Privacy Policy for PathsDirect

Last Updated: May 25, 2010

BY VISITING THIS WEBSITE AND REQUESTING INFORMATION, PRODUCTS OR SERVICES THEREIN, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT PROVIDE ANY INFORMATION OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEBSITES REFERRED TO IN THIS PRIVACY POLICY.

PLEASE NOTE: THIS PRIVACY POLICY CHANGES FROM TIME TO TIME AND CHANGES ARE EFFECTIVE UPON POSTING. PLEASE CHECK BACK FREQUENTLY FOR UPDATES AS IT IS YOUR SOLE RESPONSIBILITY TO BE AWARE OF CHANGES. WE DO NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE.

This policy describes the information collection, use, and dissemination practices of PathsDirect, LLC, ("PathsDirect") and applies to "PathsDirect" collection, use, storage and disclosure of information by PathsDirect on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the "Websites"), (b) on various Third Party websites, and (c) to Prime Advertiser's other information collection, including the purchase of customer lists from Third Parties. PathsDirect is not responsible for the information collection or privacy practices of Third Party websites or applications.

Email Anti-Spam Policy:

PathsDirect, LLC does not send unsolicited commercial email through our systems. If you believe you have received an unsolicited commercial email from PathsDirect, LLC on behalf of any of our advertisers, please send an email (with the reported unsolicited commercial email included or attached with the 'full header') to: abuse@pathsdirect.com.

Foreign Use of the Website

To the extent that you are accessing the website while domiciled outside of the United States, you acknowledge that the Personal Information you are providing PathsDirect, LLC is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information outside of your domiciled country and in the United States.

CALIFORNIA RESIDENTS PRIVACY RIGHTS

Companies that collect personally identifiable information ("PII") from California residents and disclose such information to Third Parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide an easy unsubscribe mechanism by which a consumer may opt-out of having their information shared with Third Parties. We have elected the second option and you may request that your PII not be shared with Third Parties by sending your request, including your full name, email address and postal address to: PathsDirect (or BvP / CHE) , 18124 Wedge Parkway, #208, Reno Nevada, 89511, In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov.

Special Notice to Vermont Residents

Vermont has adopted new consumer privacy regulations that may require financial institutions to obtain your consentprior to sharing nonpublic personal information about you with non-affiliated companies. If you are a resident of Vermont, by subscribing to our site, you will be deemed to have consented, or opted in to use of your information consistent with this Privacy Policy.

1.0 COLLECTION PRACTICES

We will collect and use personal information about you to respond to your request for products and services offered through this website. We will also collect information in order to notify you about products, services, and other opportunities we think will be of interest to you. The information we collect may be from the following sources:

1.1 Information You Provide:
PathsDirect collects information provided by you in connection with obtaining financial products or services such as mortgage loans (such as full name, telephone number, self-assessed property value, and social security number)a as well as information you provide us when you register to receive communications from us (such as your email address). We also collect information you provide us when you enter promotions or offers by PathsDirect (such as your full name, physical address and email address) and information you provide us through surveys, feedback, or other forms hosted on our website or the pages of one of our affiliates or associates. We also collect demographic information. Demographic information is all other information such as gender, zip code, or any information that is not tied to your personal information. In addition, we might receive information about you from other sources and may add that information to your existing account.

1.2 Survey Information:
PathsDirect collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by Third Parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Websites, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, we or a Third Party (a "Third Party") may ask an individual to provide various information to us, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, "Survey Information"). We may also collect information concerning an individual from another source and use that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to us or a Third Party, however, an individual may receive incentives from us or a Third Party in exchange for providing Survey Information to us.

1.3 Site Membership or Registration.
To the extent registration is required to receive email and possibly postal communications from PathsDirect, this Privacy Policy also applies to consumers that have agreed to receive e-mail marketing from us, whether at our Website, via email, on Third Party websites or otherwise. We collect information in certain portions of our Website, where guests provide content submissions and suggestions or participate in interactive online activities (i.e., by way of responding to questions and surveys, community listings, ratings, searches and comparison searches, bidding, purchasing, chat, games, or bulletin boards, etc.). The personal profile information you submit to us remains your property, however, by submitting that information to us you grant us the right to use that information for marketing purposes. We may also use such information for content improvement and feedback purposes and we may join together with other businesses to bring selected retail opportunities to our members. These businesses may include providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation. In addition, we reserve the right to release current or past member information in the event we believe that the membership is being or has been used in violation of the Rules or to commit unlawful acts, if the information is subpoenaed, if PathsDirect is sold or acquired, or when we deem it necessary or appropriate. By agreeing to these terms, you hereby consent to disclosure of any record or communication to any Third Party when we, in our sole discretion, determine the disclosure to be appropriate.

"Subscription" occurs when an end-user registers for our services, either via registration at our website, via co-registration at a marketing partner's website, or via a permission pass | opt-out | no-opt mailing we collect personally identifiable information about our subscribers, based on: information gathered at the time of registration, subscriber interaction and response to subsequent electronic mailings and website use, information provided by marketing partners, and information appended from data aggregators. Information collected may include, but is not necessarily limited to: name, email address, postal address, gender, birth date, telephone number, activity, interests, user behavior and other demographic information. This information enables us to better tailor our content to subscribers' needs and to help our clients to promote and sell their products and services.

1.4 Client List Information.
When using client lists, we seek assurances from the client that the client has a right to provide offers to the individuals whose personal information is included on the client's list. The client must, upon request, provide PathsDirect, LLC, with opt-in verification such as subscriber name, address, sign-up website, sign-up date/time, and subscriber IP address.

1.5 Other Information.
Other occasions when PathsDirect obtains information from individuals include (1) when you are claiming a prize or seeking to redeem an offer by PathsDirect, LLC or by a third party, (2) when an individual voluntarily subscribes to one of our services or newsletter (together, "Other Information"), and (3) when an individual requests assistance through our customer service department.

Co-sponsored Contests, Sweepstakes and Offerings

PathsDirect, LLC may provide a contest, sweepstake and other offering may be co-sponsored by another company. In those situations, the information we obtain from you in connection with such contest, sweepstake or offering may be shared with our co-sponsor. In those situations, our co-sponsors will have the right to use your information for their own purposes, in accordance with their own policies. If you do not wish for the information we obtain from you to be shared with our co-sponsor, then do not enter such contest, sweepstake or other offering or otherwise provide to us any Personal Information in connection with such contest, sweepstake or other offering. We are not responsible for how our co-sponsors may use your information.

Service Providers

We may use other parties to help operate our website and deliver products and services, and may share your Personal Information with our affiliates, service providers and other third parties that provide products or services for or through this website or for our business (such as website or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf). Unless otherwise stated, these companies do not have any right to use the Personal Information we provide to them beyond what is necessary for them to assist us. When you conduct e-commerce with one of the e-commerce affiliates or service providers to which the website may be linked, certain personal information such as your e-mail and home address may be collected by the service provider's server and made available to us.

1.6 Cookies, Web Beacons, and Other Info Collected Using Technology.
PathsDirect currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, we may use other new and evolving sources of information in the future (together, "Technology Information")

(a) Cookies and IP Addresses. A cookie is a small amount of data stored on the hard drive of the individual's computer that allows us to identify the individual with his or her corresponding data that resides in our database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites. We also keep track of Internet Protocol (IP) addresses. An IP Address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

(b) Web Beacons. A web beacon is programming code that can be used to display an image on a web page (by using an <img src="x"> programming function -- see http://truste.org for more information), but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows us to track certain websites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. In addition to using web beacons on web pages, we also uses web beacons in email messages sent to individuals listed in our database.

(c) New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is our use of new and evolving technology. As a result, we strongly encourage individuals to revisit this policy for any updates regarding its use of technology.

(d) Usage Tracking. We track information related to the electronic mailings and web pages viewed by users and subscribers, as well as the hyperlinks clicked by subscribers, while viewing our emails or visiting our websites.

(e) Log Files. Log files are used to track and monitor subscriber usage.

(f) Optional Registration. We may offer free voluntary registration to potential subscribers. During such registration, the subscriber is required to supply an email address and other personal information. This information is required if the subscriber wants to participate in Company services.

(g) Feedback and Inquiries. You have the ability to contact us to provide us with your feedback. We use this information to respond to you and analyze customer service issues.

1.7 Outside Information.
PathsDirect may receive information about individuals from Third Parties or from other sources of information outside of us including information located in public databases ("Outside Information").

1.8 Individual Information.
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information PathsDirect gathers or receives about individuals.

1.9 No Information Collected from Children.
PathsDirect will never knowingly collect any personal information about children under the age of 18. If we obtain actual knowledge that we have collected personal information about a child under the age of 18, that information will be immediately deleted from our database. Because it does not collect such information, PathsDirect has no such information to use or to disclose to Third Parties. PathsDirect has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA").

1.10 Links to External Websites.
PathsDirect" emails and websites may contain links to external websites. You will be taken to external websites if you click on these links. Your information may be passed from our database to the external website, and/or external database, for your convenience (e.g. your information may be used to pre-fill a form at a destination website). PathsDirect is not responsible for the privacy practices or content of any external website owner. We encourage you to review the privacy policy of any website they visit.

1.11 Website Security.

Information collected through our websites is done via a secure web interface and maintained within a secure operating environment. Our security professionals periodically monitor our web interface and make technology updates to ensure your data is secure. However, no security system, or system of transmitting data over the internet, can be guaranteed to be one hundred percent secure. As a result, while we strive to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the website. As such, you provide all information at your own risk.

2.0 INFORMATION SHARING AND DISCLOSURE
2.1 Discretion to Use Information. PathsDirect MAY USE ANY INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY'S SOLE DISCRETION.

The following paragraphs in Section 2 describe how we currently use Individual Information, but we may change or broaden its use at any time. As noted below, we may update this policy from time to time. PathsDirect may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, SMS text message, online banner advertising, and package stuffers, among other possible uses.

2.2 Loan Products or Service Requests-
If you submit a request for quotes for a loan product or service offered through this website, we will share the personal information contained in your request form (such as your full name, address, telephone number, property location, self-assessed value, and Social Security Number) with lenders, which include banks, mortgage lenders and brokers (collectively, "Lender" or "Lenders") in our client network to process and fulfill your request. In some circumstances, we may obtain additional information about you and/or share that information with Lenders in our network. For example, we may use your Social Security Number to obtain your credit report and credit score to help us better match you with Lenders. In addition, Lenders that receive your personal information may use your Social Security Number to pull your credit report and credit score in order to process and fulfill your request.

All Lenders in our network have entered into agreements with us and are required to comply with federal and state privacy regulations. By submitting your request to us, you understand that Lenders may contact you by telephone, email, or regular mail based on the information you provided to us in order to process and fulfill your request, even if you have opted into the National Do Not Call List administered by the Federal Trade Commission, any state equivalent Do Not Call List, or the Do Not Call List of an internal company. If one of the Lenders contacts you and you wish not to be contacted again by that Lender with respect to your inquiry, then you should specifically make a request to that Lender not to contact you again. Please note that the Lenders may maintain the information you provided whether or not you elect to use their services.

2.3 Vendors - We sometimes disclose the information we collect to companies that operate various services for us such as marketing distribution, advertising, or certain product functionalities. These vendors only have access to personal information needed to perform their functions, and may not share it with others or use it for any other purpose.

2.4 Affiliate Partners - Personal and business information submitted through an "Affiliate Program"

2.5 Subsidiaries, Parent or Sister Companies - We may share personal and demographic information about you with our subsidiaries, parent company, or sister companies.

2.6 As Permitted by Law - We may be required to share your personal information with law enforcement or government agencies in response to subpoenas, court orders, federal/state audits or similar circumstances. We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or as otherwise required by law.

2.7 Business Transfer - As with any other business, it is possible that PathsDirect, LLC in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this privacy pledge unless you consent otherwise.

2.8 Email and Unsubscribe Policy.
PathsDirect uses Individual Information to provide promotional offers by email to individuals. We may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they should follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all our email lists, a person must send an email to info@pathsdirect.com. Our unsubscribe process impacts only the future delivery of electronic mailings disseminated by PathsDirect on its own behalf. You may still receive electronic mailings sent on behalf of Third Parties and your personal information may still be shared with Third Parties for use in offline marketing and data appends, including email appends.

You should also note that unsubscribing from our electronic mailings will not automatically unsubscribe the subscriber’s information from any Third Party associates and licensees of the data. Since Third Party associates and licensee partners maintain separate databases from us, and you will need to unsubscribe from each source individually, if desired. This allows you the freedom to pick and choose which subscriptions to maintain and which to discontinue.

2.9 Targeted Advertising.
PathsDirect uses Individual Information to target advertising to an individual. When an individual is using the Internet, we use Technology Information to associate an individual with that person's Individual Information, and we attempt to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. PathsDirect may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, SMS test message, and other means of communication to provide promotional offers. PathsDirect may also provide SMS text alerts or notification of its services.

2.10 Direct Mail and Telemarketing.
PathsDirect uses Individual Information to advertise, directly or indirectly, to individuals using direct mail

2.11 SMS, Wireless and Other Mobile Offerings.
Some of the services that we provide will result in sending an SMS, wireless or other mobile offering to your cell phone. These should be obvious in the context of the offering at the time you sign up. By signing up, you are agreeing to receive these mobile offerings. You understand that your wireless carrier's standard rates apply to these messages. To unsubscribe or discontinue SMS messages, send "STOP", "END", "QUIT" to the SMS text message you have received. This process impacts only the future delivery of the particular SMS message offering, so you must send that message for each offering. This will not affect offerings sent on behalf of third parties.

2.12 Use of Technology Information.
PathsDirect uses Technology Information (1) to match a person's Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, and (2), to determine which areas of our websites are most frequently visited. This information helps us to better understand the online habits of individuals so that we can target advertising and promotions to them.

2.13 Profiles of Individuals.
PathsDirect uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.

2.14 Storage of Individual Information.
PathsDirect stores the Individual Information in a database on its computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under our control. Not withstanding such measures, we cannot guarantee that its security measures will prevent its computers from being illegally accessed, and the Individual Information on them stolen or altered.

3.0 PRIVACY PRACTICES OF THIRD PARTIES

3.1 Advertiser cookies and web beacons.
Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. PathsDirect does not control Advertisers' use of such technology and has no responsibility for the use of such technology to gather information about individuals.

3.2 Links.
The Websites and email messages sometimes contain hypertext links to the websites of Third Parties. We are not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by Third Parties. Such links are provided for your convenience and reference only. We do not operate or control in any respect any information, software, products or services available on such Third Party websites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.

3.3 Affiliated Companies.
PathsDirect may disclose and transfer Individual Information to entities affiliated with us in our sole discretion.

4.0 UNSUBSCRIBE PROCEDURES

4.1 Unsubscribe Procedures.
Users may unsubscribe from our mailing list at any time. In each email sent, there is an unsubscribe link that allows the recipient to unsubscribe from the specific marketing program by clicking the link provided. We attempt to process all unsubscribe requests in a prompt manner. Users may remove individual's information by sending your request by replying "STOP", "END", "QUIT" to the SMS text message you have received.

To globally unsubscribe from all of our lists, send an email to info@pathsdirect.com. For more information about protecting your privacy, you may wish to visit: www.ftc.gov. If you have questions about this policy, please contact us at: info@pathsdirect.com.