LEGAL

Privacy Policy

1  About This Policy

This Privacy Policy (the “Policy”) describes the information Signal Intent, Inc. (“Chimney”) collects about you, how we use and share that information, and the privacy choices we offer. This Policy applies to information we collect when you open an account through Chimney, access or use our website, mobile application, products, and services (collectively, the “Services”), or when you otherwise interact with us. This includes information we collect when you submit information to Chimney for purposes of receiving an estimate of the equity in your home. We suggest you read this Policy carefully.

The terms “Chimney,” “we,” “us,” or “our” mean Signal Intent, Inc. “You” or “your” means an individual who visits our website or uses our mobile applications or Services. The term “Platform” includes (1) all websites and mobile applications operated by Chimney that collect personal information from you and that link to this Privacy Policy, and (2) all pages within each such website, device, or mobile application, any equivalent, mirror, replacement, substitute, or backup website, device, or mobile application. By using our Services or our Platform, you acknowledge and agree to the terms of this Policy. If you do not agree to this Policy, do not use or continue to use the Services or Platform.

2 Personal Information We Collect and Disclose

Chimney collects personal information about you for a variety of purposes. We collect information about you (1) directly from you, (2) automatically when you use the Services or Platform, and (3) from third parties such as consumer reporting agencies.

Information you provide to us. Personal information you may provide us includes:

  • Contact details, such as your first and last name, email, phone number, and home address.
  • Platform account data, such as the username and password that you may use to establish an online account with us.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically collect information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Our Services and Platform may use the following technologies:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

We note that some browsers incorporate Do Not Track features intended to signal to websites that the user does not want to have online activity tracked. How browsers communicate this signal, however, is not uniform; as such, our Services and Platform are not set up to interpret or respond to Do Not Track signals.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Data brokers or consumer reporting agencies that provide us with information to allow us to better tailor our Services to you or qualify you for Services, such as information about your existing mortgage or information about your home’s current value for purposes of evaluating the equity you have in your current home and whether you qualify for other financing offers.
  • Financial institutions that operate any financial accounts or products that are connected to your Chimney Platform account, including your current mortgage lender.
  • We may also collect information about you from mailing list providers, publicly available sources, identification verification services, and other third parties.
3 How We Use Your Information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

  • Provide, operate, and improve our Services and Platform and our business, including personalizing the Services for your use;
  • Complete transactions, including enabling you to apply for financing offers from our financial partners;
  • Communicate with you about our Services or Platform, including by sending announcements, updates, security alerts, and support and administrative messages;
  • Understand your needs and interests, and personalize your experience with the Services and our communications; and
  • Provide support for our Services and Platform, and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services, our Platform, and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into aggregated, de-identified, or anonymous data by removing information that makes the data personally identifiable to you; aggregated, de-identified, and anonymous data is thus not covered by the terms of this Policy.  We may use this aggregated, de-identified, and anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and Platform, and promote our business.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

  • Direct marketing. We may send you Chimney-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in Section 5 below. 

Compliance and protection. We may use your personal information to:

  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services and Platform; and
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

Comply with law. We may use your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

4 How We Share Your Information

We share your personal information with the following third parties or as otherwise described at the time of collection:

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services, our Platform, or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). Our service providers include companies that assist us in accessing your home mortgage data. Our service providers also include professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Our financial partners. Companies with whom we partner to offer you financial products and services that you request, including identifying  financing offers that may be available to you. These companies’ privacy and information sharing practices are set forth in their respective privacy policies.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Chimney (including, in connection with a bankruptcy or similar proceedings).

Advertising partners.

Although we share your personal information as described above, we do not sell your personal information to any third parties. We also may share your personal information with additional third parties as you direct us to in writing.

5 How We Protect Your Information

We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information. Examples of measures we have taken to protect your information include, but are not limited to:

  • The use of encryption while transmitting and storing information.
  • Mobile application session timeouts to ensure your information is protected when you put down your device without logging out.
  • Passwords and personal identification numbers (“PINs”) are only known by you. No employee, contractor or third-party site has access to your Chimney password or PIN. We will never ask for your password or PIN through our customer service teams.
  • Our systems are periodically audited for security flaws.

Please take note that no security measures are failsafe, and we cannot guarantee the security of your personal information.

6 Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you.  To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in Section 10 below. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you have a Chimney Platform account, you may update some of your account details and settings by logging into your account on our Platform, by writing us at support@chimney.io. Please note that even if you close your Chimney Platform account, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

7 Children’s Privacy

Our Services and Platform are not intended for use by individuals under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

8 Links to Third-Party Services and Features

For your convenience and information, our Platform may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Chimney, we are not responsible for these third parties’ information practices.

9 Changes to This Privacy Policy

We reserve the right, at our discretion, to make changes to this Policy from time to time, so please review it frequently. You may review updates to our https://chimney.io/eula and Privacy Policy at any time at https://chimney.io/privacy-policy. You agree to accept electronic communications or postings of revised versions of this Policy on https://chimney.io/privacy-policy and agree that such electronic communications or postings constitute notice to you of the revised version of this Policy. Changes take effect immediately upon posting.

10 How to Contact Us

If you have questions or concerns regarding this Policy, you may contact us through email at support@chimney.io.

11 Federal Privacy Notice

WHAT DOES Signal Intent, Inc. (“Chimney”) DO WITH YOUR PERSONAL INFORMATION?

Why? 

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What? 

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

●  Social Security Number

●  Payment history

●  Credit history

●  Mortgage rates and payments

●  Employment information

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Chimney chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Chimney share?

 

Can you limit this sharing?

 

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations

Yes

No

For our marketing purposes– to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes –information about your transactions and experiences

No – Chimney has no affiliates

We don’t share

For our affiliates to market to you

No – Chimney has no affiliates

We don’t share

For nonaffiliates to market to you

No

We don’t share

Questions?

Email us at support@chimney.io.

Who we are

Who is providing this notice?

Chimney is providing this privacy policy and it applies to all home equity information by the company and all products and services offered in connection with such home equity information.

What we do

How does Chimney protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Chimney collect my personal information?

We collect your personal information, for example, when you

●  Open an account

●  Seek financial or tax advice

●  Apply for financing

●  Give us your contact information

●  Provide your mortgage information

We also collect your personal information from others such as credit bureaus, affiliates or other companies [OR] We also collect your personal information from other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

●  sharing for affiliates’ everyday business purposes – information about your creditworthiness

●  affiliates from using your information to market to you

●  sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Joint marketing partners can include institutions such as consumer lenders or marketers.

·   Chimney doesn’t do joint marketing

Other Important Information

For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Vermont and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization.

12 California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the Chimney Privacy Policy and applies solely to California consumers. This Statement does not apply to Chimney personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, telephone number, and other financial information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as age
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Education Information: information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Chimney Privacy Policy and for the following business purposes specified in the CCPA:

  • Auditing interactions with consumers: auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Security: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging/repair: Debugging to identify and repair errors that impair existing intended functionality
  • Certain short-term uses: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Performing services: including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services
  • Internal research for technological development and demonstration
  • Quality and safety maintenance and verification: undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

  • Directly from you, such as when you use the Chimney Platform or contact customer support
  • Our financial partners and their service providers, including your current mortgage lender
  • Your devices, when you use our Platform
  • Vendors who provide services on our behalf
  • Our joint marketing partners
  • Our business partners (such as referring websites)
  • Online advertising services and advertising networks
  • Data analytics providers
  • Government entities
  • Operating systems and platforms
  • Data brokers
  • Consumer reporting agencies

Sale of Personal Information

We do not “sell” personal information within the meaning of the CCPA.

Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below. When we share personal information with our financial partners to facilitate your submission of an application for financing to them, we do so as their service provider. The privacy practices of our financial partners are subject to their privacy notices which we strongly suggest you review. Chimney is not responsible for our financial partners’ information practices or privacy notices.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information

Category of Third Party

Identifiers

Our financial partners, our service providers, and our marketing partners

Additional Data Subject to Cal. Civ. Code § 1798.80 Law

Our financial partners, our service providers, and our marketing partners

Protected Classifications

Our financial partners

Commercial Information

Our financial partners, our service providers

Online Activity

Our service providers

Geolocation data

Our service providers, our marketing partners

Sensory Information

Our service providers

Employment Information

Our service providers

Education information

Our service providers

Inferences

Our service providers

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: government entities; other persons to whom we have a legal obligation to disclose personal information (including, for example, in response to a duly issued subpoena or search warrant); and other persons to whom you authorize Chimney to disclose your personal information.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.
  • Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access or deletion request, please submit a request by emailing support@chimney.io. To submit a Shine the Light request, submit a request by emailing support@chimney.io. Be sure not to transmit ANY sensitive information in your initial request; if we need additional information to identify you for the purpose of responding to your request, we will contact you.

If you designate an authorized agent to make an access or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in Section 10.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, your phone number, and the email and physical addresses associated with your Chimney Platform account. If you have never had a Chimney Platform account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that Chimney does not maintain information about non-accountholders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Even if we can verify your identify, we may also decline to honor your request when an exception applies, such as where disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information we maintain about you is not subject to the CCPA.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

3 How We Use Your Information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

  • Provide, operate, and improve our Services and Platform and our business, including personalizing the Services for your use;
  • Complete transactions, including enabling you to apply for financing offers from our financial partners;
  • Communicate with you about our Services or Platform, including by sending announcements, updates, security alerts, and support and administrative messages;
  • Understand your needs and interests, and personalize your experience with the Services and our communications; and
  • Provide support for our Services and Platform, and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services, our Platform, and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into aggregated, de-identified, or anonymous data by removing information that makes the data personally identifiable to you; aggregated, de-identified, and anonymous data is thus not covered by the terms of this Policy.  We may use this aggregated, de-identified, and anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and Platform, and promote our business.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

  • Direct marketing. We may send you Chimney-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in Section 5 below.

Compliance and protection. We may use your personal information to:

  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services and Platform; and
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

Comply with law. We may use your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

4 How We Share Your Information

We share your personal information with the following third parties or as otherwise described at the time of collection:

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services, our Platform, or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). Our service providers include companies that assist us in accessing your home mortgage data. Our service providers also include professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Our financial partners. Companies with whom we partner to offer you financial products and services that you request, including identifying  financing offers that may be available to you. These companies’ privacy and information sharing practices are set forth in their respective privacy policies.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Chimney (including, in connection with a bankruptcy or similar proceedings).

Advertising partners.

Although we share your personal information as described above, we do not sell your personal information to any third parties. We also may share your personal information with additional third parties as you direct us to in writing.

2 Personal Information We Collect and Disclose

Chimney collects personal information about you for a variety of purposes. We collect information about you (1) directly from you, (2) automatically when you use the Services or Platform, and (3) from third parties such as consumer reporting agencies.

Information you provide to us. Personal information you may provide us includes:

  • Contact details, such as your first and last name, email, phone number, and home address.
  • Platform account data, such as the username and password that you may use to establish an online account with us.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically collect information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Our Services and Platform may use the following technologies:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

We note that some browsers incorporate Do Not Track features intended to signal to websites that the user does not want to have online activity tracked. How browsers communicate this signal, however, is not uniform; as such, our Services and Platform are not set up to interpret or respond to Do Not Track signals.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Data brokers or consumer reporting agencies that provide us with information to allow us to better tailor our Services to you or qualify you for Services, such as information about your existing mortgage or information about your home’s current value for purposes of evaluating the equity you have in your current home and whether you qualify for other financing offers.
  • Financial institutions that operate any financial accounts or products that are connected to your Chimney Platform account, including your current mortgage lender.
  • We may also collect information about you from mailing list providers, publicly available sources, identification verification services, and other third parties.

5 How We Protect Your Information

We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information. Examples of measures we have taken to protect your information include, but are not limited to:

  • The use of encryption while transmitting and storing information.
  • Mobile application session timeouts to ensure your information is protected when you put down your device without logging out.
  • Passwords and personal identification numbers (“PINs”) are only known by you. No employee, contractor or third-party site has access to your Chimney password or PIN. We will never ask for your password or PIN through our customer service teams.
  • Our systems are periodically audited for security flaws.

Please take note that no security measures are failsafe, and we cannot guarantee the security of your personal information.

6 Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you.  To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in Section 10 below. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you have a Chimney Platform account, you may update some of your account details and settings by logging into your account on our Platform, by writing us at support@chimney.io. Please note that even if you close your Chimney Platform account, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

7 Children’s Privacy

Our Services and Platform are not intended for use by individuals under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

8 Links to Third-Party Services and Features

For your convenience and information, our Platform may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Chimney, we are not responsible for these third parties’ information practices.

9 Changes to This Privacy Policy

We reserve the right, at our discretion, to make changes to this Policy from time to time, so please review it frequently. You may review updates to our https://chimney.io/eula and Privacy Policy at any time at https://chimney.io/privacy-policy. You agree to accept electronic communications or postings of revised versions of this Policy on https://chimney.io/privacy-policy and agree that such electronic communications or postings constitute notice to you of the revised version of this Policy. Changes take effect immediately upon posting.

10 How to Contact Us

If you have questions or concerns regarding this Policy, you may contact us through email at support@chimney.io.

5 How We Protect Your Information

We take your privacy and the security of your information very seriously, and have an information security program that includes administrative, technical, and physical measures to protect your information. Examples of measures we have taken to protect your information include, but are not limited to:

  • The use of encryption while transmitting and storing information.
  • Mobile application session timeouts to ensure your information is protected when you put down your device without logging out.
  • Passwords and personal identification numbers (“PINs”) are only known by you. No employee, contractor or third-party site has access to your Chimney password or PIN. We will never ask for your password or PIN through our customer service teams.
  • Our systems are periodically audited for security flaws.

Please take note that no security measures are failsafe, and we cannot guarantee the security of your personal information.

6 Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you.  To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in Section 10 below. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you have a Chimney Platform account, you may update some of your account details and settings by logging into your account on our Platform, by writing us at support@chimney.io. Please note that even if you close your Chimney Platform account, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

7 Children’s Privacy

Our Services and Platform are not intended for use by individuals under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

8 Links to Third-Party Services and Features

For your convenience and information, our Platform may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Chimney, we are not responsible for these third parties’ information practices.

9 Changes to This Privacy Policy

We reserve the right, at our discretion, to make changes to this Policy from time to time, so please review it frequently. You may review updates to our https://chimney.io/eula and Privacy Policy at any time at https://chimney.io/privacy-policy. You agree to accept electronic communications or postings of revised versions of this Policy on https://chimney.io/privacy-policy and agree that such electronic communications or postings constitute notice to you of the revised version of this Policy. Changes take effect immediately upon posting.

10 How to Contact Us

If you have questions or concerns regarding this Policy, you may contact us through email at support@chimney.io.

11 Federal Privacy Notice

Chimney Privacy Policy

FACTS

WHAT DOES Signal Intent, Inc. (“Chimney”) DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security Number
  • Payment history
  • Credit history
  • Mortgage rates and payments
  • Employment information

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Chimney chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information Does Chimney share? Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations Yes No
For our marketing purposes– to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes –information about your transactions and experiences No – Chimney has no affiliates We don’t share
For our affiliates to market to you No – Chimney has no affiliates We don’t share
For nonaffiliates to market to you No We don’t share

Questions?

Email us at support@chimney.io.

Who we are

Who is providing this notice?

Chimney is providing this privacy policy, and it applies to all home equity information by the company and all products and services offered in connection with such home equity information.

What we do

How does Chimney protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Chimney collect my personal information?

We collect your personal information when you:

  • Open an account
  • Seek financial or tax advice
  • Apply for financing
  • Give us your contact information
  • Provide your mortgage information

We also collect your personal information from others such as credit bureaus, affiliates, or other companies [OR] We also collect your personal information from other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Joint marketing partners can include institutions such as consumer lenders or marketers.

· Chimney doesn’t do joint marketing

Other Important Information

For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Vermont and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing without your authorization.

12 California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the Chimney Privacy Policy and applies solely to California consumers. This Statement does not apply to Chimney personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, telephone number, and other financial information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as age
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Education Information: information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Chimney Privacy Policy and for the following business purposes specified in the CCPA:

  • Auditing interactions with consumers: auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Security: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging/repair: Debugging to identify and repair errors that impair existing intended functionality
  • Certain short-term uses: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Performing services: including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services
  • Internal research for technological development and demonstration
  • Quality and safety maintenance and verification: undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

  • Directly from you, such as when you use the Chimney Platform or contact customer support
  • Our financial partners and their service providers, including your current mortgage lender
  • Your devices, when you use our Platform
  • Vendors who provide services on our behalf
  • Our joint marketing partners
  • Our business partners (such as referring websites)
  • Online advertising services and advertising networks
  • Data analytics providers
  • Government entities
  • Operating systems and platforms
  • Data brokers
  • Consumer reporting agencies

Sale of Personal Information

We do not “sell” personal information within the meaning of the CCPA.

Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below. When we share personal information with our financial partners to facilitate your submission of an application for financing to them, we do so as their service provider. The privacy practices of our financial partners are subject to their privacy notices which we strongly suggest you review. Chimney is not responsible for our financial partners’ information practices or privacy notices.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Personal Information Categories

Category of Personal Information

Category of Personal Information Category of Third Party
Identifiers Our financial partners, our service providers, and our marketing partners
Additional Data Subject to Cal. Civ. Code § 1798.80 Law Our financial partners, our service providers, and our marketing partners
Protected Classifications Our financial partners
Commercial Information Our financial partners, our service providers
Online Activity Our service providers
Geolocation data Our service providers, our marketing partners
Sensory Information Our service providers
Employment Information Our service providers
Education information Our service providers
Inferences Our service providers

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: government entities; other persons to whom we have a legal obligation to disclose personal information (including, for example, in response to a duly issued subpoena or search warrant); and other persons to whom you authorize Chimney to disclose your personal information.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.
  • Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access or deletion request, please submit a request by emailing support@chimney.io. To submit a Shine the Light request, submit a request by emailing support@chimney.io. Be sure not to transmit ANY sensitive information in your initial request; if we need additional information to identify you for the purpose of responding to your request, we will contact you.

If you designate an authorized agent to make an access or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in Section 10.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, your phone number, and the email and physical addresses associated with your Chimney Platform account. If you have never had a Chimney Platform account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that Chimney does not maintain information about non-accountholders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Even if we can verify your identify, we may also decline to honor your request when an exception applies, such as where disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information we maintain about you is not subject to the CCPA.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.