Privacy Policy

0. Summary & Effective Dates

Effective Date: September 26, 2025  |  Last Updated: September 26, 2025

GoRealo® is a registered trademark and DBA of Consumer Credit Services, LLC, the licensed mortgage broker providing all loan services under our licenses (NMLS ID #1070755) through this application.

This Privacy Policy describes how Consumer Credit Services, LLC (“Company,” “we,” “our,” or “us”), operating under the GoRealo® brand, collects, uses, discloses, and protects your personal information when you use our websites, mobile applications, and related services (collectively, the “Services”). This Policy serves as our notice at collection under CCPA/CPRA. See our Terms of Use for related user agreements, including prohibited activities and consents.

This Policy is provided in clear, plain language and is reasonably accessible to consumers with disabilities (e.g., screen-reader compatible). By accessing or using our Services, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of our Services.

1. Scope of This Policy

This Privacy Policy applies to all users of our Services, including:

• Borrowers who apply for a loan through our website.
• Licensed real estate agents who use our mobile applications to submit client leads or property listings.

For mobile application users, we collect only limited information such as name, email, phone number, estimated credit score, estimated annual income, and estimated monthly debts. We do not collect sensitive personal information (such as Social Security numbers or full credit reports) through the mobile application.

2. Information We Collect

We may collect the following categories of information:

• A. Identifiers – Name, address, email, phone number, date of birth, Social Security number, driver’s license or government-issued ID number.
• B. Financial & Transactional Information (borrowers only) – Income, employment history, credit reports, bank account numbers, loan application details, payment history, tax returns, and property-related documents.
• C. Commercial Information – Loan products or services you inquired about or purchased, referral source, and transaction history.
• D. Property Information – Address, purchase agreements, appraisal details, title reports, and related documentation.
• E. Internet/Technical Data – IP address, browser type, device type, operating system, mobile device identifiers, and usage activity on our Services.
• F. Geolocation Data (if enabled) – Approximate or precise location to provide location-based services. You can revoke location consent via device settings or our contact methods.
• G. Audio/Visual Data – Call recordings for quality assurance, uploaded documents, and property photos.
• H. Inferences – Information derived from your data to assess eligibility for loan products.

3. How We Use Your Information

We use your personal information for:

• Processing and evaluating loan applications.
• Facilitating lead submissions from real estate agents.
• Communicating about your loan request, account, or transactions.
• Verifying your identity and preventing fraud.
• Complying with legal and regulatory obligations (GLBA, FCRA, etc.).
• Sharing with service providers necessary for loan processing.
• Providing customer service and responding to inquiries.
• Improving and personalizing our Services.
• Conducting analytics and internal business operations.
• Retrieving and displaying customer reviews from Google My Business for participating real estate agents.

3.5. Legal Basis for Processing

We process your personal data based on the following legal bases under GDPR:

• Contract: To process loan applications and provide Services (e.g., fulfilling your request for loan matching).
• Consent: For sharing with referring agents or communications (revocable as described).
• Legitimate Interests: For fraud prevention, analytics, and service improvement, balanced against your rights.
• Legal Obligation: For compliance with laws like GLBA/FCRA.

Providing data is necessary for contractual purposes; failure to provide it may prevent loan processing.

4. How We Share Your Information

For purposes of California law, we do not “sell” personal information as that term is defined under the CCPA/CPRA, except in cases where you have provided explicit verbal authorization. We do not repurpose or sell data for advertising without further consent.

A. If You Were NOT Referred by a Real Estate Agent

We do not share your personal information for marketing purposes without your consent. We share your information only as necessary to complete your loan request, including with:

• Licensed mortgage loan originators and lenders
• Underwriters and loan processors
• Title and escrow companies
• Real estate appraisers
• Homeowners insurance companies
• Closing agents and other settlement service providers

B. If You Were Referred by a Real Estate Agent

If you were referred to us by a licensed real estate agent, you consent to our sharing of limited loan status updates with your referring agent, such as:

• Loan application received
• Pre-approval or approval status
• Anticipated closing date

We will not share your financial details (credit score, income, account numbers) with the referring agent unless you provide explicit written consent. You may revoke this consent at any time by contacting us at legal@gorealo.com or (904) 717-3060.

5. Agent Data Handling

If you are a licensed real estate agent using our Services, any property listings, images, MLS data, customer reviews, or other information you submit will be processed and stored in accordance with this Privacy Policy. You are responsible for ensuring you have the legal right to submit any such data, including compliance with the rules, regulations, and policies of your local Multiple Listing Service (“MLS”) authority. We process Google My Business reviews and other customer feedback submitted by agents solely for the purpose of displaying them to prospective clients.

6. Data Provided by Third Parties

If a real estate agent or other third party provides us with your personal information, we will treat it in accordance with this Privacy Policy. Categories of data obtained indirectly include identifiers and commercial information from referrals.

7. Accuracy of User-Submitted Content

We do not verify, endorse, or guarantee the accuracy of any content submitted by users, including borrowers, real estate agents, or third parties. You are solely responsible for ensuring that any information you provide is accurate, complete, and lawful. Loan decisions are not guaranteed; see our Terms of Use.

8. Your Privacy Rights

Depending on your location, you may have the right to:

• Access (Right to Know) – Request the categories and specific pieces of personal information we have about you.
• Correction – Request that we correct inaccurate personal information.
• Deletion (Erasure) – Request that we delete personal information, subject to legal retention obligations.
• Restriction – Request restriction of processing in certain cases (e.g., while accuracy is verified).
• Portability – Receive your data in a structured, commonly used, machine-readable format.
• Object – Object to processing based on legitimate interests or for direct marketing.
• Withdraw Consent – Withdraw consent at any time where processing is based on consent (no effect on prior lawful processing).
• Opt-Out of Sale/Sharing – Direct us not to sell or share your personal information (via Global Privacy Control or our opt-out link).
• Limit Use of Sensitive Information – Restrict use of Social Security number, financial data, or precise geolocation to necessary purposes.
• Non-Discrimination – We will not discriminate against you for exercising any CCPA rights (e.g., no denial of services or price increases).

You can exercise these rights via in-app settings (where available) or by contacting us at legal@gorealo.com or (904) 717-3060. Requests are processed within 30 days, except where law requires retention or longer verification (up to 45 days with notice). We do not engage in automated decision-making or profiling that produces legal effects.

You have the right to lodge a complaint with your local supervisory authority (e.g., in the EU, find yours at https://ec.europa.eu/newsroom/dae/items/659626); for CCPA, contact the California Privacy Protection Agency at cppa.ca.gov.

9. Consent to Communications

By providing your contact information, you consent to receive communications from us via phone, text message, and email for the purposes of responding to your inquiries, processing your loan application, or following up on leads you submit. Standard message and data rates may apply. You may opt out of marketing communications at any time via unsubscribe links, in-app settings, or by contacting us.

10. GLBA & FTC Safeguards Compliance

We comply with the Gramm-Leach-Bliley Act (GLBA) and the FTC Safeguards Rule by:

• Limiting access to personal information to authorized personnel.
• Requiring service providers to protect your information.
• Implementing administrative, technical, and physical security measures.

11. CCPA/CPRA Disclosures (California Residents)

In the past 12 months, we have collected the categories of personal information described in Section 2 from the following sources:

• Directly from you: Identifiers, financial/transactional, commercial, property, audio/visual, geolocation (if enabled).
• Indirectly from you: Internet/technical data, inferences via analytics tools (e.g., Google Analytics).
• From third parties: Identifiers and commercial information from referring agents or service providers (e.g., credit bureaus for reports).

We have disclosed (shared for business purposes) the following categories to the recipients listed in Section 4 (e.g., lenders, underwriters): Identifiers, financial/transactional, commercial, property, and inferences. We have not sold personal information for monetary consideration without your verbal authorization. No categories were shared for cross-context behavioral advertising.

Purposes for collection/disclosure include those in Section 3 (e.g., loan processing, fraud prevention). We have not sold your personal information for monetary consideration without your verbal authorization.

12. Mobile App Analytics and Third-Party Services

We may use third-party analytics tools, including Google Analytics and Firebase, to collect information about your device, app usage, and performance.

If you enable features such as push notifications, location services, or image uploads, we may use third-party providers to deliver these services.

We also use the Google My Business API to allow real estate agents to retrieve and display customer reviews directly within our Services.

A current list of third-party SDKs and APIs used in our mobile applications is available upon request. These providers are contractually bound to protect your information and may only use it for the purpose of providing the contracted service at least as strong as our protections.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies (including local storage and device identifiers) to enhance your experience, improve our Services, and analyze performance. These may be set by us or by third-party providers such as:

• Google Analytics – to measure traffic, app usage, and performance.
• Firebase – to monitor app stability, improve features, and collect crash data.
• Google My Business API – to retrieve and display customer reviews; may store limited technical data for feature functionality.

Cookies and tracking technologies may collect information such as your IP address, device type, browser type, usage patterns, and location (if enabled).

You can manage or disable cookies through your browser or device settings. Disabling cookies may limit certain features or functionality of the Services. For more information on how Google uses your data, visit: https://policies.google.com/technologies/partner-sites

13. Legal Compliance and Disclosures

We may disclose your personal information if required by law, subpoena, or legal process, or to enforce our agreements or protect our rights.

14. Data Security

We use encryption, secure servers, and restricted access to protect your personal information.

No system is completely secure, and you provide your information at your own risk.

15. Data Retention

• Loan application records are retained for at least seven (7) years.
• Marketing and lead records are retained for up to two (2) years, unless you request deletion sooner.
• Data is minimized and deleted upon account deletion or rights request, per our Terms of Use.

16. Children’s Privacy

Our Services are not directed toward individuals under the age of 18.

17. International Users

If you access our Services from outside the United States, you understand that your information will be transferred to and processed in the United States, which may have different data protection laws than your country. For EU/EEA users, we ensure appropriate safeguards for transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission.

18. Third-Party Links and Services

We are not responsible for the privacy practices of linked third-party sites or services.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email, in-app alert, or site posting. Continued use of our Services after changes constitutes acceptance of the updated terms.

20. Contact Us