Last updated: 30th December 2024
1. Introduction
1.1 Purpose of This Privacy Policy
This Privacy Policy (“Policy”) explains how Myhomefinance (the “Website”), operated by AVM Visionaries (“Company,” “we,” “us,” or “our”), collects, uses, discloses, and safeguards your Personal Information. By “Personal Information,” we refer to information that can be used to identify you individually, such as your name, email address, phone number, and certain mortgage-related details. We are committed to handling your Personal Information responsibly and in compliance with all applicable U.S. federal and state privacy regulations.
1.2 Scope of Policy
This Policy applies solely to visitors and users of our Website and services (“Services”) located within the United States. We do not target or knowingly collect data from residents outside the United States, and our Services are intended only for U.S. users. By accessing or using our Website, you agree to the collection and use of your Personal Information as described in this Policy.
1.3 Relationship to Other Agreements
Your use of the Website is also governed by our Terms & Conditions. If any portion of this Policy conflicts with our Terms & Conditions, the terms of this Privacy Policy will apply with respect to privacy and data usage. If you do not agree to any part of this Policy, discontinue your use of the Website and Services immediately.
2. Definitions
2.1 “Company,” “We,” or “Us”
Refers to AVM Visionaries, a holding company based in Arizona, which operates and manages Myhomefinance and the Website www.myhomefinanceinfo.com.
2.2 “User,” “You,” or “Consumer”
Refers to any individual accessing or using the Website or Services for personal, non-commercial purposes.
2.3 “Website”
Means www.myhomefinanceinfo.com, including its subdomains, landing pages, and any other associated web properties controlled by us.
2.4 “Services”
Refers to the mortgage lead generation activities undertaken by the Company, including collecting, storing, and sharing Personal Information with participating Lenders or financial institutions.
2.5 “Personal Information”
Includes information that identifies, relates to, describes, or is reasonably capable of being associated with you as an individual. This specifically includes, without limitation, your name, email address, phone number, details of your current mortgage, and information relating to a prospective new mortgage.
2.6 “Lenders” or “Third-Party Partners”
Refers to the mortgage lenders, financial institutions, or other entities that purchase or otherwise receive Personal Information from us in order to offer or provide financing products to you.
3. Information We Collect
3.1 Personal Information You Provide
3.2 Non-Personal Information
When you use our Website, we may automatically collect certain non-personal information such as IP address, browser type, device type, pages visited, and the times or frequency of your visits. This type of data does not, on its own, directly identify you. However, if we link non-personal information to Personal Information, it will be protected as Personal Information under this Policy.
3.3 No Financial Account or Payment Card Details
Because Myhomefinance does not charge fees to borrowers for using our lead generation Services, we do not collect payment card information or bank account details. If ever needed, we would disclose this collection in a separate notice.
3.4 Children’s Information
Our Website is not intended for individuals under the age of thirteen (13). We do not knowingly collect Personal Information from children. Please see Section 18 (Children’s Privacy) for more details.
4. How We Collect Information
4.1 Direct Collection Through Forms
We collect Personal Information when you voluntarily submit it through online forms, prompts, or surveys on the Website. For instance, when you enter your details to request information about potential mortgage refinancing options.
4.2 Cookies and Tracking Technologies
We may use cookies, pixel tags, web beacons, or other similar technologies to collect non-personal information about your browsing activities on the Website. These technologies help us understand user preferences, improve our Services, and measure advertising effectiveness. You can manage your cookie preferences through your browser settings.
4.3 Third-Party Analytics
We may engage reputable third-party analytics providers to gather information about how users navigate and interact with the Website. This data is used to diagnose technical issues, analyze site performance, and improve user experiences.
4.4 Telephone and Email Communications
If you contact us by phone or email, we may retain records of your correspondence, including the phone number used or any Personal Information you share in the email body or subject line.
5. Purpose of Collection and Use of Information
5.1 Lead Generation and Matching Services
The primary reason we collect your Personal Information is to connect you with mortgage Lenders interested in offering financing products. We share your submitted data with these Lenders so they can assess your eligibility, provide quotes, or initiate contact regarding potential mortgage offers.
5.2 Communications
We use your Personal Information to respond to your inquiries, provide updates regarding our Services, and send relevant marketing or promotional messages (subject to your opt-out rights under Section 11 (CAN-SPAM and Email Communications)).
5.3 Legal and Regulatory Compliance
We may use your Personal Information to comply with applicable federal or state laws and regulations, including the Gramm-Leach-Bliley Act (GLBA). We also reserve the right to use your data to enforce this Policy and any applicable Terms & Conditions, or to protect our rights, property, and safety.
5.4 Site Improvements and Analytics
Your information helps us understand the effectiveness of our Website, including how visitors use different features. We use aggregated, anonymized data to enhance user experiences, troubleshoot technical issues, and develop new offerings.
5.5 Consent and Other Legitimate Interests
Where required by law, we will obtain your consent before collecting or using your Personal Information. In some cases, we may process your data based on our legitimate interest in providing secure, efficient, and user-friendly Services.
6. Sharing and Disclosure of Information
6.1 Sharing with Lenders
A core function of our Services involves sharing your Personal Information with third-party Lenders or financial institutions that purchase the information. These Lenders may use your data to evaluate your mortgage eligibility, contact you for further information, or offer you finance products. The Lenders’ use of your Personal Information is governed by their own privacy policies and practices, which we encourage you to review.
6.2 Third-Party Service Providers
We may share Personal Information with vendors or service providers who assist us with business operations, including website hosting, data analytics, email service platforms, or customer support. These third parties are authorized to use your Personal Information only as necessary to provide services to us, and they are contractually obligated to safeguard your data.
6.3 Compliance with Legal Obligations
We may disclose Personal Information if required to do so by law or in good-faith belief that such action is necessary to (a) comply with a subpoena, court order, or other legal process, (b) protect or defend our rights, safety, or property, (c) investigate fraud or enforcement of our Terms & Conditions, or (d) protect the rights and safety of users or the public.
6.4 Business Transfers
In the event of a merger, acquisition, joint venture, bankruptcy, reorganization, or sale of all or a portion of our assets, information in our possession, including Personal Information, may be transferred to the acquiring entity or other relevant third party, subject to any pre-existing consent or applicable legal constraints.
6.5 No Sale to Unrelated Third Parties (Outside of Lenders)
We do not sell or rent your Personal Information to unrelated third parties for their marketing purposes. The primary sharing of data beyond our internal operations is for the purpose of matching you with Lenders who purchase or receive the information to offer financing options.
7. GLBA Compliance
7.1 Financial Institution Status
Because our Services involve the collection and sharing of personal financial information with mortgage lenders, certain aspects of our operations may be subject to the Gramm-Leach-Bliley Act (“GLBA”) and its implementing regulations. Although we do not directly originate loans or offer credit decisions, we nonetheless take steps to safeguard personal financial information consistent with GLBA principles.
7.2 Privacy Notice Requirements
Under GLBA, financial institutions (including certain non-bank financial companies) must provide clear and conspicuous disclosure of their privacy practices. We incorporate GLBA-like disclosures into this Privacy Policy to inform you of how we collect, use, protect, and share Personal Information and financial data, where applicable.
7.3 Information Safeguards
We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and security of your Personal Information as required under GLBA. This includes limiting access to consumer data, periodically reviewing vendor contracts for data protection obligations, and training employees on proper data handling.
7.4 Opt-Out Rights (If Applicable)
Depending on your state of residence or other specific factors, you may have the right to limit how we share certain personal financial information with non-affiliated third parties. If you believe GLBA applies to your data in a manner that grants you opt-out rights, please contact us using the information in Section 24. We will review and honor your request as required by applicable law.
8. CCPA/CPRA Disclosures
8.1 California Applicability
If you are a California resident, the California Consumer Privacy Act (“CCPA”)—and as amended by the California Privacy Rights Act (“CPRA”)—may grant you additional rights regarding your Personal Information. These rights generally apply if we meet certain thresholds, such as processing the Personal Information of 100,000 or more California residents annually or deriving a certain percentage of revenue from the sale/sharing of California residents’ data. We provide these disclosures in the event we become subject to CCPA/CPRA requirements.
8.2 Categories of Personal Information Collected
Under CCPA/CPRA definitions, we may collect the following categories of Personal Information from California residents:
8.3 Your California Privacy Rights
Subject to legal exceptions, California residents may have the following rights:
8.4 How to Exercise Your Rights
To submit a verifiable consumer request, please use the contact details in Section 24. We may require additional information to verify your identity before processing your request. We will respond within the timeframe required by law.
8.5 Notice of Financial Incentive (If Applicable)
If we offer any financial incentive to California residents (e.g., discounts in exchange for data), we will provide a separate, detailed notice describing the material terms of such incentive. Currently, our Services do not involve direct monetary incentives for data collection.
9. Other State Privacy Laws
9.1 Virginia, Colorado, Connecticut, Utah
Several other states have enacted or are enacting comprehensive privacy laws (e.g., Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act). If we meet the applicable thresholds for these laws (e.g., annual revenue, volume of data processed, or targeted marketing to state residents), we will comply with each state’s specific consumer data rights and notice obligations.
9.2 State-Specific Consumer Rights
Depending on your state of residence, you may have rights similar to or in addition to those afforded under CCPA/CPRA, such as the right to access your Personal Information or request deletion. You may also have the right to appeal our decision if we decline to act on a request. We will honor valid requests in accordance with relevant state laws.
9.3 Exercising State-Level Requests
To inquire about or exercise any privacy right afforded under your state’s law, please contact us using the methods described in Section 24. We will review your request and respond within the timeframe mandated by applicable legislation.
9.4 Arizona Consumer Protection Act
The Arizona Consumer Fraud Act (A.R.S. § 44-1521 et seq.) prohibits deceptive or fraudulent practices in the handling of personal data. While the Act does not provide specific privacy provisions, we strive to adhere to its principles by ensuring transparency and fairness in our collection, use, and sharing of Personal Information. If you believe your privacy rights have been violated under Arizona law, please contact us using the details provided in Section 24.
10. Telephone Consumer Protection Act (TCPA)
10.1 Consent to Contact
By submitting your phone number on any form or prompt on the Website, you expressly consent to receive telephone calls and text messages (which may be placed using an autodialer or artificial/prerecorded voice) from us or our participating Lenders for the purpose of discussing potential mortgage or refinance options. You understand that this consent is not a condition of any purchase.
10.2 Opt-Out of Communications
If you wish to opt out of receiving calls or text messages at any time, please follow the instructions provided in the communication or contact us directly via email or phone (details in Section 24). We will comply with your request promptly, in accordance with TCPA requirements.
10.3 Do-Not-Call and Other Protections
We endeavor to respect “Do Not Call” registries. If your number is on such a registry but you have provided express consent to receive calls, we will honor the scope of your consent unless and until it is revoked. Should you revoke consent, we will update our records within a reasonable timeframe.
11. CAN-SPAM and Email Communications
11.1 Commercial Emails
We may send you emails about our Services or marketing communications from time to time. All commercial emails will clearly identify the sender, contain a valid physical address, and provide instructions for unsubscribing.
11.2 Opt-Out/Unsubscribe Process
If you prefer not to receive marketing emails, you may unsubscribe by clicking the “Unsubscribe” link in the email footer or by contacting us directly. Please note that you cannot opt out of receiving certain non-marketing emails, such as those regarding your account, transactions, or legal notices.
11.3 Accurate Header and Subject Lines
In compliance with the CAN-SPAM Act, we ensure that our email “From,” “To,” “Reply-To,” and routing information (including the originating domain name and email address) are accurate and that our subject lines are not misleading.
12. Data Retention
12.1 Retention Periods
We retain Personal Information only as long as necessary to fulfill the purposes described in this Policy or as required by law. The length of time we keep specific data may vary based on the nature of the data, the sensitivity of the data, the risk of harm if the data is misused, and legal or regulatory requirements.
12.2 Criteria for Determining Retention
We may also consider our contractual obligations, industry standards, and potential litigation or regulatory inquiries when deciding how long to keep data. Where a statute or regulation mandates a specific retention period, we comply with those requirements.
12.3 Deletion Procedures
When Personal Information is no longer needed for legal or operational purposes, we will securely dispose of it. This may involve deleting or anonymizing the data in a manner that makes it virtually impossible to re-identify.
13. Data Security Measures
13.1 Administrative Safeguards
We implement administrative measures, such as employee training and access controls, to ensure that only those individuals with a legitimate business need have access to your Personal Information. We also require our staff to adhere to internal policies and procedures designed to protect consumer data.
13.2 Technical Safeguards
Our Website may utilize encryption (e.g., Secure Socket Layer/Transport Layer Security) to protect data transmissions. We employ firewalls, malware detection, and other security technologies to mitigate risks of unauthorized access or loss. Nonetheless, no security measure is infallible, and we cannot guarantee absolute security.
13.3 Physical Safeguards
We maintain physical controls at our facilities to protect against unauthorized access to hardware or documents containing Personal Information. These controls may include locked file cabinets, secure office spaces, and monitoring systems, where applicable.
13.4 Disclaimer: No Absolute Security
Despite our commercially reasonable efforts to protect your Personal Information, no method of data storage or transmission can be guaranteed entirely secure. By using our Website and Services, you acknowledge and accept these inherent risks.
14. Data Breach Notification
14.1 Applicable State Laws
We comply with all relevant federal and state data breach notification laws. If a breach of security affecting your Personal Information occurs, we will investigate promptly and notify you and applicable regulatory authorities in accordance with legal requirements.
14.2 Notification Procedures
Depending on the nature of the breach, we may notify you by email, telephone, postal mail, prominent posting on the Website, or other means permitted by applicable law. The notification will describe, as required by law, the nature of the breach, the affected data, and any recommended measures to protect your information.
14.3 User Responsibilities
You are responsible for maintaining the security of your account credentials, if any. Please contact us immediately if you suspect unauthorized access to your account or any misuse of your Personal Information.
15. No Cost to Borrowers / Payment Information
15.1 Free Service Explanation
Myhomefinance’s lead generation Services are provided at no direct cost to borrowers. We do not charge fees to consumers seeking mortgage or refinance information through our Website. Lenders may compensate us for leads, but that compensation does not affect the consumer’s use of the Website.
15.2 No Payment Card Data Collected
We do not request or store payment card information (e.g., credit card numbers) from borrowers. If you are ever asked to provide such details on our Website, please contact us immediately via the information provided in Section 24.
15.3 Third-Party Fees
If, in the future, any fees or costs become applicable for certain premium features or additional services, we will provide clear disclosures about those fees and the methods of payment prior to collecting any financial information.
16. Cookies and Tracking Technologies
16.1 Types of Cookies
We may use session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until they expire or are deleted) to enhance site functionality, analyze usage, and remember your preferences. Some cookies may be placed by third-party service providers acting on our behalf.
16.2 Purposes of Use
16.3 Managing Cookies
You can typically set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, blocking or deleting cookies may limit your access to certain features of the Website.
16.4 “Do Not Track” Signals
Our Website does not currently respond to “Do Not Track” browser signals, in part because there is no industry or legal standard for recognizing or honoring them.
17. Targeted Advertising and Marketing Disclosures
(If Applicable)
17.1 Behavioral Advertising
We or our advertising partners may use tracking technologies (e.g., cookies, pixels) to collect information about your browsing activities on this Website over time and across third-party sites or online services. This data may be used to display ads relevant to your interests, also known as interest-based or behavioral advertising.
17.2 Opt-Out Options
Depending on your state of residence or personal preferences, you may have the right to opt out of targeted advertising. You can often manage advertising preferences through your browser settings or via industry opt-out tools such as the Digital Advertising Alliance’s WebChoices tool.
17.3 Advertising Partners
Any ads or sponsored content on our Website may be delivered by reputable third-party advertising networks. We encourage you to review their privacy practices as they may differ from ours, especially regarding how they process or store your Personal Information.
18. Children’s Privacy
18.1 No Collection from Children Under 13
Our Website and Services are not directed at children under the age of thirteen (13), and we do not knowingly collect Personal Information from them. If you are under 13, please do not submit any information through this Website.
18.2 COPPA Compliance Statement
We comply with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws designed to protect minors’ privacy online. If we learn that a child under 13 has provided Personal Information, we will delete that data promptly and terminate the associated account, if any.
18.3 Parental Rights and Contact
If you believe that we may have collected Personal Information from a child under 13, please contact us using the details provided in Section 24. We will investigate and remove any such information in accordance with applicable laws.
19. User Choices and Rights
19.1 Access and Correction
Depending on your state of residence and the nature of the Personal Information we maintain, you may have the right to access certain information we hold about you and request corrections if the data is inaccurate or outdated. To make such a request, please contact us at the address or email listed in Section 24. We may require additional information to verify your identity before granting access or making corrections.
19.2 Deletion Requests
Certain U.S. privacy laws grant eligible consumers the right to request deletion of their Personal Information. If you believe you qualify for this right, please submit a verifiable deletion request using the methods described in Section 24. We will remove your data in accordance with applicable laws, subject to retention exceptions where legally permissible (e.g., compliance with regulatory requirements).
19.3 Opt-Out of Marketing Communications
You can opt out of receiving marketing or promotional emails at any time by following the unsubscribe instructions in each message or by contacting us directly. Note that certain non-marketing communications, such as those related to your account or transactions, may still be sent even after you unsubscribe.
19.4 Limit Use of Sensitive Information
If applicable state law grants you the right to restrict or limit the processing of certain sensitive information (e.g., financial or health-related data), you may submit a request to exercise this right. We will comply where required under relevant regulations.
20. Third-Party Websites
20.1 External Links
Our Website may contain links to external websites or online services that we do not operate or control. These links are provided solely for your convenience and do not constitute an endorsement by us of the content, policies, or practices of such external websites.
20.2 No Responsibility for Third-Party Privacy Practices
We are not responsible for the privacy or security practices of any third parties, including any Lenders or other websites that may be referenced or accessible through our Website. Please review the privacy statements of those third-party sites before submitting any Personal Information to them.
20.3 Encouragement to Review Third-Party Policies
We strongly recommend that you familiarize yourself with the privacy policies and terms of service of any third-party websites or Lenders to whom you provide Personal Information. Doing so will help ensure that you understand how your data is handled once it leaves our control.
21. State-Specific Disclosure Requirements
21.1 “Shine the Light” Law (California)
Under California’s “Shine the Light” law (Civil Code § 1798.83), California residents who have provided Personal Information to a business may request certain information regarding the business’s disclosure of Personal Information to third parties for direct marketing purposes. If you are a California resident and wish to make such a request, please contact us using the details in Section 24.
21.2 Other State-Specific Disclosures
Certain states require specific disclosures regarding data collection, sharing, or processing practices. Where these laws apply, we will provide supplemental notices or instructions as required by the relevant state statutes. Examples may include the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), or the Utah Consumer Privacy Act (UCPA).
21.3 Contacting Company for Details
If you have questions regarding your state’s privacy rights or how to exercise them, please direct your inquiry to the address or email listed in Section 24. We will review your request and respond within the timeframe required by applicable law.
22. Changes to This Privacy Policy
22.1 Right to Modify
We reserve the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our practices, legal requirements, or the services we offer. Any material changes will be posted on this page along with the effective date of the revised Policy.
22.2 Effective Date of Changes
We will indicate the date this Policy was last revised at the bottom of the document. If we make significant changes to how we handle your Personal Information, we may provide additional, more prominent notice (e.g., a website banner or email notification).
22.3 Notification of Material Changes
Where required by law, we will provide you with advance notice of material modifications to this Policy and an opportunity to review the revised terms before they become effective. Your continued use of our Website or Services after such changes indicates your acceptance of the new terms.
23. Governing Law
23.1 Arizona Law
This Privacy Policy, and any claims arising from or related to your use of the Website or our handling of your Personal Information, shall be governed by and interpreted in accordance with the laws of the State of Arizona, without regard to its conflict-of-law provisions.
23.2 Applicability in Other Jurisdictions
By choosing to access or use our Services from outside Arizona, you do so on your own initiative and are responsible for compliance with local laws. However, we do not warrant or represent that this Privacy Policy or our data practices comply with the legal requirements of every jurisdiction.
23.3 Dispute Resolution
Any disputes related to this Privacy Policy may be subject to the dispute resolution provisions set forth in our Terms & Conditions, including any arbitration clause or other agreed-upon mechanism for resolving conflicts.
24. Contact Information
24.1 Email Address
For questions, concerns, or requests relating to this Privacy Policy or your Personal Information, you may contact us at:
[Email Address]
24.2 Customer Support
If you prefer, you can reach out to our customer support team via phone at [Phone Number], Monday through Friday, [Business Hours]. When contacting us, please provide sufficient detail about your inquiry or request to enable us to respond promptly and accurately.
25. Acceptance and Acknowledgment
25.1 Consent to Policy
By accessing or using the Website and our Services, you signify that you have read, understood, and agree to the collection and use of your Personal Information in accordance with this Privacy Policy, as well as any other applicable documents referenced herein.
25.2 Binding Effect
This Privacy Policy forms a legal agreement between you and us concerning your use of the Website. If you do not agree to be bound by the terms of this Policy, you must refrain from using the Website and the Services.
25.3 Date of Last Update
This Privacy Policy was last updated on: 30th December 2024