Privacy Policy

1. Introduction

ClearMark, LLC ("ClearMark," "we," "us," or "our") respects your privacy. This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our website (clearmarkhome.com) and our PMI cancellation coordination services.

By using our services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use our services.

2. Information We Collect

2.1 Personal Information You Provide

• Identity Information: Full name, email address, phone number, mailing address
• Property Information: Property address, property type, property condition details
• Financial Information: Current loan balance, monthly PMI amount, mortgage servicer name, loan/account number, interest rate, origination date, purchase price, down payment amount, payment history status
• Payment Information: Credit card or bank account details (processed and stored securely by Stripe; ClearMark does not store full payment card numbers)
• Documents: Mortgage statements, servicer correspondence, and other documents you upload or provide
• Communications: Emails, support requests, and other messages you send to us

2.2 Information We Collect Automatically

• Device Information: Browser type and version, operating system, device type
• Log Data: IP address, access times, referring URLs
• Cookies and Tracking Technologies: See Section 4 below

2.3 Information from Third-Party Sources

• Property Valuation Data: Automated valuation model (AVM) data from third-party providers
• Public Records: Property transaction history, tax assessments, and comparable sales data
• Authentication Data: Account information from Clerk (our authentication provider)

3. How We Use Your Information

We use your information to:

• Provide property valuation analysis and PMI eligibility assessments
• Prepare and submit PMI cancellation requests to your mortgage servicer
• Coordinate your property appraisal
• Communicate with you about your case status, next steps, and important updates
• Process payments after Confirmed PMI Removal
• Coordinate with your mortgage servicer as your authorized representative
• Respond to your support requests and inquiries
• Extract information from documents you upload (such as mortgage statements) using automated processing tools
• Detect and resolve technical issues and prevent fraud
• Comply with legal obligations, including record-keeping and regulatory requirements

We do not use your information for purposes unrelated to our services unless we obtain your separate consent.

4. Cookies and Tracking Technologies

We use cookies and similar technologies on our website. Cookies are small text files stored on your device that help us provide and improve our services.

4.1 Essential Cookies (Always Active)

These cookies are necessary for the website to function and cannot be disabled:

• Clerk — Authentication and session management. Required to sign in and access your account.
• Stripe — Payment processing. Required to securely process service fee payments.

4.2 Analytics Cookies

We do not currently use third-party analytics cookies. If we add analytics tools in the future, we will update this policy and provide you with notice and the ability to opt out before any analytics cookies are set.

4.3 Other Third-Party Resources

• Google Fonts — Loads typefaces for visual styling. When Google Fonts is loaded, your browser sends a request to Google's servers, which may include your IP address. No personal data is collected by ClearMark through this service.

4.4 Managing Your Cookie Preferences

You can manage cookies through your browser settings. Essential cookies cannot be disabled as they are necessary for the site to function. We also honor Global Privacy Control (GPC) browser signals (see Section 11).

5. How We Share Your Information

We do not sell your personal information in exchange for monetary consideration. We share your information only in the following circumstances:

5.1 Service Providers

We work with the following third-party service providers to deliver our services:

• Clerk — User authentication and account management
• Stripe — Payment processing and billing
• DocuSign — Electronic signature and document management
• Twilio — SMS notifications and communications
• Lob — Physical mail (certified letters) and check payments
• Resend — Email notifications and communications
• Anthropic — Document processing (extracts data from mortgage statements you upload using AI; document content is sent to Anthropic's API for processing and is not retained by Anthropic after processing)

Each provider maintains their own privacy policies and data protection practices. We share only the information necessary for them to perform their services on your behalf. Your use of our services is also subject to the terms and privacy policies of these third-party providers.

5.2 Your Mortgage Servicer

With your authorization (via the Authorization for Third-Party Representation you sign), we share relevant loan and property information with your mortgage servicer for the purpose of processing your PMI cancellation request.

5.3 Appraisers

We share your property address and relevant details with the licensed appraiser coordinating your appraisal inspection.

5.4 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect the rights, property, or safety of ClearMark, our users, or the public.

5.5 Business Transfers

If ClearMark is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such transfer and any choices you may have.

6. Financial Information (GLBA Notice)

ClearMark collects nonpublic personal financial information (such as mortgage balance, property value, loan number, and servicer details) in the course of providing our PMI cancellation coordination service. This information is protected under the Gramm-Leach-Bliley Act (GLBA).

• We do not share your nonpublic personal financial information with nonaffiliated third parties for marketing purposes.
• We share financial information only as necessary to provide our services (e.g., submitting a PMI cancellation request to your servicer, coordinating an appraisal) or as required by law.
• Your financial information is collected only after you provide affirmative consent during the onboarding process, including acknowledgment of our Service Agreement.

7. Data Retention

We retain your information according to the following schedule:

• Active cases: Information is retained throughout the duration of your case and for seven (7) years after case completion or termination, as required for financial record-keeping and potential dispute resolution.
• Incomplete applications: Data from incomplete applications may be retained for up to 90 days after the last activity, after which it may be deleted.
• Payment records: Retained for seven (7) years in accordance with financial record-keeping requirements.
• Marketing communications: Until you unsubscribe or request removal.

We may retain certain information longer if required by law or for legitimate business purposes such as resolving disputes or enforcing our agreements.

8. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your personal information, including:

• Encryption of data in transit (TLS/SSL)
• Secure access controls and authentication via Clerk
• Payment processing through Stripe's PCI DSS-compliant platform (ClearMark does not store full payment card numbers)
• Role-based access controls for internal staff

No method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8A. Data Breach Notification

In the event of a security breach involving your personal information, ClearMark will notify affected individuals within thirty (30) calendar days of discovering the breach, in accordance with applicable federal and state law. If the breach affects 500 or more residents of any state with attorney general notification requirements, we will also notify the applicable state attorney general within the required timeframe. Notification will include the nature of the breach, the types of information involved, and steps you can take to protect yourself.

9. Your Privacy Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

• Right to Know / Access: Request a copy of the personal information we have collected about you, including the categories of information, the sources, the business purpose for collection, and the categories of third parties with whom we share it.
• Right to Correct: Request correction of inaccurate or incomplete personal information.
• Right to Delete: Request deletion of your personal information, subject to legal retention requirements and exceptions (e.g., completing a transaction, detecting fraud, complying with legal obligations).
• Right to Opt-Out of Sale/Sharing: Opt out of the "sale" or "sharing" of your personal information as defined by applicable state privacy laws.
• Right to Limit Use of Sensitive Personal Information: Where applicable, you may direct us to limit the use of your sensitive personal information (including financial account information collected for payment processing) to purposes necessary to provide the services you requested. ClearMark uses sensitive personal information only for service delivery and payment processing and does not use it for profiling or advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
• Right to Data Portability: Where applicable, receive your personal information in a structured, commonly used, and machine-readable format.
• Right to Appeal: If we deny your privacy request in whole or in part, you may appeal our decision by contacting us at support@clearmarkhome.com within sixty (60) days of receiving the denial. We will respond to your appeal within sixty (60) days. If your appeal is denied, we will provide information on how to contact your state's attorney general or relevant regulatory authority.

To exercise any of these rights, please contact us at support@clearmarkhome.com. We will acknowledge your request within ten (10) business days, verify your identity, and provide a substantive response within forty-five (45) calendar days (or up to ninety (90) calendar days total with notice if additional time is reasonably necessary). You may also designate an authorized agent to make a request on your behalf; we may require a signed written authorization or power of attorney and direct verification of your identity.

10. Do Not Sell or Share My Personal Information

ClearMark does not sell your personal information in exchange for monetary consideration. We do not currently share personal information with third-party analytics or advertising providers.

If we introduce analytics or advertising tools in the future that constitute "sharing" under applicable state privacy laws, we will update this policy and provide you with the ability to opt out before any such sharing begins.

You have the right to opt out of any future sale or sharing of your personal information. Contact us at support@clearmarkhome.com to exercise this right.

11. Global Privacy Control (GPC)

We honor the Global Privacy Control (GPC) signal. If your browser sends a GPC signal, we treat this as a request to opt out of any non-essential tracking and data sharing.

GPC signals are recognized as legally valid opt-out requests under the laws of California, Colorado, Connecticut, Texas, Montana, Oregon, Delaware, New Hampshire, Nebraska, New Jersey, Minnesota, and Maryland.

GPC is supported by most modern browsers and can be enabled in your browser's privacy settings. For more information, visit globalprivacycontrol.org.

12. California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

Categories of personal information collected in the preceding 12 months:

Category	Examples	Business Purpose
Identifiers	Name, email, phone, mailing address	Service delivery, communications
Financial information	Loan details, property value, payment info	Eligibility analysis, payment processing
Internet/electronic activity	IP address, browser type, access times	Security, fraud prevention
Geolocation data	Property address	Property valuation, servicer identification
Professional information	Mortgage servicer name	PMI cancellation coordination

Sale/Sharing: ClearMark does not currently sell or share personal information with third parties for advertising or analytics purposes.

Sensitive personal information: We collect financial account information (bank account or credit card details) for the sole purpose of processing payments. This information is processed by Stripe and is not used for profiling or advertising purposes.

Do Not Track: We honor Do Not Track browser signals and Global Privacy Control signals.

California "Shine the Light" (Cal. Civ. Code § 1798.83): ClearMark does not share personal information with third parties for their own direct marketing purposes. If our practices change, we will notify you and provide an opt-out.

13. Other State Privacy Rights

If you reside in Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, or another state with comprehensive privacy legislation, you may have similar rights to those described in Sections 9 and 12. Contact us at support@clearmarkhome.com to exercise your rights, and we will process your request in accordance with applicable state law.

Nevada Residents (NRS 603A): You may submit a verified request to opt out of the sale of your personal information by contacting our designated request address: support@clearmarkhome.com.

14. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected information from a child under 18, we will promptly delete it.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be posted on our website with an updated "Last Updated" date. We will notify active customers of material changes via email. Your continued use of our services after changes constitutes acceptance of the updated policy.

16. Contact Us

For questions about this Privacy Policy, to exercise your privacy rights, or to submit a complaint, please contact us at:

ClearMark, LLC
7533 S Center View Ct #5755, West Jordan, UT 84084
Email: support@clearmarkhome.com

ClearMark, LLC is not affiliated with your lender, servicer, or any government agency.