PRIVACY POLICY

Last revised: August, 2024

Welcome!

We are providing this Privacy Policy to help you understand how we collect, use, share, and process your Personal Information (defined below) and to tell you about your rights and choices regarding how we process your Personal Information.  Please read this Policy carefully.

California Notice at Collection. See Your California Privacy Rights below for important information about your rights under applicable state privacy laws.

When you use our Services you acknowledge that you have accepted the practices we describe in this Policy. If you do not agree with these practices, please do not use or access the Services.  

Changes to Our Policy

We may change this Policy from time to time. If we make material changes to this Policy, we will notify you by updating the date of this Policy and posting it on the Services (Defined below) or other appropriate means. Any modifications to this Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services following notice of any changes indicates your acknowledgment of the modified Policy.

Who We Are

This is the Policy of Pedagogy Inc., a California corporation (collectively, “Company”, “us”, “our”, or “we”). Our principal office is located at 24552 Raymond Way # 863 Lake Forest, CA 92630. 

You can contact us using the information below.

What Does This Policy Cover?

This Policy applies to our “Services,” which include thehomeloansource.net , and any other websites where we link to or post this Policy, including any subdomains or mobile versions (the “Site” or “Sites”), any Aven mobile applications, as well as any online services available through our Sites, except as otherwise specified below.

This Policy does not apply to nonpublic personal information we process in connection with our financial products and services listed below. All nonpublic personal information processed in connection with our financial products or services is governed by our Consumer Privacy Notice which are also available on our Sites, including without limitation:

• Credit card/loan applications (including pre-qualification verifications)
• Credit card/loan account information or statements
• Credit card/loan transaction/payment information
• Device/Network data collected in connection with our financial products or services (e.g. anti-fraud or security related information).

How We Collect and Use Personal Information

Personal Information We Collect

In order to provide our Services, we may collect and process information that relates to identified or identifiable individuals (“Personal Information”). We collect and process the following categories of Personal Information (note, specific Personal Information elements are examples and may change):

Automatic Data Collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and Similar Tracking Technologies. Some of the automatic collection described above is facilitated by the following cookies and similar technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Session-replay Technologies. We use session replay technologies on the Services, such as those provided by OpenReply and/or LogRocket who employs software code to record users’ interactions with the Site in a manner that allows us to watch video replays of those user sessions. The replays capture data such as users’ mouse movements, page visits, network requests and responses, console logs, JavaScript exceptions, and browser performance metrics. These replays help us diagnose usability problems and identify areas for improvement.

Sources of Personal Information

We collect Personal Information from various sources based on the context in which we process it:

You:        We collect Personal Information from you directly, for example, when you input information into an online form, sign up for a waiting list, or contact us directly.

Your Devices:        We may collect certain Personal Information automatically from your devices. For example, we collect Device/Network Information automatically using cookies and similar technologies when you use our Service, access our Sites, or when you open our marketing communications. 

Third-Parties:        We receive Personal Information from third parties with whom we have a relationship in connection with a relevant transaction, or who collect information on our behalf.

Data Aggregators:         We collect Personal Information from data aggregators that maintain databases of information relating to individuals and who provide us with certain data we use to augment an individual’s profile or other Personal Information we maintain.

Advertising Networks:        We may collect certain information, such as Device/Network Information or Inference Information from advertising networks that operate on our Sites. 

Creation/Inference:        We (or third parties operating on our behalf) create and infer Personal Information (such as Inference Information) based on our observations or analysis of other Personal Information we process, and we may correlate this information with other information we process about you.

How We Use Personal Information

Communications

We may process Personal Information in connection with email and SMS marketing communications (such as promotional emails), which you might receive if you sign up for updates regarding our products and services, choose to receive SMS/email marketing communications, or engage in a transaction allowing us to send you email marketing communications. We may also collect Personal Information when you open or interact with email marketing communications. We may send you SMS communications by automated means.

Subject to your rights and choices, we use Personal Information as necessary to customize, deliver, and otherwise process marketing communications, and in order to tailor certain communications to individuals’ preferences and requests. Additionally, we may process Personal Information from devices receiving those marketing communications as part of our business interests in understanding whether our emails are opened or other aspects of engagement with such marketing communications.

Account Registration & Profiles

We process Personal Information when you register and create an account or complete a profile on our Service. We may also collect Personal Information on certain profile forms. We generally use this as necessary to create, maintain, and provide your account and the service or features you request, or as necessary to contact you with important information about your account or our Service.

We may also use profile information for certain commercial purposes (described below), such as to determine the value of property and determine various offers or promotions that may interest you, or your estimated creditworthiness. Information submitted in your profile is used to provide estimates and general information to you.

When You Access or Use Our Services

When you access or use our services, we use Personal Information to verify your location, customize content available through the Services based on your location, and other features that require the use of location. We may also use this information to create aggregate information about users’ location and patterns, in connection with security/anti-fraud purposes, or to help improve our Services.

When You Contact Us

We use Personal Information as necessary to communicate with you about the subject matter of your request and related matters when you contact us through the Site via a contact box or our chat. We may also use information collected when you contact us in connection with marketing communications, if relevant to your request. We may use a third-party service provider to operate our chat.

Cookies and Similar Tracking Technologies

Subject to your rights and choices, we may use information that we collect through cookies and similar technologies as follows:

• for “essential” or “functional” purposes, such as to enable certain features of the Services, or keeping you logged in during your session;
• for “analytics” and “personalization” purposes, consistent with our business interest in how the Services are used or perform, how users engage with and navigate through our Service, what sites users visit before visiting the Services, how often they visit the Service, and other similar information, as well as to greet users by name and modify the appearance of the Service to usage history, tailor the Service based on geographic location or customer, and understand characteristics of users in various technical and geographic contexts; and
• for retargeting or online advertising (described below), such as:

• for social media integration e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter;
• to collect information about your preferences and demographics to help target advertisements which are more likely to be of interest to you using behavioral advertising; and
• to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services which you have previously looked at on a website but have not purchased).

Note:        Some of these technologies can be used to identify you across Services, devices, sites, and other services.

Service Provision and Contractual Obligations

We process any Personal Information as is necessary to provide the Services, and as otherwise necessary to fulfill our obligations to you, for example, to provide you with the information, features, and services you request or enable the functionality of our Services, such as keeping you logged in, delivering pages, etc. We may also use Personal Information to fulfill any contracts we have with you.

Internal Processes and Service Improvement

We may use any Personal Information we process through our Services as necessary to improve the design of our Services, understand how our Services are used or function, for customer service purposes, to create and analyze logs and metadata relating to Service use, and to ensure the security and stability of the Services. Additionally, we may use Personal Information to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our users.

Aggregate, Deidentified, and Anonymized Analytics

We process Personal Information as necessary in connection with our creation of aggregate, deidentified, and anonymized analytics relating to how our Services are used, the products and services our users purchase, to create service delivery metrics, and to create other reports regarding the use of our Services, demographics of our Users, and other similar information and metrics. The resulting information will not contain information from which an individual may be readily identified.

Security and Fraud Detection

We may process any Personal Information we collect in connection with our legitimate business interest in ensuring that our properties and locations are secure, to identify and prevent crime, prevent fraud, and ensure the safety of our users. Similarly, we process Personal Information on our Services as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Information in connection with our information security activities.

Compliance, Health, Safety & Public Interest

We may process Personal Information for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfill our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority.

With Your Consent

In some cases, we may specifically ask for your consent to collect, use, or share your Personal Information, such as when required by law.

Personalization & Consumer Profiles

In order to understand our customers’ preferences, and better recommend products and services to users, we may create a consumer profile by linking together and analyzing Personal Information we collect through our Services. We may also augment consumer profiles with Personal Information that we create or that we receive from certain third parties.

We use consumer profiles to conduct market research and statistical analysis in connection with the improvement of our Services, as well as in connection with the analysis of customer property, potential collateral, and to tailor what services we may suggest to you. For example, we may analyze the value of certain property, estimate available loan terms, or suggest offers, products, or services that may be of interest to you. We may also use consumer profiles in connection with our marketing communications, or online advertising (as described below).

Online Advertising

We, and certain service providers operating on our behalf, may engage in online advertising that involves the processing of Personal Information we collect under this Policy. Online advertising involves various parties engaged in the processing of Personal Information in connection with the delivery, analysis, and other processing related to our online advertising activities. For example, these third parties may, on our behalf, augment your profile with demographic and other information, and may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a transaction for a good or services you were shown in an advertisement. We generally use online advertising for the purpose of marketing our Services and goods and services of our affiliates and related parties, as part of our marketing communications, or in connection with the development of marketing profiles or audiences.

How We Disclose Information

We may disclose information we collect with third parties, depending upon the purpose for and context in which we obtained the information, as described below.

Banking/Lending Partners

We may operate our Services in connection with third party banks or lenders. Where we partner with a bank or third-party lender as part of the services you receive, we may share Personal Information collected as part of your account registration and profile with that partner/lender.

Service Providers

In connection with our general business operations, product or service improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Information with service providers or sub-processors who provide certain services or process information on our behalf. For example, we may use cloud-based hosting providers to host our Services or disclose information as part of our own internal operations, such as security operations, internal research, etc.).

The Home Loan Source requires all service providers and data aggregators to provide proof of full compliance with federal laws and regulations by performing due diligence on all of their relevant policies and procedures, data security and integrity, safeguards, financial status, insurance status, and sanctioning screening of the Company and controlling members. All service providers and data aggregators that share NPI or any confidential information with Aven must comply with the GLBA and all other relevant federal regulations. This ensures any data processed by a 3rd party that Aven receives and/or sends meets The Home Loan Source’s data security and integrity standards. An annual due diligence review is performed on all first and second tier vendors. Service providers may use information that was collected from financial institutions and other 3rd party servicers.

Aven may disclose your Personal Information to commercial providers for a business purpose. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract. We share Personal Information with certain of our service providers subject to contract terms that limit their use of Personal Data.

Data Aggregators

In connection with our product and personalization services, we may share certain Personal Information contained in a user profile with third party service providers who provide us with data to augment or provide additional data or context to user profiles. For example, we may request data from data aggregators to determine the value of certain property and to obtain additional information regarding the credit products most likely to appeal to an individual.

Business Transferees

We may disclose your Personal Information to acquirers and other relevant participantsin the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Affiliates

In order to streamline certain business operations, marketing activities, services, offers, and other content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share your Personal Information with any of our current or future affiliated entities, subsidiaries, and parent companies.

Advertising Partners

We may disclose your information to third-party advertising companies for the interest-based advertising purposes described in this Policy.

Professional Advisors

We may disclose your information to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and Others

We may disclose your information to law enforcement, government authorities, and private parties as we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use or a customer agreement, or in the vital interests of us or any person. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.

Your Choices

You may have the following choices regarding the Personal Information we process, to the extent required under applicable law:

Consent:        If you consent to processing, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services.

Direct Marketing:        You have the choice to opt-out of or withdraw your consent to marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications, by replying STOP to any SMS message, or by contacting us re: direct marketing.

Location Information:        You may control or limit Location Information that we collect using our online Services by changing your preferences in your device’s location services preferences menu, or through your choices regarding the use of Bluetooth, WiFi, and other network interfaces you may use to interact with our Services.

Cookies & Similar Tech:        If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies and certain similar technologies using your browser’s settings menu. You must opt out of the use of some third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Ads Privacy Policy, or Google Analytics Opt-out.

Behavioral advertising:        You may opt out or withdraw your consent to behavioral advertising. You must opt out of third party services directly via the third party. For example, to opt out of Google’s use of cookies, visit Google’s Ads Settings, here. To opt out from Facebook Custom Audience Pixel, visit their customer support page here. To learn more about how to opt out of Twitter’s use of audience pixels, visit the Twitter help page here. If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/optout_nonppii.asp. AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of behavioral advertising in mobile apps served by participating members of the Digital Advertising Alliance. You can also use your mobile device settings to limit use of the advertising ID associated with your mobile device for behavioral advertising purposes. You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for behavioral advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Other Processing:        You may have additional choices under applicable law. Contact us re: data rights requests if you believe you have such rights.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect Personal Information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Security

We implement and maintain technical, organizational, and physical safeguards that are designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Information.

Data Retention

We retain information for so long as it is necessary to fulfill the purposes for what we collected it, as described in this Policy.

Children

Our Services are neither directed at nor intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected Personal Information in a manner prohibited by law, please contact us as detailed below. If we learn that we have collected Personal Information through the Services from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete it.

International Transfers

We operate in and use service providers located in the United States, and our Service is intended solely for the US market. If you are located outside the U.S., your Personal Information may be transferred to the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in foreign countries.

Contact Us

Feel free to contact us with questions or concerns using the appropriate address below.

General inquiries:      support@thehomeloansource.net

Information rights requests:       support@thehomeloansource.net

Physical address:      24552 Raymond Way # 863, Lake Forest, CA 92630

Phone:        714-352-0808

Your California Privacy Rights

This section applies only to California residents. It describes how we collect, use, disclose and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act but does not include data exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.

• Information. You can request information about the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting, sharing and/or selling Personal Information; the categories of any Personal Information that we sold or disclosed for a business purpose; and the categories of any third parties with whom Personal Information was sold, shared or disclosed for a business purpose.
• Access. You can request a copy of the Personal Information that we have collected about you.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
• Opt-out. You can opt-out of the sharing of your Personal Information for cross-contextual behavioral advertising purposes and/or from the sale of your Personal Information for monetary or other valuable consideration.  
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to Exercise Your Rights

• Right to information, access, correction, and deletion. You can request to exercise these rights by emailing us at support@thehomeloansource.net.
• Right to opt-out of the “sale” or “sharing” of your Personal Information. You can request to opt-out of the “sharing” of your Personal Information by clicking the Do Not Sell or Share My Personal Information link in the footer of this webpage. Your request to opt-out will apply only to the browser and the device from which you submit the request. We do not otherwise “sell” Personal Information as defined by the CCPA.  

Identity verification. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into your account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email address used to make the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.

Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

Information practices. The following describes our practices currently and during the past 12 months:

• Sale and sharing of Personal Information. Our use of the behavioral advertising services described above may constitute “sharing” of your Personal Information with our advertising partners from which you have the right to opt-out under the CCPA. You can request to opt-out of this “sharing” as detailed above. The categories of Personal Information shared include Identifiers and Internet or Network Information as described in the CCPA. As stated above, we do not otherwise “sell” Personal Information as defined by the CCPA. Although our Services are not intended for children under 16 years of age, we are required to inform you that we do not have actual knowledge that we have sold or shared the Personal Information of children under 16.
• Sensitive personal information. We do not use or disclose sensitive personal information (as that term is defined under CCPA) for purposes that California residents have a right to limit under the CCPA.
• Deidentified data. We do not to attempt to reidentify deidentified information that we derive from Personal Information except that we may do so to test whether our deidentification processes comply with applicable law.
• Retention. Our criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Privacy Policy, including complying with our legal obligations.  
• Sources and purposes. We collect all categories of Personal Information from the sources, use them for the business purposes described in the How We Collect and Use Personal Information section above, and disclose them for the business purposes described in the How We Disclose Information section above.

Collection and disclosure. The chart below describes the Personal Information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose Personal Information for business purposes. The terms in the chart refer to the categories of information and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below. We may also disclose Personal Information to professional advisors, authorities and others, and business transferees as described above in the How We Disclose Information section above.

California Shine the Light Law. California residents may send us requests to support@thehomeloansource.net for identification of third parties to whom we have disclosed your personal information during the preceding calendar year for such third parties’ direct-marketing purposes. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.