Privacy Policy

This Privacy Policy was last updated on November 24, 2020.

Welcome to homesteady.so! This Privacy Policy applies to homesteady.so (and any subdomains thereof) (the “Site”), which is owned, operated, licensed, and controlled by HomeSteady Digital Finance, Inc., a Delaware corporation (together with its related, affiliated, and subsidiary companies, “HomeSteady,” “we,” or “us”). This Site has been created to provide information about our company, our home equity marketplace, and related services (together with the Site, the “Services”) to our Service visitors (“you,” or “your”). This Privacy Policy describes how HomeSteady collects and uses the personal information you provide on our Site. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Your privacy and the protection of your sensitive personal information are important to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information. If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

In addition to this Privacy Policy, you are subject to additional policies, such as our Terms of UseCredit Report Policy, and Consent to Electronic Communications and Electronic Signatures (collectively, the “HomeSteady Policies”), that may be posted on the Site from time to time. All terms from such HomeSteady Policies are hereby incorporated by reference. You also have certain rights under the Fair Credit Reporting Act, a summary of which can be found here.

IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY AND THE OTHER POINT POLICIES, DO NOT USE THE SITE.

If you have any questions, complaints or suggestions regarding our Privacy Policy or practices, please contact us at policies@homesteady.so.

CHANGES TO PRIVACY POLICY

The Services, relevant privacy laws, and our privacy practices may change from time to time. As a result, at times it may be necessary for HomeSteady to make changes to this Privacy Policy. HomeSteady reserves the right to update or modify this Privacy Policy at any time without prior notice. When HomeSteady makes changes to this Privacy Notice, we will post the updated notice on this Site and update the date on which this Privacy Policy was last updated. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services and this Site after the posting of changes to this Privacy Policy constitutes your acceptance of the revised Privacy Policy.

INFORMATION WE COLLECT

When you interact with us through the Services, we may collect personal data and other information from you, as further described below:

Personal Data That You Provide Through the Services

We collect personally identifiable data including financial information (“Personal Data”) from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, apply for a HomeSteady product, or use certain Services. Most of the collection occurs when you register with the Site to apply for a HomeSteady product.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of HomeSteady and the authorized third parties referred to herein located in the United States.

We will retain your Personal Data as long as your account is active or as needed to provide you the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. HomeSteady may still need to keep certain personal details of customers to ensure that systems reflect your preferences even if a customer has chosen to opt out of allowing HomeSteady to use that customer’s personal details for marketing purposes. HomeSteady may keep records of any transaction a customer enters into on the Site for a minimum of seven years from the end of HomeSteady’s relationship with the customer. HomeSteady may keep other information about a customer only to the extent necessary to comply with applicable laws and to further legitimate business needs.

Some of the Services implement the Google Maps web mapping service. Your use of Google Maps is subject to Google's Privacy Policy, available at https://www.google.com/intl/ALL/policies/privacy/index.html.

Other Information: Non-Identifiable Data

HomeSteady uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant HomeSteady and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy. If you choose to become a HomeSteady customer, HomeSteady may continue to access, transfer, and store your data using Plaid for the duration of your agreement.

When you interact with HomeSteady through the Services, we receive and store certain personally non- identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. HomeSteady may store such information itself or such information may be included in databases owned and maintained by HomeSteady affiliates, agents, or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, IP addresses, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. HomeSteady or its service providers send cookies when you surf our Site or sites where HomeSteady ads appear, make purchases, request or personalize information, or register yourself for certain Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features; if cookies are not accepted, most features of our Site will not be available to you. HomeSteady does not store passwords or any other information about a visitor without a HomeSteady account in a cookie that would identify them, locate them, and determine their preferences or their financial activity.

Other Information: Aggregated Personal Data

In an ongoing effort to better understand and serve the users of the Services, HomeSteady often conducts research on its customer demographics, interests, and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and HomeSteady may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. HomeSteady may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site, including if users browse the Site across multiple devices such as a home computer and mobile device, and enhance your experience when you use the Service. Your continued use of the Site indicates your consent to our use of Google Analytics. If you wish to opt out from HomeSteady’s use of Google Analytics go to https://support.google.com/analytics/answer/181881?hl=en for instructions on installing the Google Analytics opt-out browser add-on. For more information on how Google uses this data, go to http://www.google.com/policies/privacy/partners/.

OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION

HomeSteady uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. HomeSteady and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. HomeSteady and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us at policies@homesteady.so. If HomeSteady intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION

HomeSteady is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

YOUR CHOICES

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

EXCLUSIONS

This Privacy Policy does not apply to any Personal Data collected by HomeSteady other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to HomeSteady through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, blogs, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and HomeSteady shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

CALIFORNIA PRIVACY RIGHTS AND DISCLOSURES

This summary of California privacy rights and disclosures (“California Notice”) applies solely to residents of the State of California and provides additional information about how we collect, use, and disclose personal information of California residents in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”).  Any terms defined in the CCPA have the same meaning when used in this California Notice.

For the purposes of this California Notice, “personal information” has the meaning provided by the CCPA and does not include:

Collection and Use of Personal Information

We collect personal information from and about you for the following purposes: provide Services to you; to communicate with you; for marketing and advertising purposes; to monitor, improve, and develop our products and Services; to protect the security and integrity of our business; comply with regulatory requirements and obligations; for our business and operational purposes; and/or as otherwise permitted or required by law.

In the past 12 months, we have collected the following categories of personal information:

Category of Personal Information Collected Sources of Personal Information Business or Commercial Purposes for Collection of Personal Information
Identifiers, including your name, address, and phone number.
  • Our business partners and affiliates
  • Third parties you direct to share information with us
  • Social networks
  • Data providers
  • Create accounts
  • Provide the Services
  • Internal research, including maintaining and developing the Services
  • Marketing
  • Security and detection of unauthorized activities
Internet/Network Information, including your device information, logs, and analytics data.
  • Directly from you, if any
  • Indirectly from you (e.g., through cookies)
  • Third-party service providers (e.g., Google Analytics)
  • Provide the Services
  • Internal research, including maintaining and developing the Services
  • Marketing
  • Security and detection of unauthorized activities
Geolocation Data, such as precise location information
  • Your browser or device
  • Generated based on IP address
  • Provide the Services
  • Internal research, including maintaining and developing the Services
Inferences about your interests and preferences generated from your use of our Site.
  • User-submitted information
  • Passive data collection
  • Provide the Services
  • Internal research, including maintaining and developing the Services
  • Marketing

Disclosure of Personal Information for a Business Purpose

In the preceding 12 months, we have disclosed the categories of personal information detailed in the table above to service providers.  When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose other than providing the services under the contract.

Sale of Personal Information

We have not sold your personal information in the past 12 months.

Your Rights and Choices

The CCPA provides you, as a California resident, with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

If you are a California resident whose information is covered by the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the Exercising Access, Data Portability, and Deletion Rights section below), we will disclose to you:

Deletion Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see the Exercising Access, Data Portability, and Deletion Rights section below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above,please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  

Household Information: There may be some types of personal information that can be associated with a household (a group of people living together in a single home). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above. If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request.

Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

CHILDREN

HomeSteady does not knowingly collect Personal Data from minors under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a minor under the age of 18 has provided Personal Data to HomeSteady through the Services, please contact us at policies@homesteady.so, and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by HomeSteady (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that HomeSteady endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

INTEGRATION SOCIAL NETWORKING SERVICES

One of the special features we may offer with the Service is to enable you to log in to various social networking services like LinkedIn or Facebook (“Social Networking Service(s)”) via the Services. By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and HomeSteady shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

TELL-A-FRIEND AND OTHER USER REFERRAL ACTIVITIES

Users may choose to refer friends to the Site via email.

If this referral occurs independently of our Site or a partner’s site, we do not track the referral other than as a unique page view. Since we do not collect any information from the referring party or the recipient of the external email referencing our site, we do not capture or store any information about either party. If friends refer each other to our Site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities that contributed to the referral. Our users can also refer friends to the Site by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular HomeSteady product request, and the sender will not know whether you are an applicant, investor, or customer. The information collected in this process is only kept long enough to monitor whether the referral program is achieving the desired results in terms of attracting new visitors to the Site and converting them into applicants. Again, these are messages initiated by friends of the recipients, and the recipients will not be added to any mailing list or contacted by HomeSteady apart from this referral process, which may include invitation reminders. In the case where a bonus is offered to a member in return for the referral, HomeSteady will only retain the information about the referred parties to properly credit the account of the member initiating the referral. The information is not used for any other purpose.

Your friend may contact us at policies@homesteady.so to request that we remove this information from our database.

SECURITY

HomeSteady takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. All data entered into the HomeSteady site is encrypted using industry-standard 128-bit AES cipher and transported over secure TLS protocols. TLS allows sensitive information such as social security numbers to be transmitted securely. Your information is unreadable to anyone except HomeSteady. Additionally, HomeSteady does not store the login details of your linked accounts, such as usernames and passwords. No one at HomeSteady has access to the login details of your linked accounts.

Despite our efforts, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to HomeSteady via the Internet.

You can take several precautions to protect the security of your computer and Personal Data:

OTHER TERMS AND CONDITIONS

Your access to and use of the Services is subject to the Terms of Use.

ACCESS TO INFORMATION; CONTACTING POINT

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about HomeSteady’s Privacy Policy or the information practices of the Services at policies@homesteady.so.