I.  Scope of Policy.

This Digital Privacy and Cookies Policy (“Policy”) applies to your interaction with Home Kapital Finance, LLC or any of its affiliates (collectively, “Home Kapital,” “we,” “us,” “our”): (1) at any online or mobile site or application that we own and control (“Site”), unless a different online and/or mobile or other privacy policy is posted relating to a particular site, application, product, or service, or is made available to you and by its terms supplants this Policy: or (2) via a Home Kapital advertisement, page, or account on a third party site. We may collect, retain, use, and disclose personal and other information about you in accordance with this Policy. Other privacy policies may also apply in addition to the terms of this Policy.

II.  Agreement to Policy.

To the extent permitted by applicable law, by using a Site or interacting with a Home Kapital page or account on a third party site, you consent to this Policy, including your consent to our use and disclosure of information about you in the manner described in this Policy.

III.  Gathering, Using, and Sharing Information.

You may interact with us in a variety of ways online, including through a mobile device. We may offer sites or applications that permit browsing and do not require registration. We may also offer the ability to enroll, register or access your accounts online. Information that we may collect about you through online interaction includes information that you input, such as your name, address, email address, and other contact information; data resulting from your activity, such as transaction information and the pages you visit on Site; location information; and biometric information. We may also gather additional information, such as the type of device and browser you are using, the IP address of your device, information about your device’s operating system, and additional information associated with your device. We may also gather information collected through cookies, tags, and other technologies, as described further below.

Some pages on the Site may use a technology called “cookies.”  A cookie is an electronic token that a server gives to your browser when you access a website. Cookies are used to store many types of data and may be placed by Home Kapital or a third party. Cookies help provide additional functionality to the Site or help provide and analyze Site traffic and usage information. Usage data can be stored in these cookies to record your preferences, log-in details and settings for future visits, and in some cases to personalize the content displayed on the Site. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to our Site.

In addition to the cookies we set during your use of the Site, additional cookies may be set, where applicable, by third party providers when you visit our Site. This occurs because we have commissioned third parties to collect information for us, for example for statistical usage analysis; it also occurs because our Site may contain content of third parties. Where required, your browser connects, for the purpose of accessing such third party content, directly with the servers of the third party providers, thus enabling those providers to place their own cookies on your end device.

We may make use of tools to analyze the information obtained by the cookies about your use of the Site to statistically evaluate your use of our Site for us, to create reports on Site activities and to provide further services related to the Site and the internet usage for us. This information may be transmitted to a server in another jurisdiction and stored there or in the cloud.

We may also use additional technologies such as pixel tags, web beacons, and clear GIFs, and may permit our third party service providers to use these technologies. We use these technologies for purposes such as measuring the effectiveness of our advertisements or other communications, determining viewing and response rates, and determining which offers to present to you on our own or on third party sites.

In addition to the uses described above, we use information for purposes as allowed by law such as: servicing; communicating with you; improving our Site, products, or services; legal compliance; risk control; information security; anti-fraud purposes; marketing or personalizing the presentation of our products and services to you; or tracking email access or Site usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our sites.

IV.  Children’s Privacy.

Our Sites are not directed to children under the age of 13, and we do not knowingly collect personal information from such children.

V.  Policy Updates and Effective Date.

You agree and acknowledge that we may revise or change this Policy at any time, without notice to you, and you agree the provisions of this Policy will be effect as they appear on this page at the time you access these pages. Because this Policy may change, we encourage you to refer back often to this Policy.  To the extent permitted by applicable law, your use of the Site following the update to the Policy means that you accept the updated Policy.