Privacy Policy

In this Privacy Policy (“Policy”), we describe how Monster Lead Group d/b/a Loansure (“Loansure,” “we,” “us,” or “our”) collects, uses, and discloses information that we obtain about visitors to our websites Loansure.ai and Loansure.io (the “Sites”), other digital or online properties that link to this Privacy Policy, our marketing activities, live events and other services described in this Privacy Policy (collectively, the “Services”).

This Privacy Policy applies to our business customers, as well as individual consumers, such as prospective borrowers, whose personal information we collect, use, and disclose in connection with our Services. To the extent that we process personal information strictly on behalf of our business customers (such as lenders and other organizations) while providing our Services to them, such processing may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that business customer.

This Privacy Policy does not apply to our employees or independent contractors or job candidates.

See the U.S. State Privacy Rights Notice at Collection section of this Privacy Policy for additional information if you are a U.S. resident.

The Information We Collect About You

We may collect the following information about you directly from you or from third parties:

• Contact data, such as your name, email address, phone number, professional title and company name, and billing address;
• Demographic data, such as your city, state, country of residence, postal code, gender, physical characteristics, income or income range, economic standing, and age.
• Account data, such as the username and password that you set to establish an account on the Service.
• Call recordings and transcriptions, such as recordings and transcriptions of calls between our business customers and prospective borrowers in connection with providing our marketing services.
• Call intelligence and customer attribution data, such as call outcome information.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
• In addition, we may collect publicly available information (e.g., property record information, tax data and mortgage data) which may not qualify as personal information.

Third-party sources. We may obtain personal information from third party sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as information services and data licensors.
• Service providers, such as those that provide services on our behalf or help us operate the Service or our business.
• Customers.

For information about how these third-party sources may use and disclose your information, including any information you make public, please consult their respective privacy policies. We have no control over how any third party, except for our service providers, uses or discloses the personal information it collects about you.

Information We Collect Automatically. We and our service providers may automatically collect information about your use of our Services through cookies, web beacons, and other technologies. We may combine this information with other information we collect about you. Please see the section “Tracking Technologies” below for more information.

For example, we may collect:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data, such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
• Call metadata, such as telephone numbers, call date, time, and duration, and connected, missed, and abandoned call data.

Tracking Technologies. Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our Sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.

Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.

How We Use Your Information

We may use your information, including your personal information, for the following purposes:

• Service delivery and operations, such as to provide and operate our Services, to communicate with you about your use of our Services, to respond to your inquiries, enable security features of the Services, fraud prevention and security, and for other customer service purposes.
• Service personalization, such as to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Sites or our Services.
• Marketing, such as for direct marketing and promotional communications. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you.
• Research and development, such as using your personal information to develop, analyze, and improve our products and services, including to train our AI, enrich borrower profiles we maintain, and create and generate marketing reports we share with our business customers (e.g., aggregated marketing analytics reports) in connection with our marketing services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information. We may use this anonymous or de-identified data and share it with our business customers and other third parties for any lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
• Compliance and protection, such as using your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;

protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

audit our internal processes for compliance with legal and contractual requirements or our internal policies;

enforce the terms and conditions that govern the Service; and

prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

• With your consent, such as, in some cases, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Tracking Technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as remembering selections as you navigate the Sites and remembering whether you are logged in.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our Sites here: https://tools.google.com/dlpage/gaoptout.

Data sharing in the context of corporate transactions, we may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How We Share Your Information, below.

How We Share Your Information

We may share your information, including personal information, as follows (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection):

• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
• Service Providers. We may disclose the information we collect about you to third party vendors, service providers, contractors or agents who perform functions on our behalf, such as hosting, information technology, customer support, AI providers, email delivery, marketing, and others.
• Business Customers. We may share personal information about prospective borrowers with our business customers that we provide marketing services to.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
• Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Loansure, financing of Loansure, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Loansure or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
• Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Other Sites and Services. Our Sites and Services may contain links to websites, mobile applications, and other online services operated by third parties. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We are not responsible for the information practices of such third party websites. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Your Choices

In this section, we describe the choices available to you.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. To do this, follow the instructions in your browser settings. Visitors to our Sites who disable cookies will be able to browse certain areas of the Sites, but some features may not function. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Opt-out of communications. We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested. You may opt-out of text messages by texting “STOP” in response to a text that you receive or by other reasonable means.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies). To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Training data. As set out in the How We Use Personal Information section, we may use your personal information to train our AI models and for other machine learning purposes.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Shine the Light law opt out. Under California’s Shine the Light law (California Civil Code Section 1798.83), we give you the right to opt-out of our disclosure of your personal information (as defined by this law) to third parties for their direct marketing purposes. You may send us requests to hello@loansure.ai. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.

How do we protect your information?

We implement security measures designed to maintain the safety of your personal information. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

Children and Teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Policy

We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites or other appropriate means.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at hello@loansure.ai.

U.S. State Privacy Rights Notice At Collection

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This State Privacy Rights Notice At Collection is part of our full Privacy Policy.

Please note that not all rights listed below may be afforded to all individuals and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device.

We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

Right to know

You can request to know whether we process your personal information.

• You can request the following information about how we have collected and used your personal information during the past 12 months and how we will continue to do so:
  The categories of personal information that we have collected.The categories of sources from which we collected personal information.The business or commercial purpose for collecting, selling, and/or sharing personal information for targeted advertising purposes.The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.The specific third parties to which we have disclosed personal information.
• Access. You can request a portable copy or representative summary of the personal information that we have collected about you.
• Correction. You can ask us to correct inaccurate personal information that we have collected about you.
• Deletion. You can ask us to delete the personal information that we have collected from or about you.
• Revoke consent. You may have the right to revoke your consent to our processing of your personal information.
• Opt-out.
  • Targeted advertising/sale of your Personal Information. We do not sell personal information (including sensitive personal information), and we do not "share" or otherwise process personal information (including sensitive personal information) for purposes of cross-context behavioral or targeted advertising, as defined under applicable law. We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated. Without limiting the foregoing, we do not sell or "share"/knowingly sell or "share" personal information (including sensitive personal information) of minors under 18 years of age.
  • Automated decision making. We do not use your personal information to engage in automated processing or profiling personal information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.
• Sensitive Personal Information. We generally do not solicit or request sensitive personal information and take reasonable measures not to collect or derive sensitive personal information from prospective borrowers or our business customers. If we learn that we have collected sensitive personal information through the Service, we will comply with applicable legal requirements regarding the processing of such information, including rights requests related to opting out of or limiting the use of such personal information.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.
• Appeal. You can appeal our denial of any request validly submitted.

Exercising your right to know, access, correction, deletion, and appeal. You may submit requests at https://loansure.ai/contact, calling us at (410) 504-6584 or via email to hello@loansure.ai.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Verification of Identity; Authorized agents. We may need to verify your identity to process your know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. We may need to request you to provide information we can match against information we have collected from you previously, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose, sell to or share with third parties by reference below to both the categories of personal information defined in the “The Information We Collect About You,” “How We Use Your Information,” and “How We Share Your Information” sections of this Policy above and the categories of personal information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms or in the course of discussions with prospective borrowers or our business customers, may contain other categories of personal information not described below.

See our full Privacy Policy for descriptions of each entry in this table.

Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.‍

‍Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale, as defined, of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email hello@loansure.ai.‍

‍Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including sensitive personal information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.‍

‍Additional information for Connecticut residents. We collect, use, or sell personal data for the purpose of training large language models (“LLMs”).‍

‍Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the Contact Us section, above.

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