Privacy Policy
LeedWallet ("we," "us," or "our") connects consumers interested in a loan, including a mortgage loan ("leads"), with interested mortgage lenders, brokers, capital providers, loan buyers, or other partners (“Lead Buyers”). This Privacy Policy ("Policy") describes how we collect, use, disclose, sell, share, and protect Personal Information obtained from leads or users (together “you” or “your”) of our Site, Services, or Affiliate Data. This Policy applies to Personal Information that we:
- collect directly through the website located at LeedWallet.com, any related websites, landing pages, applications, inquiry forms, or other online services that link to this Policy (collectively, the "Site");
- collect in connection with any products, services, transactions, communications, marketing activities, or other interactions you may have with us (collectively, the "Services"); and
- receive from third parties, including our affiliates under common ownership or control, such as Nation Capital Group, Inc. and its affiliates, where such information is shared with us as permitted by the applicable privacy policy, consumer disclosure, consent, or other authorization governing the collection of that information (together “Affiliate Data”).
This Policy forms part of the Terms of Use that govern your use of and access to the Site and Services. Please read both this Policy and the Terms of Use carefully.
This Policy applies both to Personal Information that we collect directly through the Site and Services and to Affiliate-Data that we receive from affiliates under common ownership or control. If you use our Site or Services, your use is subject to this Policy and the applicable Terms of Use. If we receive your Personal Information from an affiliate or other third party, our use of that Affiliate Data will be governed by this Policy, together with any privacy notice, disclosure, consent, or authorization pursuant to which your Personal Information was originally collected and shared with us.
If you do not agree with this Policy, you should not use the Site or Services or provide Personal Information that may be shared with us.
We may update this Policy from time to time. The "Last Updated" date at the top of this Policy indicates when the Policy was most recently revised. Your continued use of the Site or Services, and/or your failure to exercise any of your rights described herein, after any update constitutes acceptance of the revised Policy.
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What Information is Subject to this Policy?
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Personal Information
“Personal Information” refers to any information, in any form, about an identified or identifiable individual or household, including an individual or household whose identity may be inferred or determined from such information.
We may collect the following categories of Personal Information: full name; email address; mobile and/or landline telephone number; current mailing or residential address; subject property address; property type; estimated AS-IS property value; purchase price (where applicable); requested loan amount; loan purpose; estimated monthly rental income; estimated annual property taxes; estimated annual insurance; estimated HOA dues; estimated debt-service-coverage ratio (DSCR); estimated loan-to-value (LTV); occupancy designation; entity vs. individual borrower status; entity name; citizenship/residency status (where requested); a credit-score band verified through a soft credit pull at intake; preferred timeline to close; consent acknowledgments and TCPA disclosure responses; IP address; submission timestamp; provenance metadata (including TrustedForm, Jornaya, or equivalent consent certificate where available); traffic-source/campaign parameters (UTM data); browser type; operating system; device identifiers; access times; referring URLs, and Site-interaction data collected automatically through cookies and similar technologies.
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Sensitive Personal Information
“Sensitive Personal Information” is a more sensitive subset of Personal Information (e.g. social security numbers, financial account credentials, precise geolocation, etc.). We do not knowingly collect, process, use, or share any Sensitive Personal Information.
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What is Non-Public Personal Information (“NPI”)?
NPI is non-public information collected by financial institutions under the Gramm-Leach-Bliley Act (“GLBA”) and certain state laws, including information consumers provide to obtain financial products/services, transaction results, or information obtained in connection with providing financial products/services.
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What is not Personal Information?
Personal Information does not include publicly available information; de-identified or aggregated consumer information; or information exempted from applicable state privacy laws, including information collected or processed solely to comply with legal or regulatory obligations.
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Do we collect NPI?
We may be considered a financial institution, finder, service provider, or other GLBA-regulated entity with respect to certain products, services, activities, or information and certain of the information we collect may, in turn, constitute NPI subject to the GLBA.
As a result, some or all of our collection, use, disclosure, and processing of information may be subject to the GLBA and other applicable financial privacy laws. In certain jurisdictions, we may be wholly or partially exempt from otherwise applicable state privacy laws because of our status as a GLBA-regulated entity. In other jurisdictions, only certain categories of information—such as nonpublic personal information ("NPI") subject to GLBA—may be exempt from applicable state privacy laws, while other information remains subject to those laws.
To the extent information is subject to GLBA or otherwise exempt from applicable state privacy laws, such information will be governed by our GLBA Privacy Notice and applicable financial privacy laws. Information that is not subject to GLBA, including certain website usage information, cookie data, analytics data, advertising-related information, and information relating to commercial or business-purpose financing activities, may remain subject to this Privacy Policy and applicable state privacy laws.
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Sources of Personal Information
We obtain Personal Information from three principal sources: (a) Personal Information you submit voluntarily, for example through any forms on the Site or by telephone or email; (b) Personal Information generated automatically when you interact with the Site; and (c) Personal Information and Affiliate Data from third parties, including our affiliates (such as Nation Capital) with whom you share your Personal Information, credit-reporting agencies, the lead-generation sources or partners from whom we may acquire inquiries, advertising platforms, and our service providers.
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Purposes for Collecting Your Personal Information
We may collect and use your Personal Information and Affiliate Data for any of the following purposes:
- Communicate with you, including responding to your inquiries or request for information;
- Provide the Services, including by pre-qualifying leads for certain financial products and services and identifying and matching leads with lenders, finance companies, or investors;
- Ensure safety, security, fraud prevention
- Personalize your experience
- Conduct marketing and advertising
- Manage and improve the Site or Services
- Meet legal, regulatory, and compliance obligations and enforce our rights
- Conduct analytics, auditing, research, and monitor trends and usage to improve our offerings
- Evaluate or conduct mergers, acquisitions, restructurings, or other business transfers
- As otherwise agreed and approved by you.
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Your Privacy Choices and State Privacy Rights
If you live in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, Oklahoma, Vermont, or Louisiana, you may have the rights and/or choices described in this section:
- Right to access: The right for a consumer to access from a business/data controller the information or categories of information collected about a consumer, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared, including, where required by applicable law, the specific third parties to whom your Personal Information has been disclosed; or, some combination of similar information. In some states you may have the right to make a request up to twice in a 12-month period free of charge. If requests are excessive, repetitive, or manifestly unfounded, we may charge a reasonable fee or decline to act on the request as permitted by applicable law.
- Right to correct: The right for a consumer to request that incorrect or outdated Personal Information be corrected but not deleted.
- Right to Delete: The right for a consumer to request deletion of Personal Information about the consumer under certain conditions.
- Right to Confirm Processing: The right to confirm whether we are processing your Personal Information.
- Right to opt out of certain processing: The right for a consumer to restrict a business’s ability to process certain types of Personal Information about the consumer, such as the right to opt out of sharing of Sensitive Personal Information or profiling, where applicable.
- Right to opt out of targeted advertising: The right to opt out of the use of your Personal Information for targeted or cross-context behavioral advertising.
- Right to portability: The right for a consumer to request Personal Information about the consumer be disclosed in a common file format.
- Right to opt-out of sales or sharing: The right for a consumer to opt out of the sale of Personal Information about the consumer to third parties.
- Right to limit the use of Sensitive Personal Information: You may have a right to limit our use of Sensitive Personal Information for any purposes other than to provide the Services or goods you request or as otherwise permitted by law. As noted in Section 1.B, we do not knowingly collect or process your Sensitive Personal Information.
- Right against automated decision making: A prohibition against a business making decisions about a consumer based solely on an automated process without human input. We do not engage in automated decision making.
- Right to opt out of profiling: The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, where applicable. While we may use Personal Information for analytics and targeted advertising, we do not engage in profiling.
- Right to appeal: Where a controller declines to take action regarding a consumer's request to exercise any privacy right, the controller must allow the consumer to appeal the decision and provide instructions on how they may request an appeal.
- Right to withdraw consent: You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.
- Right of Non-Discrimination: You have a right to exercise your rights under this section free of discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section.
Please Note: These rights do not extend to Personal Information that is exempted from your state’s applicable privacy laws. For NPI and other information exempted from state privacy laws under the GLBA, please see our GLBA Privacy Notice for more information about how we use and process your information and your rights.
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How do you opt out of data sharing/sale?
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Opt Out Request Form
You may opt out by clicking the “Do Not Sell or Share My Personal Information” link in the footer of our website.
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Universal Opt Out Mechanism
With respect to Personal Information obtained through our Site, we honor Global Privacy Control (GPC) and other opt-out signals as requests to:
- Opt out of Personal Information sales
- Opt out of sharing for targeted advertising
- Limit use of Sensitive Personal Information, where applicable
We process recognized universal opt-out signals in accordance with applicable state privacy laws.
Your opt-out applies only to the specific browser/device sending the signal. Renew if you switch devices/browsers or clear cookies.
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How do you make a request to exercise your rights or choices?
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How to make a Request
To exercise your rights or to make an inquiry, please visit our Data Request Form or you can contact us using any of the methods listed in the Contact Us section.
We may verify your identity before processing requests. Verification information is used only for verification, security, or fraud-prevention and deleted after processing.
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Our Response to Requests
We will process all opt out requests as soon as reasonably practical and in accordance with applicable law.
For all other requests, we will confirm receipt of your request within 10 business days. In general, we will respond within 45 days of our receipt of your request. If we need more time to respond, we will let you know the reason for the additional time and may take up to another 45 days to respond
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Authorized Agents
You may designate an authorized agent to exercise your rights on your behalf. We require verification of the agent's authority and may require attestation under penalty of perjury. Without power of attorney, we also require you to verify your identity.
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What to do if you disagree with our decision
If we deny your request, you may appeal by contacting us (see Contact Us section) with your name, email, request type, appeal reason, and original request reference. We will respond to appeals within the time required by applicable law. In most cases, we will respond within forty-five (45) days of receiving your appeal. Our response will explain the action taken or not taken. If your appeal is denied, we will provide instructions on how you may submit a complaint to the applicable state Attorney General.
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What is de-identified or aggregate data and how do we use such data?
"De-identified data" cannot reasonably be linked to a particular person. "Aggregate data" shows high-level trends without linking to individuals.
We may de-identify and aggregate data for business purposes, including improving the Services, security, analytics, and reporting. We maintain such data in de-identified or aggregate form and do not attempt to re-identify it except as legally permitted. Third parties receiving such data commit to maintaining it in de-identified or aggregate form.
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Data Security
We use commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information and Affiliate Data from unauthorized access, misuse, or disclosure. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You transmit Personal Information to us at your own risk.
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Children's Privacy
The Site and Services are not intended for users under the age of eighteen (18), nor do we knowingly collect, retain or share information in connection with the Site or Services from children under the age of 18.
With respect to children under the age of thirteen (13), we do not knowingly collect information from children under 13. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).
If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us using the information listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information.
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Do we use or process Personal Information outside the country where the data was originally collected?
We may send Personal Information to servers outside your country. By using the Site and Services, you consent to transfer and processing in other countries. Data protection laws may differ from your country of residence. We take steps to ensure secure treatment in accordance with our Terms and this Policy.
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Data Retention
Unless you request deletion, we retain Personal Information and Affiliate Data for as long as necessary to fulfill the purposes described in this Policy. We consider amount, nature, sensitivity, risk of harm, processing purposes, and legal requirements when determining retention periods. Lead inquiries are generally retained for as long as necessary to document consumer consent, maintain transaction records, comply with legal obligations, resolve disputes, enforce agreements, and support audit and compliance functions.
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Third-Party Websites
Our Site may include links to websites or services operated by third parties that are not affiliated with us. A link to a third party’s site does not necessarily mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party sites. These third parties have their own privacy policies and practices, which we encourage you to review, as we do not control and are not responsible for their content, security, or handling of Personal Information. Review their privacy policies when linking.
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Other information about your privacy
We generally act as a “controller” of your Personal Information. Lead buyers, lenders, brokers, investors, and certain affiliated entities receiving your information may act as independent businesses/controllers and are responsible for their own privacy practices. You are responsible for any Personal Information you choose to share publicly, whether through the Site or any third-party platforms.
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Communications by Phone, including Call and SMS/MMS, and Marketing Consent
By providing your phone number, you are providing your express written consent to receive phone calls and text messages (SMS/MMS/other) from us (including our service providers or vendors sending communications on our behalf or at our direction) and lead buyers. Calls and texts may be placed using equipment which may qualify as an automatic telephone dialing system or other similar technology and or using a prerecorded/artificial voice message. Calls and texts will only be placed for both informational purposes (e.g. relating to your account or to respond to your requests) unless you have provided your prior express written consent to receive marketing calls or texts. Your consent to marketing calls/texts is not required to purchase any products, goods, or services from us. You understand and agree that you are consenting to calls/texts even if you have previously listed yourself on any state or federal Do-Not-Call List. Message frequency varies. Message & data rates may apply. Reply HELP for assistance, STOP to cancel.
By using the Site and Services, you understand and agree that we are a lead generator that connects interested borrowers with interested lenders. When you submit a request through any web forms available on the Site, any websites operated by our affiliates companies under common ownership or control, including Nation Capital, or by telephone, email, or otherwise, you understand that in order to provide the Services you requested, we must share or sell your Personal Information and Affiliate Data, including the contact information that you provide, so that interested financial institutions and lead buyers can contact you to discuss your request. We will only share your consent to receive calls or text messages with third parties when you have provided prior express written consent to receive communications from those third parties at the time you provide your phone number.
For additional details regarding our communications with you, please see the Terms at Section
If you have provided consent to receive communications from us by phone, we will not share or sell that consent to any third party without your prior express written consent.
To Nevada Consumers
We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing by using the contact information provided in Section 20. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.
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Changes to This Policy
We may modify this Policy at any time. Changes supersede previous policies. Updates will be posted with a revised "Last Updated" date. Check frequently for updates. Where required by applicable law, we will notify you of any material changes (including changes to how we share and/or sell your Personal Information and Affiliate Data) to this Policy by email and/or account notice. For changes to how we collect, use, process, or share personal data, we’ll provide opportunity to consent or opt out as required by applicable law, and such changes will not apply retroactively without your consent.
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State Specific Disclosures
California – Shine the Light Law
California residents have the right to request certain details about how their Personal Information is shared with third parties and, in some cases, affiliates for direct marketing purposes. We may from time to time elect to share certain Personal Information about you with third parties for those third parties’ direct marketing purposes. If you are a California resident, you may obtain the categories of Personal Information shared and the names and addresses of third parties that received Personal Information for their direct marketing purposes during the preceding calendar year. You may make this request by contacting us using the information provided in the Contact Us section. Such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. To help us determine if this right applies to you, we may ask that you attest to the fact that you are a California resident and provide a current California address. Please note that we are only required to respond to one request per customer each year.
California and Vermont
We automatically treat accounts with Vermont and California billing addresses as if you requested we not share information with nonaffiliated third parties and limit information shared with affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.
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How to Contact Us
If you have any questions or concerns about us, the Site, the Services, this Policy, the Gramm-Leach-Bliley Privacy Policy, or to exercise your rights or choices, please contact us:
Address: LeedWallet,
21414 Gosier Way
Boca Raton, FL 33428Email: info@leedwallet.com Call: 516-564-7959