END-USER PRIVACY POLICY

OF

MIRADOR FINANCIAL, INC.


Last modified: September 5, 2014


Introduction


We, Mirador Financial, Inc., a Delaware corporation (the “Company” or “We”), respect your privacy and are committed to protecting it through our compliance with this policy. This policy applies to all loan applicants using the Mirador Technology (as defined below).  By using the Mirador Technology, you are agreeing with and consenting to the terms of this policy.  If you do not agree with or consent to the terms of this policy, do not use the Mirador Technology.  This policy describes:


The types of information we may collect or that you may provide when you access or use Mirador’s loan application and related services (the “Mirador Technology”).  For the avoidance of doubt, this policy only governs your use of the Mirador Technology and does not govern your use your use of any other portion of the website of the financial or lending institution into which the Mirador Technology is embedded.  


Our practices for collecting, using, maintaining, protecting and disclosing that information.


This policy applies only to information we collect in the Mirador Technology and in e-mail, text and other electronic communications sent through or in connection with the Mirador Technology.


This policy DOES NOT apply to information that:


We collect offline or on or through any other Company technology, applications, or websites, including websites you may access through the Mirador Technology.


Third parties (including the financial or lending institutions whose websites have the Mirador Technology embedded therein) may have in their own privacy policy, which we encourage you to read before providing information on or through them.


Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access or use the Mirador Technology. By accessing or using the Mirador Technology you agree to this privacy policy. This policy may change from time to time. Your continued use of the Mirador Technology after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.


Children under the Age of 13


The Mirador Technology is not intended for children under 13 years of age, and we do not knowingly collect Personal Information (as defined below) from children under 13. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected]


Information We Collect and How We Collect It


We collect information from and about users of our Mirador Technology:


Directly from you when you provide it to us;

Automatically when you use the Mirador Technology;

We retrieve information about you that is made publicly available, whether through public records, online sources, or other sources;

From third parties that have provided us with information about you; and

We collect information you authorize us to collect, such as bank account information, credit reports, and other information our partners need to make a lending decision.


Consent to Retrieve Information


By submitting your information into, or otherwise using, the Mirador Technology, you thereby give your consent to us to conduct a search for additional information about you, including, but not limited to:


Credit reports;

Records in the public record or public domain (including, but not limited to, court records and real property records);

Information made publicly available through social media sites and searches;

Financial information (such as business and personal financials);

Tax returns;

Information that you have provided to third parties that is relevant to making a lending decision; and

Other documentation required as part of a lending decision.


Information You Provide to Us


When you use the Mirador Technology, we may ask you to provide information:


By which you may be personally identified, or by which your business may be identified, such as name, postal address, e-mail address, telephone number, social security number, employer identification number, or any other identifier by which you may be contacted online or offline (“Personal Information”).


That is about you or your business but individually does not identify you or your business.


This information includes:


Information that you provide by filling in forms in the Mirador Technology. This includes information provided at the time of submitting a loan application through the Mirador Technology. We may also ask you for information to take part in a promotion sponsored by us, and when you report a problem with the Mirador Technology.


Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us.


Your responses to surveys that we might ask you to complete for research purposes.


Automatic Information Collection and Tracking


When you access and use the Mirador Technology, it may use technology to automatically collect:


Usage Details. When you access and use the Mirador Technology, we may automatically collect certain details of your access to and use of the Mirador Technology, including traffic data, location data, usage patterns, logs, and other communication data and the resources that you access and use on or through the Mirador Technology.


Device Information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and mobile network information.


If you do not want us to collect this information do not access or use the Mirador Technology.


Information Collection and Tracking Technologies.  The technologies we use for automatic information collection may include:


Cookies (or mobile cookies). A cookie is a small file placed on your device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of our Mirador Technology. 


Web Beacons. Pages of the Mirador Technology and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related Mirador Technology statistics (for example, recording the popularity of certain Mirador Technology content and verifying system and server integrity).


How We Use Your Information


We use information that we collect about you or that you provide to us, including any Personal Information, to:


Provide you with the Mirador Technology and its contents (including updates and maintenance releases), and any other information, products or services that you request from us.


Fulfill any other purpose for which you provide it.


Give you notices about your loan status.


Carry out our obligations and enforce our rights arising from any contracts entered into between us and the financial and lending institutions to whom you are submitting a loan application.


Compile use statistics and run analytics on such information.


To comply with applicable laws and regulations.


The usage information we collect helps us to improve our Mirador Technology and to deliver a better and more personalized experience by enabling us to:


Evaluate our customer usage patterns.


Store information about your preferences, allowing us to customize our Mirador Technology according to your individual interests.


Recognize you when you use the Mirador Technology.


In the event the financial or lending institution to whom you submitted a loan applications declines your loan application or otherwise does not close a loan with you, we may also use your information to contact you about other financial and lending institutions that may be interested in underwriting your proposed loan. 


Disclosure of Your Information


We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.


In addition, we may disclose Personal Information that we collect or you provide:


To the financial or lending facility to whom you submitted a loan application.


In the event your application is declined or a loan is otherwise not made, we may request your permission to disclose such Personal Information to other financial or lending institutions that may be interested in underwriting your proposed loan.


To our subsidiaries and affiliates.


To contractors, service providers and other third parties we use to support our business.


To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Company about our Mirador Technology users is among the assets transferred.


To fulfill the purpose for which you provide it.


For any other purpose disclosed by us when you provide the information.


With your consent.


To comply with any court order, law or legal process, including to respond to any government or regulatory request.


To enforce our rights arising from any contracts entered into between us and the financial or lending institution who is using the Mirador Technology


If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. 


Accessing and correcting your Personal Information.


You can review and change your Personal Information by contacting the financial or lending facility to whom you submitted a loan application.

 

You may also send us an e-mail at [email protected] to request access to, correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.


Your California Privacy Rights


California Civil Code Section 1798.83 permits users of our Mirador Technology that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to [email protected] or write us at: Mirador Financial, Inc., 319 SW Washington St. Suite 501, Portland, OR 97204.


Data Security


We have policies restricting access to nonpublic Personal Information about you to those employees and affiliates who have a need to know such information (e.g., to process your loan application or provide services to you). We and our affiliates have implemented and maintain physical, electronic, and procedural safeguards designed to protect against loss or unauthorized access, disclosure, alteration or destruction of the information you provide through the Mirador Technology.  


Additionally, we have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls, and all transmitted data will be encrypted using SSL technology.


The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Mirador Technology, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out private information to other users of the Mirador Technology or third parties.


Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our Mirador Technology. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.


Data Retention and Deletion Policy


Mirador will retain all user information (including Personal Information) that it collects for an indefinite period of time.  Mirador will use such information to help improve the Mirador Technology.  Notwithstanding the foregoing and subject to applicable law, Mirador reserves the right to delete or destroy any information collected at any time without further notice to you. If you would like Mirador to delete your information from their servers and databases, please contact Mirador directly using the contact information provided below and Mirador will use reasonable efforts to accommodate your request.


Changes to Our Privacy Policy


We may update our privacy policy from time to time. If we make material changes to how we treat our users’ Personal Information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated.


The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.


Contact Information


To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected] or write us at: Mirador Financial, Inc., 319 SW Washington St. Suite 501, Portland, OR 97204.