Privacy Policy

Angel Twin Privacy Policy

Your information privacy is important to us. We provide this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you visit our website and any other website or platform on which this policy is posted (collectively, the "Site"), the Angel Twin platform, and associated portals, features, content and services offered by us and any time you interact with our Company (collectively, the "Services"), This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the Site and Services. The Site and Services are provided by Angel Twin Incorporated ("Angel Twin" "Company" "we" "our" "us")
BY USING THE SITE OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

1. Personal Information We Collect

We collect the following categories and types of "Personal Information":
  • Contact Information: your first and last name, mailing address, email address, business contact information and phone number;
  • Other Identifying Information: IP address, government issued ID number, signature, social media and other online identifiers, vehicle license plate or VIN number, passwords and other security information for authentication and access, tax identification number;
  • Financial Information: credit card, debit card and bank account information, SWIFT/BIC number, international bank account number, payroll records, credit history, salary and other tax reporting information;
  • Demographic Information: gender, date of birth, physical description;
  • Education Information: education history, transcripts;
  • Employment Information: employment history, resume, references, date of hire or resignation, offer letters, emergency contact information, records of promotions or transfers, pension plan records, agreements, and/or enrollment forms;
  • Geolocation Data: region and address from which the Site or Services are accessed;
  • Internet or Other Electronic Activity: your browsing and click history, search history, cookie data, online and device identifier, IP address, advertisement interaction data, including information about how you navigate within our Site and Services;
  • Audio/Visual Information: photographs, video surveillance, audio messages, text messages;
  • Biometric Information: voice recordings;
  • Health Insurance Information: policy number, insurance application information, claims history, dependent or spouse information, health insurance group ID, health insurance plan member ID;
  • Medical Information: medical history, medical treatment, diagnosis, provider name, dates of service, medical notes;
  • Commercial Information: records of personal property, products or services purchased or viewed on our Site or through the Services;
  • Sensitive Information and Characteristics of Protected Classifications under Applicable Law: social security number, driver's license, state identification card, passport number or other government identification, your precise geolocation, race, ethnicity, national origin, citizenship, physical or mental disability, health information, marital status, gender identity, sexual orientation, veteran or military status, pregnancy or related information, contents of mail/email/text messages;
  • Inferences: drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior, and attitude.

2. How We Use Personal Information

We use your Personal Information for the following categories of use:
Transactional Purposes: We use your contact information, other identifying information, demographic information, financial information, sensitive information and commercial information to:
  1. Receive, confirm and process your registration or account;
  2. Manage your account;
  3. Provide, analyze and maintain the Services; and
  4. Communicate with you about your account.
Analytical Purposes: We use your other identifying information, internet activity and browsing history, commercial information, demographic information, sensitive information and geolocation data to analyze preferences, trends and statistics.
Marketing and Promotional Purposes: We use your contact information, commercial information, demographic information, internet or other electronic activity, geolocation data, sensitive information and inferences to:
  1. Inform you of our new products, services and offers;
  2. Provide you with targeted advertising; and
  3. Provide you with other information from and about our Company, including personalized marketing communications.
Maintenance and Improvement of the Site and Services: We use your contact information, commercial information, and internet activity and browsing history to:
  1. Provide you with the Site and Services, including to send you alerts about your account;
  2. Handle your customer services requests; and
  3. Help us diagnose technical and service problems and administer the Site, and the Services.
Security and Fraud Prevention: We use your contact information, other identifying information, commercial information, financial information, geolocation data, sensitive information, internet activity and browsing history, and inferences to protect the Site and services, our Company, and others and to prevent fraud, theft and misconduct.
Training AI Models: We use both manual and automated methods of processing. In particular, we may use automated methods of processing such as Artificial Intelligence ("AI") and Machine Learning ("ML"), which are a set of technologies programmed to perform tasks and actions that are commonly associated with human beings. We may use AI and/or ML to optimize and increase the efficiency of business processes (e.g. to support customer service) and/or to support and enhance existing security controls. We may use your contact information, other identifying information, commercial information, financial information, demographic information, educational information, employment information, geolocation information, audio/visual information, internet activity and browsing history, sensitive information and inferences to train our AI and ML models in order to develop advanced technologies and improve the Services.

3. Sources of Personal Information

We collect Personal Information from the following sources:
  • We collect information directly from you: We collect contact information, demographic information, employment information, biometric information, audio/visual information, financial information and sensitive information directly from you. We also collect health and medical information from you in connection with your employment.
  • We collect information from third parties: We collect identifying information, demographic information, employment and financial information from our affiliates and vendors (including credit and background check vendors) and from the third-party financial institutions and service providers you interact with. We also collect health and medical information from our benefit providers in connection with your employment.
  • We collect information from you passively: We collect other identifying information, geolocation information, commercial information, internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Cookies section below. We also capture certain usage data to provide and analyze a 'session replay' of your activities on the Site, which allows us to optimize the Site and Services. The session replay may record, for example, clicks, mouse movements, scrolling, typing, navigation through the Site and the technical specifications of your device.

4. Categories of Third Parties We Share Personal Information With

Service Providers: From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours ("Service Providers"). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to help protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
Third Parties: Other than our Service Providers, we may share Personal Information with other third parties if you specifically authorize it, or it is required in order to complete a transaction, provide a product feature, service or activity that you initiated or requested. We may also share your Personal Information with a third party for their direct marketing purpose. Note: When we share Personal Information with third parties, the collection and processing of your Personal Information will be subject to the privacy policy of such third party;
Our Affiliates: We may share Personal Information with businesses controlling, controlled by, or under common control with our Company;
Corporate Transactions: If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such a transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy;
Compliance with Laws and Law Enforcement: We cooperate with government and law enforcement officials and private parties to enforce and comply with the law, including "know your customer" and anti-money laundering laws. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law;

5. Cookies

We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other similar technologies to analyze use of and improve the Site and Services. Most web browsers are initially set up to accept cookies. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. If you block cookies, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers (defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.
We use analytic providers such as Google Analytics on the Site and Services to analyze how users use the Site and Services, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

6. Session Replay Technology

We use session replay technology on our Site. Session replay technology, also referred to as session playback or user experience (UX) replay, collects information regarding, records, and tracks your interactions with a website or application. It then transforms those logged user events (such as mouse movements, clicks, page visits, scrolling, tapping, etc.) into a reproduction of what you actually did on the website or application. We use session replays for quality control, customer service, fraud prevention and security purposes. Our session replay technology may be owned and operated by a third-party who acts as our service provider, in which case, the information collected by this technology may be collected by, transferred to, and stored by our third-party service provider.

7. Chatbot Technology

Some of our Services include chatbot technology. For example, we use chatbots to help provide customer service and support, including through the use of a virtual assistant. In addition, the Angel Twin platform is a chatbot provided in connection with certain financial services. A chatbot is a software application that mimics human conversations in text or voice interactions on our website or through our customer service hotline. It enables the communication between a human and a machine, which can take the form of messages or voice commands. The chatbot is designed to work without the assistance of a human operator. It responds to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts and machine learning algorithms. When asked a question, the chatbot will answer using the knowledge database that is currently available to it. If the conversation introduces a concept it is not programmed to understand; it will pass it to a human operator. If you use our chatbot service, we will collect any Personal Information you provide to us. We will also create and store a session replay (as described in Section 6 above) and a transcript of your chat interaction with us which may be shared with and stored by a third-party service provider. We use these transcripts and the information you provide to provide you the Services you request and for quality control, customer service, analysis, product improvement, fraud prevention, and security.

8. Advertising and Online Tracking

We may allow third-party companies to serve ads and collect certain information when you visit the Site and Services. These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. Our advertising partners may collect information about your activities on our Sites or mobile applications on your current device and combine it with information about your activities on other websites, mobile apps, and devices. These companies typically use cookies or other tracking technologies (such as web beacons, tags, pixels, mobile advertising IDs and similar technologies) to collect this information. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. These third party partners use this information for our and their own advertising, analytics, attribution, and reporting purposes. Our systems do not recognize browser "Do Not Track" signals, but several of our Service Providers who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the "Managing Your Information Preferences" section of this Privacy Policy. You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online cookies and tracking technology by clicking on the cookie manager on the Site and changing your cookie preferences to ensure that analytics and advertising cookies are disabled.

9. Managing Your Information Preferences

You can opt out of receiving marketing e-mails from us by following the link provided at the bottom of all marketing e-mails you receive from us. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account.
If you have questions or concerns regarding this Privacy Policy, please e-mail us at that same address.

10. Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others.
This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications. We cannot control and are not responsible for what such third parties may do with your information, so you should exercise caution when choosing to share it.

11. Security

We maintain physical, electronic, and procedural safeguards to help protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure.
As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

12. Links; Third Party Platforms

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party's website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.
Additionally, the Site or Services may contain or link (via API or otherwise) content provided by third party sites, providers or platforms such as financial institutions (collectively, 'Third Party Platforms'). When you interact with such Third-Party Platform(s), including by interacting with third party content made available on the Site or through the Services, the associated collection and processing of your Personal Information will be subject to the privacy policy of such Third-Party Platform(s).You should review the privacy policies of these Third-Party Platforms before interacting with them. By enabling the use and integration of your selected Third-Party Platforms in connection with the Services, you are expressly permitting Angel Twin to disclose your Personal Information to such Third-Party Platform(s) as necessary to facilitate your enablement and use of such Third-Party Platform(s) as part of the Services.

13. Children's Privacy

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.

14. Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States.The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

15. Your Privacy Rights

Residents of California or jurisdictions with similar laws (e.g., Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana) have certain additional privacy rights under the applicable privacy laws in such states ("State Privacy Laws"). This section generally describes those rights and how you can exercise them. Note that we allow all users of the Site and Services to exercise the rights set forth in this section in accordance with this Policy.
These rights are not absolute. In some situations, we may not be able to process your request. This may include if a legal exception applies. These rights may be offered based on your location. We will let you know when or if a right does not apply to you. You will not be discriminated against for exercising a privacy right. If you disagree with our decision, you can contact us as described at the end of this policy. Those rights are:
Access: to learn the categories of Personal Information we collect, use, disclose and sell; for those in California, the categories of sources of collection, the third parties to whom the Personal Information is disclosed or sold, and the business purpose for such collection or disclosure; for those in Oregon, a list of specific third parties (as defined under Oregon law) to whom we have disclosed the Personal Information.
Portability: a copy of the specific pieces of Personal Information collected;
Deletion: to have us delete Personal Information we collected from you; and Correction: asking us to fix your Personal Information.
We will also maintain a record of your rights requests.
Please note that if we delete your Personal Information, some of our services will not work the same. For example, your previous opt out requests will not be saved and saved preferences and information will no longer be available.
Exercising your Rights:
To exercise your rights, submit a verifiable consumer request to us by either:
Calling us toll-free at (855) 711-1770; or Email us at legal@angeltwin.com.
Your verifiable consumer request must:
Provide sufficient identifying information (including full name and email address) to allow us to reasonably verify you are the person about whom we collected and retained Personal Information, and/or your authority to make such request on behalf of the data subject, and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Note that we will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request or to review and comply with the request.
You may authorize someone to act as your agent and submit a request on your behalf. Due to the sensitivity of such requests, you must verify the agent's authorization before we will act. Accordingly:
You or your agent must supply proof that the agent is registered with the Secretary of State to act on your behalf; or
You or your agent must supply other written permission for a specific agent to act on your behalf; and
We will use your email address to connect directly with you to verify agent identity and authority.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm with a level of confidence appropriate to the sensitivity of the information that the Personal Information we have collected and retained in our systems and databases relates to you.
Making a verifiable consumer request does not require you to create an account with us, but if you have an account with us, we may require you to log-in to such account in order to verify your identity or authority or to provide or delete your information.
Right to Opt-out of the Sale or Sharing of Personal Information.
Residents of certain jurisdictions (e.g., California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia) have the right to opt out of the "sale" or "sharing" of their personal data, as such terms are defined under State Privacy Laws.
Under California law, "share" means disclosing your personal information by us to a third party for cross-context behavioral advertising, in exchange for money or anything else of value. Thus, when we use the term "share" under this section, we are using it in the narrow meaning of how it is defined under California law. Other State Privacy Laws do not use the term "share," but describe the concept as using personal information for targeted advertising.
The term "sell" has a different meaning under certain State Privacy Laws. For example, under the laws of California and Colorado, "sell" means exchanging your personal information by us with a third party for money or anything else of value, while under Virginia law, "sell" is the exchange of personal information for money only.
Currently, we participate in digital advertising networks to deliver advertising that is tailored to your interests. The participation in certain ad networks can constitute a "sale" or "sharing" of personal data under State Privacy Laws. The categories of third parties to whom information may be disclosed in this context is our third-party partners (e.g., advertisers and marketing partners, and data analytics providers).
We also disclose contact information to our affiliates and other third-party partners for their direct marketing purposes.
We may "sell" and/or "share" the following categories of Personal Information:
Contact Information;
Online Identifiers;
Geolocation information;
Internet/electronic activity;
Commercial information.
You can opt-out of our disclosure of this information to our referral partners by clicking the "DO NOT SELL OR SHARE MY PERSONAL INFORMATION" link at the bottom of our Site.
You can opt-out of our disclosure of this information for digital advertising purposes by opting out of cookies HERE. Please note that your opt-out preferences are website/device specific.
You may request a list of third parties that we have shared your Personal Information with for their direct marketing purposes or opt out of this practice by emailing us at legal@angeltwin.com.
You can also opt-out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Note that we will only apply the request to that specific device or browser and only for cookie or pixel-based selling and sharing. Thus, you will need opt out on each browser and device where you use our services. If you clear your cookie history on a particular browser or device, your opt-out request will no longer be saved.
To learn more about these advertising practices or to opt out of this type of advertising of your personal data, please visit https://optout.aboutads.info/ and https://www.networkadvertising.org/. to opt out. You can also opt out of the re-sale of your Personal Information by other participants in these digital advertising networks by visiting this site and opting out of each participant's digital property. Please note that, otherwise, we do not presently exchange Personal Information for money with anyone, nor do we otherwise "share" or "sell" Personal Information, as such terms are defined under applicable
State Privacy Laws.
Right to Opt-out of Profiling
Residents of some jurisdictions (e.g., California, Colorado, Connecticut, Montana, Oregon, Texas, Virginia)—subject to certain exceptions—may have a right to opt out of forms of automated processing performed on Personal Information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements ("Profiling").
We engage in cookie-based or digital advertising-based Profiling. To opt out of this practice, please follow the instructions detailed above regarding opting out of the sale or sharing of your Personal Information.
We engage in cookie-based or digital advertising-based Profiling. To opt out of this practice, please follow the instructions detailed above regarding opting out of the sale or sharing of your Personal Information.
We may also engage in Profiling when we assess your interaction with this Website and our Services for the purpose of providing you information on additional products and services which may be of interest to you. Note, you can opt out of marketing emails as explained in the "Managing Your Marketing Preferences" section above.
We also use automated tools to process your information and determine whether you are eligible for a particular product or service. If you would like to opt out of this type of Profiling, and except as set forth in the following paragraph as related to Angel Twin, contact us as set forth in the "Exercising Your Rights" section above.
In addition, the Angel Twin platform is an AI-driven platform that streamlines the mortgage process by guiding users through financial transactions from origination to closing. In order to do so, it creates a personalized profile for each user based on the financial and other information provided to it in order to ensure a tailored and efficient processing of their application. Despite the automated nature of this processing, humans are still involved, and have the authority to change or influence the ultimate outcome of any decisions or recommendations by Angel Twin. Nevertheless, if you do not want us to create a profile about you through this automated process, please do not use the Angel Twin platform.
Finally, if you are using our services from a country within the European Union (EU), we do not make decisions based solely on automated processing and profiling which has legal effects or similarly significantly impacts you, except where required by applicable law or as agreed with you.
We do not otherwise engage in Profiling.
Right to Limit the Use or Disclosure of Sensitive Personal Information
Residents of some jurisdictions may have a right to limit the processing of their Sensitive Personal Information (as defined by the applicable State Privacy Law). If you would like to limit our use of your sensitive personal information to that which is necessary to perform the specific services or complete a specific transaction you have requested, please contact us as set forth above or click the "LIMIT THE USE OF MY SENSITIVE PERSONAL INFORMATION" button on the Site.
Right to Appeal
Residents of some jurisdictions (e.g., Montana, Virginia, Texas and Colorado) have a right to appeal our decision on a privacy rights request. If we were unable to fulfill your request, you may appeal our request by emailing us at legal@angeltwin.com within fourteen days of our decision, and provide a detailed reason for your appeal, as well as your state of residence.
Notice to Nevada Residents/Your Nevada Privacy Rights
If you are a Nevada resident, you may opt out of the future sale of your information to a third party so that they may license or sell that information. To do this, email us at legal@angeltwin.com.
Financial Incentives

16. Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the 'Revised' date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

17. Contact Us

If you have any questions or concerns, you may contact us at (855) 711-1770.
PLEASE PRINT A COPY OF THESE TERMS FOR YOUR RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES TO THESE TERMS.