Privacy Policy

 

Last Updated: April 7, 2023

Overview

This Privacy Policy describes how Brizzi Financial collects, uses, and shares personal information. This Privacy Policy applies to personal information we collect when you access or use our websites, mobile applications, or other platforms, use our products and services, communicate with us by telephone, chat or SMS, or otherwise interact with us. This Privacy Policy also applies to personal information we collect from other sources, including our parent company Brizzi, Inc., other loan originators, realtors and other business users that use our systems for uploading, downloading, and managing documents and information.

By "personal information," we mean information that uniquely identifies an individual, such as a name, email address, or government-issued identification number (such as a driver’s license number or social security number); unique financial information; and information that we link to an individual’s unique identifier(s) or unique financial information. If information is de-linked or de-identified, we do not consider it to be personal information. For example, a postal address would not be personal information if it were included in a list of addresses without names or other unique identifiers. Business information (such as the name of a business or the business address or phone number) is not personal information.

When you interact with us, we will collect your personal information and use it to interact with you as described in this Privacy Policy. 

References to Brizzi Financial also include companies providing services to Brizzi Financial, Brizzi, Inc., and Organizations or other business partners, to the extent that such parties are collecting, using, or sharing personal information for or on behalf of Brizzi Financial. This Privacy Policy applies to information collected by those companies only when they provide it to Brizzi Financial.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by posting the updated Privacy Policy on our website and updating the effective date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our websites’ homepages or sending you a notification).  

If you do not agree with the terms of this Privacy Policy, please do not continue using our services.

Information We Collect

Information You Give to Us

We collect information that you provide directly to us. For example, we collect mortgage and borrower-related information and documents you send to us via email or fax, or upload to our systems. You may also provide us information to receive other benefits of our services, when you request customer support, or when you otherwise transact business with us; when you provide a success story or other testimonial about your experiences with Brizzi Financial; when you engage with us on social media or participate in our promotional marketing programs; when you contact our sales team on behalf of your business; or when you otherwise provide or upload content that includes personal information.

Information We Collect Automatically 

When you access or use our services or when we send you emails, we may use tracking technologies to automatically collect information about you.  Automatically collected information may be associated with your unique browser, device identifier or Internet protocol (IP) address, but we do not consider it to be personal information unless it is linked to your unique identifier(s).  

Automatically collected information includes: 

  • Log Information. We, along with some of our third party systems, log information such as IP address, access times, operating system, browser type and language, Internet service provider (ISP), and the web page you visited before navigating to our Services. 

  • Usage and Session Information. We, along with some of our third party systems, collect usage information, such as how many visitors visit a specific page, how long they stay, which links they click on, and how, when and how often they order particular services, and session information, such as mouse actions, pages visited, screen actions and other interaction patterns.

  • Device Information. We, along with some of our third party systems, collect information about the computer or mobile device you use to access our platforms, including the hardware model, operating system and version, unique device identifiers and mobile network information.

  • Location Data. If you are using a mobile device, we, along with some of our third party systems, may collect location data directly from your mobile device if your device allows us to do so. In addition, your IP address may provide an approximate geo-location. 

  • Transaction Information. When you utilize our systems, we, along with some of our third party systems, collect information about the transaction, such as the date and location of the platform interaction.

  • Emails. When you receive emails from us, we collect information about whether and when you opened the email, whether you clicked on the images and links in the email, and whether your computer or mobile device is capable of receiving HTML-based email.

Information We Collect from Organizations, Porch Group Companies and Third Parties

We obtain your personal information from Organizations, when they invite you (as a borrower) to use our loan document workflow management system and when they submit or upload information in connection with your loan application. 

We may also obtain information from Brizzi, Inc. and other companies that partner with us to offer promotions to their or our clients or users.  For example, a Brizzi, Inc. Company may provide us with consumer information to allow us to offer them Brizzi Financial services.

We may obtain personal information (such as business lead information) from third-party data providers and public sources.

Information Collected from Calls

When you call us, when we call you, we may monitor and/or record those calls for quality assurance and customer satisfaction purposes. In those jurisdictions where consent is required for a party to record a telephone call, you consent to us recording such calls. We treat the records of these calls, when linked to your unique identifier(s), as personal information.

Social Media 

When you interact or engage with us on social media sites such as Facebook through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, or better understand user reactions and issues. Once collected, this information may remain with us even if you delete it from the social media site(s).

Testimonials

We post success stories or other testimonials on our website, which may contain personal information. Before posting a testimonial, we obtain the person’s consent to post their name and image along with their testimonial.

Aggregate and Anonymized Information

We may also aggregate (group) or de-link/de-identify (anonymize) information. For example, we may collect and compile anonymous demographic information about the age, gender, household income and financial information of our borrower users; or statistics about how many loan applications and documents were processed through our system. Aggregated, anonymized data is not personal information subject to this Privacy Policy, and we may use it to analyze usage of our sevices or for any other purpose. We may also share aggregated and/or anonymized information with Brizzi, Inc. and our and their business partners. 

Categories of Personal Information Collected 

In the last 12 months, Brizzi Financial has collected the following categories of personal information from the categories of sources described above. We consider this information to be personal information to the extent that it is information that uniquely identifies you, is unique financial information, or is linked to your unique identifier(s), or if it is defined as personal information by applicable state law. 

Category

Examples

Identifiers — Real name; postal address; unique personal identifier or online identifier; Internet Protocol (IP) address; email address; account name; social security number, driver’s license number, passport number, or other similar identifiers

Personal information categories listed in the California customer records statute (Cal. Civ. Code § 1798.80(e)) — Name; signature; telephone number; credit card or debit card number, bank account number, or other financial information; insurance policy number; education, employment or employment history; Address (in states that designate a postal address as personal information, such as California). Types of personal information included in the CA customer records statute that are included in other categories are not repeated here.

Protected classification characteristics under California or federal law — Age (40 years or older); race, national origin, ethnicity; citizenship status; marital status or familial status; sex; veteran or military status

Commercial information — Records of personal and real property

Internet or other network activity information — Browsing history; search history; information regarding a consumer's interaction with a website, application, or advertisement 

Geolocation data — The location of a consumer’s computer or device when accessing or using the Properties

Audio, electronic, visual, thermal, olfactory, or similar information — Call recordings of customer service calls; photographs of individuals

Professional or employment-related information — Current or past employment history; place of work

Biometric Information — None

Education Information — None (except as included in other categories)

Inferences drawn from other personal information — None

How We Use Information We Collect

In general, we use the information we collect to operate our business and, where we are legally and contractually permitted to do so, to facilitate the business of Brizzi, Inc., including:

  • To provide, maintain, improve, and personalize our services and the services of Brizzi, Inc.

  • To process transactions, to provide and improve customer service and performance, to communicate with you about your account, changes in our policies or other service matters, and to otherwise manage our customer relationships.

  • To offer products and services from Brizzi Financial, Brizzi, Inc., and our and their business partners (when permitted to do so under this privacy policy).

  • To optimize marketing campaigns and to analyze their effectiveness, distribution and reach.

  • To develop new products and services.

  • To administer contests, promotions or sweepstakes.

  • To detect, investigate and address technical issues, security incidents, fraudulent transactions, abuse, violations of our agreements and policies, and illegal activities.

  • To comply with our legal obligations and legal process.

  • To create aggregated or de-identified data sets.

  • To analyze trends, administer platforms, and track visitor navigations on our platforms to understand what our visitors are looking for.

  • To carry out certain short-term activities and other reasonable internal purposes related to our services or our customers’ ongoing relationship with us. 

  • To perform other business purposes described at the time the information is collected or as otherwise set forth in applicable data privacy laws.

Brizzi Financial will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice. 

How We Share Information

Except as described in this Privacy Policy, we do not sell or rent personal information to any third party. If we share personal information, we do so only as follows.

User-Directed Disclosures

We share your personal information when you direct us to do something that requires its disclosure or when you otherwise provide your consent. For example:

  • when you utilize our systems and third party systems to provide your documents and information to Brizzi Financial, we will receive your personal information;

  • when you choose to pursue a loan or loan scenario with an approved lender of Brizzi Financial, the lender will receive your information (in accordance with your privacy settings with the third-party services); and 

  • if you opt in to receiving marketing from Brizzi, Inc., as described below, we will provide your information to them for that purpose.

Brizzi, Inc.

If you are a borrower and you consent to your receiving marketing from Brizzi, Inc., we will provide your information to Brizzi, Inc. so that they can offer you other products and services of interest to you. If your information is shared with Brizzi, Inc. through this opt-in, they may also use your information to improve their products and services (such as confirming or supplementing information they have about you or classifying you as a mover). If you do not consent to marketing from Brizzi, Inc., we will not provide your information to them for the purposes of marketing or improving their products and services. However, we may provide your personal information to Brizzi, Inc. in connection with the database, technical, legal, accounting, and other services (other than marketing) shared between us and Brizzi, Inc. and for other internal business purposes.

When you interact with Brizzi Financial, we may share your information with Brizzi, Inc. to allow them to offer relevant services to your business and to personalize their communications with your associated borrowers who have opted into marketing from Brizzi, Inc.

Brizzi, Inc. will be bound by the terms of this Privacy Policy with respect to personal information received from Brizzi Financial and will use that personal information only as described in this Privacy Policy. 

Companies Providing Services to Brizzi Financial

We share information with third-party vendors, consultants, and other service providers that are providing business services to Brizzi Financial. For instance, we may share information with a third-party service provider that hosts our online platforms, provides call center or other customer service, processes payments, sends out emails, serves ads to you on our platforms or on a third-party platform, or monitors or analyzes service data. Such companies will have access to personal information only as necessary to carry out their work and are prohibited from using it for any other purpose.

Brizzi Financial Business Partners  

If you are not already a client, we may provide your personal information to Brizzi, Inc. and its affiliates to enable them to offer you relevant financial services. When you interact with Brizzi Financial on behalf of your business, we may share your personal information with our business partners to allow them to offer services or promotions to your business.

Companies with Whom You Have an Existing Relationship

If you are already a customer of or otherwise have a direct relationship with a business partner of Brizzi, Inc. and we have shared your information with them for marketing and product/service improvement purposes as described above (i.e., with your consent), they may disclose certain information about you to them. If you are a match to a customer on the Brizzi, Inc. customer list, they may provide the customer with information such as the groups or segments you belong to (such as agent or homeowner) and demographic information about you and your home (such as estimated household income and square footage), so that they can provide you with more relevant advertising, products and services. Brizzi, Inc. will not give out any of your contact information, unique personal identifiers, or unique financial information unless for another purpose permitted in this Privacy Policy. However, they may already have some or all of that information (because of its existing relationship with you) and they will be able to link you with the other information about you that Brizzi, Inc. provides to them.

Contests and Sweepstakes

When you sign up for and participate in a contest or sweepstakes, we may publicly disclose your name, company, city and state if you win. 

Compliance with Laws and Policies; Protection of Rights

We may disclose your personal information if we believe disclosure is necessary to comply with any applicable law, regulation, or legal process, to cooperate with government or law enforcement, or to avoid legal liability; to resolve complaints or disputes; to investigate and resolve technical issues, security incidents, fraud, abuse, and illegal activities; if we believe your actions are inconsistent with the spirit or language of our user agreements or policies; or to protect the rights, reputation, safety and property of Brizzi Financial or others.

Strategic Transactions 

We may disclose personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business or in a bankruptcy, liquidation, dissolution or similar transaction. In the event that we or all of our assets are acquired in such a transaction, our collected information would be one of the transferred assets.

Professional Information

We do not consider business information to be personal information. Accordingly, we may share business names, owner/proprietor names, business contact information and other information with third parties for any purpose.

Categories of Personal Information Disclosed 

In the last 12 months, Brizzi Financial has disclosed the following categories of personal information for a business purpose to the following categories of third parties: 

Category of Information and Third Parties

Identifiers — Borrower-associated organizations; Companies providing business services to Brizzi Financial; Brizzi, Inc. and its affiliated companies (For the purposes described above and as part of an acquisition as described in Strategic Transactions above)

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) — Borrower-associated organizations; Companies providing business services to Brizzi Financial; Brizzi, Inc. and its affiliated companies (For the purposes described above and as part of an acquisition as described in Strategic Transactions above)

Protected classification characteristics under California or federal law — Borrower-associated organizations; Companies providing business services to Brizzi Financial; Brizzi, Inc. (For the purposes described above and as part of an acquisition as described in Strategic Transactions above)

Commercial Information — Borrower-associated Organizations; Companies providing business services to Brizzi Financial; Brizzi, Inc. (For the purposes described above and as part of an acquisition as described in Strategic Transactions above)

Internet or other similar network activity — Borrower-associated Organizations; Companies providing business services to Brizzi Financial; Advertising networks

Geolocation data — None (except approximate geo-location data included in information in other categories)

Audio, electronic, visual, thermal, olfactory, or similar information — None

Professional or employment-related information — Borrower-associated Organizations; Companies providing business services to Brizzi Financial; Brizzi, Inc. (For the purposes described above and as part of an acquisition as described in Strategic Transactions above)

Education Information — None (except as included in other categories)

Biometric Information — None

Inferences drawn from other personal information — None

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to restrict access to your personal information and help protect it from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no such measure is 100% secure.

Third-Party Websites or Services 

Our platforms may contain links to other third-party websites and services, either directly or through advertisements on our platforms. For example, there are a number of products and services offered by third parties advertised by us through our mortgage services that may be complementary to your use of our services. If you choose to utilize any of these products or services, disclose information to the third-party providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. Brizzi Financial is not responsible for the content or privacy practices of websites operated by third parties, including our advertising partners and networks.  We encourage you to review the privacy policies of third-party websites and services before providing any information to them.

Managing and Accessing Your Personal Information

If you wish to access your personal information, including past loan documentation, please email us at info@brizzifinancial.com.

Brizzi Financial may retain your personal information as required by law or for legitimate business purposes and your personal information may be retained by third parties with whom such information has already been shared. We may also retain cached or archived copies of your information. Please note that, even if your loan file has closed and you no longer wish to use Brizzi Financial’s services, information that you chose to provide may not be deleted.

If you are a borrower and wish to correct your information in our records, please email us at info@brizzifinancial.com.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services. 

To opt out of being tracked by Google Analytics when using web-based services, visit https://tools.google.com/dlpage/gaoptout.

Promotional Communications

Receiving promotional calls, text (SMS) messages, emails and direct mail from Brizzi Financial is completely voluntary, and you may opt out at any time. To opt out of promotional communications from Floify, email us at info@brizzifinancial.com. You can also opt out of receiving promotional emails by clicking the unsubscribe link in the email, and you can opt out of promotional text (SMS) messages by texting STOP. You may receive a final email or text message confirming your opt-out. Message and data rates may apply. Please allow up to 10 business days to process any opt-out request. 

Please note that even if you opt out, we may still send you non-promotional communications, such as responses to requests that you have submitted.

Communications By Third Parties

To opt out from receiving promotional communications from any third party, or to make requests regarding your personal information or other information held by them, you should contact them directly.

Children and Our Services

Our Services are not directed to children, and you may not use our Services if you are under the age of 18. If we learn that we have collected personal information of a child under 16, we will make commercially reasonable efforts to delete such information from our files.

State-Specific Rights

Your California Resident Privacy Rights

Under the California Consumer Privacy Act or CCPA, California residents have certain rights regarding their personal information, including:

  • The right to know the categories of personal information we’ve collected about them and the categories of sources from which we got the information (see Information We Collect);

  • The right to know the business purposes for which we’ve shared their personal information (see How We Use Information We Collect);

  • The right to know the categories of third parties with whom we’ve shared their personal information (see How We Share Information We Collect);

  • The right to access the specific pieces of personal information we’ve collected about them and to request that we delete personal information, subject to certain exceptions (see below); 

  • The right to opt out of the sale of their personal information (see below); and

  • The right to not be discriminated against for exercising their CCPA privacy rights.

For purposes of these rights, “sold” and “business purpose” have the meanings given in the CCPA. For example, if you submit an opt-out request, you will not be opted out from transactions that the CCPA does not deem to be sales. In addition, please note that the CCPA does not require us to delete personal information that we need to maintain for certain purposes.

To exercise the access and deletion rights described above with respect to your personal information, you may submit a verifiable consumer request to us by either:

  • Calling us toll free at 916.514.9540; or

  • Emailing us at info@brizzifinancial.com

Only you, or someone that you authorize to act on your  behalf, may make a verifiable consumer request related to your personal information. We will work to respond to a consumer request within 15 business days (for opt-out requests) or 45 calendar days (for deletion and access requests) of receipt. We will not charge you a fee for making a request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will notify you and explain our decision before completing your request. 

Retention

Brizzi Financial retains personal information as long as it is needed for business or legal purposes.

Governing Law; Visitors Residing Outside the United States  

Our Properties and Services are hosted and performed, and all personal data is processed, in the United States. This Privacy Policy is subject the laws of the United States of America, without regard to conflict of law principles. If you reside outside of the United States, you are responsible for complying with local laws in connection with your use of the Services, and you consent to the collection, transfer, storage, and use of your personal information in the United States in accordance with this Privacy Policy.

The laws governing processing of personal information vary depending on the jurisdiction in which you reside. To the extent the laws of your jurisdiction are different or more restrictive than the terms of this Privacy Policy, it is Brizzi Financial’s policy to follow the requirements of those laws to the extent those laws are applicable to Brizzi Financial’s activities or your personal information. 

Additional Information or Assistance

Please address comments or questions to info@brizzifinancial.com or write to us at the address listed below.

Brizzi Financial

5800 Lonetree Blvd Suite 101

Rocklin, CA 95765