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TrueOwn Loan Officer Privacy Policy

Effective April 17, 2026 · Last updated April 17, 2026

The short version.

  • This policy covers how we handle your personal data as a loan officer using the LO Portal — your account, your profile, your billing, and your usage.
  • It does not cover Client Data you upload. That is governed by a separate Data Processing Addendum ("DPA"), where TrueOwn acts as a service provider/processor on your behalf.
  • We use your data to run the LO Portal, process your subscription, communicate with you, keep the platform secure, and comply with the law.
  • We don't sell your data. We use your data for marketing only if you opt in.

Questions: privacy@trueown.com.

This Privacy Policy applies to mortgage professionals (loan officers, processors, brokers, and branch managers, collectively "LOs" or "you") using lo.trueown.com.

If you are a homeowner, see the Homeowner Privacy Policy.

For how TrueOwn handles Client Data you upload (names, emails, property addresses, loan details about your clients), see the Data Processing Addendum, which governs TrueOwn's role as your service provider/processor for that data.

This Privacy Policy explains how TrueOwn ("we," "us") collects, uses, shares, and protects your personal information as a loan officer when you use the TrueOwn LO Portal.

1. What We Collect About You

1.1 Account and Profile Information You Provide

  • Name, work email address, work phone number
  • Company or sponsoring lender
  • NMLS ID and license state(s)
  • Job title and photo (if you upload one)
  • Authentication credentials (password, MFA device)
  • Marketing and communication preferences

1.2 Billing and Subscription Information

  • Subscription tier, billing cycle, renewal status
  • Billing name and address
  • Payment method metadata (we use Stripe for payment processing; Stripe stores full card details and shares only the information we need to manage your subscription, such as last four digits, expiration, and billing events)
  • Invoices, receipts, refund records

1.3 Information Collected Automatically

  • Device type, browser, operating system, IP address
  • Pages viewed in the LO Portal, features used, timestamps
  • Click-through activity on TrueOwn-branded content
  • Referring URL
  • Cookies and similar technologies (see Section 7)

1.4 Information From Third Parties

  • NMLS Consumer Access — we may verify your license status using NMLS's public-facing records.
  • Email and SMS service providers — delivery, bounce, open, and click events for messages we send to you.
  • Analytics and error-monitoring vendors — aggregated and individual event data about your use of the LO Portal.

1.5 What We Don't Collect About You

  • We do not collect your Social Security number.
  • We do not pull your consumer credit report.
  • We do not collect information about your personal mortgage or financial accounts (unless you separately sign up as a homeowner, which is a different account).

2. How We Use Your Information

Operate the LO Portal:

  • Authenticate you and maintain your session
  • Provision your account and enforce subscription tier limits
  • Display your profile on communications sent to your clients (as authorized under the LO Terms)
  • Process subscription payments and send billing communications
  • Provide customer support

Communicate with you:

  • Service communications (always — account status, billing, security, policy changes)
  • Product updates (where permitted by your preferences)
  • Marketing communications only if you have opted in
  • Respond to your inquiries

Keep the platform safe:

  • Detect fraud, abuse, and suspicious activity
  • Enforce the LO Terms and the DPA
  • Maintain our information security program under GLBA and applicable state laws

Comply with the law:

  • Maintain records required by federal and state laws
  • Verify your NMLS license status
  • Respond to lawful requests from government agencies
  • Enforce our agreements and protect our rights

Improve the LO Portal:

  • Analyze usage patterns in aggregated or de-identified form to improve features
  • Test and debug

2.1 What We Won't Do

  • We will not sell your personal information.
  • We will not share your personal information with other LOs, your sponsoring lender, or any third party for marketing purposes without your consent.
  • We will not use your personal information to create or update consumer reports or credit files.

3. How We Share Your Information

3.1 Service Providers

We share your information with vendors that help us run the LO Portal, under written agreements requiring them to protect the information and use it only as we authorize. Current categories:

  • Cloud infrastructure: Cloudflare, Supabase
  • Payments: Stripe
  • Email: Resend
  • Analytics and error monitoring: product analytics and error monitoring vendors
  • Support tooling: customer support platform
  • Identity verification: NMLS Consumer Access (public records)

3.2 Communications to Your Clients

When we send LO-branded communications to your clients on your behalf, those communications display your name, NMLS ID, and contact information. Your clients see those details as part of the message. This is the purpose of the LO Portal and is authorized by you under the LO Terms.

3.3 Legal and Safety

We may disclose your information if required by law, subpoena, court order, or to protect the rights, property, or safety of TrueOwn, our users, or others.

3.4 Business Transfers

If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred. We will notify you of any change in the controller of your personal information.

3.5 With Your Consent

We may share with third parties when you specifically ask us to (for example, if you integrate a third-party CRM).

4. How Long We Keep Information

  • LO account and profile data: while your account is active, plus up to 3 years after closure for legal and business purposes.
  • Billing records: retained for at least 7 years as required by tax, accounting, and audit rules.
  • Communications you sent through TrueOwn and copies of LO-branded messages: retained for at least 24 months after last use to support MAP Rule (12 CFR Part 1014) recordkeeping for mortgage advertising, and for at least 3 years overall.
  • Support communications: retained for at least 3 years.
  • Consent and activity logs: retained for at least 7 years for legal evidence and regulatory examination.
  • Analytics and error logs: retained for up to 24 months, typically in de-identified form.
  • NMLS verification records: retained for the duration of your account plus 3 years.

Where the law requires longer retention, we follow the law.

5. Your Rights and Choices

  • Access and correction: You can view and update most profile data in your LO Portal settings. For anything else, email privacy@trueown.com.
  • Deletion: You can close your account and request deletion of your personal data by emailing privacy@trueown.com. We will delete data that is not subject to legal retention requirements (for example, we must retain billing and consent records as described in Section 4).
  • Export: You can request a copy of your account data.
  • Opt out of marketing: Use the unsubscribe link in any marketing email, change your preferences in settings, or email privacy@trueown.com. Service communications (account, billing, security) cannot be opted out of while your account is active.
  • SMS: We do not send SMS messages to LOs without your prior express written consent. You can revoke at any time by replying STOP or emailing privacy@trueown.com.

5.1 State Privacy Rights

If you are a Florida, California, Virginia, Colorado, Connecticut, Texas, Oregon, Utah, or other state resident with applicable privacy rights, you may have additional rights including access, correction, deletion, portability, opt-out of targeted advertising, opt-out of sale/share, and opt-out of profiling with legal/significant effects. TrueOwn does not sell personal information and does not use it for targeted advertising. To exercise any right, email privacy@trueown.com.

5.2 Automated Decision-Making

We do not use solely automated decision-making with legal or similarly significant effects on you. If this changes, we will update this Policy and provide notice.

6. How We Protect Your Information

We apply the same GLBA Safeguards Rule program and security controls described in our homeowner-facing security disclosures:

  • TLS 1.2+ in transit; at-rest encryption via our cloud providers
  • Access controls with MFA for administrative access
  • Audit logs reviewed regularly
  • Written data protection agreements with vendors
  • Written incident response plan with regulator and user notification obligations
  • Security training for personnel

Report suspected account compromise immediately to security@trueown.com.

7. Cookies and Similar Technologies

We use cookies to:

  • Keep you signed in and maintain session state
  • Remember your preferences
  • Measure usage and performance of the LO Portal

You can control cookies through your browser settings. We do not use cookies for cross-site behavioral advertising. We honor Global Privacy Control (GPC) signals where applicable.

8. International Users

TrueOwn is operated in the United States and is available only to LOs licensed in U.S. states. If you access the LO Portal from outside the U.S., your information will be transferred to and processed in the U.S.

9. Children

The LO Portal is not intended for anyone under 18. We do not knowingly collect information from anyone under 18.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or in-product notice at least 30 days before the change takes effect.

11. Contact Us

TrueOwn

This Policy covers only data about you as an LO user of TrueOwn. For Client Data you upload about homeowners, see the Data Processing Addendum, which governs TrueOwn's role as your service provider/processor for that data.