Privacy Policy

Last updated: March 13, 2025

We take our clients’ privacy very seriously. We understand that your privacy is important. This Privacy Policy describes how we collect and use the personal information that we collect about you on www.trovy.com and the Trovy mobile application (the “Site”).

By continuing to use the Site, you agree to this Privacy Policy and the collection, use, disclosure, and storage of your personal information as described by this Privacy Policy.

If you are a Trovy consumer or customer and applied for or obtained a financial product or service with Trovy, read our Consumer Privacy Notice to learn how we collect, use, protect and share your personal information covered by the Gramm-Leach-Bliley Act (“GLBA”) and the privacy options available to you.

1. Information We Collect

When you use the Site, we and/or our subsidiaries (collectively referred to herein as “we”, “us” or “our”) may collect personal information about you, such as your name, address, Social Security number, telephone number, email address, asset information, income information, or any other information that you submit on applications or other forms made available through the Site.

We may also collect personal information about you from third party sources, which we may combine with information that you provided to us or we previously collected. For example, we may receive information from a social media service about you if you use a social media account to log into the Site.

We also automatically collect certain information related to you and your activities on the Site when you visit the Site. This information includes information such as your IP address, your internet browser and operating system type, the date and time of your visit, and the website that referred you to us.

2. Cookies and Other Tracking Technologies

Our Site uses the following technologies to facilitate the automatic data collection described above:

• 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 we place on our websites and app for social media, advertising, analytics companies, and other service providers.
• Logical 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.
• Pixels or web beacons, also known as pixel tags or clear GIFs, enable collection, storage, and sometimes sharing of your information and/or your actions taken, such as whether you accessed or opened a webpage or email or that you viewed or clicked certain content. Certain pixels include computer-code snippets that enable the collection and sharing of information back to web servers of third parties.
• Session Replay Technologies. Trovy will capture your use of the Site and may record your use. We use third-party services that employ software code to record users’ interactions with the Website in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. We may use the Cookies and similar technologies for the following purposes:
• Technical operation. To allow the technical operation of our Services, such as by remembering your selections and preferences as you navigate our websites and app.
• Functionality. To enhance the performance and functionality of our Services.
• Advertising. To help our third-party marketing providers collect information about how you use our Services over time to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions 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?hl=en.

Cookie Opt-outs. You can disable cookies via most browsers. This may affect site functionality. To opt out of cookies on our site, click the “Your Privacy Options” link in the footer of our website, click “cookie choices” and select your preference.

3. How We Use Collected Information

We use personal information and anonymous information for the following purposes:

• To complete and fulfill your loan application;
• To respond to and fulfill your requests;
• For our marketing efforts, such as to send you marketing communications that we believe may be of interest to you;
• For our business purposes, such as for analysis and to develop new products and services;
• To improve the Site and for analytics purposes; or
• For any other purpose to which you consent.

The Fair Credit Reporting Act gives you the opportunity to limit the sharing of “non-experience information” among our affiliates. “Non-experience information” includes information that is used, expected to be used, or collected for the purpose of establishing your eligibility for consumer credit, insurance or deposit accounts, and is not related solely to your transactions or other experiences with us, including information:

• From your applications, such as your income or marital status
• From a credit report, such as your credit history
• From sources used to verify representations made by you, such as your open lines of credit or employment history
• Within our family of companies, we may share the customer information we collect with:
• Our subsidiary and affiliated businesses, providing financial and other services such as:
• Residential mortgage products
• Insurance and real estate brokerage
• Home security products
• Residential homebuilding

4. How We Share Personal Information

We will only share personal information with third parties as described in this Privacy Policy. We may share personal information with third parties, such as:

• Vendors who provide credit, title, identity verification or other necessary services;
• Trovy Technologies, Inc. affiliated businesses that provide quality services or products you may be interested in (unless you’ve opted out);
• Other partners with which we have marketing arrangements or to others that may want to provide information to you about the products and services that they offer (unless you’ve opted out);
• For any purpose to which you expressly consent;
• To protect our rights or the rights or safety of others; and
• As may be required by law or regulation.

Please note, we do not share SMS text opt-in data with any third parties.

We limit the information that we send service providers, and require that our service providers only use shared personal information to perform the services requested in accordance with this Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

For example, after you authorize us to verify your credit history, we send the minimal set of information needed (potentially including your social security number) to ensure we are requesting the correct record in an encrypted form to the relevant credit bureaus with the sole purpose of retrieving your credit report and associated credit history data. We would not send the same level of information to a service provider where it is not essential to perform their services.

For retrieving bank information, we use Finicity as a third-party service provider. Their privacy policy is available here.

In the event that we enter into a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), personal information that we have collected may be transferred in the course of that corporate transaction to the relevant third party purchaser, joint venture partner, merged entity, assignee or similar party.

5. Access to and Control Over Information

You may opt-out of any future marketing contacts from us at any time. You can do the following by contacting us at 1-833-987-6890 or by sending an email to privacy@trovy.com:

• See what data we have about you, if any;
• Change/correct any data we have about you;
• Delete any information about you that we are not required by law to keep; and
• Express any concern you have about our use of your data.

6. How We Protect Personal Information

We use reasonable physical, technical, and administrative security measures to protect personal information we collect from loss, misuse, unauthorized access, or improper disclosure. For example, we use encryption technologies when transmitting information to and from the Site and with our third-party service providers. Please understand that no security technology is completely secure, and remember that when communicating with us, email is not a secure form of communication when transmitting sensitive or personal information.

7. Links to Other Sites

The Site may contain links to third-party websites, such as social media websites. This Privacy Policy is only applicable to this Site, and we have no control of these third-party websites’ information practices. Please be sure to review these third-party websites’ privacy policies before visiting these third-party websites.

8. Children’s Privacy

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from an individual under age 18. If you are under the age of 18, please do not submit any personal information through the Site, app, or service. If you have reason to believe that we may have accidentally received personal information from an individual under age 18, please contact us immediately at 1-833-987-6890.

We do not knowingly collect, sell, or share the personal information of children under the age of 16.

9. Updates to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we do, we will let you know by appropriate means such as by posting the revised Privacy Policy on our website with a new “Last Updated” date. Any changes to this Privacy Policy will become effective when posted unless indicated otherwise. Your continued use of the Site after these updates are posted represents your consent to the terms of the new Privacy Policy. Please regularly check this Privacy Policy for any such updates.

10. California Privacy Rights

California residents may have rights under the California Consumer Privacy Act (“CCPA”) as described in our California Consumer Privacy Act Disclosure. Trovy’s Privacy Policy, Terms of Service, and Consumer Privacy Notice should be read in conjunction with the California Consumer Privacy Act Disclosure.

11. Your Nevada Privacy Rights

Senate Bill No. 220 (May 29, 2019) amends Chapter 603A of the Nevada Revised Statutes to permit a Nevada consumer to direct an operator of an Internet Website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by calling us at 1-833-987-6890

We will provide further information about how we verify the authenticity of the request and your identity.

12. Contacting Us

If you have any questions, you can contact us at 1-833-987-6890 or privacy@trovy.com