Privacy Policy

• Identity Data: Name, date of birth, Social Security number, marital status
• Contact Data: Address, phone number, email address
• Financial Data: Income, assets, liabilities, employment information, tax returns
• Property Data: Property address, purchase price, estimated value, property characteristics
• Communication Data: Messages with loan officers, chat conversations with Arlo, emails, call logs
• Account Data: Username, password hash, profile preferences, marketing preferences

• Device & Technical Data: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent, features used, click patterns, form interactions
• Cookie & Tracking Data: See our Cookie Policy for detailed information
• Location Data: Approximate location derived from IP address for fraud prevention

• Arive: Loan application data, credit reports, underwriting information
• Credit Reporting Agencies: Credit scores, credit history, public records
• eSign Providers: Document execution status, timestamps, audit trails
• Connected Services: Information you authorize us to import from third-party financial accounts

• Mortgage Services: Process loan applications, underwrite loans, coordinate closings
• Platform Operations: Authenticate users, maintain accounts, provide support
• Communications: Send loan updates, appointment reminders, system notifications
• SMS Messaging: Send transactional messages, appointment confirmations, status updates (with your consent)
• AI-Powered Features: Power Arlo assistant responses, analyze conversations for training
• Analytics & Improvement: Monitor platform usage, identify bugs, improve user experience
• Engagement & Retention: Send marketing communications, loan check-ins (with opt-out rights)
• Legal Compliance: Meet regulatory requirements, respond to legal requests, prevent fraud

• We do not sell or rent your personal information. SMS consent and phone numbers are never shared with third parties or affiliates for marketing purposes.
• Service Providers: Technology vendors who support our platform (cloud hosting, analytics, CRM)
• Loan Origination Partners: Lenders, underwriters, appraisers, title companies needed to process your loan
• Real Estate Partners: Agents, builders, or other parties you authorize to receive loan status updates
• Legal & Regulatory: Government agencies, regulators, or courts when required by law
• Business Transfers: In the event of a merger, acquisition, or sale of assets

• AI assistant may produce inaccurate responses and should not be solely relied upon for critical decisions
• Arlo does not make lending decisions or approve loans — all approvals require human review
• Conversations with Arlo are logged and may be reviewed by loan officers for quality and training
• Information you share with Arlo may be processed by third-party AI service providers
• AI-generated responses do not constitute financial, legal, or tax advice
• Always verify important information with your assigned loan officer

• Loan Records: Retained for a minimum of 3 years after loan closing or application withdrawal (regulatory requirement)
• Communication Records: Retained for 3 years (includes emails, chat logs, call recordings)
• Account Data: Retained for the duration of your relationship plus 1 year
• Analytics Data: Retained indefinitely in aggregated, non-identifiable form
• To request deletion of your data, contact us at privacy@refinemortgage.com. Note that we may retain certain data as required by law.

We implement industry-standard security measures to protect your information, including encryption in transit (TLS 1.2+) and at rest, role-based access controls, multi-factor authentication for team members, regular security audits, and secure infrastructure provided by Supabase. While we take reasonable precautions, no method of transmission or storage is 100% secure. If you suspect a security breach, contact us immediately at privacy@refinemortgage.com.

• Essential Cookies: Required for platform functionality (authentication, security). Cannot be disabled.
• Analytics Cookies: Help us understand how users interact with our platform. You may opt out.
• Marketing Cookies: Used to deliver relevant advertising and measure campaign effectiveness. You may opt out.
• You can manage cookie preferences through the cookie consent banner on first visit or via the link in the footer. You may also configure your browser settings to block cookies, though this may impact platform functionality.

• We will not send SMS/text messages without your explicit prior consent
• Opt-in occurs at the point of collection with clear disclosure of message purpose
• Consent timestamps and method are recorded for compliance purposes
• You may revoke SMS consent at any time by replying STOP to any message
• Reply HELP for assistance or contact us at (980) 247-0549
• Message and data rates may apply based on your carrier plan
• Your SMS consent and phone number are never shared with third parties or affiliates for marketing purposes

• All Users: Access your personal information, request correction of inaccurate data, request deletion (subject to legal retention requirements), opt out of marketing communications, withdraw SMS consent
• California Residents (CCPA/CPRA): In addition to rights above, you have the right to know what personal information we collect, the right to know what personal information is sold or shared (we do not sell personal information), the right to opt out of sale/sharing, the right to limit use of sensitive personal information, the right to non-discrimination for exercising privacy rights
• To exercise your rights, contact us at privacy@refinemortgage.com or call (980) 247-0549. We will respond within the timeframe required by applicable law.

Our platform may contain links to third-party websites, services, or applications (such as Arive, eSign providers, or credit reporting agencies). This Privacy Policy does not apply to those third parties. We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party services you interact with.

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@refinemortgage.com and we will promptly delete such information.

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. Material changes will be communicated via email or through a notice on our website. The "Last Updated" date at the top of this policy indicates when it was last revised. Your continued use of our platform after any changes constitutes acceptance of the updated policy.

• Refine Mortgage Inc., Attn: Privacy Officer
• 1096 Assembly Drive, Suite 212
• Fort Mill, SC 29708
• Email: privacy@refinemortgage.com
• Phone: (980) 247-0549