One Real Mortgage Privacy Policy

One Real Mortgage Corp.

You have the right to know how your data is collected, to access and correct your information, to opt out of marketing, and to receive disclosures about our data-sharing practices. We do not sell your personal information.

1. Summary

This Privacy Policy explains how One Real Mortgage Corp. collects, uses, and shares personal data in connection with our digital services.
This Privacy Policy applies to all U.S. consumers who use our mortgage services or visit our website.
Additional state rights appear in the ‘Privacy Rights’ section below.

2. Introduction

This Privacy Policy describes how we collect, use, and disclose Personal Information in connection with our mortgage origination and mortgage brokering services, website, and related digital tools.

One Real Mortgage Corp. (“ORM,” “we,” “our,” or “us”) is a mortgage broker and an affiliate of The Real Brokerage Inc. (NASDAQ: REAX). We respect your privacy and are committed to protecting it through compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from individual consumers, business representatives, and website visitors who visit or use our website located at www.onerealmortgage.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. For purposes of this Privacy Policy, our Website and all related services and functionality that we provide or make available through it, are referred to as our “Digital Services”.

This policy applies to information we collect:

on our Digital Services;
in email, text, and other electronic messages between you and our Digital Services; and
when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by ORM or any third party;
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Digital Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Digital Services. This Privacy Policy may change from time to time (see ‘Changes to Our Privacy Policy’). Your continued use of our Digital Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

3. Age Requirement

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Digital Services. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on or in our Digital Services or on or through any of their features, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please email us at support@onerealmortgage.com or call us at 855-549-7001.

4. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Digital Services (“Personal Information”) to operate, improve, and provide our products and services.

Financial Privacy Notice (GLBA)

We comply with the federal Gramm–Leach–Bliley Act (GLBA) and related Regulation P requirements. Information provided in connection with your mortgage application or loan is collected, used, and shared as permitted by law to process, service, and administer your loan. We do not sell or share your nonpublic personal information except as allowed by law, and we provide an annual privacy notice as required. For details on annual delivery of our GLBA Privacy Notice, see the ‘Annual Privacy Notice’ section below.

California and State Privacy Disclosures

Certain information we collect, such as data obtained in connection with a mortgage application, is subject to the Gramm-Leach-Bliley Act (“GLBA”) and exempt from the California Consumer Privacy Act (“CCPA”). We do not sell Personal Information as defined under the CCPA. However, we provide the following disclosures for transparency.

Pursuant to California Civil Code § 1798.130(a)(5)(B)(i) and similar state laws, ORM has collected and disclosed the following categories of Personal Information in the past 12 months:

• Identifiers such as name, postal address, email address, phone number, online identifier, or IP address;

• Government Identifiers such as driver’s-license, Social Security, or passport number;

• Financial Information such as income, assets, bank-account details, or credit information provided for loan qualification;

• Protected Classification Characteristics such as age, marital status, or similar attributes if voluntarily provided;

• Commercial Information such as records of products or services purchased or considered and transaction data;

• Internet or Network Information such as browsing history or interaction with our websites and apps;

• Geolocation Data such as approximate location derived from device settings;

• Employment Information such as employer name, position, or verification of employment for loan processing; and

• Inferences such as preferences or characteristics derived from other information.

We collect these categories directly from you, from affiliates and service providers, or automatically through our Digital Services, and we use them for the business purposes described in ‘How We Use Your Information.’

Information You Provide to Us

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

The Personal Information we collect includes:

Information that you provide by filling in forms on our Digital Services, including information supplied when registering an account, applying for a mortgage, using or purchasing products or services, or requesting further assistance. We may also ask you for information when you report a problem with our Digital Services;
Records and copies of your correspondence with us, such as your email address, email content, phone number, and recordings or transcriptions of calls.
Your responses to surveys we ask you to complete for research, development, or marketing purposes.
Details of transactions (including electronic-signature transactions), including mortgage applications, closings, or related service transactions, you carry out through our Digital Services and the fulfillment of those orders or services. You may be required to provide financial information before placing an order or requesting certain services.

You also may provide information to be published or displayed (“User Contributions”) on public areas of the Digital Services or transmitted to other users or third parties. User Contributions are posted at your own risk. Although we limit access to certain pages, no security measures are perfect, and we cannot control the actions of other users who may view or share your content.

When you apply for a mortgage or request loan information, we may collect additional data such as income, assets, employment information, bank account information, property address, credit and transaction history, and government-issued identification numbers as required by law.

Information We Collect Automatically

When you use our Digital Services, we automatically collect information about your device, browsing activity, and usage patterns through cookies, analytics tools, and similar technologies.

As you navigate through and interact with our Digital Services, we may use automatic data-collection technologies to gather information about your equipment, browsing actions, and patterns, such as:

Usage Details. Traffic data, location, logs, referring/exit pages, date and time of your visit or use, error information, clickstream data, and the resources you access and use.
Device Information. Details about your computer, mobile device, and Internet connection, including IP address, operating system, and browser type.
Location Data. Information about your location collected through geolocation technology.

This automatically collected information helps us improve our Digital Services and deliver a more personalized experience by enabling us to:

Estimate audience size and usage patterns;
Improve our product and service offerings;
Store information about your preferences to customize the Digital Services; and
Recognize you when you return to the Digital Services.

Technologies We Use.

Cookies (or browser cookies). We and our service providers use cookies, web beacons, and similar technologies to receive and store certain information whenever you interact with our Digital Services through your computer or mobile device. You may refuse cookies through your browser or device settings, but some features may not function properly if you do so.
Pixels and Web Beacons. Pages on our Digital Services or our emails may contain small electronic files (clear GIFs, pixel tags, or single-pixel GIFs) that allow us to, for example, count users who have visited a page or opened an email and verify system and server integrity.
Google Analytics. We use Google Analytics, a web-analytics service provided by Google Inc., to help us analyze site usage and improve performance. You can learn more about how Google uses data at www.google.com/policies/privacy/partners/
Sonar. We use Sonar, a software as a service for loan origination, by Simplist Technologies, Inc.

5. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

To provide and operate our Digital Services (including our Website) and their functionality, content, and services;
To provide you with information, products, or services that you request from us or that may be of interest to you;
To process, fulfill, support, and administer transactions and orders for products and services you purchase or use;
To evaluate, underwrite, and process mortgage applications, verify identity and employment, determine credit eligibility, and service or administer loans;
To communicate loan-status updates and coordinate with your real-estate agent, brokerage, title, or escrow company;
To satisfy legal and regulatory obligations applicable to mortgage lenders and brokers.
To personalize your experience with our Digital Services and to deliver content and product offerings relevant to your interests;
To market our products and services and to determine your eligibility for those products and services;
To provide personalized and interest-based advertising;
To provide notices about your account and respond to your inquiries or requests;
To carry out our obligations and enforce our rights under contracts between you and us (including for billing, collection, or enforcement of our financial partners’ rights under cardholder agreements);
To notify you about changes to our Digital Services or products;
To facilitate communications using automated systems. ORM may use automated systems, including artificial intelligence tools, to facilitate certain customer communications. These tools do not make lending or eligibility determinations and are used solely to support communications or customer-service functions.
To develop and improve our products, services, including by testing and monitoring performance and analyzing business operations;
To fulfill any other purpose for which you provide the information;
In any other way we describe when you provide the information;
For any other purpose with your consent; and
To contact you about goods and services that may be of interest to you, including through newsletters.

If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see ‘Choices About How We Use and Disclose Your Information.’

6. Disclosure of Your Information

Disclosure to Affiliates, Service Providers and Vendors

We disclose information to our affiliates, contractors, service providers, and other third parties we use to support our business. These third parties are bound by contractual obligations to keep Personal Information confidential and to use it only for the purposes for which we disclose it.

Affiliate Coordination. We may share limited and generic information about your loan status — such as “application received,” “processing,” “underwriting,” or “clear to close” with your real-estate agent or brokerage affiliates solely to coordinate your transaction. This information does not include your credit history, credit score, payment history, or any reason for loan approval or denial. We may also share address-only property information with affiliated entities for business coordination or marketing purposes, without including any client-identifying details.

Disclosure for Legal and Compliance Purposes

We may disclose Personal Information to:

Comply with any court order, law, or legal process, including to respond to lawful government or regulatory requests;
Enforce or apply our Terms of Use or other agreements; and
Protect the rights, property, or safety of ORM, our customers, or others.

Corporate Transactions

We may disclose Personal Information in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ORM about our Digital Services users is among the assets transferred.

Aggregate or De-Identified Information

We may disclose aggregated or de-identified information that does not identify any individual for research, analytics, or marketing purposes.

Mortgage Application and Loan Information

In connection with your mortgage application and loan servicing, we collect and disclose Personal Information to verify eligibility, underwrite and fund loans, and comply with banking, mortgage, and consumer-finance laws. We may share this information with credit bureaus, title and escrow companies, government agencies, financial partners involved in funding or servicing your loan, and other parties as required by law.

Equal Credit Opportunity.

ORM complies with the Equal Credit Opportunity Act (ECOA) and does not discriminate against any applicant on a prohibited basis. Information regarding marital status, income, or demographic data is collected only as required by law for regulatory monitoring purposes.

Fair Credit Reporting Act (FCRA) Disclosure

We may obtain and share consumer reports or credit information with credit bureaus and other financial institutions for purposes of evaluating, originating, or servicing your mortgage. You have the right to dispute inaccurate information appearing on your credit report by contacting the credit reporting agency directly.

Servicing Transfers

If your loan is sold or servicing is transferred, we may disclose your loan and contact information to the new servicer as permitted by law to ensure continuity of your account and communications.

7. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:

Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Digital Services may then be inaccessible or not function properly.
Promotional Offers from ORM. If you do not wish to have your email address used by ORM to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to ORM as a result of a product purchase, or your use of our services.
Disclosure of Your Information to Affiliates and Third Parties. If you wish to unsubscribe from affiliates and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them. If you wish to opt-out of such sharing, please change your preferences in your Account Preferences page or email us support@onerealmortgage.com
Interest-Based Targeted Advertising.
We may use your Personal Information to provide interest-based advertisements from us and that are customized to your particular preferences, including for companies that are not affiliated with us. We partner with third party advertising networks that collect IP addresses, unique device identifiers, browser type, operating system, time zone, country, referring pages, and other information through the use of cookies, pixel tags, and server logs on our Digital Services. They use this information to provide you with interest-based advertisements that are customized to your particular preferences, including for companies that are not affiliated with us.
You may see these interest-based advertisements on our Digital Services, as well as on third party websites and apps, and across different devices you use. We may use this process to help us manage and improve the effectiveness of our marketing efforts. It also allows us to display ads to our users about ORM after they leave our Digital Services, and to track users after they see or click on an advertisement, keep track of users who access our Digital Services or advertisements from different devices, and better provide advertisements to our target audiences. The data collected through these tracking technologies is also saved and processed by our advertising and marketing service provider partners.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
Communications Compliance. All marketing and text messages comply with the CAN-SPAM Act and the Telephone Consumer Protection Act (TCPA). You may opt out of receiving marketing communications at any time, and opting out will not affect transactional or legally required messages related to your loan.

8. Your Rights and Choices Regarding Your Information and Accessing and Correcting Your Information

You may contact us to access, delete, or change your Personal Information. You may also be able to review, delete, and change your Personal Information by logging into the Digital Service and visiting your Account Preferences page. However, please note that we may retain records of your information for legal, compliance and audit purposes, even after your information has been deleted from or changed in your account.

You can Contact Us to access and/or find out what information we have about you, and to correct that information. You can also review and change your Personal Information by logging into our Digital Services and visiting either the Settings or Account Preferences sections of our Digital Services. You may also notify us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We may not be able to delete some of your Personal Information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Messages. If you do not wish to have your email address used by ORM to send you advertising messages and content, you can opt out at any time by clicking the unsubscribe link at the bottom of any marketing emails you receive from us. You may have other options with respect to marketing and communication preferences through our Digital Services.

9. Do Not Track Signals

We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

10. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. You can help protect your Personal Information and other information by keeping your password to our Digital Services confidential.

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology, including TLS (Transport Layer Security) encryption for information transmitted over the Internet, and maintain industry-standard safeguards to protect data stored on our systems (“data at rest”).

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Digital Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to, on or through our Digital Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, or in your operating system.

11. Privacy Rights in California and Certain Other US States

In addition to the disclosures and rights set forth elsewhere in this Policy, you and other users may have certain rights based on applicable U.S. state law, for example, the California Consumer Privacy Act, as updated by the California Privacy Rights Act (CCPA). Other states have passed consumer privacy laws that may be applicable to ORM and your use of this Site. These supplemental disclosures and rights apply to you and your use of our Digital Services to the extent applicable U.S. state law applies to ORM and your use of our Digital Services. Please contact us if you have any questions regarding your rights under applicable state law.

Nevada Residents: You may be placed on our internal “do not call” list by emailing support@onerealmortgage.com or calling 855-549-7001.
Vermont Residents: We do not disclose your nonpublic personal information to nonaffiliated third parties, except as permitted by law.
California Residents: Information collected for mortgage or financial services is covered by federal financial privacy laws (GLBA) and not the California Consumer Privacy Act.

Categories of Sources from which ORM has collected Personal Information
As described in more detail elsewhere in this Policy, we collect Personal Information directly from you, for example when you provide it to us, when you contact us through our Digital Services, when you create an ORM account; and indirectly from you automatically through your computer or device as you use our Digital Services. We may also collect Personal Information about you from our advertising partners and service providers.

Use of Personal Information
We may use or disclose the personal information we collect for our business purposes described elsewhere in this Privacy Policy (for example, please refer to ‘How We Use Your Information’ and ‘Disclosure of Your Information’).

Disclosures of Personal Information for Business Purposes
As described in more detail elsewhere in this Policy, we may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising. Please refer to ‘Information We Collect About You and How We Collect It’ for additional information and details.

We disclose your Personal Information to certain third parties such as our vendors, business partners, service providers, including companies that assist us with marketing and advertising. For additional information please refer to ‘How We Use Your Information’ and ‘Disclosure of Your Information’).

Access Request Rights
You may have the right to request that ORM disclose certain information to you about our collection and use of your Personal Information for the above business and commercial purposes. To submit an access request, see ‘Exercising Access and Deletion Rights’. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you.
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

sales, identifying the Personal Information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights
You may have the right to request that ORM delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.

Correction Request Rights
You may have the right to ask us to correct Personal Information that is inaccurate or out of date. You may also be able to review and change your Personal Information by logging into the Digital Services and visiting your Account Preferences page.

Right to Opt Out of Selling or Sharing Personal Information for Targeted Advertising
As explained in the Interest-Based Targeted Advertising section above, we may share Personal Information with advertising partners that display targeted advertisements to users around the web, including through the use of cookies and other similar technologies on our Websites. This may qualify as a “sale” or “share” of Personal Information under applicable privacy laws. You can opt out of sharing for these purposes by clicking Your Privacy Choices on the footer of our website or contacting us as described below.

Exporting Data
If you need to export or obtain a copy of your data, please let us know and we will assist you with your request. We retain the data we collect for different periods of time depending on what it is, how we use it and applicable legal requirements. We may retain some data for longer periods of time than other data when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.

Data Retention
Mortgage records, including application and loan information, are retained for at least seven (7) years or longer as required by federal and state law, including recordkeeping obligations under the Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA), and GLBA. We may retain some Personal Information longer as required by federal and state mortgage and consumer-finance laws, including under the Equal Credit Opportunity Act (ECOA) and Fair Credit Reporting Act (FCRA).

Exercising Access, Correction, and Deletion Rights
To exercise the access, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 855-549-7001.
Emailing us at support@onerealmortgage.com.

Only you, or your legal representative authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information, including requests to access your Personal Information. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note that applicable law limits your rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

Non-Discrimination
We will not discriminate against you for exercising any of your rights under applicable U.S. state law. Unless permitted by applicable law, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

12. Job Applicants

If you apply for employment with ORM, we collect and process the information you provide in connection with your application.

This may include your name, contact information, resume or curriculum vitae, employment and education history, qualifications, and any other information you choose to submit.

We use applicant data to:

Evaluate and manage applications and recruiting processes;
Conduct background checks or other due diligence as permitted by law;
Communicate with you about potential employment; and
Comply with applicable legal and regulatory obligations.

We may share applicant data with affiliates, service providers, or partners assisting in recruitment, and with authorities where required by law.
Applicant information is retained only as long as necessary for hiring and legal compliance purposes.

Text Messaging for Recruiting. If you provide your mobile number as part of your application, we or our recruiting service providers may send you SMS or text messages related to your application or scheduling interviews. By providing your number, you consent to receive such text messages. Message frequency will vary based on the hiring process. You can opt out at any time by replying STOP to any message. Your consent to receive texts is not a condition of applying for or obtaining employment. Message and data rates may apply.

International Users (Outside of the United States)

Our Website is intended for use by residents in the United States. Our Website is not intended for use by and is not directed to residents of the European Union. All data is stored and processed in the United States. By using and accessing our site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Changes to This Privacy Policy

We may change this Privacy Policy at any time. When we do, we will post the updated version on our Website with the date of last revision at the top of the page and, if the changes are material, notify you by email or a notice on our Website’s home page.

Annual Privacy Notice

In accordance with the Gramm–Leach–Bliley Act (GLBA) and Regulation P, ORM provides a privacy notice to customers at the time a loan application is submitted and annually thereafter for as long as the customer relationship continues.

Our annual privacy notice explains how we collect, use, and share nonpublic personal information, and how you can limit certain types of sharing. You can access our most recent GLBA Privacy Notice at [www.onerealmortgage.com/privacy-notice] or request a printed copy by emailing support@onerealmortgage.com or calling 855-549-7001.

Contact Information
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the ‘Contact Us’ page on or in our Digital Services.

How to Contact Us:

Telephone: 855-549-7001
Email: support@onerealmortgage.com

Address: One Real Mortgage Corp., 485 Route 1 South, Building E, Suite 250, Iselin, NJ 08830

Accessibility and Complaints
We are committed to ensuring that our privacy practices are accessible and understandable. If you need this Privacy Policy in an alternative format or wish to raise a concern about how your information has been handled, please contact us at support@onerealmortgage.com or by phone at 855-549-7001.