Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). For Utah residents, we are subject to the Utah Consumer Privacy Act (UCPA), effective December 31, 2023. For Colorado residents, we are subject to the Colorado Privacy Act (CPA), effective July 1, 2023. For Virginia residents, we are subject to the Virginia Consumer Data Protection Act (VCDPA), effective January 1, 2023. For Connecticut residents we are subject to the Connecticut Data Protection Act (CTDPA), effective July 1, 2023. We may update and make changes to this policy, so we encourage you to review it periodically. We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.
Key Terms. It would be helpful to start by explaining some key terms used in this policy:
We, us, our | HOUSEWELL TECHNOLOGIES, INC. and our group companies, including Housewell.com Realty, LLC |
Our representative | Parker Bryant or his named successor |
Our data protection officer | Parker Bryant or his named successor parker@housewell.com |
Personal information | Any information relating to an identified or identifiable individual. |
Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation. |
Sensitive Personal Information | Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information. |
Biometric Information | An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
Loan Services | The mortgage services will be referred to as “Loan Services” and together with other services - the “Services” |
Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information | Specific Types of Personal Information Collected |
Identifiers | Name, online identifier, Internet Protocol address, and if provided and useful for a transaction: full name, alias, postal address, unique personal identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. |
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, household income and expenses, financial account details, payment card information, outstanding debt, demographic information, and other information related to funding availability, any other financial information, medical information, or health insurance information. Property Information, such as addresses, prices, photos, and other information about the properties you own or consider financing. | No information in this category unless voluntarily provided by you or authorized by you to be obtained from third-parties, and beneficial in the use of our services. |
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | No information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Characteristics of protected classifications under California or federal law. | No additional information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | No information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Biometric information | No information in this category. |
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) | No information in this category. |
Geolocation data | No information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Audio, electronic, visual, thermal, olfactory, or similar information | No information in this category. |
Professional or employment-related information | No information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) | No information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | We may use any of the information identified above to draw inferences about the commercial appropriateness of any brokerage, administrative, ministerial and/ or financial services provided to you by us. We do not broker, market, or offer you any additional or third party services to you based on our inferences other than those services specifically listed on our website and platforms. |
Racial or ethnic origin, religious or philosophical beliefs, or union membership | No information in this category unless voluntarily provided by you and beneficial in the use of our services. |
Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication | No information. |
Genetic data | No information. |
Processing of biometric information for the purpose of uniquely identifying a consumer | No information. |
Health information | No information. |
Sex life or sexual orientation | No information. |
Additional Information We Collect from Others | We obtain information from our mortgage partner, Embed Inc. and third-party services and organizations with respect to your mortgage loan application and purchased property/property of interest. This information may include the following: your loan application status, your pre-approval amount, your loan, amount, loan rate and other loan terms, your borrowers’ and co-borrowers’ information, information of other property owners not in the loan application, information of the subject property, property purchase price, your loan team, escrow and title professionals and the real estate agents in your purchase transaction. |
If you do not provide personal information required to provide products AND/OR services to you, unfortunately it may delay or prevent us from providing products AND/OR services to you.
How Your Personal Information is Collected. We collect personal information from the following categories of sources:
You, directly in person, by telephone, text, or email and/or via our website, the Housewell platform related and applications which you access in conjunction with using our services.
Third party with your consent (e.g., your bank)
Advertising networks
Internet service providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks
Data brokers
Publicly accessible sources (e.g., property records)
Cookies on our website
Our IT and security systems, including:
Door entry systems and reception logs
Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems –and–
any other relevant systems if applicable
How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party –or–
Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for | Our reasons |
To provide products AND/OR services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
To prevent and detect fraud against you or us | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator |
To comply with our legal and regulatory obligations such as maintaining records for tax purposes or responding to awful requests from law enforcement or regulatory agencies. |
If necessary, for gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information and to comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price We may use your information to analyze customer behavior, evaluate the effectiveness of our marketing strategies, and identify areas for improvement in our products, services, or website. Your information may be used to conduct research and develop new products, services, or technologies. |
Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
Statutory returns | To comply with our legal and regulatory obligations |
Customer Support | We may use your information to respond to customer inquiries, provide assistance, or troubleshoot issues related to products or services. |
Mergers and Acquisitions | In the event of a business merger, acquisition, or sale, your information may be transferred to the acquiring or resulting entity as part of the transaction. |
Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing and telephonic communications regarding our services and those of selected third parties to:
|
For our legitimate interests or those of a third party affiliate, i.e., to promote our business to existing and former customers We may use your information to market our Services to you. This may include sending you communications about our Services, features, promotions, surveys, news, updates, and events, and managing your participation in these promotions and events. We may use your information to contact you by telephone for any purpose described above, including marketing. By providing us a telephone number, you are providing express written permission and consent for us to contact you at that phone number at any time, for any lawful purpose. The ways in which we may contact you include live operator, automatic telephone dialing system (auto-dialer), prerecorded and artificial voice message, or text/SMS. Phone numbers you provide include those you give to us and those from which you, or someone acting on your behalf, contact us. You may revoke your authorization for some, but not all, types and forms of communications. If you would like to revoke your consent to receive marketing calls or text messages and/or automated calls or text messages, email us at support@housewell.com |
When applicable, credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.
EEA Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside the Housewell family for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
Contacting us at support@housewell.com
Using the “unsubscribe” link in emails or “STOP” number in texts or
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With. We routinely share personal information with:
Our affiliates, including companies within the Housewell family of companies, and with Embed Inc. dba Pylon, Pylon Lending, our non-affiliated mortgage partner (“Pylon”). We share your information with Pylon for the processing and origination of your loan. By creating your account on our mortgage platform you are providing us with your express consent to share your information with Pylon. Please note:
Pylon and we are not engaged in joint marketing activities
Pylon and we share consumers’ information for marketing purposes as described herein
Pylon and we do not share consumers’ information with affiliates
Pylon and we share consumers’ information with nonaffiliates (with one another and service providers)
Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies
Other third parties we use to help us run our business, such as marketing agencies or website hosts
Financial Institutions. We may share your information with financial institutions to process payments you have authorized.
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
Credit reporting agencies
Our insurers and brokers
Our bank(s)
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Personal Information We Sold or Shared. In light of Section 6, in the preceding 12 months, we may have sold or shared the following categories of personal information:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Characteristics of protected classifications under California or federal law
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Biometric information
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) –and–
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Categories of Personal Information We May Have Disclosed for a Business Purpose. In the preceding 12 months, we may have disclosed the following categories of personal information for a business purpose:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Characteristics of protected classifications under California or federal law
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Biometric information
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–
Sensitive personal information
How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf,
To show that we treated you fairly –or–
To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When and if it is no longer necessary to retain your personal information, we will delete or anonymize it.
California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of:
Please note that we are not required to:
|
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: housewell.com/limit-do-not-share |
Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, visit our homepage and click on the "Limit the Use of My Sensitive Personal Information" link here: housewell.com/limit-do-not-share |
Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is reasonably necessary to:
|
Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
EEA Data Subjects: Your Rights Under the EU GDPR.
Right to Be Informed | The right to know or be notified about the collection and use of your personal information. |
Right to Access | The right to be provided with a copy of your personal information (the right of access) |
Right to Rectification | The right to require us to correct any mistakes in your personal information |
Right to be Forgotten | The right to require us to delete your personal information—in certain situations |
Right to Restriction of Processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data |
Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations |
Right to Object | The right to object:
|
Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.
How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: housewell.com/limit-do-not-share You may also call us at 678-602-9511 or email us at support@housewell.com Parker to provide this information.
Please note, due to the nature of services we provide, the analytical and fraud prevention requirements necessary to provide these services, and the nature of the real estate and financial industries in general, in the if we are required to delete or return certain data, then we may not be able to provide you with certain services and inform you accordingly.
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by [website/email/phone/in writing], you will need to provide us with:
Enough information to identify you (e.g., your full name, address and customer or matter reference number)
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
EEA Data Subjects: Where Your Personal Information is Held. Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”
EEA Data Subjects: Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
With our offices outside the EEA in the US
With your and our service providers located outside the EEA
If you are based outside the EEA –or–
Where there is an international dimension to the services we are providing to you
These transfers are subject to special rules under European and UK data protection law.
The US is a non-EEA countries and certain States within the US and the US as a whole does not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact our Data Protection Officer (see “How To Contact Us” below).
Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
EEA Data Subjects: How to File a GDPR Complaint. We hope that [we OR our Data Protection Officer] can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Notice. This privacy notice was published on 12/20/2023 and last updated on 12/20/2023.
We may change this privacy notice from time to time–when we do, we will inform you via our website.
How to Contact Us. Please contact our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Our contact details | Our Data Protection Officer's contact details |
580 Marsh Park Drive Duluth, Georgia | 580 Marsh Park Drive Duluth, Georgia |
support@housewell.com | parker@housewell.com |
678-602-9511 | 678-602-9511 |
Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).