Privacy Policy

Welcome to the website of PLUM, Inc., and thank you for paying us a visit! We are committed to respecting your privacy and this Privacy Policy explains how we gather, track and use information we learn about you through your use of our website and its services. As further explained below, tracking is only intended to improve our website, products and services. When you voluntarily provide information to us, we use it for the purpose for which it is intended – to analyze your request for a loan or other financial service and to see whether we can help you immediately or at some point in the future.

By using our website at www.plumlending.com or any subdomain thereof (the Site) or any of the services provided on our website (the Services), you consent to the data practices set forth in this Privacy Policy as well as the Site’s Terms of Service. Please understand that this Privacy Policy applies only to information collected through our Site and not to information collected from you offline or through other means of communication. If you have questions or concerns regarding this Privacy Policy, please feel free to contact us at hello@plumlending.com.

Information We Collect; Tracking Policies:

You can visit the Site without providing any personal data. The term “personal data” includes any information that enables the identification of a natural person, such as your name, physical address, email address and phone number and behavior. If you choose not to provide any personal data (which is perfectly acceptable), please understand you may not be able to use certain of the Services. When you interact with us through the Site, we may collect personal data, non-personal data and other information from you, all as described below:

1. Personal Data That You Provide Through the Services:

We may collect personal data from you when you voluntarily provide such information, such as when you contact us with inquiries, submit loan applications, register for access to the Services or use certain Services. This personal data may include, for example, personal information required to verify your identity, personal and financial information to assess your eligibility to borrow money through us or one of our business partners, personal information you may wish to share in furtherance of your goals in using our Services, and information about your visits to and use of this Site to help us maintain the appropriate features, functionality and user experience.
Certain personal information must be supplied during the loan application process through the “Apply Now” feature on our Site. This basic personal information may include:

• Your name
• Your email address
• Your telephone number
• A description of the property you own; and
• Other Information relevant to your loan request.

By voluntarily providing us with personal data, you are consenting to our use of it in accordance with this Privacy Policy and you acknowledge and agree that such personal data may be transferred from your current location to our offices and servers and the authorized third parties referred to in this Privacy Policy.

2. Non-Identifiable & Aggregated Personal Data:

When you visit the Site or interact with us through the Services, we receive and store certain personally non-identifiable information (such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files). Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. It is possible that third parties may collect certain similar information about your computer and other pages you may visit when you visit our Site.

In operating the Services, we may use technologies commonly called cookies, web beacons (also known as clear gifs, pixel tags, targeting and re-targeting pixels, third party pixels or web bugs) and other standard internet technologies to collect information from your computer and about your activities on our Site. A “cookie” is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services. If you do not want us to deploy cookies, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. Just understand that rejecting cookies may affect your ability to use the Site. If you do not reject cookies, we assume that you consent to the use of cookies. 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.

Our Use of Your Personal Data and Other Information:

We use 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 it in connection with the reason for which it was provided. For instance, when you apply for a loan, we may use this information to assess your loan, to facilitate activities and transactions that need to occur during the lending process, and to provide you with information about us. For example, we may:

• Contact you to discuss your loan request or other inquiries;
• Maintain regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, etc.; and
• To inform you about new product offers, carry out online surveys, or initiate similar measures aimed towards improving our Site and Services.

With respect to non-personal data that is gathered when you visit the Site or interact with us through the Services, we may use such information to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. We may also use such data and pool it with other information to track, for example the total number visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. In an ongoing effort to better understand and serve the users of the Services, we may choose to conduct research on our customer demographics, interest 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 we may choose to share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We 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.

Finally, we may use this information to contact you in the future to tell you about services we believe will be of interest to you. 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 as indicated below. When you register on our Site you may receive emails that confirm specific actions you requested. For example, you may receive notifications confirming your registration, the successful verification of email addresses, and confirmation of successful submissions of loan requests. You may also receive progress updates on the status of loan requests. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we may also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

HOW AND WHEN YOUR INFORMATION IS SHARED WITH OTHER PARTIES:

We consider your information and personal data to be an important part of our relationship with you. However, you should be aware that there are circumstances in which we may share your information and personal data with certain third parties without further notice to you, including, but not limited to, those set forth below:

• Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.
• Agents & Consultants: We, like many businesses, sometimes hire other companies to perform certain business-related functions, including, but not limited to companies that perform services on our behalf in connection with your request for a loan or the funding, sale and/or servicing of your loan.
• Lenders: In submitting a request for a loan product or service offered through this Site, you signify your agreement to proceed you are consenting, acknowledging and agreeing to the disclosure of your personal data with lenders in our network (Lenders) with whom you are or may be matched or to whom we may sell your loan.
• Legal Requirements: We may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, (iv) protect against legal liability, or (v) limit fraud.

Exclusions:

This Privacy Policy does not apply to any personal data collected by us other than personal data collected through the use of the Site and Services. Per our Terms of Service, this Privacy Policy does not apply to any personal data that is volunteered to us by anyone other than residents of the United States. This Privacy Policy shall not apply to any unsolicited information you provide to us 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 blogs and forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (Unsolicited Information). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Ownership and Purpose of the Site and Services:

The Site is owned and operated by us and has been created to provide information to you about our Services, including, without limitation, our real estate lending services, wealth management and investment products and services, property management and user forums, and all other related and ancillary services. This Site is a commercial website and is intended for use by commercial real estate owners and borrowers, real estate professionals, investors, and their employees and agents, to obtain information about our commercial financial products and services.

Children and Minors:

We do 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 us through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites:

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

Security:

We take reasonable steps to protect the personal data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any personal data via the Internet. Please refer to the Federal Trade Commission’s website for information about how to protect yourself against identity theft.

Special Notice to California Residents:

If you are a resident of California, in addition to the rights set forth in this Privacy Policy:

1. We will not share any personal information about you to the extent prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law; and
2. You have the right to request information from us regarding the manner in which we share certain categories of information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive the following information:
   1. the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
   2. the names and addresses of the third parties that received that information; and
   3. if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is hello@plumlending.com.

Compliance with State and Federal Laws:

This Privacy Policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our borrowers and members. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Other Terms and Conditions:

Your access to and use of the Services is subject to the Terms of Service which can be accessed through the Site and is incorporated herein by reference.

Changes to Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice, so please review this policy periodically and especially before you provide any personal data. Please check this Privacy Policy each time you use our Site to ensure you are aware of any changes in our practices. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. This Privacy Policy was last updated on the date first indicated above.

Access to Information; Contacting Us:

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 our Privacy Policy or the Services. You may contact us as follows:
PLUM, Inc.
445 Bush Street, Suite 500
San Francisco, CA 94108
Email: hello@plumlending.com

Updated and effective as of May 25, 2018