Privacy Policy
Last updated: July 2022
We at Incenter respect your concerns about privacy and the privacy of information our clients provide to us. This Online Privacy Notice describes the types of personal information we obtain, how we may use the information, with whom we may share it and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.
This Online Privacy Notice applies to personal information we obtain through this website and other sites, applications and other data collection points that link to this Online Privacy Notice (collectively, the “Site”). Other privacy principles or policies could apply depending on how you interact with us, the financial products or services you may ultimately obtain from us, or the jurisdiction in which we are doing business with you.
Information We Obtain
We may obtain the following types of personal information when you choose to provide it through our Site:
contact information, such as your name, telephone number, postal address and email address;
when you register for an online account, which may include information about your lender and loan amount;
login credentials, such as your username and password;
information about your interest in or application for an employment opportunity; and
any other personal information in content you provide on our Site.
In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner may include IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, is a tiny graphic image that may be used on our Site. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.
How We Use The Information We Obtain
We use the information we obtain through the Site to:
create and manage your account;
provide products and services that you requested or were requested on your behalf;
display content on our Site;
respond to and communicate with you about your requests, questions and comments;
to ensure the proper competition of services for our clients.
operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, analyzing and enhancing our products, services and Site; and performing accounting, auditing, billing, reconciliation and collection activities);
perform data analyses and other processing (including market and consumer research, trend analysis, financial analysis, anonymization, encryption and tokenization of personal information);
manage career opportunities;
protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
comply with and enforce applicable legal requirements, relevant industry standards and our policies.
In addition, we may use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content (including advertising) tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our business. We also use this information to help diagnose technical and service problems, administer our Site, and identify users of our Site. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Third-Party Analytics Services
We may use third-party web analytics services on our Site, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyze your use of the Site. To learn more about Google Analytics and how to opt out, please visit google.com/intl/en/analytics/learn/privacy.html or support.google.com/analytics/answer/181881?hl=en.
Our Site is not designed to respond to “do not track” signals received from browsers.
Information We Share
We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice. We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
Your Choices
We may offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice.
Please note that if you ask to be removed from a mailing list, we may still contact you regarding specific services or transactions we are performing on your behalf.
Links To Other Websites
Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Incenter. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Incenter companies, any use of those websites, or the privacy practices of those websites.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards reasonably designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Children’s Personal Information
Our Site is designed for a general audience and is not directed to children. We do not knowingly collect or solicit personal information from children under the age of thirteen (13) through our Site. If we become aware that we have collected personal information from a child under thirteen (13), we will promptly delete the information from our records. If you believe a child under thirteen (13) may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Online Privacy Notice.
Updates To Our Online Privacy Notice
This Online Privacy Notice will be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated.
How To Contact Us
If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at [email protected] or write to us at:
Incenter LLC
Attn: Legal and Compliance
550 Pinetown Road
Suite 208
Fort Washington, PA 19034
California Consumer Privacy Statement
This California Consumer Privacy Statement (“Statement”) supplements the Incenter Online Privacy Notice and applies solely to the personal information of California consumers collected by Incenter. This Statement does not apply to the Incenter personnel, applicants or B2B personnel, or to information collected, processed, sold, or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. In addition, this Statement does not apply to personal information Incenter processes as a service provider to another entity.
This Statement is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”), and certain terms used herein have the meaning given to them in the CCPA. Nothing in this Statement is intended to contradict or limit the applicability of the information provided in our Privacy Policy.
- Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology); telephone number, online identifier, internet protocol address, email address, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Geolocation Data: Information about your location, such as your physical location.
Sensory Information: audio, electronic, visual or similar information
Employment Information: professional or employment-related information
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We may use your personal information for the purposes described in our Online Privacy Notice. In addition, we may use your personal information for certain business purposes specified in the CCPA, including as described below:
Performing Services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
Auditing: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short Term Use: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Security Purposes: Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
Debugging: Debugging to identify and repair errors that impair existing intended functionality
Undertaking Internal Research: Undertaking internal research for technological development and demonstration
Undertaking Other Activities: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
- Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information and (b) information regarding our sharing of personal information with third parties.
- Sources of Personal Information
We may have obtained personal information about you from various sources, including as described below:
Directly from you or your attorney, agent or representative, such as when you provide us information, connect to us via our website, or send us questions, requests or comments
From your devices, such as when you visit our Site
Our affiliates, such as Incenter Appraisal Management
Business partners (such as lenders, title agents or real estate agents) and Vendors who provide services on our behalf
Public databases and government entities
- Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, including as described in our Online Privacy Notice and below, including for the business purposes described above.
We do not sell your personal information in exchange for monetary compensation or other valuable consideration. We do not have actual knowledge that we sell personal information of minors under 16 years of age.
- California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. To submit an access request, please email us at [email protected] or call us at 1-866-483-2763.
Deletion: You have the right to request that we delete certain personal information we have collected from you, subject to certain exceptions under applicable law. To submit a deletion request, please email us at [email protected] or call us at 1-888-557-3017.
Shine the Light Request: Subject to certain limitations under California Civil Code § 1798.83, you may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To submit a Shine the Light request, email us at [email protected].
Authorized Agents. To submit a request as an authorized agent on behalf of a consumer, please submit the request through the web form below and email a signed authorization from the consumer to [email protected].
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request by emailing [email protected] or calling 1-888-557-3017.
