Privacy
Last updated: June 24, 2024
This Privacy Policy explains how RateGravity, Inc., a Delaware corporation d/b/a Own Up ("Own Up," "Company", "we," "our" or "us") collect, use, disclose, and protect information we collect through our online services, website, and also any and all communications with us via phone (including your cell-phone), email, text or otherwise (each, a "Service" and collectively, "Services"). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms and Conditions. When you use the Services, you consent to our collection, use, disclosure, and protection of information about you as described in this Privacy Policy.By accessing or using the services, you agree to this policy. If you do not agree to this policy, please do not use the service.
Notice for California Residents: find more information about your California Privacy Rights and for our Notice of Collection of Personal Information here.1. Collection of your information
Information you provide us directly
The information we collect from you will vary depending on the product or service requested. We may ask for certain information such as your username, first and last name, birth date, telephone number, email address, outstanding loan balances, social security number, income, employment history, and other details related to your financial situation when you use our Service and/or register for an Own Up account. We may collect information that you voluntarily provide to us when using the Service. All of the information we collect from you directly is identified in the forms, other places where you respond to questions, or where you indicate preferences throughout the Service, either online or communicated through our customer service representatives.We may also collect and store information you provide about other people. By submitting information about someone other than yourself, you represent that you are authorized to provide us with that person's information for the purposes identified in this Privacy Policy and/or in connection with the Service.We may also retain any messages you send through the Service or customer service correspondence (via telephone, chat, text, email or otherwise). Calls to Own Up may be recorded or monitored for quality assurance, customer service, training, and/or risk management. We may also collect your information through the use of our automated chatbot, "Katina".Information that is collected automatically
In addition to the information you provide to us directly, we may automatically collect information about your use of the Service, as described below.- Log file information. Log file information is automatically reported by your browser each time you access the Service. When you use our Service, our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
- Location information. When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, features and/or products made available via the Service.
- Cookies and other technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, beacons, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, deliver tailored advertising, and improve the products and services we provide. You can choose to accept or decline certain cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer. If you disable cookies, you may be prevented from accessing or taking full advantage of the Services.
- Cookies. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser or stores information or settings on your device. Cookies let us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. Our Service may use HTTP cookies, HTML5 cookies and other types of local storage (such as browser-based or plugin-based local storage).
- Clear gifs/web beacons. When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened, which links are clicked by recipients, and whether our emails are forwarded. The information allows for more accurate reporting and improvement of the Service.
- Web analytics. We may use third-party Web analytics services on our Service, such as those of Google Analytics. These service providers use the technology described above to help us analyze how users use the Service. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on.
We may use this information in a number of ways, including: (a) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) to provide custom, personalized content and information; (c) to provide our Service and monitor its effectiveness, including on or through our affiliates and/or other third party service providers; (d) to monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in and; (g) to deliver advertising to you or (h) provide further training and development of our automated chatbot “Katina”.Information from Third-Party sources
We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, when you request prequalified rates, we will ask your permission to conduct a soft credit inquiry. Likewise, when you apply for a loan product, either we or a Provider may conduct a hard credit inquiry. When you apply for a mortgage, we will conduct a search of public records to determine the estimated value of your home and your estimated taxes in order to automate the loan application process and make things more convenient and streamlined for you.
2. Do not track signals and similar mechanisms
Do Not Track
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.Use of Cookies
Own Up may use Cookies to store or retrieve information. Cookies are a small piece of text stored on Your browser which may allow Own Up to identify You upon return to the website or to remember specific information such as Your display options. Cookies are neither a virus nor spyware. You hereby authorize the use of cookies by Own Up.
3. Use of your information
- To provide you with and manage the Service. We use your information to provide, develop, maintain and improve our Service and the features and functionality of the Service. This may include customization and tailoring the Service features according to the information that you provide.
- To process and fulfill a request or other transaction submitted to us. We use your information to process or fulfill requests or transactions that you have requested.
- To share information about you with the lenders in our lender marketplace.
- To communicate with you. We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails.
- Provide personalized services, including content, ads, products or services. We may use the information we collect to provide personalized services and advertising to you either through Own Up, Own Up's affiliates or a third party marketing partner, subject to the requirements of the Privacy Notice.
- Surveys, Offers, Sweepstakes. We may use your information to conduct surveys and offer sweepstakes, drawings, and similar promotions.
- Marketing and Advertising. We may use your information to market and advertise our services and the services of certain third parties we work with.
- Unique Identifiers. Sometimes, we, our affiliates or our service providers may use the information we collect - for instance, log-in credentials, IP addresses and unique mobile device identifiers - to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor advertising, content, and features, and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
- Research and Analytics. We may use your information for research and analytical purposes, for example, to identify trends and effectiveness of certain marketing campaigns we run.
- Business Operations. We may use your information for certain operational purposes including, for example, to perform audits and quality control.
- To protect the rights of Own Up and others. We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of Own Up, its affiliates, employees or agents, or other users and to comply with applicable law.
- With your consent. We may otherwise use your information with your consent or at your direction.
- To aggregate/de-identify data. We may aggregate and/or de-identify information collected through the Service. We may use de-identified and/or aggregated data for any purpose and without any restrictions, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
4. Sharing of your information
- Providers. We may share your information with Providers for the purpose of providing the Service to you such that they may provide you with information about your request for prequalified rates, offers, and information related to other products and services they offer.
- You agree that when you submit information to a Provider or third-party through the Service, such submission of your information may also be governed by Provider or third-party privacy and security policies which differ from our Privacy Policy. For details of these policies, please consult the policies of the Providers or third-parties directly.
- You understand that, subject to any applicable laws or regulations, Providers may keep your information that relates to any submission of information that you may make through your use of the Service and any other information provided by Own Up or Own Up affiliates in the processing of any submission of information, whether or not you are eligible for the Provider's products or services. You agree to notify any particular Provider directly if you no longer want them to keep your information.
- As a prospective borrower or applicant of a Provider's products or services, you agree that when you nominate a co-signer/co-applicant, Own Up may share Provider responses relating to your submission with your nominated co-signer/co-applicant, and, as a co-signer/co-applicant, we may share Provider responses relating to your submission with the prospective borrower or applicant.
- Affiliates. We may share information with our parent company and any of our parent company's subsidiaries.
- Service providers. We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, agents and other representatives. Service providers assist us with a variety of functions. This includes, for example, assisting with customer service-related functions, providing advertising (including interest-based advertising) and analytics services (e.g., Google Analytics and Facebook Custom Audiences), helping us verify your identity, obtain your credit report, providing website hosting services, assisting with auditing functions, and helping us with marketing and related research activities.
- Marketing partners. We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with. Marketing partners also include those entities who maintain a link to our Services on their site, or an Own Up widget on their site, when you interact with that widget or click from their site to our Services.
- Other parties when required by law or as necessary to protect our users and services. Own Up may share your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms and Conditions or to protect the security or integrity of our Service; and/or (c) exercise or protect the rights, property, or personal safety of Own Up, our Users or others.
- Business transfers. We may buy or sell/divest/transfer Own Up (including any shares in Own Up), or any combination of its products, services, assets and/or businesses. Your information, which may include NPI, usernames and email addresses, and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of Own Up.
- Training and development of our automated chatbot "Katina" or other artificial intelligence bots.
- Aggregated or de-identified information. We may also aggregate or de-identify data and may share that data without restriction.
- Otherwise with your consent or at your direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third-parties whenever you consent to or direct such sharing.
5. How we store and protect your information
Keeping your information safe.
Own Up takes technical and organizational measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures vary depending on the sensitivity of the information we have collected from you. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. Own Up is not responsible for the functionality or security measures of any third-party or Provider.
To protect your privacy and security, we take steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Own Up, at all times. Do not share your password with anyone and do limit your access to your computer or other devices by signing off after you have finished accessing your account.
For information about how to protect yourself against identity theft, please refer to the Federal Trade Commission's website.Storage and Security of Personal Information.
Information Security Officer.
We have designated an Information Security Officer (ISO) who has the duty to (i) ensure by contract that third parties to whom the company transfers personal information will adequately protect the information and use it only for specified lawful purposes; (ii) protect Your personal data using appropriate security measures; (iii) notify authorities of personal data breaches when required; (iv) obtain appropriate consents for processing data; (v) keep records detailing data processing; (vi) train privacy personnel and employees.Information Storage.
Own Up stores Your Personal Information on our computers, and we believe we have reasonable security measures in place including administrative, technical and physical safeguards that are appropriate for the size and complexity of our business to protect Your Personal Information including encryption of any personally identifying information.Security Breach Notice.
When required by applicable regulations, we will notify you of any unencrypted data that we maintain that includes Personal Information, we will notify You of any unencrypted Personal Information that was, or is reasonably believed to have been, acquired by an unauthorized person.
6. Your choices about your information
Your account information and settings
If you choose to set up a profile, you may update your account information at any time by logging into your account and changing your profile settings. You can also contact us at support@ownup.comto change your preferences.Email promotions
You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, transaction-related updates, changes/updates to features of the Service, and technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at support@ownup.com.Opt-out and annual notice
If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information, including the right to opt-out to the sharing of certain information.Text message opt-out
If you are receiving text messages from us and wish to stop receiving them, simply respond with either "STOP" or "UNSUBSCRIBE" to the number from which you received the message. Once we receive your message, you will no longer receive further text messages from us.
7. How long we keep your user content
8. Children's privacy
9. Links to other web sites and services
10. Your California privacy rights
Own Up
50 Milk St, Floor 16
Boston, MA 02109
11. Complaints and how to contact us
12. Changes to our Privacy Policy
13. Use of Artificial Intelligence
California Consumer Privacy Act Notice for California Consumers
This California Consumer Privacy Act Notice for California Consumers ("CCPA Notice") supplements Own Up ("Company" or "Own Up") Privacy Policy and Gramm-Leach-Bliley Act ("GLBA") notice. This notice applies solely to California residents. The California Consumer Privacy Act ("CCPA") affords California consumers certain rights over their personal information (subject to certain exceptions). This CCPA Notice outlines those rights and explains how such rights may be exercised. This CCPA Notice also summarizes our data collection and sharing practices, as required by the CCPA. Terms used but not defined shall have the meaning ascribed to them in the CCPA. For the purpose of this CCPA Notice, we refer to our websites, applications that run on mobile devices and tablets, call centers, and other products and services as "Services" or "Sites."1. What information is covered by this CCPA notice
2. Where do we collect personal information from?
3. How do we use personal information?
4. Who do we share personal information with?
Providers
We may share your personal information with third parties we give you opportunities to interact with through the use of our Services such as when we provide you with the opportunity to obtain prequalified rates from lenders for a personal loan or to submit your loan application to a lender. The term "Provider" referenced here is defined in our Terms and Conditions. In some cases, if you click to go to a Provider's site, you will automatically be sending your personal information to that Provider (e.g., when clicking on an option to learn more about debt service providers, high yield savings providers or insurance providers or when applying for a credit card with one of our partner credit card issuers). Remember that any information you provide to the Provider, whether through us or on your own, will be subject to their privacy practices and terms and conditions.Service providers
We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, agents and other representatives (collectively, "Service Providers"). Service Providers assist us with a variety of functions. This includes, for example, assisting with customer service-related functions, providing advertising (including interest-based advertising) and analytics services (e.g., Google Analytics), helping us verify your identity, obtaining your credit report, providing website hosting services, assisting with auditing functions, and helping us with marketing and related research activities.Marketing partners
We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with (collectively, "Marketing Partners"). Marketing Partners also include those entities who maintain a link to our Services on their site.Affiliate companies
We may share personal information with our parent company and wholly owned subsidiaries (collectively, "Affiliate Companies").Special circumstances
We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) to protect or prevent harm or financial loss; (iii) to protect our legitimate interests and legal rights; and (iv) to detect, investigate and help prevent security, fraud or technical issues (collectively, "Special Circumstances"). For the purpose of this CCPA Notice, third parties who receive personal information in accordance with this section shall be referred to as "Special Circumstances Recipients."Corporate transactions
We may transfer your personal information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets (collectively, "Corporate Transactions"). For the purpose of this CCPA Notice, third parties who receive personal information in accordance with this section shall be referred to as "Corporate Transaction Recipients."
5. Summary of collection, use and disclosure of personal information
Categories of personal information collected | Categories of sources from which the personal information was collected | Business or commercial purposes for which personal information was collected | Categories of third-parties with whom we may have shared personal information | Disclosed for a commercial purpose [ Y / N ] | Disclosed for a business purpose [ Y / N ] |
---|---|---|---|---|---|
Identifiers such as name, Social Security number, address, telephone number, driver's license or state identification card number, bank account number, loan identifier, credit card information, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or any other similar identifiers |
|
|
| Yes | Yes |
Characteristics of protected classifications under California or federal law (e.g., race, religion, and gender) |
|
|
| Yes | Yes |
Records of personal property, property-related details, existing loan information (e.g., lender name, estimated balance, type of loan, assets owned, sources of assets) |
|
|
| Yes | Yes |
Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement |
|
|
| Yes | Yes |
Professional or employment-related information (e.g., employment history) or education information |
|
|
| Yes | Yes |
Information you provide in reviews, questions, and comments |
|
|
| Yes | Yes |
6. Your CCPA rights
Request to know
You have a right to request that the Company disclose what personal information it collects, uses, discloses, and sells. It includes a request for any or all of the following:- Specific pieces of personal information that the Company has about you;
- Categories of personal information the Company has collected about you;
- Categories of sources from which your personal information is collected;
- Categories of personal information that the Company has sold or disclosed for a business purpose about you;
- Categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information.
Request to delete
You have a right to request that the Company delete your personal information that we have collected from you. However, certain information regulated by other privacy and data protection laws (including, for example, the Gramm-Leach-Bliley Act) may be exempt from, or outside the scope of, any deletion request (i.e., the GLBA's requirement to retain the information may preempt your request that we delete it. In other words, we may be legally required to retain your data for a certain period of time and therefore we cannot delete your data at your request. If this happens, we will let you know in response to your request). As a result, in some instances, we may decline all or part of a deletion request if related to this type of exempt information.Request to opt-out
We do not provide personal information about you to other companies for money. The advertising services we use may collect certain information, including cookies and similar information stored on your browsers, advertising identifiers on your mobile devices, and/or the IP address of your devices when you visit our sites or use our apps. Those advertising services we use may tailor and deliver ads to you on your devices. Even though we do not provide personal information to these companies for money, California law may characterize this activity by the advertising providers as "sales" of personal information. You have a right to request that these companies discontinue these targeted advertising activities.No discrimination
You have a right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA.
7. How to exercise your CCPA rights
Submitting a request to know or request to delete
You may submit a Request to Know or a Request to Delete by contacting us at this toll-free number, (877) 791-6510 or by using this interactive webform.Submitting a request to opt-out
You may submit a Request to Opt-Out by contacting us at this toll-free number, (877) 791-6510 or by using this interactive webform. We currently do not have a method that would allow us to contact the advertising service providers on your behalf as we do not associate these cookies and other signals to any personally identifiable information we may maintain about you.Verification methods
Once you submit a request, we will verify that you are the consumer to which the request pertains by matching your name, email address and physical address with information we maintain. Depending on the type of request you submit, we will attempt to match either two or three of these data points to the information maintained in our systems. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request. We may also reach out to you for additional verifying information for requests requiring a higher degree of verification because of the type or sensitivity of the request.