Privacy Policy

1. Scope of This Policy

This Privacy Policy applies to information collected through our Website, our pre-qualification engine at bankingafterhours.com, our refinance calculator at richrefi.com, and any interactions with our Services. When you submit a loan application through our borrower portal (powered by Finmo/Jupiter), your information is also subject to Finmo's Privacy Policy and Rocket Mortgage's Privacy Notice.

As a licensed mortgage lender, we are also subject to the Gramm-Leach-Bliley Act ("GLBA") and Regulation P, which govern how financial institutions collect, share, and protect nonpublic personal information ("NPI"). This policy is designed to meet those requirements.

2. Information We Collect

We collect the following categories of information depending on how you interact with us:

Contact and Account Information

Name, email address, phone number, mailing address, and other contact information you provide when you inquire about our services, schedule a consultation, or create an account.

Mortgage Application Information

When you submit a loan application or use our pre-qualification tools, we may collect: Social Security number, date of birth, marital status, citizenship status, employment history and income, assets and bank account information, property address and details, credit history (obtained with your authorization from consumer reporting agencies), existing debts and liabilities, housing history, and military/veteran status.

Financial Information

Tax returns, pay stubs, bank statements, investment account statements, and other documentation required for mortgage underwriting.

Usage and Technical Information

When you visit our Website, we automatically collect: IP address, browser type and version, operating system, device information, pages visited, referring URL, and date/time of access. This information is collected via Vercel Analytics.

Scheduling Information

When you book a consultation through Cal.com, we receive your name, email, phone number, and any notes you provide.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To process and evaluate your mortgage application, including pre-qualification and pre-approval
• To communicate with you about your loan application, rates, and available programs
• To verify your identity and the accuracy of information you provide
• To comply with federal and state lending regulations, including GLBA, RESPA, TILA, ECOA, and HMDA
• To obtain credit reports and verify employment, income, and assets
• To respond to your inquiries and provide customer service
• To improve our Website, Services, and customer experience
• To detect, prevent, and address fraud or other illegal activity
• To send you mortgage-related communications, rate updates, and market information (with your consent)
• As otherwise required or permitted by law

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

Mortgage Processing and Underwriting

When you submit a loan application, your information flows through the following parties as necessary to process your mortgage:

• Finmo (Lendesk Technologies ULC) — Our loan origination platform that processes and transmits your application
• Rocket Mortgage, LLC — Our wholesale lending partner that underwrites and funds loans
• Consumer Reporting Agencies — Equifax, Experian, and/or TransUnion for credit reports (with your authorization)
• Title Companies — For title search, insurance, and closing services
• Appraisal Management Companies — For property valuation
• Government Agencies — FHA, VA, USDA, Fannie Mae, Freddie Mac as required for loan programs

Service Providers

We use the following third-party services that may process your data:

• Vercel — Website hosting and analytics
• Cal.com — Consultation scheduling
• Banking After Hours (Anthropic API) — AI-assisted pre-qualification and rate information
• Google Fonts — Typography delivery
• SendGrid — Email communications
• Twilio — SMS communications

Each of these services has its own privacy policy governing its use of your data.

Legal and Regulatory Disclosures

We may disclose your information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5. GLBA Privacy Notice

As a financial institution subject to the Gramm-Leach-Bliley Act, we are required to provide you with this notice about our information-sharing practices.

Categories of NPI we collect: Information from loan applications (name, SSN, income, assets, debts), information from consumer reporting agencies (credit history, credit scores), and information from your transactions with us (loan balances, payment history).

Categories of parties to whom we disclose NPI: Wholesale lending partners, consumer reporting agencies, government agencies, title and settlement companies, appraisal management companies, and service providers who assist in processing your loan.

Your right to opt out: We do not share your nonpublic personal information with nonaffiliated third parties for marketing purposes. If our practices change, we will provide you with a revised notice and an opportunity to opt out before sharing your information for such purposes.

6. Cookies and Tracking Technologies

Our Website uses minimal cookies necessary for site functionality. We use Vercel Analytics to collect anonymized usage data. We do not use advertising cookies, retargeting pixels, or third-party tracking cookies on richhomeloans.com.

Third-party services embedded on our site (such as Cal.com for scheduling) may set their own cookies. Please refer to their respective privacy policies for more information. You may configure your browser to reject cookies, though some features of our Website may not function properly without them.

Do Not Track. Some web browsers may transmit "Do Not Track" signals to websites. We currently do not respond to "Do Not Track" signals. To learn more about "Do Not Track," please visit allaboutdnt.com.

7. Data Security

We implement commercially reasonable physical, organizational, and technological security measures to protect your personal and financial information from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (HTTPS/TLS), access controls limiting data access to personnel with a business need, secure hosting infrastructure, and security headers on all web pages.

Despite these measures, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security of your information. In the event of a data breach that poses a risk of harm to you, we will notify you and applicable regulatory authorities as required by law.

Important: Do not transmit sensitive financial information (Social Security numbers, bank account numbers) via unencrypted email. Use our secure loan application portal or provide such information directly to your loan officer.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. Mortgage application records are retained in accordance with federal and state record-keeping requirements, which generally require retention for a minimum of three (3) to seven (7) years after the loan is closed, denied, or withdrawn. After the applicable retention period expires, we will securely dispose of or anonymize your information.

9. Your Rights

Depending on your state of residence, you may have some or all of the following rights regarding your personal information:

• Right to Know / Access: You may request a copy of the personal information we have collected about you in the preceding 12 months, including the categories of information, sources, purposes, and third parties with whom it has been shared.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions required by law (such as regulatory record-keeping requirements).
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Data Portability: You may request your personal information in a structured, commonly used, and machine-readable format.
• Right to Opt Out of Sale: We do not sell your personal information. If this practice changes, you will be notified and given the opportunity to opt out.
• Right to Limit Sensitive Data Use: You may request that we limit the use and disclosure of your sensitive personal information to purposes necessary for providing our Services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
• Right to Appeal: If we deny your privacy request, you may appeal that decision by contacting us.

To exercise any of these rights, contact us at richblanchard@richhomeloans.com or call (720) 619-9900. We may require verification of your identity before processing your request. We will respond to verifiable requests within 45 days, or notify you if additional time is needed.

10. Supplemental Notice for State Residents

Colorado Residents

Under the Colorado Privacy Act (CPA), you have the right to access, correct, delete, and obtain a portable copy of your personal data, as well as the right to opt out of the processing of your personal data for targeted advertising, sale, or profiling. To exercise these rights or to appeal a decision regarding your request, contact us using the information in the Contact section below.

Texas Residents

Under the Texas Data Privacy and Security Act (TDPSA), you have the right to confirm whether we are processing your personal data, access your data, correct inaccuracies, delete your data, obtain a portable copy, and opt out of processing for targeted advertising, sale, or profiling. To exercise these rights, contact us using the information below.

California Residents

Although RICH Home Loans is not currently licensed in California, if you are a California resident and we hold your personal information, you may have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to know, delete, correct, opt out of sale/sharing, and limit use of sensitive personal information. We collect the following categories of sensitive personal information as defined under the CCPA: Social Security numbers, driver's license numbers, and financial account information.

Kansas and Missouri Residents

Kansas and Missouri do not currently have comprehensive consumer data privacy statutes. However, you may exercise the general rights described in Section 9 above. We will honor reasonable requests to access, correct, or delete your personal information regardless of your state of residence.

11. Consent

By using our Website or Services, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. Where required by law, we will obtain your express consent before collecting or using your information for purposes not described herein.

You may withdraw your consent at any time by contacting us. However, withdrawal of consent may limit our ability to provide certain Services to you, including processing a mortgage application. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

12. Marketing Communications

With your consent, we may send you mortgage-related communications, rate updates, and market information via email or SMS. You may opt out of marketing communications at any time by clicking "unsubscribe" in any email, replying STOP to any text message, or contacting us directly. Opting out of marketing communications will not affect transactional messages related to your active loan application.

13. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will promptly delete that information. If you believe a child has provided us with personal information, please contact us.

14. Third-Party Websites

Our Website contains links to third-party websites and services, including Banking After Hours, Jupiter LOS, Cal.com, Redfin, HousingBrief, and NMLS Consumer Access. This Privacy Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party site you visit. We are not responsible for the privacy practices or content of third-party websites.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Effective" date at the top of this page. Your continued use of our Website or Services after a revised policy is posted constitutes your acceptance of the changes. We encourage you to review this policy periodically.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us:

RICH Home Loans LLC

Attn: Privacy Inquiries

1550 Wewatta St, 2nd FL, Denver, CO 80202

Email: richblanchard@richhomeloans.com

Phone: (720) 619-9900

NMLS #1787717