providers, publicly available databases, and joint marketing partners, when they share the information with us.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We use, collect and process the information described above for the following purposes:

• To operate the Services and fulfilling your requests. Including matching Consumers and Subscribers, tailoring matches to stated loan preferences, property information, and financial information, completing your transactions, and operating, maintaining, and securing the Services.

• To facilitate the Consumer-Subscriber relationship. Including sharing Consumer data with matched Subscribers.
• To improve and develop the Services. Including analyzing how users interact with the Platform in the aggregate, debugging and resolving issues, and developing new features.
• To communicate with you. Including sending account-related notices (such as confirmation emails, security alerts, and changes to our terms or policies) and responding to your support requests.
• To provide you with our newsletter and/or other marketing materials and facilitating social sharing.
• To allow you to participate in promotions.
• To comply with legal obligations and enforce our agreements. Including complying with applicable law, responding to lawful requests, enforcing our Terms of Service and/or the Subscriber Agreement between Company and Subscribers, and protecting our rights, property, and safety, and that of our users and others.
• To create aggregated and de-identified data. See Aggregated and De-Identified Data below.

We do not access, obtain, or use consumer report information from any consumer reporting agency, as those terms are defined under the Fair Credit Reporting Act ("FCRA"). As part of the inquiry process, Consumers may optionally self-report an estimated credit score range. Such self-reported range does not constitute a consumer report, is passed to matched Subscribers solely as context voluntarily provided by the Consumer, and is used by Company solely to facilitate matching with Subscribers. Company's use of such information does not constitute a permissible purpose under FCRA. Company does not make credit decisions and is not a "user" of consumer reports as defined under FCRA. Consumers should be aware that Subscribers may independently obtain consumer report information in connection with any formal loan application submitted directly to a Subscriber, subject to the Subscriber's own FCRA obligations.

We share your information with the following categories of recipients:

• Matched Consumers and Subscribers. We share your data with the Consumer(s) or Subscriber(s) matched to you.
• Service providers. Third parties that provide services (including hosting, storage, artificial intelligence, analytics, payments, and communications services) on our behalf.
• Business transfers. If we are involved in a merger, acquisition, financing, reorganization, sale of business assets, or similar transaction, your information may be transferred as part of that transaction.
• Legal compliance and protection. We may disclose information when we believe it is necessary to comply with applicable law or legal process, respond to government or law enforcement requests, enforce our Terms of Service or the Subscriber Agreement, or protect the rights, property, or safety of our users, our company, or others.
• With your direction. We will share information with third parties when you specifically direct us to do so.

"Other Information" is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
• Your use of the App. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Cookies. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to allaboutcookies.org. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
• Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
• Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to google.com/policies/privacy/partners, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as personal information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with personal information. If we do, we will treat the combined information as personal information as long as it is combined.

We may create aggregated, de-identified, or anonymized information from the information described in this Privacy Policy. Aggregated and de-identified information does not identify you and is not personal information. We may use and disclose aggregated and de-identified information for any lawful purpose, including improving the Services and conducting research. Where we maintain de-identified data, we will maintain and use the data in de-identified form and will not attempt to re-identify it except as required or permitted by law.

When you purchase a paid subscription or otherwise make a payment to us, payment processing is handled by Stripe, Inc. ("Stripe"). Stripe collects and processes your full payment information (including credit card number, CVV, and billing details) on our behalf as a service provider. We do not receive or store your full payment card details. We do receive certain payment-related information from Stripe. Stripe's collection, use, and disclosure of your information is subject to Stripe's own privacy policy.

For Subscribers only: We use one or more third-party identity verification providers to verify a Subscriber's identity in connection with license verification. The applicable provider(s) will be identified to Subscribers at the time of verification and may process biometric information as part of this verification, subject to the applicable provider's own privacy policy. We receive the results of the verification from the provider(s).

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal data you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

We retain your personal information only for as long as reasonably necessary to provide the Services to you, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. When information is no longer needed for these purposes, we delete it or de-identify it. We may retain aggregated and de-identified data for as long as it is useful for the purposes described in this Privacy Policy.

We use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you suspect that the security of your account has been compromised), please contact us using the contact information below.

The Platform provides several ways to manage your information:

• Edit your account. Update your name, email address, or password in your account settings.
• Request deletion of your account. You may submit a request to delete your account through the account settings. We may retain certain information as required for recordkeeping, legal, tax or regulatory purposes, even after an account deletion request is confirmed.

Depending on your state of residence, you may have some or all of the following rights with respect to personal information about you:

• Right to Know. The right to know whether we are processing personal information about you and to obtain certain details about the personal information we have collected, including the categories of personal information, categories of sources, categories of recipients, and purposes of processing.
• Right to Access. The right to access the personal information we have collected about you and, to the extent technically feasible and required by law, to receive a portable copy.
• Right to Correct. The right to correct inaccuracies in your personal information.
• Right to Delete. The right to request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Limit Use and Disclosure of Sensitive Personal Information. Where applicable, the right to limit our use and disclosure of sensitive personal information.
• Right to Non-Discrimination. The right to be free from retaliatory or discriminatory treatment for exercising your privacy rights.

To submit a privacy rights request, please contact us at support@theloanofficer.io. We may need to verify your identity and your state of residence before processing your request. Verification may require us to request additional personal information from you, ask you to confirm details about your account, or ask you to log in to your account if you have one. In certain circumstances, we may decline or limit your request, including where we are unable to verify your identity or as otherwise permitted by law.

The Platform is not directed to and not intended for use by individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18. If you believe that we have inadvertently collected personal information from an individual under 18, please contact us using the contact information below and we will take steps to delete that information.

Unless we specifically request it, we ask that you not send us, and not disclose, any sensitive personal information (for example, information about racial or ethnic origin, physical or mental health, or sexual orientation) through the Platform or otherwise to us.

The Platform is operated from the United States and is intended for users located in the United States. Your information will be stored and processed in the United States. By using the Platform you understand that your information will be transferred to and processed in the United States, which may have data protection rules that differ from those of your country of residence.

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Changes become effective when we post the revised Privacy Policy on the Platform. If we make material changes, we will notify you through the Platform or by other means before the changes take effect.

If you have any questions about this Privacy Policy, please contact us at support@theloanofficer.io.