eCommercial Mortgage LLC., together with any of its subsidiaries, affiliates, successors and assigns (collectively, "we," "us," "our" or "eCommercial Mortgage"), takes the privacy of its users seriously. We are committed to safeguarding the privacy of our users while providing a personalized and valuable service. This privacy policy statement explains the data processing practices of eCommercial Mortgage and describes how eCommercial  Mortgage and its websites, including eCommercial Mortgage.com, and the listing tools and other web products and services provided there (collectively, "eCommercial Mortgage Web"), treat personal information that eCommercial Mortgage Web collects and receives. Personal information is information about you that is personally identifiable – such as your name, address, e-mail, address, or phone number – and that is not otherwise publicly available (also referred to as your "Data"). References to Data also include any non-publicly available financial information provided by you through eCommercial Mortgage Web.

This privacy policy does not apply to the practices of companies that eCommercial Mortgage does not own or control (by way of example, external websites you may link to from or through eCommercial Mortgage Web, such as third party advertisers). While we try to link only to sites that share our high standards and respect for privacy, eCommercial Mortgage is not responsible for the content, security or privacy practices employed by other sites. We encourage our users to read the privacy policies of all websites. This privacy policy also does not apply to people or entities that eCommercial Mortgage does not employ or control, such as borrowers, lenders, brokers or other intermediaries that use eCommercial Mortgage Web. Because the borrowers, lenders and intermediaries that may connect to you through eCommercial Mortgage Web may retain or use your personal and financial Data (whether or not you qualify for or obtain a loan or other loan-related services from them, or fund a loan for them), you should contact these parties directly concerning their privacy and information sharing practices. This privacy policy only applies to eCommercial Mortgage Web.

If you have any requests concerning your personal information or any queries with regard to these practices please contact our Privacy Officer by e-mail at: confidential@ecommercialmortgage.com.

By visiting eCommercial Mortgage Web you are accepting the PRIVACY POLICY, TERMS of USE AND CONSENTING TO THE DATA COLLECTION AND USAGE PRACTICES described in this privacy policy, in addition to the eCommercial Mortgage Web.

Information Collected

We may collect Data from you when you register or subscribe for an account with eCommercial Mortgage Web (a "eCommercial Mortgage Account") or use the eCommercial Mortgage Web software or services. Elements of Data may include your name, e-mail, address, billing address, phone and fax number, credit card information, and various optional information (such as company name and work experience) that you may choose to provide. In posting listings, you will also be asked to provide certain financial Data. If you do not elect to provide all the requested Data, eCommercial Mortgage Web may not be able to provide you with all available services, including those services requested by you.

eCommercial Mortgage Web may also collect information about your transactions with us and with some of our business partners. This information might include market research data, as well as information necessary to process payments due to us from you, such as your credit card number.

When you send e-mail or other communication to eCommercial Mortgage Web, including through the registration process and Contact Us section of eCommercial Mortgage Web, we may retain those communications in order to process your inquiries, respond to your requests and improve eCommercial Mortgage Web.

We also collect information automatically about your visit to our site(s). Please see the IP Address and Use of Cookies and Other Tracking Devices sections of this privacy policy for more details.

Use and Disclosure of Personal and Financial Information

When you provide personal and financial information through or using eCommercial Mortgage Web you are sharing your Data with eCommercial Mortgage Web and its affiliated entities. The use of your Data by these organizations is subject to this privacy policy. We may use your Data for the following purposes:

•     Delivering products and services requested by you
•     Providing users with a personalized service
•     Matching prospective borrowers and intermediaries with lenders and intermediaries
•     Facilitating loan-related communications between users
•     Processing orders for subscription services
•     Responding to registration requests and questions
•     Conducting market research surveys and running competitions
•     Providing you with information about products and services offered by eCommercial Mortgage Web
•     Sharing your Data with third party organizations who offer products or services which you have requested or that we feel may be of interest to you (provided that you do not elect to opt-out of such  sharing)
•    Managing our business
•     Verifying your identity
•     Enforcing the eCommercial Mortgage Web Terms of Use
•     Other purposes we describe to you at the time your Data is collected

eCommercial Mortgage Web may provide your Data to lenders, brokers and other intermediaries (as eCommercial Mortgage Web does not act as your lender, broker or intermediary itself). The lenders, brokers and other intermediaries that participate in eCommercial Mortgage Web are subject to applicable federal, state and local laws and regulations and are regulated by federal and state agencies.

In the course of operating our business it may be necessary or appropriate for us to provide access to your Data to other third parties, such as our service providers, contractors and select vendors so that we can operate and improve eCommercial Mortgage Web and our business. Unless it is not commercially reasonable, we generally seek to obtain confidentiality agreements that are consistent with this policy or otherwise limit the use or disclosure by others of the information you have shared.

eCommercial Mortgage Web may use or share your personal information where it is necessary to complete a transaction (such as processing credit card payments and managing billing), to operate or improve the technical functionality of eCommercial Mortgage Web, or to do something that you have asked us to do.

eCommercial Mortgage Web may share your personal information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or other applicable policies, or as otherwise required by law. We may also disclose your information to business partners, successors to our business, or in accordance with a properly executed court order or as otherwise required to do so by law.

In addition, we may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who accessed a particular area of eCommercial Mortgage Web, for example, or how many users clicked on a particular link or used particular features. Such aggregated information will not identify you individually. Among other things, aggregate information may be used by eCommercial Mortgage Web to build up marketing profiles, to aid strategic development, to improve eCommercial Mortgage Web functionality, to manage our relationship with advertisers and to audit usage of the eCommercial Mortgage Web sites.

We usually will use the e-mail and contact Data you provide to us only to respond to your inquiry or to process your request (such as receiving certain marketing information or ordering our products and services) or in accordance with your stated preferences. However, we reserve the right to send you certain communications relating to eCommercial Mortgage Web, such as service announcements and administrative messages that are related to your use of eCommercial Mortgage Web and maintenance of your eCommercial Mortgage Account, without offering you the opportunity to opt-out of receiving them.

Security Policy

Your having a secure online experience is one of e Commercial Mortgage's highest priorities, and we take the privacy of our users seriously. However, no data transmissions over the Internet can be guaranteed to be one hundred percent secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your Data transmission, we make efforts to ensure security on our systems. We use physical, electronic, and procedural safeguards and other appropriate measures to protect personal information about you and to protect your Data against unauthorized access or use, alteration, unlawful or accidental destruction and accidental loss.

If you have registered for subscriber services, your eCommercial Mortgage Web account information will be password-protected. It is important for you to protect against unauthorized access to your user name, password and to your computer. Be sure to log off from eCommercial Mortgage Web when finished using a shared computer. Areas of eCommercial Mortgage Web where you are requested to input personal information use industry-standard Secure Sockets Layer (SSL) encryption to protect the data you input. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. Data transmission over the Internet is not guaranteed to be 100% secure. If eCommercial Mortgage Web learns of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using eCommercial Mortgage Web or providing Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of those sites, products and services.

User Content

Although eCommercial Mortgage Web reserves the right to refuse to post any or all content submitted by you in our sole discretion, when you post a message or other content to or through eCommercial Mortgage Web, including in a blog or forum, you may have the ability to include personally identifiable information about yourself. If you choose to make your own personally identifiable information available online (through a hyperlink or otherwise) such that it is accessible to other eCommercial Mortgage Web users, you may receive unsolicited messages from other parties in return.

Please be reminded that any content or links posted by you must comply with the eCommercial Mortgage Web Terms of Use. Any violation by any user may result in immediate termination of such user's account and access to eCommercial Mortgage Web, and may also subject such user to criminal penalties among other legal consequences.

Transfer of Data

The Internet is a global environment. Using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. This means that your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Therefore, by browsing eCommercial Mortgage Web and communicating electronically with us you acknowledge and agree to our processing of your personal data in this way, and agree to be bound by the applicable privacy laws that eCommercial Mortgage is governed by as well as the jurisdiction and venue provisions of the eCommercial Mortgage Web Terms of Use.

Links to Other Sites

eCommercial Mortgage Web contains links to other websites. If you choose to visit an advertiser by "clicking on" a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that eCommercial Mortgage Web displays a link to a third party website or presents a banner ad or other type of advertisement for goods or services of a third party is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of that third party's privacy or information security policies or practices. eCommercial Mortgage does not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information submitted to them. We strongly encourage you to read the privacy policies or statements of the other websites you visit.

User Access and Control of Data

If you wish to amend any of the Data which we hold about you, or update your marketing preferences, please contact confidential@ecommercialmortgage.com or visit the “My Profile” page on our website when logged in where you will be able to edit the information you have previously submitted.

You may also cancel your registration and terminate your account with eCommercial Mortgage Web, in which case your eCommercial Mortgage Web Account information will generally be deleted from eCommercial Mortgage Web. However, some Data, primarily your contact and billing information, may remain in our records to the extent necessary to protect our legal interests or document compliance with any applicable legal or regulatory requirements, and we may elect to retain any aggregate and non-personally identifiable information related to your eCommercial Mortgage Web Account indefinitely. All Data we retain will continue to be subject to the terms of the eCommercial Mortgage Web privacy policy that you previously agreed to when you used eCommercial Mortgage Web.

Opting Out

eCommercial Mortgage Web users will be given the choice to opt-out of receiving communications from us and our affiliates and marketing partners. To "opt-out" you may either use the "opt-out" or "unsubscribe" option contained within any e-mail message delivered to you, or by e-mailing your opt-out request to admin@ecommercialmortgage.com with the word “unsubscribe” in the e-mail subject line. Users should allow a reasonable time (but not more than 10 days) for the opt-out request to be processed. Please be aware that your opt-out choice may mean that certain eCommercial Mortgage Web services will no longer be available to you.

Use by Minors

Persons under age 18 are not eligible to use eCommercial Mortgage Web. Without limiting this restriction, in particular, we do not knowingly collect or store any information on children under 13 years of age. We will undertake to delete any details of such users where a parent or guardian has notified us that any such details have been obtained.

Contacting eCommercial Mortgage

If you have a privacy concern regarding eCommercial Mortgage Web or this policy, and if you cannot satisfactorily resolve it through eCommercial Mortgage Web, please address your concern to eCommercial Mortgage at admin@ecommercialmortgage.com. If you object to any sharing of your Data that may be permitted under this policy, you may do so by writing us at the above e-mail. We will take reasonable steps to accommodate your requests. In some instances, honoring your requests may interfere with or preclude your ability to use eCommercial Mortgage Web or may require us to terminate your eCommercial Mortgage Account and our relationship with you.

Changes to this Policy

From time to time we may make changes to this privacy policy statement to reflect any changes to our privacy practices in accordance with changes to legislation, best practice or website enhancements. We will endeavor to notify you about any material changes in the way we treat Data by placing a notice on eCommercial Mortgage Web, and, in some circumstances, eCommercial Mortgage Web reserves the right to also send a notice of such material changes to the primary e-mail address specified in your eCommercial Mortgage Web Account.

Use of Cookies and Other Tracking Devices

We use cookies to help personalize your use of our sites. A cookie is a small amount of data that often includes an anonymous unique identifier that is sent to your browser from a website's computer and stored on your computer's hard drive.

This data may include information relating to your use of our sites, information about your computer such as the computer's IP address and browser type, demographic data and, if you arrived at our site via a link from third party site, the URL of the linking page. If you are a registered user or subscriber this may include your name and e-mail address for verification purposes. We use information from cookies for purposes which may include:

•     Identifying returning users, registrants and subscribers and to allow subscribers to be presented with a personalized version of the site
• Enabling you to move more easily around our site
•     Tracking your use of our site to better develop our sites in accordance with your requirements
•     Building up a demographic profile

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some eCommercial Mortgage Web features and services may not function properly if your cookies are disabled. For example, if you choose to reject all cookies, you may not be able to use services or sites on eCommercial Mortgage Web that require you to "login," and you may not be able to take full advantage of all of the eCommercial Mortgage Web features. For further information on how to prevent cookies from being stored on your computer refer to the help menu within your Internet browser.

From time to time we may permit third party companies to set cookies on eCommercial Mortgage Web sites for purposes which may include market research, serving advertisements, revenue tracking or to improve functionality of the site. Any external websites you link to through or in connection with eCommercial Mortgage Web use of their cookies are subject to their own privacy policies, and not this policy. Advertisers or other entities do not have access to eCommercial Mortgage Web cookies. We encourage our users to read the privacy policies of all websites. This privacy policy applies only to information collected by eCommercial Mortgage.

IP Address

Every computer connected to the Internet is given a set of numbers that serve as that computer's Internet Protocol or "IP" address. The IP address reveals nothing personal about you other than the IP address from which you have accessed eCommercial Mortgage Web. eCommercial Mortgage Web may occasionally obtain IP addresses from users depending upon how you access our website(s). When you request a page or access a search result from any page within eCommercial Mortgage Web, our servers automatically recognize your IP address. IP addresses, browser and session information may be used for various purposes, including to:

    Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP

    Estimate the total number of users visiting eCommercial Mortgage Web from specific organizations or geographical regions help determine which users have access privileges to certain content, services or resources that we offer monitor and prevent fraud and abuse.

Your IP address may also be recorded when you post content on eCommercial Mortgage Web.

 2011 eCommercialMortgage LLC  All Rights Reserved. Other product and company names mentioned herein, including the names of participating lenders, may be the trademarks of their respective owners.

Last Updated: 03/07/2011