defi SOLUTIONS™ defiSOLUTIONS.COM PRIVACY POLICY

Last modified: December 03, 2018

defi Solutions LLC (“ defi SOLUTIONS”) operates the website located at defiSolutions.com (“Site”). defi SOLUTIONS is a cloud-based loan origination software platform gives banks, credit unions, lenders of all types flexible technology for their lending programs (“Services”).

defi SOLUTIONS respects and protects the privacy of the users of our Services. We maintain strict policies to ensure the privacy of those who use our services or those who may just be visiting our Site. This policy (“Privacy Policy”) describes the types of information we may collect from you and our practices for how we collect, use, maintain, protect, and disclose such information when using the Site. This policy does not cover the way that we collect and use your information when you create an account with defi SOLUTIONS. This Privacy Policy also includes a description of certain rights that you may have over information that we may collect from you.

This Site is used as a marketing tool for our Services and we use targeting advertising resulting from your use of the Site. By visiting the Site or submitting or requesting information you agree to this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Site.

Information that defi SOLUTIONS Collects
Types of Information Collected Personal Data “Personal Data” is information by which you may be personally identified. defi SOLUTIONS may collect the following Personal Data from you:

  • Name,
  • Email,
  • Phone Number,
  • Company Name,
  • Job Title, or,
  • IP address.
Non-Personal Data Non-personal data includes any data that cannot be used on its own to identify, trace, or identify a person. This may include browser type, device information, domain names, access times, and physical location.

We may combine non-Personal Data you give to us with Personal Data we collect about you. When combined, this will be treated as Personal Data and we will only use it in accordance with this Privacy Policy.

How we collect information. We collect your Personal Data when you affirmatively give it to us through interactions with defi SOLUTIONS, including:

  • When you sign up to receive notices from defi SOLUTIONS,
  • Through service requests;
  • Through survey forms; or
  • When you choose to post information through the Site.

We may collect non-Personal Data via automatic means including through cookies or through our third-party service providers listed below.

Why we collect and how we use your information. (Legal Basis) In general, we collect and use your Personal Data for the following reasons:

  • When it is for our legitimate business interests, these include but are not limited to: direct marketing, network and information systems security, data analytics or data enhancement, modifying or improving our services, identifying usage trends, and determining the effectiveness of promotional campaigns and advertising. You have the right to opt out of this processing;
  • When it is necessary in connection with any contract you have entered into with us (including our terms of service for when we are offering services), or to take steps prior to entering into a contract with us;
  • When we have obtained your prior consent to the use (like when you request information from us to sign up for our Services; this legal basis is only used in relation to uses that are entirely voluntary – it is not used for information processing that is necessary or obligatory in any way);
  • When have a legitimate interest in using the information for the purpose of contacting you, subject to compliance with applicable law; or
  • When we have a legitimate interest in using the information for the purpose of detecting, and protecting against, breaches of our policies and applicable laws.

We may use aggregated (anonymized) information, and information that does not identify any individual, without restriction.

Accessing Your Information defi SOLUTIONS acknowledges the individual’s right to access their Personal Data. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should contact us at info@defiSOLUTIONS.com. If requested to remove data, we will respond within a reasonable timeframe.
How Long do we Store Personal Data? We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it is collected. This length of time may vary according to the nature of your relationship with us.
Automated Data Collection Methods Cookies A cookie is a small file placed on the hard drive of your computer. We use cookies to help us manage and report on your interaction with the Site. Through cookies, we are able to collect information that we use to improve the Services, tailor advertisements to your interests, keep count of return visits to our website, keep track of click-stream data, collect and report on aggregate statistical information, or manage multiple instances of the Site in a single browser. We may also use cookies to collect other data such as the date and time you visited the Site, and your current IP address.

If you do not accept the use of cookies, please disable by changing your browser settings so that cookies from the Site cannot be placed on your computer or mobile device. Refusing cookies through your browser may cause the functions of the Site to be impaired and you may not have the same user experience.

Log Files and Web Beacons Pages of the Site 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 us, for example, to count users who have visited those pages or opened an email and for other related statistics. Occasionally, we connect Personal Data to information gathered in our log files as necessary to improve our Services.
Users under the age of 16 Our Services are not intended for children under 16 years of age and we do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or register on the Services, make any purchases, use any of the interactive or public comment features, or provide any information about yourself to us. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address listed below.
Do Not Track Settings We do not track our Users over time and across third party websites to provide targeted advertising and do not specifically respond to Do Not Track (“DNT”) signals.
Who We Share Data With
We may use aggregated (anonymized) information about you, and information that does not identify any individual, without restriction.
Affiliates We may, for our legitimate interests, share your information with entities under common ownership or control with us who will process your information in a manner consistent with this Privacy Policy and subject to appropriate safeguards.
Successors in Interest. We may, for our legitimate interests, share your information with 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 defi SOLUTIONS’ assets, in which Personal Data held by defi SOLUTIONS about you is among the assets transferred. You will be notified of any such change by a prominent notice displayed on our Site or by e-mail. Any successor in interest to this Privacy Policy will be bound to the Privacy Policy at the time of transfer.
Compliance with law and protection of people and property. We may share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.
Service providers and partners. We may, for our legitimate interests, provide your Personal Data to contractors, service providers, third party authenticators, and other third parties who assist us in operating our website, conducting our business, or servicing you. These service providers are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These service providers may be located in the EEA, US or in other locations.

We also use third-party companies to serve ads and/or collect certain anonymous information when you visit our Site. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit http://www.aboutads.info/choices/ or the Network Advertising Initiative (www.networkadvertising.org).

A list of service providers and partners is provided below.

Service Provider/Partner Why we Share Privacy Practices
Google AdWords We use Google AdWords to assist is with remarketing and behavioral targeting. Google AdWords is provided by Google Inc. and it connects the activity of this Application with the AdWords advertising network and the DoubleClick Cookie.

Google AdWords collects cookies and usage data.

If you would like to opt-out of targeted ads, you may do so by visiting the Google Marketing Platform opt-out page or the Network Advertising Initiative opt-out page.

https://policies.google.com/privacy?hl=en
Google Analytics We use Google Analytics for Site analytics. Google will use information on our behalf to evaluate the use of our online products and services by you, to compile reports on the activities within these online products and services and to provide us with further services associated with the use of these online products and services.

Google Analytics collects cookies and usage data.

If you would like to opt-out from your data being used by Google Analytics, please download the opt-out browser add-on for Google Analytics.

http://www.google.com/privacy.html
HubSpot We use HubSpot as a marketing automation service provider, including for email marketing and analysis. Analysis can include measuring your interactions with our communications or advertisements. https://policies.google.com/privacy?hl=en
Salesforce Einstein We use Salesforce Einstein for our customer relationship management service provider. This service keeps track of requests and communications that you may make with us. https://www.salesforce.com/company/privacy/
Salesforce Pardot We use Salesforce Pardot as a marketing automation service provider, including for email marketing and analysis. Analysis can include measuring your interactions with our communications or advertisements. https://www.pardot.com/legal/
WP Engine We use WP Engine, by WordPress, to host the Site. https://wpengine.com/legal/privacy/
Third-Party Services and Websites
defi SOLUTIONS is not responsible for the privacy policies or other practices employed by websites (including social media sites) linked to, or from, our Site nor the information or content contained therein, and we encourage you to read the privacy statements of any linked third party.
Data Storage and How defi SOLUTIONS Protects Your Information
defi SOLUTIONS stores Personal Data about you within the United States. If you are using the Site from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Data to the United States. The United States may have laws which are different, and potentially not as protective, as the laws of your own country. By providing your Personal Data, you consent to any transfer and processing in accordance with this Privacy Policy.

defi SOLUTIONS employs industry standard physical, electronic and managerial control procedures to safeguard and help prevent unauthorized access to your information. We choose these safeguards based on the sensitivity of the information that we collect, process and store and the current state of technology. Our outsourced service providers who support our operations are also vetted to ensure that they too have the appropriate organizational and technical measures in place to protect your information

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your information transmitted to defi SOLUTIONS. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. In the event that there is breach in the information that we hold, we shall notify of such breach via email or via notice on the Site.

California and Vermont Specific Rights
California: If you are a California resident, we will not share Personal Data we collect about you except to the extent permitted under California law. California residents are permitted to request a full list of Personal Data stored by defi SOLUTIONS, which may be subject to a reasonable fee. To make such a request, please send an email to the email address listed below.

Vermont: If you are Vermont resident, we will not share Personal Data we collect about you with non-affiliates unless the law allows or you provide authorization.

Changes to the Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat your Personal Data, we will notify you by email to the email provided to us or through a prominent notice on the Site. Such changes will be effective when posted. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of our Site following the posting of any modification to this Privacy Policy shall constitute your acceptance of the amendments to this Privacy Policy. You can choose to discontinue use of the Service if you do not accept any modified version of this Privacy Policy.
Questions and Comments
If you have any questions about this Privacy Policy, please contact us by email at info@defiSOLUTIONS.com or call us at 800-926-6750.
 
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