
Privacy Policy
Updated: January 20, 2021
Top Smart Mortgage takes your privacy and your rights to control your Personal Information very seriously. This Privacy Policy will let you know what Personal Information Top Smart Mortgage collects and processes, how we use the Personal Information collected, and your rights in relation to controlling and protecting your Personal Information.
Top Smart Mortgage may update this Privacy Policy from time to time in accordance with its business needs or as a result of a regulatory change and we encourage you to check back this Privacy Policy occasionally in order to make sure you are aware of any changes. Your continued use of Top Smart Mortgage’s services, including without limitations, engaging with our partners, completing any forms, or otherwise communicating with Top Smart Mortgage or any of our partners introduced to you by Top Smart Mortgage shall constitute your agreement with any such changes.
This Privacy Policy is adopted by Top Smart Mortgage among others to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws.
- General
Top Smart Mortgage provides its partners, who are merchants in various industries (the “Partners”) with an online platform to access high quality leads in order to approach such leads with commercial offers concerning the Partners’ products and services.
Top Smart Mortgage invites potential leads to join the platform by completing digital forms made available to them among others through Top Smart Mortgage’s landing pages or other media assets.
Top Smart Mortgage benefits both Partners and leads by helping Partners focus their marketing efforts on quality and fully consenting leads while making attractive commercial offers available to the leads who joined the platform, in full compliance with the applicable regulation.
For any privacy or data protection related issues, please email Top Smart Mortgage at privacy@topsmartmortgage.com
- The Information We Collect
You may give us your Personal Information directly when you complete forms made available to you among others through our landing pages or when you register to our website, if applicable, rate or review our services, or otherwise communicate with us.
The Personal Information you provide us may include:
- private and family name;
- address and contact details (such as your email address and phone number);
- your position/job details & title;
- your gender;
- your age/birth date;
- your education;
- financial information (such as salary, income, ownership of assets, loans, etc.); and
- other information if relevant for the purpose for which the Personal Information is collected, such as interests, hobbies, views, etc.
Top Smart Mortgage also collects information automatically. Information that we collect automatically may include log information (personal identifiers, mobile advertising IDs, details about your use of our services, such as IP addresses, web pages visited, and actions performed on websites, geolocation data, etc.) and calls and correspondence between us.
- Cookies
We use cookies and other similar technologies to collect and store information about your activity while using our services among others in order to improve and personalize our services. A cookie is a small text file that we store on your browser or the hard drive of your device.
For example, cookies can be used to collect information about your use of the services during your session time, your operating system and browser, your IP address, websites you visited before our website, etc.
You may choose to set your browser to refuse cookies altogether or on a case by case basis or to delete cookies, however certain features of our services may not operate correctly if you do so.
- How do we use your information?
Please note that as part of providing our services, your Personal Information will be shared with Partners which decided to purchase leads on our platform with the same characteristics as the characteristics of your Personal Information (e.g. age, gender, location, interests, etc.).
We will not share such Personal Information before having the relevant Partner executing a binding agreement containing obligations on the part of the Partner to protect your privacy and to use your Personal Information in compliance with applicable laws and regulations.
We may also use Personal Information we collect about you in the following ways:
- to provide you with services and offers regarding services (i.e. connecting you with commercial offers from our partners, as well as to improve our services and offer you, safeguard, provide and improve our services);
- to contact you regarding our services (including without limitations concerning changes to our services, information about promotions, and existing and new features of our services), by sending you emails or text messages. We may also deliver to you marketing communications concerning the products and services of our partners, all subject to applicable law.
If you do not want to receive marketing communications from us please email Top Smart Mortgage at privacy@topsmartmortgage.com
We may use and share Personal Information for legal purposes, including sharing information with regulatory authorities, or disclosing information to third parties if required by law or if we reasonably believe that the use or disclosure of the information is necessary to protect our or our Partners or other persons’ rights.
Top Smart Mortgage may also use and share information (especially non-personal information) to analyze our services and the use of services by Partners and by potential leads.
Top Smart Mortgage may also use and share your Personal Information with its services providers, other business partners, contractors, etc. for the purpose of providing our services and ancillary purposes (e.g. hosting, maintenance and support, marketing, backup, etc.).
Top Smart Mortgage may also use and share your Personal Information with its group companies from time to time, subject to appropriate arrangements to protect your privacy such as confidentiality agreements and data processing agreements (which agreements will be used with any third party to whom we will provide access to your Personal Information).
In the event that Top Smart Mortgage consummates a merger or an acquisition by another company or otherwise undergoes a change of control, Top Smart Mortgage may disclose or transfer all of your Personal Information to the successor company.
- Disclosure or Sale of Personal Information and your Right to Opt-Out
Top Smart Mortgage sells Personal Information collected for our database to our Partners in order to provide our services to such Partners and to the leads joining our database.
This information is sold to the Partners for the purpose of the Partners contacting the owners of the Personal Information with commercial offers regarding the Partners’ products and services.
You have the right to opt-out of the sale of your Personal Information by submitting a request to remove or delete your Personal Information.
Top Smart Mortgage does not sell the Personal Information of minors under 16 years of age.
If you want to opt-out from the sale of your Personal Information, please email Top Smart Mortgage at privacy@topsmartmortgage.com or you may also contact us by calling +1 (332) 207-7318
- Consumers Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information:
Access to Specific Information and Data Portability Rights
A consumer has the right to request that Top Smart Mortgage discloses certain information to that consumer about collection and use of that consumer’s Personal Information over the past 12 months:
- categories of Personal Information collected;
- categories of sources for the collected Personal Information;
- Top Smart Mortgage business or commercial purposes for collecting or selling Personal Information; and
- categories of third parties with whom Top Smart Mortgage shares Personal information.
Deletion Requests, Access and Portability Rights
A consumer has the right to request that Top Smart Mortgage deletes any of the Personal Information collected about such consumer, subject to certain exceptions under applicable law.
A consumer may also contact Top Smart Mortgage to inquire what Personal Information is retained and processed about the consumer or to request that such Personal Information or any part of it will be transferred to a third party or to such consumer – all subject to the exemption available under applicable law.
To submit a request to action any rights described above, please email Top Smart Mortgage at privacy@topsmartmortgage.com.
- How We Protect Your Information
Top Smart Mortgage has made reasonable technical and organizational measures designed to secure your Personal Information from accidental loss and from unauthorized access.
While we take reasonable precautions against possible security breaches of our services, no website or Internet transmission is completely secure, and Top Smart Mortgage cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
- Changes to this Privacy Statement
Changes to this Statement will appear on this page. Any changes to our Privacy Policy will be posted on our website(s) in order to keep you informed and where appropriate, we shall notify you via email.
Top Smart Mortgage’s goal is to help users make confident decisions online and connect between lenders and users. top lending’s website contains information about products and services.
Please be advised that this site accepts advertising compensation from companies that appear on the site, and such compensation impacts the location and order in which the companies are presented, and in some cases may also impact the rating that is assigned to them.
We do not provide any products or services other than as specifically set forth on our website and terms of use. Among others, we do not provide any loans or other financial services. We also do not endorse any products or services offered by any third parties contacting you through our services. We are not responsible in any way for the conduct or quality of services or products of such third parties. Our services are being provided to you on an “As Is” and “as available” basis.