Quick Reference
This Privacy Policy applies to Genrae websites and online interactions that link to it. It is written for a housing finance business, not for a general consumer app, social network, or child-directed service.
- Genrae's website and products are intended for adults.
- Genrae does not sell personal information for money.
- Genrae does not knowingly sell or share personal information of anyone under 18.
- Mortgage, lender, investor, employment, and signed transaction relationships may be governed by additional privacy notices or agreements.
- Do not send Social Security numbers, bank account details, wire instructions, credit reports, tax returns, or similar sensitive information through ordinary website forms or unsecured email unless Genrae or a participating counterparty has specifically directed you to a secure channel.
Scope
This Policy describes information collected through Genrae websites, online pages, email interactions, business-development conversations, and related digital communications that link to this Policy.
This Policy does not replace any privacy notice, lender disclosure, investor notice, employment notice, transaction document, data-room term, vendor agreement, or other signed agreement that applies to a specific relationship. If a separate notice or agreement applies to particular information, that notice or agreement controls for that information.
Information We May Collect
The information Genrae collects depends on how you interact with us. We may collect information directly from you, automatically through website technology, and from participating lenders, counterparties, vendors, advisors, investors, or other business contacts.
- Identifiers and contact details, such as name, email address, phone number, mailing address, company, role, and professional affiliation.
- Communications, such as messages, inquiries, meeting requests, feedback, attachments, call notes, and related metadata.
- Business and professional information submitted in connection with lender, investor, partner, vendor, advisor, media, policy, or employment inquiries.
- Website and device information, such as IP address, browser type, device type, operating system, pages viewed, links clicked, referring pages, approximate location, session data, cookie identifiers, and analytics events.
- Program or transaction information if you interact with Genrae about a potential borrower, homeowner, lender, investor, or partner relationship, including eligibility, property, mortgage, title, closing, compliance, education, servicing, and documentation information where applicable.
- Sensitive financial or identity information only where relevant to a secure transaction, diligence, compliance, employment, or counterparty workflow. This may include government identification, date of birth, income, assets, bank information, credit-related information, tax information, insurance information, property information, or wire-related information if provided through an approved channel.
Sensitive Financial Information
Genrae operates in a housing finance context. Information connected with a mortgage, home purchase, refinance, purchase option, lender relationship, investor relationship, or related transaction may be more sensitive than ordinary website data.
Where information is subject to the Gramm-Leach-Bliley Act, other financial privacy laws, a lender privacy notice, or a transaction-specific notice, Genrae treats that information in accordance with the applicable notice, agreement, and legal requirements. Participating lenders, servicers, title companies, settlement agents, investors, custodians, data-room providers, and other counterparties may have their own privacy obligations and notices.
How We Use Personal Information
- Respond to inquiries, schedule calls, provide requested information, and communicate with you.
- Evaluate potential borrower, lender, investor, vendor, advisor, and partner relationships.
- Support product education, eligibility review, transaction coordination, diligence, compliance, legal, servicing, reporting, and operational workflows where applicable.
- Operate, secure, monitor, debug, measure, and improve the website and related systems.
- Maintain business records, audit trails, accounting records, tax records, legal files, security logs, and other operational records.
- Comply with law, regulation, subpoena, court order, regulator request, contract, investor obligation, lender requirement, tax obligation, audit requirement, and risk-management obligation.
- Detect, prevent, investigate, and respond to fraud, impersonation, unauthorized access, cybersecurity incidents, suspicious payment instructions, misuse of Genrae's name, and other harmful activity.
- Evaluate or carry out a financing, investment, merger, acquisition, reorganization, restructuring, transfer, or similar corporate transaction.
How We Disclose Personal Information
Genrae may disclose personal information when appropriate for the purposes described in this Policy and subject to applicable law, contract, confidentiality obligations, or transaction safeguards.
- Affiliates, subsidiaries, and related entities.
- Website hosting, analytics, communications, security, CRM, data-room, document-management, cloud, and other technology providers.
- Participating lenders, servicers, title companies, settlement agents, custodians, trustees, investors, capital providers, diligence providers, auditors, consultants, and other transaction counterparties where relevant to a relationship or transaction.
- Attorneys, accountants, tax advisors, compliance consultants, insurance providers, auditors, and other professional advisors.
- Government agencies, regulators, law enforcement, courts, arbitrators, and parties to legal process when Genrae believes disclosure is required or appropriate.
- Parties involved in a financing, investment, merger, acquisition, reorganization, restructuring, sale of assets, transfer, or similar corporate transaction.
- Other parties with your direction, consent, or as otherwise permitted or required by law.
No Sale or Targeted Advertising
Genrae does not sell personal information for money. Genrae also does not currently use personal information collected through the website for cross-context behavioral advertising or targeted advertising.
Some privacy laws define sale, sharing, or targeted advertising more broadly than a money-for-data transaction. If Genrae's website practices change in a way that triggers opt-out rights, Genrae will update this Policy and provide required privacy choices.
Genrae does not have actual knowledge that it sells or shares personal information of anyone under 18, and Genrae's business is not directed to minors.
Security
Genrae uses administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, misuse, or destruction. Safeguards may include access controls, vendor controls, security monitoring, encryption where appropriate, recordkeeping controls, and internal limits on who may access sensitive information.
No website, email system, cloud service, or electronic storage system can be guaranteed completely secure. You should not send highly sensitive financial, identity, payment, or wire information through ordinary website forms or unsecured email unless specifically directed to do so through an approved secure process.
Retention
Genrae retains personal information for as long as reasonably necessary for the purposes described in this Policy or otherwise permitted by law. Retention periods may depend on the type of information, the relationship, the transaction, legal and regulatory requirements, lender or investor requirements, audit needs, tax and accounting rules, security needs, dispute-resolution needs, and recordkeeping obligations.
Genrae may retain de-identified, aggregated, backup, archival, security, or audit information where permitted by law and consistent with applicable safeguards.
State Privacy Rights
Depending on where you live and how you interact with Genrae, you may have rights to request access, correction, deletion, portability, restriction, objection, opt-out, or limitation of certain processing of personal information. Genrae will respond to privacy requests as required by applicable law.
Certain information may be exempt from some state privacy laws because it is covered by federal financial privacy laws, transaction-specific privacy notices, employment laws, legal privilege, security exceptions, or other exemptions.
To make a privacy request, contact Genrae at legal@genrae.com. Include enough information for Genrae to understand the request, verify your identity or authority, and respond. Genrae may request additional information if needed to verify or process the request.
California Notice
If the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to your information, California residents may have rights to know, access, correct, delete, obtain a copy of, and opt out of certain sale or sharing of personal information, and to limit certain uses or disclosures of sensitive personal information.
The categories of personal information Genrae may collect are described in the Information We May Collect section. The categories of third parties to whom Genrae may disclose personal information are described in the How We Disclose Personal Information section. Genrae does not currently sell personal information for money or use website-collected personal information for cross-context behavioral advertising.
California privacy rights may not apply to information exempt from the California Consumer Privacy Act, including certain information covered by federal financial privacy laws. Genrae will not discriminate against you for exercising privacy rights that apply to you.
Minors
Genrae's website and products are intended for adults. The website is not directed to minors, and Genrae does not knowingly collect personal information from anyone under 18 through the website.
If you believe a minor has provided personal information to Genrae through the website, contact Genrae at legal@genrae.com so Genrae can review the issue and delete the information where appropriate and legally permitted.
Visitors Outside the United States
Genrae is based in the United States, and the website is intended for use in the United States. If you access the website from outside the United States, your information may be processed in the United States or other jurisdictions that may not provide the same level of data protection as your location.
Updates
Genrae may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised date. Material changes will apply prospectively unless otherwise permitted by law.
Contact
Questions or privacy requests may be directed to Genrae at legal@genrae.com.