Ardley Privacy Policy

Last Updated: August 25, 2022
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1.0 Introduction

Ardley Technologies, Inc is a technology company headquartered in Reston, Virginia, which focuses on providing automation services to mortgage servicers, mortgage originators, banks and other financial institutions.

For more information about our services, please refer to our website:

‍www.ardley.com

‍This Privacy Policy is applicable to Ardley Technologies, Inc ("Ardley," “we,” “our,” or “us”) as related to our Services, which collectively include:

• the use of ardley.com(“website”)
• the use of the application website white labeled for our clients (“application”)
• social media messages and marketing campaigns and
• the use of our products and services
• the use of our products and services f the financial institution you use (your "Financial Services Provider" has engaged Ardley to provide an online experience.

This Privacy Policy sets out the essential details relating to your personal data relationships with Ardley Technologies, Inc as:

• A website visitor
• An end user of the application (“end user”)
• A prospective client
• A job applicant and
• Partners

Clients contract the use of our application and give access to their employees and other third parties, as solely decided by them, by creating users who access the application with their email address and credentials. The clients’ administrators grant end users roles, which result in different permissions and access rights to the information held in the Client account.
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2.0 Personal Information We Collect

2.1 Information You Choose to Provide to Us

WHEN
‍We may ask you to provide personal information when:

• You use the website to download articles, data sheets or eBooks.
• You request a free trial or demo.
• You refer a friend to us.
• You connect with us directly via phone calls or video conferencing platforms.
• We or Client Account Administrators grant you access to the application.
• You or Client Account Administrators upload or enter personal information into the application.
• You participate in a marketing/sales promotion.
• You attend trade events and other industry networking events.
• You register or attend a webinar or other event.
• You participate in programs we may offer from time to time.
• You participate in chats.
• You pay for our services.
• You use the Ardley application through a Client.

If you choose to provide us with a third-party’s personal information (the person’s name, email and company) when taking part in our referral program, you represent that you have the third-party’s permission to do so.

WHAT
‍We collect personal information that may include first and last name, business email address, phone number and/or company name. As an end user of the application, we collect your personal information (such as name, address, email, telephone number, IP address, or similar identifiers) and any comments you make in the application.In addition, we may collect data uploaded by you, your employer or other users of the application that may be required to use Ardley Technologies, Inc services. We expect all users to follow their organization’s privacy policy and any applicable regulatory requirements when uploading, accessing and using personal information into our application. The data uploaded may include personal information like:
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• Employee names, email addresses and contractual agreements
• Vendor names, email addresses, contractual agreements or other personal data necessary for Ardley Technologies, Inc services
• Customer names and email addresses used to provide services within Ardley Technologies, Inc’s platform
• Financial information (such as financial history including income and asset information)
• Transactional information from behind a secure login about your relationship with various financial institutions (such as account balances or the state in which you bank)
• Professional and employment information (such as employment history)
• Internet and network device activity (such as information about the device you are using, the presence of software on your device, your browser type, search engine traffic referral information)
• Educational history (such as information about your educational history and institutions)
• Geolocation information (such as information inferred from an IP address)
• Website analytics information (such as pages visited and average time spent on a particular page)

As a job applicant, we may also collect your resume and cover letter.
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2.2 Information We Collect Automatically

WHEN
‍We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology. NOTE: It is necessary to install a cookie on your browser to identify that you have opted-out. If you delete the opt-out cookie, or change devices or web browsers, you will need to opt-out again.

‍WHAT
‍The information collected includes:

• access times
• the pages you view
• the links you click on
• the search terms you enter
• actions you take in connection with any of the visited pages
• your device information such as IP address, location, browser type and language
• the Uniform Resource Locator (URL) of the website that referred you to our website and
• the URL you browse away from our pages if you click on an external link

We may also collect information when you open email messages from us or click on links within those email messages.

‍2.3 Information We May Collect From Third Parties

WHEN
‍We may combine the information we collect from your direct interactions with us with information obtained through other third-party sources, such as the credit reports and credit scores we request on your behalf from your mortgage servicer, TransUnion, Experian and Equifax, and bank account and other financial account information.

‍WHAT
‍We may also work with different third party partners to supplement the Personal Information and other information we collect directly from you. For example, our partners may provide us with information such as employment or income data, vehicle or driver information, or information about special offers available based on your credit profile so we can give you more personalized recommendations.
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3.0 How We Use Personal Information  
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We use the personal information we collect from you and third parties to operate our Services, communicate with you, conduct research and development to improve or enhance our Services and our users' experience, and promote our Services.
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• Deliver the contracted services and allow full use of the application functionality as purchased by the clients.
• Deliver training and support to our application end users and/or carry out the transactions you have requested.
• To create your account and provide Services to you. We use the information we collect to create and secure your account, create and maintain your account profile, and to provide the Services to you.
• To provide features to you, such as mortgage loans. We use your Personal Information to help you find mortgage loan options and help you close your mortgage loan efficiently.
• To communicate with you directly through emails, calls, chats, video conferencing.
• Process payments for application subscriptions.
• Send communications to you about:

• New application features and upgrades.
• Our services and offerings.
• Event announcements.
• Product notices and changes to our terms and policies.
• Particular programs in which you have chosen to participate.
• Promotional offers and surveys.
• Scheduling demos and managing free trials.

• Advertise and market our products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites.
• Carry out market research to understand how to improve our services and their delivery.
• Create and manage marketing campaigns.
• Generate sales leads and increase our market share.
• Analyze user clicks and usage of the application and website to improve user experience and maximize usage of our services.
• Manage our website and application to maintain and deliver the contracted functionality and services .
• Enforce our website and application terms and/or separate contracts (if applicable) with you
• Prevent fraud and other prohibited or illegal activities.
• Protect the security or integrity of the website, application, our business or services.
• Or otherwise, as disclosed to you at the point of collection or as required or permitted by law.
• For legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to:

• Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law;
• Enforce our Terms of use, including investigating any potential violations;
• Protect the safety, integrity, rights or security of our users, our Services or equipment, or any third party; or
• Detect, prevent or otherwise address fraud, security or technical issues related to our Services or our partners.

Please note that sometimes we may record the video conferencing call in which you participate to analyze and improve our staff’s communication skills. If we do so, we will be announcing it at the beginning of the conference call and in the meeting invite, and we will be providing a link to our Privacy Policy in the meeting invites and on the registration page.

We do not sell your information to any third party.
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4.0 How We Share Personal Information
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If you are an end user of our application, your personal information may be viewed by other users with access to the application.  We do not share your credit reports, credit scores, financial account information with unaffiliated third parties (except to your Financial Services Provider or agents acting on our behalf).

We do not sell your Personal Information to or share your Personal Information with unaffiliated third parties for their own advertising or marketing purposes.

Sharing Personal Information with Third Parities
‍Now that we've covered what information we do not share, let us explain how we may share information with third parties. We may share information about you, including Personal Information, with third parties in a variety of ways, such as:
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• Your Financial Services Provider. Ardley collects information for your Financial Services Provider that are evaluating, processing or funding loan applications. We will share the information you provide with your Financial Services Provider and their successors-in-interest, and other relevant third parties that your Financial Services Provider has authorized to access the information in order to facilitate the transaction. If you have questions about your Financial Services Provider or no longer want to be contacted by them, you must contact them directly. Ardley is not responsible for the privacy policies of our Financial Services Provider
• Agents acting on our behalf. We may share information about you with service providers or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Statement and our Terms of Use. This includes things like designing or operating features, helping us research and test feature improvements, identifying offers or personalized recommendations, performing analytics and marketing our Services. These third parties are acting on our behalf so while they may have access to your information, including things like your credit scores and financial account information, they're required to follow our instructions and meet the standards explained in our Privacy Statement when handling information about you that we provide them.
• Our partners when you ask for their services. We may also give you opportunities to interact with third party partners through our Services, such as when we provide you with the opportunity to review and send your personal information to a partner in order to pre-populate your mortgage application or we send you to the partner’s site for you to provide the information directly to them. In some cases, if you click through to go to a partner’s site, you will automatically be sending your personal information to that partner. When this happens, you will still have to submit your mortgage application on the partner’s site. Remember that any information you provide to the partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
• With Your Consent. There may also be other contexts in which we share specific types of personal information with your express consent.

Legal Disclosures
‍It is possible that we may need to disclose personal information when required by law, subpoena or other legal processes as identified in the applicable legislation. We attempt to notify our clients about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

‍Change in Control
‍We can also share your personal data as part of a sale, merger, change in control or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
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5.0 How We Secure Personal Information

We are committed to protecting the security of all of the personal information we collect and use. We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit.
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6.0 Your Rights

We provide the same suite of services to all of our clients and end users worldwide. We offer the following rights to all individuals regardless of their location or applicable privacy regulations.

For personal information we have about you, you can:

• You have the right to be notified of what personal information we collect about you and how we use it, disclose it and protect it.

This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly.

• Change or correct your personal information.

You have the right to update/correct your personal information or ask us to do it on your behalf. You can edit your information through the user account in the application or ask us to change or correct it by contacting us at info@ardley.com.

• Delete or erase your personal information.

You have the right to request the deletion of your personal information at any time. We will communicate back to you within reasonable timelines the result of your request. We may not be able to delete or erase your personal information, but we will inform you of these reasons and any further actions available to you.

• Object to the processing of your personal information.

You have the right to object to our processing of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes.

Simply use the unsubscribe feature provided within each e-mail or contact Ardley at info@ardley.com. If you opt-out from receiving promotional materials, you may continue to receive important service announcements, which contain information about the Services to which you subscribe.

• Ask us to restrict the processing of your personal information.

You may have the right to ask us to limit the way that we use your personal information.

• Export your personal data.

You have the right to request that we export to you in a machine-readable format all of the personal information we have about you. We do not process personal information through the use of automated means. If you would like to exercise any of the rights described above, please contact us at info@ardley.com. You also have the right to lodge a complaint with the local organizations in charge of enforcing the privacy legislation applicable in your territory.
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7.0 How Long We Keep Your Personal Information

We retain information as long as it is necessary to provide the services to you and our clients, subject to any legal obligations to further retain such information.

We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law.

The information we retain will be handled following this Privacy Policy.Information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data.

This information may provide insights that are commercially valuable to Ardley Technologies, Inc, such as statistics of the use of the services.
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8.0 Other Important Information

We process data in the United States and rely on legally-provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations.

We will only collect and process your personal data where we have a lawful reason for its collection.When you visit our website and provide us with your personal information, we collect and use it with your consent.  

As an application end user, you consent to our collection of your personal information when you log in for the first time. However, your employer has control of the account and may upload and share additional personal information. Your employer’s responsibility is to ensure that collecting, using and sharing the personal information uploaded to the application complies with all applicable legislation.

You can review the terms and conditions of use here: www.ardley.com/termsofuse

‍Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at info@ardley.com.

How to select your communications preferences

You may choose to receive or not receive marketing communications from us. Please click the “Unsubscribe” link in the email we sent you to stop receiving marketing communications.

You may choose which information we collect automatically from your device by controlling cookie settings on your browser or by selecting your preferences through our Cookie Policy.

Even if you opt-out of receiving marketing communications, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.
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9.0 Contact Information

You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us at info@ardley.com.

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APPENDIX
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A.1 For Individuals Based in the European Union (EU), European Economic Area (EEA) and Switzerland

If you are based in one of these jurisdictions, Ardley Technologies, Inc is the controller of your personal data collected in the following instances:
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• When you visit our website www.ardley.com
• When we process your personal data for sales and marketing purposes
• When you access our service through your Financial Services Provider

Ardley Technologies, Inc is a processor of all personal data processed on the application, on behalf of our clients. We only process the personal data under their direction. Please contact your employer or your Financial Services organization that granted you access to the application for details on their privacy practices.

We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:
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• Consent: We will ask for your express and informed consent every time we collect your personal data on this legal basis.
• Contractual basis: We process the personal data as necessary to fulfill our contractual terms with you or our clients.
• Legitimate interest: We process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation.

You have the following rights under the GDPR:
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• Be informed about the collection and use of your personal data
• Access your personal data
• Correct errors in your personal data
• Erase your personal data
• Object to the processing of your personal data.

• This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request.

• Export your personal data
• Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above).

We process personal data in the United States of America and share it with our service providers in the United States of America and other jurisdictions. We use standard contractual clauses as the data transfer mechanism of transferring EU data to countries subject to data transfer requirements.

You may contact us at info@ardley.com or you may contact our EU Data Representative at Taylor Potter

You may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC). See their contact details here National Data Protection Authorities.
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A.2 For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

‍A.2.1 Collection and Use of Personal Information

‍In the last 12 months, we have collected the following categories of personal information:
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• Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department
• Internet/network information, such as your browsing history, log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data
• Geolocation data, such as information about your location (at country and city level) collected from your IP address
• Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law
• Profession/employment information that you send to us when applying for a position included in your CV and cover letter
• Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

‍A.2.2 Recipients of Personal Information

‍We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

Please see the “How We Share Information” section of the Privacy Policy above for more information.

‍A.2.3 California Privacy Rights

‍As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
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• The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):

• The specific pieces of personal information we have collected about you
• The categories of personal information we have collected about you
• The categories of sources of the personal information
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
• The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
• The business or commercial purposes for collecting or selling the personal information.

• The right to request deletion of personal information we have collected from you, subject to certain exceptions.
• The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights.

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

‍A.2.4 How to Exercise Your California Consumer Rights
‍To exercise your right to know and/or your right to deletion, please submit a request by contacting us at info@ardley.com.

‍We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Ardley Technologies, Inc client that uses our application and services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate, etc.), who was given access to the Ardley Technologies, Inc application by a Ardley Technologies, Inc client, please direct your requests and/or questions directly to the Ardley Technologies, Inc client that gave you access.

‍Minors Under Age 16
‍Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.‍‍