This Privacy Policy (“Policy”) describes how Embed Inc. d/b/a Pylon, Pylon Lending (“Pylon,” “we,” or “us”) may collect, use, disclose, and otherwise process personal information in connection with our “Powered by Pylon” suite of products and services that allows our business clients to integrate Pylon services or features within their own websites (collectively, the “Services” and “Partner/s”). 

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”), as amended by the Consumer Privacy Rights Act of 2023, provides specific rights and protections to California residents. If you are a California resident, please see our Privacy Notice for California Consumers for more information. Pylon further recognizes privacy legislation in other states, including Colorado, Connecticut, Utah, and Virgina and will provide all consumer rights applicable in accordance with legal and regulatory thresholds.  

What We Collect

The categories of personal information we collect depend on how you interact with our Services, and the requirements of applicable law. For example, we may collect:

• Consumer’s Personal Information, such as a consumer’s name, address, telephone number, mobile number, email address, and Social Security Number.
• Loan Application Information, such as when you apply for a loan, a pre-approval letter, or request related information such as mortgage rates, we may collect financial information such as your household income and expenses, financial account details, employment history and payment card information, outstanding debt, mortgage pre-approval documentation, demographic information, and other information related to funding availability. 
• Property Information, such as addresses, prices, photos, and other information about the properties. 
• Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams.
• Online Identifiers, such as geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
• Usage Data, such as authentication data, and other data collected via cookies and similar technologies.
• Information We Get From Others. We may obtain information about you from other sources, including through third party services and organizations. We may collect information about your identity and finances from third parties. For example, we may receive information about you from a third-party identity verification service. We may also receive information about your funding availability from a third-party financial institution. In addition, if you access our Services through a third-party application, such as a social networking site, third-party login service or other website (our “Partner/s”), we may collect information about you from that third-party that you have made available via your privacy settings or have otherwise consented to disclose. In addition, we may receive information about you from a third-party through which you have expressed interest in buying or selling a home and consented to sharing of your information for that purpose.
• Credit Information. When you check your rate or apply for a loan, we may collect information from credit bureaus and other third parties to facilitate determinations for credit eligibility, perform analyses, provide you with marketing offers, and/or assess risks related to extending credit to you and any co-applicant, and, if you are a  loan applicant, to help investors determine whether to commit to your loan. Such information may include your credit score, credit history, and other information related to your creditworthiness, identity, and financial transactions. When you obtain a loan, we may also collect information throughout the life of your financial obligation to us from the credit bureaus and other third parties in order to assess risks associated with your financial obligation, perform analyses, provide information to investors interested in buying or selling your financial obligation, and/or to provide you with marketing offers. If another entity refers you to us or assists you in any way in the application process, we may also collect your information from that company.
• Information from cookies and other tracking technologies. We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of our Sites and mobile apps, and collect information about the use of the Services, as well as about our interactions with you. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, and information about your interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Services may not function properly.
• Third Party Property Information. We may collect information about properties from third parties. This information may include photos, location, price and sales transaction details, tax records, and appraisals. This third party property information may relate to properties you identify, and may be associated with your account.

How We Use Information

We use your personal information for a variety of business purposes, including:

• Providing Services And Features. We may use the information we collect to provide, personalize, maintain, and improve our products and Services. This includes using information to:
  1. operate, maintain, customize, measure, and improve our Services, and manage our business; 
  2. create and update user accounts;
  3. process transactions, including providing services specific to the escrow and loan approval process;
  4. send information, including confirmations, notices, invoices, technical notices, updates, security alerts, and support and administrative messages; and 
  5. to create de-identified or aggregated data.
  6. to assess and pursue potential business opportunities.
• Safety And Security. We may use your information to help maintain the safety, security, and integrity of you as a customer and our Services, including to:
  1. protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
  2. monitor and verify identity or service access, combat spam, malware or security risks;
  3. perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems;
  4. enforce our agreements with third parties, and address violations of our Terms of Service or agreements for other Services; and
  5. comply with applicable security laws and regulations.
• Customer Support. We may use information we collect to provide customer support, including to:
  1. direct questions to the appropriate customer support person;
  2. investigate and address user concerns; and
  3. monitor and improve our customer support responses and processes.
• Research And Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes, develop new features and products, and facilitate payment solutions in connection with our Services.
• Legal And Regulatory Compliance. Many of our Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. We also use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. If you do not provide information required by law, we will have to close your account and/or will not be able to provide you with Services. We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
• De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
• Direct Marketing. We may use the information we collect 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. If you do not want us to send you marketing communications, please opt out by selecting “unsubscribe” to any marketing email sent by us or by contacting us at compliance@pylonlending.com.
• Telephonic Communications. We may use the information we collect 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 compliance@pylonlending.com.

How We Share And Disclose Information

We may share your information in the following circumstances:

• With Your Consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
• With Our Partner/s Who Hosts The Platform For Our Services. We share your Loan Application Information with our Partner whose website you use to access our Services. Such information may be used for any of the following purposes: a. integration of the Services into our Partner’s website; b. improvement of the quality of the services and products offered to you by our Partner; c. marketing purposes by our Partner. By creating your account on the Platform you are providing us with your express consent to share your information with our Partner’s whose website you are using to access the Services. Please note that we will never share your Credit Information with our Partner/s other than on a need to know basis for the fulfillment of professional services provided to you and in accordance with the required licensing.

Federal law gives you the right to limit our sharing of information when it is used for the purpose of marketing to you. We may begin sharing your information to be used for marketing purposes 30 days from the date that we first provided this notice if you have not opted-out. If you wish to opt out of our sharing your information for marketing purposes, please contact us at compliance@pylonlending.com. Please note that you may still receive marketing communications from our Partner, but those marketing communications will not result from our information sharing and may be less relevant to you. 

• To Comply With Our Legal Obligations. We may share your information: (A) to comply with laws and regulations; (B) to cooperate with government or other regulatory investigations, including when we are compelled to do so by a subpoena, court order, or similar legal procedure; (C) to comply with one or more forms of “travel rules” that require our transmitting of your information to another financial institution; (D) when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss; (E) to report suspected illegal activity; or (F) to investigate violations of our User Agreement or any other applicable policies.
• With Third-Party Identity Verification Services. We may share your information to help prevent fraud and deny service to persons presenting an unacceptable level of money laundering, terrorism financing, or fraud risks. This allows us to confirm your identity by comparing the information you provide us to public records and other third-party databases. These providers may create derivative data based on your personal information that they can use in connection with provision of identity verification and fraud prevention services. We do not control these providers’ privacy policies.
• With Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment, loan, and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services. 
• With Financial Institutions. We may share your information with financial institutions to process payments you have authorized.
• During A Change To Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, or other change of control, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated Or De-identified Data. We may share aggregated and/or anonymized data with others for their own uses.

Data Retention

We store the personal information we receive as described in this Privacy Policy For as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We use significant safeguards, including physical, electronic, and operational controls to protect your personal information, both during transmission and once received. These may include secure servers, encryption, firewalls, antivirus systems, antispam technologies, access minimization, intrusion prevention systems, malware detection systems, data loss prevention systems, and vulnerability scans.

Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you. 

You are responsible for maintaining the confidentiality of your login id, password or any links sent to you related to your information. If you believe that they have been stolen or been made known to others, you must contact us immediately at compliance@pylonlending.com.

We are not responsible if someone else accesses your account through information they have obtained from you or through a violation by you of this Privacy Policy or Pylon Terms of Use.

If you are forwarding any links related to data or otherwise provided by Pylon, you are doing so at your own risk. Pylon cannot be held liable for any consequences of such sharing.

If you have a security related concern, please contact us at compliance@pylonlending.com. We will work closely with you to ensure a rapid and personal response to your concerns.

Age Limitations

The Services are directed to those  18 years of age or older , capable of forming a binding contract and are not barred from using the Services under applicable law. We do not knowingly collect personal information from anyone under 18 years of age. If you learn that your minor child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

Changes To This Policy

If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed. If we make material changes, we will provide additional notice, such as via the email specified in your account or through the Services or Sites.

Online Tracking Opt-Out Guide

Like many companies online, we use services provided by Google and other companies that use tracking technology. These services rely on tracking technologies—such as cookies and web beacons—to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.  For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers.

Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

• Google: https://adssettings.google.com

Advertising industry opt-out tools.  You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

• Digital Advertising Alliance: http://optout.aboutads.info
• Network Advertising Initiative: http://optout.networkadvertising.org/?c=1
• Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

How You Can Change Your Personal Information

If you have applied for a loan, you can access the personal information you have provided to us by logging in and navigating to the “Settings” page of your account. You can update your password, email, phone number, or home address at any time. As a registered personal loan applicant or borrower, you may update your password, email, phone number, bank account information, or mailing address at any time, though certain changes prior to loan origination may require you to submit a new loan application. To change your information, you may also contact us at compliance@pylonlending.com. We will respond to your request within a reasonable time.

Or by calling our customer service at (855) 300-8520.

For all customers, we will retain your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes, conduct analysis and audits, or enforce our agreements as otherwise permitted and/or required by law.

Contact Us

Please contact us if you have any questions about this Policy or if you are seeking to exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at compliance@pylonlending.com or at our mailing address below: 

Address: 215 Park Avenue South, 11th FL

New York, NY 10003

Attn: Legal Department

Federal Policy Notice

Date: July 17, 2024