PRIVACY POLICY

Effective as of 12/15/19

This “Privacy Policy” describes the privacy practices of Daily AI Mortgage, LLC (together with our parent Daily AI, LLC and our subsidiaries and affiliates collectively, “Daily AI”, “we”, “us”, or “our”) in connection with the dailyai.io website (the “Site”), the Daily AI mobile application (the “App”), and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Services”), and the rights and choices available to individuals with respect to their information.

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Services or otherwise includes:

a. Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional license identification (e.g. real estate license or loan officer number), professional title and company name.

b. Content you choose to upload to the Services, such as text and images along with the metadata associated with the files you upload.

c. Profile information, such as your username and password that you may set to establish an online account with us.

d. Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

e. Demographic Information, such as your city, state, country of residence, postal code, and age.

f. Financial information, such as your financial account numbers or payment card information.

g. Precise geolocation information, such as when you authorize our mobile application to access your location.

h.Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us.

i.Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Services.

j.Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

k. Other information, that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from email, calendar, and social media platforms.As part of the Services, you will have the option to connect you email (e.g. Gmail and Outlook) as well as their corresponding calendar applications to your Account. If you choose to connect your email and calendar to your Account we may collect, store, and analyze information from such platforms and will treat such information in accordance with this Privacy Policy.
We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
If you choose to login to the Services via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Services, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address. You can read more about your privacy choices in the “Third party platforms or social media networks” portion of the “Your Choices” section.
App's use of information received, and App's transfer of information to any other app, from Google APIs will adhere to Google's Limited Use Requirements.

Information we obtain from other third parties: We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers. We partner with Ellie Mae, Inc., and collect certain information form Ellie Mae’ s Encompass Platform, such information may include information about you and/or your business dealings.

Cookies and Other Information Collected by Automated Means: We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services, including but not limited, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile application, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.
A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites. A SDK is third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our App, or to facilitate online advertising.

Referrals

Users of the Service may have the opportunity to refer business partners or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Services. We use your personal information to:

• provide, operate and improve the Services;

• provide information about our products and services;

• facilitate your to login to the Services via third-party identity and access management providers, such as Facebook;

• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

• communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages

• provide support and maintenance for the Services;

• to respond to your requests, questions and feedback.

For research and development. We analyze use of the Services to analyze and improve the Services and to develop new products and services, including by studying user demographics and use of the Services.

To send you marketing and promotional communications. to solely the email and phone number you registered with. We may send you Daily AI-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To display advertisements. We work with advertising partners to display advertisements on the Services or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services, the information you provided upon registration, or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Other Users of the Services and the Public. We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. You may also be able to submit content to the Services (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. [We may make available settings through the [My Account] page that enable you to exercise choice regarding certain information that is displayed publicly or to other users.] We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Service providers. We may share your personal information that you provided upon registration with third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
Personal data being collected will not be connected to Gmail OAuth.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by logging in to the Services using your account with the third-party, providing your API key or similar access token for the Services to a third-party, or otherwise linking your account with the Services to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other Users of the Services and the Public. We may make available settings through your Account page that enable you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at compliance@dailyai.io.. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site or App may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users the App may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

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.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Services via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.

Other sites, mobile applications and services

The Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security practices

The security of your personal information is important to us. We employ commercially reasonable and appropriate organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to compliance@dailyai.io. You may also write to us via postal mail at: Daily AI, LLC Attn: 1919 14th Street, Suite 700, Boulder, CO 80302

Information for California Residents

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at compliance@dailyai.io. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. Additionally, if you are a California resident, you have the following rights:

Information. To request that we disclose the following information about our collection and use of your personal information during the past 12 months:

• The categories of personal information that we have collected about you;

• The categories of sources from which personal information is collected;

• The business or commercial purpose for collecting or selling personal information;

• The categories of third parties with whom we share your personal information;

• Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient; and

• Whether we have sold your personal information, and, if so, the categories of personal information received by each category of recipient.

Access. To request a copy of the personal information that we have collected about you during the past 12 months.

Deletion. To request that we delete personal information about you that we have collected from you.

Opt out of sales. To direct us not to sell your personal information if we do, and if you are under 16 years of age, we are required to ask for affirmative authorization from you (or it you are under 13, your parent or guardian) to sell your personal information before we do so.

Nondiscrimination. To exercise your rights described above free from discrimination, such as denial of goods or services; price/rate increases for goods or services (including through grants of discounts/benefits or imposing penalties); decreases in service quality; or suggesting that such discriminatory acts may occur if you exercise your rights. However, a difference in price or service quality is not discriminatory if reasonably related to the value to our business of the personal information we are unable to use due to the exercise of your rights, and we may offer you certain financial incentives that can result in different prices, rates or service quality.

Financial incentive program disclosures. Receive a clear description of the material terms of any program involving financial incentives for the collection, sale or deletion of your personal information, and decide if you want to consent to be entered in it (you can revoke this consent at any time).

How to exercise your rights

You may exercise the rights described above as follows:

Right to opt out of sales You may exercise your right to opt out of sales of your personal information by visiting the following web page:Do Not Sell My Personal Information

Right to information, access and deletion
You may exercise the information, access and deletion rights described above by submitting a verifiable request to us by:

• visiting dailyai.io

• emailing compliance@dailyai.io

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are a California resident about whom we collected personal information or their authorized representative; and

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

These rights are not absolute, are subject to exceptions, and we may be required or permitted by law to decline your request.

Personal information that we collect, use and share

The chart below provides information that we are required to give you under California law about the categories of personal information that we have collected, used and shared in the 12 months preceding the last update of this Privacy Policy. See our Privacy Policy for a description of the sources of the personal information we collect, as well as the business and commercial purposes for which we collect, use and share this information.