Online and Mobile Privacy Notice
Last Updated April 26, 2023
This Online and Mobile Privacy Notice describes the Privacy practices of Guaranteed Rate Insurance, an affiliate of Guaranteed Rate, Inc. and the Guaranteed Rate affiliated Companies which include Guaranteed Rate Affinity. Guaranteed Rate Insurance and the Guaranteed Rate affiliated Companies (“GRI”, “Company”, “we”, “us”, or “our”) are committed to respecting your privacy and protecting your personal information no matter how you engage with us. We may interact with you in a variety of ways online or by mobile device.
This Online and Mobile Privacy Notice (“Online Privacy Notice”) explains how we collect,why we collect, how we disclose, use, share and protect your personal information when you visit our websites, download our mobile applications (“apps”), use our websites and apps to engage with us, apply for a service or product electronically, access your account electronically, view, or interact with our social media pages, as well as interactions you may have while viewing content provided through a digital advertising or marketing campaign (collectively, “Online Services”). It also explains information about the choices that you can make regarding your information. By using our Online Services, you agree to the collection, use, and disclosure of information in accordance with this Online and Mobile Privacy Notice.
PLEASE CAREFULLY READ THIS STATEMENT BEFORE USING THIS SITE, AS IT AFFECTS YOUR LEGAL RIGHTS AND OBLIGATIONS. CONTINUING TO NAVIGATE THIS SITE CONSTITUTES YOUR AGREEMENT TO THE TERMS OF THIS STATEMENT.
If you are a potential, current, or former customer, or you have applied for a product, read our Gramm Leach Bliley Privacy Notice to understand additional financial privacy practices that may apply to you.
If you are a California resident, please read our California Resident’s Privacy Notice.
If you are a Vermont resident, please read our Vermont Resident’s Privacy Notice.
We may change this Online and Mobile Privacy Notice from time to time. Any changes to this Online and Mobile Privacy Notice will become effective when posted unless indicated otherwise.
As you review this Online and Mobile Privacy Notice, please keep in mind:
- Each time you use or continue to use our Online Services, you are acknowledging and consenting to the collection, use, and disclosure of information about you as described in this Online and Mobile Privacy Notice.
- Our online products and services are intended for a U.S. audience. If you reside outside of the U.S., you understand and agree that your personal information may be transferred or processed in the U.S. If you are a non-U.S. resident who is interested in our products and services, please contact us at [email protected] To learn more about how your personal information is treated and safeguarded, please contact us at: [email protected]
- Consent to Transfer: if you are located outside of the United States, please be aware that information we collect through the App will be transferred to and processed in the United States. By using the App or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
- Our Online site and Mobile Application services are not intended for children 17 years of age or younger. We feel strongly about protecting children’s privacy. We do not knowingly collect personally identifiable information from children. If you are 17 years old or younger, please do provide us personally identifiable information of any kind.
- Your Personal Information Sharing Preferences are important. We would like to share your personal information with one or more of Our Affiliates in order to make you aware of different products and services they can provide which may be of interest to you. Our Affiliates include Guaranteed Rate, Inc., Guaranteed Rate Affinity, LLC, Advocus Title Agency, LLC, Proper Rate, OriginPoint, and Owning. You can request that we not share your personal information with our Affiliates to market their products and services by contacting us at [email protected]
How Do We Collect Information via our Online Website, through a Mobile Device or Application?
We collect personal information in a variety of contexts. We may collect personal information:
- Directly from you. You voluntarily provide personal information to us when you apply for our products online, subscribe to communications, email our representatives, create an account, use our mobile app, respond to surveys, participate in contests, sweepstakes, or promotions, provide feedback or engage in other similar activities.
- Automatically and passively when you use our Online Services. We collect device data, online/mobile activity data and other information, including when you visit our websites, download and use our mobile apps, and interact with our online ads.
We may combine and create inferences from the online information we collect with information we collect in other contexts, such as from phone calls, SMS text messages, e-mails, and other written correspondence, and in-person visits to our branches, open houses, or events.
What Information Do We Collect Online?
Information Collected from a PC, Tablet, or Mobile Device. We collect various types of personal information depending on how and to what extent you use our Online Services. When you browse our websites or use our mobile apps via a PC, tablet, mobile or other device, we may actively and passively collect:
- Device data. The types of data we may collect from your device include your device type, device identifiers, web browser type and version, operating systems type and versions, iOS or macOS, MAC ID, MAID ID, display/screen settings, language preferences, documents and photos stored in your device (e.g., to upload requested documents or identification cards we need to perform a service for you), internet protocol address (IP Address), mobile network information, mobile configuration data, general location (e.g., city, state, or country), geolocation/precise location (e.g., latitude/longitude), mobile advertising IDs (e.g. Apple’s IDFA or Google’s Ad ID), which version of our app is installed on your device, ISP or mobile carrier, mobile session ID and events (crash logs, up-time, run-time, and general performance and usage data) connections among different browsers and devices that you use (collectively “Device Data”).
- Important Note Regarding Location Data. When you access our online services or mobile app with your mobile device, location information may be available when your device communicates with a cell tower, Wi-Fi router or access point. Therefore, we may collect general location and geolocation information from the device you use when accessing our Online Services that tells us your approximate physical location. You control our ability to access your mobile location information. Refer to your device user guide and settings regarding how to allow, block, or limit collection of location information. If you choose not to provide location information, some Online Services may not operate correctly or be available to you.
- Online and mobile activity. We may collect your search history, information about how you use and interact with our Online Services or advertisements (such as, content viewed, links clicked, and features used), when and how often you use our Online Services, the webpage from which you clicked a link to visit our Online Services (e.g. referrer URL), browsing behavior within our websites and webpages, use of webtools (ex. Cookies and Pixel Tags), and feedback you may provide (collectively “Online Activity”).
Information We Collect
Our websites and mobile applications may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our websites may have collected the following categories of personal information from consumers since January 1, 2020. Though not all categories apply to an individual, customer or applicant, the summary purposes and uses for the information we collect are also listed.
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers||
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||
|D. Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|E. Biometric Information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity||Information regarding interactions with our website, mobile applications, emails computer systems, devices, or advertisements, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers, including browsing or search history,||
|G. Geolocation Data||Device location, IP address, physical location.||
|H. Audio and Visual Information||Audio, electronic, visual or similar information (e.g. when customer interacts with employee regarding product and services).||
|I. Inferences drawn from personal information||Derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data; a characteristic deduced about a consumer.||
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||
|K. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We do Not Collect or Store Biometric Information via your use of Touch ID, Finger Print, Face ID Authentication
Certain devices are eligible for enrollment in Touch ID®, Face ID® or fingerprint login. Fingerprint/Face ID Authentication is an optional authentication method offered to log in to Mobile App. It is available for iOS devices with Touch ID™ capability and Android devices that have compatible Fingerprint/Face ID support (running Android 6.0 or higher). While Fingerprint/Face ID is a biometric recognition feature, designed, released and trademarked by Apple Inc., we do not collect your biometric information nor store biometric information from you. Your Fingerprint/Face ID is stored on your device when you set up your Fingerprint/Face ID enabled device. Apple, the Apple logo, iPhone, iPad, Apple Watch and Touch ID are trademarks of Apple Inc., registered in the U.S. and other countries. App Store is a service mark of Apple Inc. Google Pay and Android is a trademark of Google Inc. Samsung is a registered trademark of Samsung Electronics Co., Ltd.
Marketing: Use for “Marketing,” as described in the chart above, means contacting you through means other than telephone (for example, email or postal mail) to offer and market to you services or products, including special offers or advertisements, any of which may be tailored to you.
Performing Services: Use for “Performing services” means using information about you to: (1) allow you to participate in the product, features, services we offer or to provide related customer service; (2) process your registration, including to verify that information you provide is valid; (3) process a transaction you initiate; (4) improve the App and our products, and for internal business purposes, including the measurement of the App’s functionality and/or effectiveness; and (5) contact you with regard to your use of the App and, in our discretion, changes to our policies.
In addition to the uses described above, to analyze our App, we may use various analytics services, which may independently collect Usage Information, set and access their own tracking technologies, and otherwise collect or have access to non-personally or personally identifiable information about you.
We may also use your information for purposes disclosed at the time you provide your information, or with your consent.
Information Sharing for Legal Purposes
Sharing for “Legal Purposes,” as described in the chart above, means we may disclose your information (i) if we are required or permitted to do so by law or legal process, (ii) to law enforcement authorities, or (iii) 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 illegal activity.
In addition to the information sharing described in the chart above, we may also share your information with third parties with your consent or at your request, or as disclosed at the time you provide us with information. We also reserve the right to disclose and transfer your information if our Company goes through a business transition, such as a merger, acquisition by another company, sale of all or a portion of its assets, or other corporate change, including during the course of any due diligence process.
Information Sharing Non-Personal information
We may also share non-personal Information, such as aggregate user statistics (e.g., number of downloads and registrations, and most popular merchants), demographic information and Usage Information, with affiliates and third parties, including advertisers, content providers, and analytics providers.
Third parties may collect non-personal Information when you download or use the App. Some third parties may collect your personal information when you visit the App. We do not control the information collection, use, or sharing practices of third parties, including analytics providers.
Information Sharing Personal Information with our Affiliates
Our Affiliates offer products and services that may be of interest to you. We may share personal information with our Affiliates to provide information to you about their products and services that may be of interest to you.
Retention and Deletion Practices
We retain your information only as long as necessary to provide the products and services for which the information was collected, to process and maintain a record of transactions, and as long as necessary for legal process or to satisfy government retention requirements. To determine whether the data is needed, we consider the reason your data was collected and used and any legal requirements to hold onto your data. We review your data periodically to ensure it is still needed to fulfill the purpose for which it was collected or any other legal requirements. When the retention period expires, we destroy data that was maintained in any form in a manner that renders it completely unusable and incapable of restoration.
We take commercially reasonable security measures to help protect your information, both during transmission and once we receive it. However, no method of electronic transmission or method of electronic storage is 100% secure. Therefore, we cannot guarantee the security of any information you submit and you do so at your own initiative and risk.
Consent to Transfer
If you are located outside of the United States, please be aware that our products are intended for a United States audience. If you are located outside of the United States, be aware that any information we collect through the Mobile App will be transferred to and processed in the United States. By using the Mobile App or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Online Employment Applicant Information. If you are a Non-California resident and apply for employment online, we may collect personal information about you that includes personal identifier, work history, prior employer information, and education. If you are a California resident and you have inquired about or applied for a job with us, or are a former employee, please refer to our California Applicant Privacy Notice for more information.
Be aware that if you apply and/or disclose any personal information of another while using our Online Services, you represent that you are doing so with their permission, or you otherwise have the authority to do so. By continuing to use our Online Services, you permit us the use of the information in accordance with this Online Privacy Notice and applicable laws. If you do not have permission or authority to provide another’s information, please do not disclose their personal information to us.
How Do We Use Information We Collect from Online Services?
We may use the information we collect from you while using our Online Services as described below.
- To perform or fulfill the online service you requested. We use information to do business with you by providing our services to you and fulfilling your requests.
- To Provide necessary communications. We use information to inform you of a change that may impact you, including changes to our business, our contact information, or notifications related to your personal information.
- Protecting against fraud and business risks. We use information to monitor network activity logs, detect security incidents, conduct data security investigations, and protect against malicious, deceptive, fraudulent, or illegal activity. We may use your information to protect you, our company, our assets, or any individual or entity we feel, in our discretion, is at risk of being harmed.
- Advertising, marketing, and recommendations. We use information to stay engaged with you by sending you product offers, business and industry announcements, to display online advertising that may interest you, evaluate and improve the effectiveness of our marketing efforts, connect you with a professional within our organization, and push notifications and alerts through our apps.
- Conducting analytics and research. We use information to examine which parts of our websites or apps you find most useful, to monitor user interfaces and experiences, to test features and functionality, to perform debugging and error repair, and to analyze the use of our Online Services.
- Improving our products and services. We use information to personalize and enhance your online and mobile experience, reveal opportunities for business growth, and to develop new products and services.
- Aggregation and de-identification. We may use, modify, or disclose information in a way that removes a way to reasonably identify you to compile statistics, understand trends and volume usage of Online Services. Aggregated and de-identified information is not subject to any privacy notice.
- Data archival and retention. We may use or delete your information in accordance with our data retention policies and as otherwise permitted or required by law.
- Legitimate business purposes. We may use your information for any of our other legitimate business purposes not otherwise prohibited by applicable law.
How We Disclose Your Online Information
We do not sell Personal Information for Money. However, our use of tracking technologies may be considered a “sale” or “sharing” under California law. We share Personal Information with our Service Providers for the business purposes listed in the chart above. The categories of Personal Information we share for a business purpose include:
- Personal Identifiers
- Personal Records
- Characteristics of Protected Classes
- Purchase Information
- Internet or Online Information
- Geolocation Data
- Audio and Visual Information
- Employment Verification
- Education Information
Accordingly, we disclose information in a variety of different contexts as described below.
- Third parties with whom you authorize or direct us to disclose your information. We will disclose your information with a third party with your consent.
- Affiliated and related companies. We may disclose your information with our related companies, including our direct and indirect parents, subsidiaries and affiliates. If we are involved with a merger, acquisition, sale, dissolution, or liquidation of all or part of our business to another company, we may disclose your information with that company and its advisors before and after the transaction date. We may transfer or have transferred to us, all information collected about you to merge, transition, or wind-down a company’s activities. Customers can find additional information about how we collect and use your personal data here.
- Service providers, contractors, and vendors. We may disclose information with service providers or contractors, or they may disclose, collect, store, access, transfer, or otherwise process your information on our behalf to enable our Online Services. We require service providers or contractors to implement reasonable organizational controls to maintain the privacy and security of information provided to them.
- Marketing and marketing analytics. We may disclose information with third parties for marketing purposes, analytics, (ex: Adobe Analytics, Google Analytics) and to jointly market products, services, promotions, and events. We may receive your information from a third party you authorized to share or sell your information.
- When you connect to our social media pages or forums. Our websites enable you to connect to our social media pages. We may provide opportunities for you to publicly post reviews, questions, comments, or suggestions, which may include personal information, such as your name or username. Anything you disclose in a public forum is public, so think carefully before you disclose.
- Government, regulatory, and court proceedings. We disclose information to government, regulatory, and throughout court proceedings to respond to their inquiries, enforce our terms and conditions, exercise or defend a claim or if we determine disclosure is necessary or appropriate to protect the life, safety, or property of ourselves or others.
Access to Information
Your access to the information we collect electronically is governed by the law where you reside. If you have created an account with us, you can correct and update your information from your account.
For further access requests, please contact our Privacy Department at [email protected]
Online Tracking Technologies and Your Choices
When you visit our website or download our apps, we may use online tracking tools as described below.
- Server logs. Server logs automatically record information and details about your online interaction with us. We use this log information for administration and technical troubleshooting.
- Pixel tags. A Pixel Tag, (also called a Web Beacon or clear GIF), is an image or small string of code that may be placed in a website, advertisement, or email. It allows us to set and read cookies (described below) and transfer information to our server when you load a webpage or interact with online content. We, our service providers, and our subsidiaries and affiliates may use pixel tags to summarize visitor patterns and to provide personalized services. We may also use Pixel tags to track visitor preferences or gather aggregated information about visitor usage.
- Third-party plugins. Our Online Services may include plugins from other companies. These plugins may collect information, such as information about the pages you visit, and disclose it to the company that created the plugin. Third party plugins are governed by the privacy polices’ of the company that created the plugin.
- SDK and Mobile Advertising IDs. Our mobile apps may include third-party development kits (“SDKs”) that allow us and our service providers to collect information about your mobile activity. Some mobile devices have a resettable advertising ID (e.g., Apple IDFA and Google’s Advertising ID) that allows us and our service providers to identify your mobile device for advertising purposes.
- We and our service providers may collect information about your online activities across different websites, mobile apps, and devices over time for targeted advertising purposes.
Choices You Have to Limit Sharing of Online Information
You may opt-out of certain electronic marketing communications and targeted advertising by clicking the opt-out button below or selecting unsubscribe within any marketing email communication you receive.
Please note you still may receive communications from us. Your opt-out may only apply to the specific browser or device from which you opt-out. You will need to opt-out separately on all of your browsers and devices. Further, the links provided in this section do not apply to physical mailings, telephone calls, or text. To opt-out of other methods of communications, please contact us at [email protected]
You may also have the choice to limit sharing of online information as described below.
- Do Not Track Signals. Some Internet browsers can communicate your privacy preferences to the websites you visit, like, requests not to track your usage and browsing history. We do not participate in third party ad network self-regulatory programs for online behavioral advertising. This means that our websites do not respond to “do not track” opt-out mechanisms and signals to prevent online advertising to you. Instead, we utilize the established industry mechanisms. You can limit the amount of online advertising you receive by visiting one or both of these examples:
- Electronic Marketing Communications. You have the choice to tailor how we provide electronic marketing communications to you. You have the option to opt-out, subscribe, or re-subscribe to our marketing communications.
There are two ways to unsubscribe from our email marketing communications:
- Send an email to: [email protected]
- From one of our emails, open the email, towards the bottom of the email, Click the “Unsubscribe” link. Please allow 10 days for the completion of your request.
Note, this opt-out method is only applicable to marketing emails. This opt-out and unsubscribe method will not impact telephone calls, mailing lists, or text messages you may receive from us. This opt-out will also not apply to transactional or relationship related emails we send related to our services or to provide you various services.
- Interest-Based Advertising or Online Behavioral Advertising. You may see our advertisements on other websites. These advertisements are based on your Internet browsing history across different websites or platforms. We or third parties we contract with collect information in this way to advertise more effectively. You can control your choice to opt-out of interest-based advertising in the following ways.
- You can opt-out from the specific advertisement itself. Advertisements that utilize interest-based advertising will have an “Advertising Option” icon in the advertisements. Once you click on the icon, you will have an option to opt-out.
- On some mobile device, Android or iOS phones may have capabilities to limit receiving interest-based advertisements located in your phone’s settings.
- Through advertising industry and trade regulatory agencies, operated by the Network Advertising Initiative or Digital Advertising Alliance and following their instructions on how to opt-out of interest-based advertising.
- Preferences in Your Mobile Device. You may be able to control other preferences on your mobile device. Your device’s setting may allow you to reject push notification and limit our app’s access to other information on your mobile device. Note, this may result in the loss of app functionality or our ability to provide Online Services to you through a mobile device.
COLORADO, CONNECTICUT, UTAH, VIRGINIA RESIDENTS
Colorado, Connecticut, Utah, and Virginia law require certain disclosures for companies that “sell” personal information pursuant to the respective state’s privacy law. Each state defines the “sale” of data differently. Colorado, Connecticut, Utah, and Virginia define the “sale” of data as a company exchanging personal information for monetary consideration with a non-affiliated third party.
Under Colorado, Connecticut, Utah, and Virginia law, we do not “sell” your personal information.
If you are a resident of Vermont, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.
If you are a resident of California, we will not share personal information we collect about you unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits to which you are entitled. We also limit sharing among our Affiliates to the extent required by California law. For example, we may share minimal California resident personal information with Affiliates who may be able to provide a complementary or related service to you and market those products or services to you, as well as build and tailor our own Services and for you. We may share information with our partners if we believe the disclosure is reasonably necessary to protect us, users of our Services, or the public from harm, fraud, or potentially prohibited or illegal activities. You may visit our California Applicant Privacy Notice which provides more information about California residents and their rights under the applicable laws.
California residents also have specific privacy rights provided by the California Consumer Privacy Act (CCPA), as it may be amended from time to time. These include: (1) the right to request information from us regarding what categories of personal data we have collected about you; (2) the right to request a copy of the specific personal information collected about you during the last 12 months; (3) a limited right to have such information deleted (with exceptions); (4) the right to request that your personal information not be sold to third parties, if applicable; and (5) the right not to be discriminated against because you exercise your rights.
California residents have the right to request deletion of personal data that has been collected within the last 12 months. There are circumstances where the law may not permit or require removal in certain circumstances. You may visit our California Applicant Privacy Notice [https://www.rate.com/privacy/applicant-notice-and-privacy-policy ] for more information about California residents and their rights under the applicable laws.
To exercise these rights or to inquire about privacy protection at the Company, you may visit Do Not Sell or Share Data
California’s Shine the Light Law
Under California Civil Code Section 1798 (California’s Shine the Light Law), California residents with an established business relationship with us can request information once a year about sharing their personal data with third parties for the third parties’ direct marketing. If you are a California resident and want to request information from us based on the Shine the Light Law, you can do so via the Contact Information below.
California Verifiable Client Requests
Applicable California law requires that a business must verify the identity of the requesting individual and respond. Absent an extension, applicable California law requires a business substantively respond to a consumer request to know, delete, and/or correct inaccurate information within 45 days of receipt of the request. On average, we process and respond to each request in less than ten days.
Changes to Our Privacy Notice
We reserve the right to amend this Online and Mobile Application Privacy Notice at our discretion and at any time. When we make changes to this Online and Mobile Application Privacy Notice, we will post the updated Notice on the Websites and update the Notice’s effective date. Your continued use of our Websites and Mobile Application following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Online and Mobile Application Privacy Notice, the ways in which Guaranteed Rate Insurance collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:
Email: [email protected]
Sending a letter to us at: Guaranteed Rate Insurance
Attn: Compliance Officer
1501 Woodfield Rd Suite 205S
Schaumburg, IL 60173