Privacy Policy

Last updated on August 3, 2026

Shogun Enterprises Inc. doing business as “Hearth” and “Hearth Brokerage” and its affiliated companies (“Hearth,” “we,” “us,” and “our”), is a technology company that connects consumers with potential lenders. This online privacy policy (“Privacy Policy”) applies only to the information Hearth collects through this website, and all of the associated content, functionalities and advertising (collectively the “Services”). This Privacy Policy governs the Services regardless of how you access them. Some Services may have a specific, separate Privacy Policy that will govern use of those Services. Undefined capitalized terms used in this Privacy Policy shall have the definition given in our Terms of Use.

Sections 1 through 15 of this Privacy Policy are directed to individual consumers who interact with the Services, including homeowners and other individuals who use or are referred to Hearth’s financing products. If you are a contractor, or a business customer of Hearth, or a personnel member of such a business, Section 16 (“Additional Notice for Contractors”) applies to you in addition to, and to the extent of any conflict in lieu of, the applicable provisions of Sections 1 through 15. If you are a California employee or job applicant of Hearth, Section 17 (“Additional Notice for California Employees and Job Applicants”) applies to you in lieu of the consumer-directed provisions of this Privacy Policy.

Please see our Financial Privacy Policy Notice for a summary of privacy options related to some of our services.

If you do not agree to the terms contained in this Privacy Policy, you must immediately exit the Services.

The Privacy Policy describes:

The information we collect and how we collect it;
What we do with the information we collect;
How we share and disclose user information with third parties;
Hearth’s use of online analytics and tailored advertising;
California Do-Not-Track disclosure requirements;
How you can access and update your information;
How we protect information;
Linked sites and advertisements;
Use of the Services by users from outside the United States;
Use of the Services by children;
How to contact us;
Text messaging originator opt-in data;
Your California privacy rights;
No rights of third parties;
Changes to this Privacy Policy; and
Assistance to Victims of Identity Theft.
Additional Notice for Contractors; and
Additional Notice for California Employees and Job Applicants.

1. The information we collect and how we collect it.

How we collect and store information depends on the pages of this website you visit, the activities in which you participate and the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.

1.1 Information you provide

In addition to the individuals described elsewhere in this Privacy Policy, we also collect personal information about our employees and contractors, including information provided during onboarding (such as government-issued identification numbers, banking and payroll information, benefits elections, and background check results), and about business contacts of our customers, vendors, and service providers.

We may collect information about you during your use of the Services, including your first name, last name, email address, loan amount, phone number(s), zip code, employment status, annual income, credit score/FICO range, and information you provide or post on our Services or allow us to access when you do certain things, such as:

Enter registration information for one or more of our Services;
Request information from Hearth’s lending partners regarding their financial products;
Request certain features (e.g., newsletters, updates, and other products);
Sign up to receive SMS (text message) notifications;
Download or use one of our mobile applications;
Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS); or
Post user-generated content, including comments, to or on any of our Services.

Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via a SNS, on message boards, chat areas or in advertising or notices you post, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties.

1.2 Automatically-collected information

1.2.1 Device/usage information

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.

We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique Hearth identifier (that is not intended to be used by itself to identify you) for our internal use, in which case your Hearth identifier will be considered Hearth information and nothing in this Privacy Policy restricts how Hearth may use this information.

1.2.2 Location information

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Chicago, the Services may be customized with Chicago-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

1.2.3 Cookies and other electronic technologies

When you use the Services, we use persistent and session cookies and other similar tracking technologies to: (a) analyze the usage of our sites and Services by collecting the information discussed in section 1.2.1 above; (b) customize the Services to your preferences; and (c) control the advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications. The cookies may reflect de-identified data linked to or derived from data you voluntarily have submitted to us, e.g., a hashed version of your email address that we may share with service providers, solely in non-human readable form. We and our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, as well as serve you ads when you are using our Services and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. As we adopt additional technologies, we may also gather additional information through other methods.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browsers toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

1.3 Information from third parties

We may obtain additional information about you from third parties such as service providers, credit bureaus, marketers, partners, researchers, and others. We may also receive information from lenders regarding the status of your application including, but not limited to, the amount or disposition of your loan. This information may include your Social Security number, FICO score, credit report, transaction history, payment history, name, phone number, email address, ZIP code, whether you have received loan offers, and which loan offers you have received. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

Among these third parties, we obtain identity- and fraud-related information from providers, and we obtain information about website visitors and prospective customers from marketing and analytics platforms.

1.4 Aggregate or de-identified data

We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

2. What we do with the information we collect.

We use the information that we collect for the following purposes:

For the purposes for which you provided it;
To deliver the products and services you requested;
To match you with lenders or provide you with lenders’ conditional loan offers;
To verify your identity;
To protect against or identify possible fraudulent transactions;
To send you information about your relationship or transactions with us;
To send you alerts or other communications via SMS messages or other media or networks;
To notify you about new features of the Services, special events, or products, services, and special offers;
To administer sweepstakes and contests;
To process and respond to your inquiries and requests for customer support;
To contact you with information that we believe will be of interest to you;
To attribute content that you make available through the Services;
To generate and review reports and data about our user base and Service usage patterns;
To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;
To improve the content and features of the Services or develop new Services;
To allow us to personalize the content and advertising that you see on the Services and to understand how users interact with and use our advertisements and Services;
To enforce the legal terms that govern your use of the Services;
To administer and troubleshoot the Services; and
To associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications and websites);
To comply with legal and regulatory obligations, including under the Gramm-Leach-Bliley Act and applicable anti-money laundering laws; and
To manage our employees and contractors, including for payroll, benefits, equity administration, and workforce management purposes.

We may send you commercial emails regarding products you may be interested in. Each such email we send you will have an opt-out that you can use to stop receiving such communications. If you opt out of receiving commercial emails about products we think you may be interested in, we may still send you emails about any services you have requested or received from us.

3. How we share and disclose user information with third parties.

We will make your information available to other companies, websites, applications or people in the circumstances described below:

We may rent, sell, or share your information with non-affiliated third parties: (a) in order to provide services or products that you have requested or (b) as described in this Privacy Policy. Unless authorized, Hearth will not share any personal identifiable information (“PII”) or nonpublic personal information (“NPI”) with non-affiliated third parties. Hearth will only share aggregated, de-identified information with non-affiliated third parties inside our platform. Please refer to section 1.4 Aggregated or de-identified data.

We may share your information with any agent or company that is part of Hearth in order to provide the Services or advertising or to communicate with you on our behalf.

In submitting an inquiry for a loan product or other service offered through this website, you are acknowledging and agreeing to the disclosure of information you have provided or that we have received from third parties to lenders in our network (“Lenders”) with whom you are or may be matched. We may also use the information you provide or that we obtain from third parties to submit to credit reporting agencies to conduct a soft credit pull inquiry. Please note that no hard inquiry of credit will be performed by Hearth or its network Lenders unless you authorize us to do so by submitting a completed loan request. NOTE THAT even if you do not provide your Social Security number, we may access your credit file to assist in the prevention of identity theft and to verify your request is accurate and complete. Not all network Lenders will obtain your SSN and each Lender has its own requirements, disclosures and consent requirements. BE AWARE that the Lenders with whom you are matched may retain or use your information whether or not you use their services and you should contact these Lenders directly concerning their privacy and information sharing practices which may differ from Hearth.

When you express interest in other products, services, promotions that we offer (by, for example, completing an inquiry for such services), we will share your request or expression of interest with the businesses with which we partner to offer you those products, services and promotions, and, as applicable, with their affiliates and third party finder or marketing companies (collectively, “Business Providers”). When you choose to participate in a particular offer or program, you authorize us to provide information and other personally identifiable information to those Business Providers. Be aware the Business Providers with whom we share your information and other personally identifiable information may retain or use your information whether or not you use their services and you should contact these parties directly concerning their privacy and information sharing practices which may differ from ours.

When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers, operators, or sponsors privacy policies or practices.

We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.

We may share your personal information with our authorized service providers that perform certain services on our behalf including, but not limited to service providers that perform services on our behalf in connection with your request for a loan or the funding, sale and/or servicing of your loan. These third parties include, without limitation credit bureaus, marketing and customer services firms, or entities that provide business analysis or website support. These third parties may have access to information and other personally identifiable information needed to perform their functions. We may also share your information with other third-parties with whom we have a contractual relationship for their own direct marketing or advertising purposes.

These service providers fall into the following categories: identity and fraud verification; banking and financial services; communications; customer relationship management and sales; human resources, payroll, and benefits administration; cloud infrastructure; analytics and product; and security and compliance. All such service providers are subject to review under our vendor management policy prior to onboarding.

We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service for the Services you accessed, and/or to protect the rights and property of Hearth, our employees, users and the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

We may disclose your information in connection with reporting required in connection with state and/or federal licensing requirements. You authorize Hearth to obtain any and all necessary information required from the Lender or Provider you choose to report back any and all required information relating to the disposition of your request. For example, if the loan closed, if you withdrew the request, and/or if you were not approved. In addition, under current reporting requirements the lender may provide to Hearth the loan you selected, the terms of the same, fees, rate, APR etc. in order to comply with current laws and regulations.

We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all Hearth assets, or a financing or acquisition of all or a portion of our business by another company.

We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose.

We may employ third-party software provided by FullStory, Inc. to improve the quality of the Services. This allows Hearth to review a video-playback of your use of Services and any other activity on Hearth’s website. By using this site, you expressly consent to Shogun’s use of FullStory Inc.’s service. If you would like to opt-out, please click here.

We may employ third-party software provided by UXCam, Inc. to improve the quality of the Services. This allows Hearth to review a video-playback of your use of Services and any other activity on Hearth’s website. By using this site, you expressly consent to Shogun’s use of UXCam Inc.’s service. If you would like to opt-out, please email us at [email protected].

If you are a contractor and were referred to us by a third-party partner, we may share information about you, including but not limited to your subscription status, usage data, and information about any loans obtained or loan requests made by customers using your co-branded page.

If you are a consumer who uses services from this website, we may share information about you to third parties, including but not limited to information about any loans obtained, loan requests made by you, and any loan options that you may have prequalified for in an aggregated and/or de-identified form.

3.1 Google user data (Gmail and Google Calendar)

If you connect your Google account to our Services, our access to and use of raw or derived user data received from Google Workspace APIs (including Gmail and Google Calendar data, “Google user data”) will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

We do not sell, rent, or share Google user data with third parties for purposes other than providing or improving our Services’ user-facing features, and we do not transfer Google user data to third parties for advertising purposes.
We do not use Google user data, raw, aggregated, anonymized, or derived to develop, improve, or train generalized or foundational artificial intelligence (AI) or machine learning (ML) models.
Where our Services use AI to provide user-facing features, Google user data may be processed by third-party AI service providers solely to deliver those features. We use these providers only under terms that prohibit them from using Google user data to train or improve their own AI/ML models.
Google user data is retained only as long as necessary to provide our Services; you may request deletion at any time by emailing [email protected].

4. Hearth’s use of online analytics and tailored advertising.

4.1 Online analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.2 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

4.2 Tailored advertising

Hearth maintains a cookie policy and uses a consent management platform (“CMP”) to provide notice of, and to obtain and manage, cookie consent, including for visitors located in California and other states with applicable consent requirements. You can manage your cookie preferences at any time through the cookie preference tool available on our website.

When you use the Service, Hearth may serve you with ads based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

Also, third parties, including without limitation those whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that tailored ads may be delivered to you when you are using other websites. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g., user-generated content) for purposes of delivering tailored advertising on the Services and/or other websites.

Hearth deploys retargeting and remarketing pixels, which allow Hearth and these platforms to show you advertisements based on your prior visits to our website. You may opt out of such retargeting advertising using the mechanisms described below or through your cookie preferences via our CMP.

5. California Do-Not-Track Disclosure Requirements.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link available through the Services.

To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

When using a mobile application, you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

6. How you can access and update your information.

To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at [email protected].

Contractors and customers using the Hearth platform may update certain personal information, such as contact details and bank account information, directly within the platform. Employees may update their personal information through Hearth’s human resources platform or by contacting Hearth’s People Operations team.

7. How we protect information.

We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information, including as required by applicable federal law. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Although we take measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

8. Linked sites and advertisements.

The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.

We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit sites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the site or Services in connection with such content, products, services, or functionalities, we may share any information you provide or that is collected during your use of those Services with those providers. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.

9. Use of the Services by users from outside the United States.

The Services are hosted in the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy and processed in those facilities.

10. Use of the Services by children.

The Services are not intended for persons under the age of 18. We require that only persons 18 years of age or older use the Services. By using the Services, you hereby represent that you are at least 18 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.

11. How to contact us.

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to [email protected].

12. Text messaging originator opt-in data

Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

13. Your California privacy rights; No Rights of Third Parties.

This section applies to any California residents – and only to California residents – about whom we have collected personal information from any source, including through your use of our Website(s), by buying our products or services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).

For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. Personal information does not include publicly available information or information that has been de-identified or aggregated.

13.1. What Information We May Collect

We may collect the following categories of personal information about you:

Identifiers, which includes real name and alias; postal address; unique personal identifier; online identifiers as detailed below; Internet Protocol (“IP”) address; email address; telephone number; account number, name, and password; Social Security number; driver’s license number, passport number, state or other government-issued identification card number; and/or other similar identifiers;
Commercial information, which includes records of personal property; products or services purchased, obtained, or considered; vehicle identification number (VIN); account balances, payment history, or account activity; bank account information and other information relating to your financial institution; credit application, credit checks, and information from credit reporting agencies; information related to housing costs; information related to home improvement services; information related to potential financial products, including prequalified personal loan APRs, principal amounts, monthly payments, terms, and the identity of the prequalifying lender; monthly housing payment information; information regarding potential home improvement projects or other potential uses for financing; and/or other purchasing or consumer histories or tendencies;
Information relating to Internet activity or other electronic network activity, which includes cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”);
Geolocation data, which includes GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s) or vehicle(s);
Audio, electronic, or visual information, which includes records of calls to or from our customer service centers; and/or video surveillance information;
Professional or employment-related information, such as your current and previous employers; job title and responsibilities; assets; income; and/or other information related to your work history and/or prospective employment;
Education information;
Inferences about you;
Information not listed above and related to characteristics protected under California or federal law; which includes gender; race and ethnicity; nationality; marital status; military service / veteran status; and/or date of birth;
Other personal information not listed above and described in California Civil Code § 1798.80(e), which includes signature; physical characteristics or description; insurance policy number; and/or bank account number credit card number, debit card number, and other financial, medical, and/or health insurance information).
Financial information protected under the Gramm-Leach-Bliley Act, which includes bank account and routing numbers, financial transaction data, income and revenue data, and credit-related information collected in connection with financing applications and payments;

13.2. What We Do With Your Information

Other than the purposes for which you have provided separate express consent, we may also collect or use personal information from you for the following purposes:

Internal analytics;
Assessing third party vendors / service providers;
Audit, compliance, policy, procedures, or regulatory compliance;
Billing, payment, and fulfillment;
Customer claims and fraud investigation and prevention;
Customer communications;
Customer relationship management;
General business administration or our service providers’ general business administration;
Marketing our products and services;
Marketing the products and services of others;
Financial reporting and accounting;
Website optimization and maintenance; and
Systems and data security.

13.3. Sources of Collected Information

We may collect personal information from the following categories of sources:

Our customers, potential customers, users of our websites and mobile applications, commercial counterparties, and other individuals, including via our websites, mobile applications, telephone, text message, postal mail, social media, forums, message boards, chatbot, or other means;
Our Affiliates, which includes Hearth Home Improvement Solutions, Inc.;
Our service providers, which includes customer relationship management providers, analytics providers, website hosting providers, systems administrators, communications delivery services, and Hearth SaaS Customers;
Nonaffiliated companies with which we have a business relationship, including promotional and joint marketing partners;
Other third parties, including operators of other websites and mobile applications, online advertising partners, and other data suppliers;
Things that other third parties may post publicly about you or otherwise provide to us; and
Employees, job applicants, and potential job applicants.

As of the date of this Privacy Policy, we do not have operating affiliates or subsidiaries to which we transfer personal information.

13.4. Who We Share Information With

We do not sell personal information. We may share your personal information with the following categories of third parties:

Affiliates;
Service providers using Hearth with whom you have expressly consented to share information, including Lenders and Hearth SaaS Customers;
Companies offering similar products and services as Shogun;
Advertising and marketing companies;
Social media companies;
Technology companies; and
Nonaffiliated companies with which we have a business relationship, such as lenders, brokers, insurance carriers, or insurance brokers.

Other than with respect to information covered by the Gramm Leach Bliley Act, we may disclose any of the categories of information listed above in Section 13.1A, from any of the sources listed in Section 13.3C, for any of the business purposes listed in Section 13.2B to any of the parties identified in Section 13.4D.

Your Privacy Rights

If you are a California resident, subject to applicable law, you may have the following rights under California law with respect to your personal information:

Right to Know. You have the right to request what personal information about you we collect, use, disclose, and/or sell, as applicable.
Right to Delete. You have the right to request the deletion of certain personal information that is collected or maintained by us.
Right to Opt-Out of Sale. California provides you with a right to opt-out of the sale of your personal information by us. However, to be clear, Hearth does not sell your personal information.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

Proxy Authorization: You may also authorize someone to exercise the above rights on your behalf by sending a certified letter, including a fully executed power-of-attorney signed by you, detailing such request to the address listed below.

Verification: The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws. Any such requests must include at least five pieces of verifiable information, including at least your full name, your email address, your phone number, your date of birth, and the last four digits of your social security number.

If you are a California resident and wish to seek to exercise you Right to Know or your Right to Delete or after January 1, 2020, please reach us in one of the following ways:

On the web: Click here.
By toll-free phone call: 844-675-7372
By email: [email protected]
By mail: Attn: Hearth CCPA Team, 5812 Trade Center Dr #100, Austin, TX 78744

The CCPA also provides you with certain rights related to opting out from any “data sale.” Because Hearth does not engage in any “data sale” as that term is defined in applicable law, there is no link on this website to opt out of such sales.

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

By toll-free phone call: 844-675-7372
By email: [email protected]
By mail: Attn: Hearth CCPA Team, 5812 Trade Center Dr #100, Austin, TX 78744

13.5. No rights of third parties.

This Privacy Policy does not create rights enforceable by third parties.

14. Changes to this Privacy Policy.

Hearth reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.

15. Assistance to Victims of Identity Theft

If you suspect that someone has had unauthorized access to your Information or access to your personally identifiable information, you should report this crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free 1-877-IDTheft (1-877-438-4338). Or, to enter information about your complaint into a secure FTC online database, visit www.consumer.gov/idtheft. The site also provides links to consumer education materials.

16. ADDITIONAL NOTICE FOR CONTRACTORS

This Section 16 applies to contractors and other business customers of Hearth, and to the owners, employees, and other personnel of such businesses, who interact with the Services in a business capacity (collectively, “Contractors”). This Section 16 supplements, and to the extent of any conflict supersedes, the consumer-directed provisions of Sections 1 through 15 as applied to Contractors.

16.1 Information We Collect About Contractors.

In connection with a Contractor’s use of the Services, we collect: (a) business contact information, such as business name, EIN, business address, phone number, and email address; (b) platform account credentials and usage data; (c) financial and payment information, including bank account and routing numbers, used to facilitate payments and financing; (d) information the Contractor submits about its own customers (including homeowners) in connection with financing applications, quotes, invoices, or scheduling; and (e) records of communications between the Contractor and Hearth, including calls, emails, and text messages.

16.2 How We Use Contractor Information.

We use Contractor information to: operate and provide the Services (including quotes, invoicing, scheduling, and the financing marketplace); process and facilitate financing applications submitted on behalf of a Contractor’s customers; detect and prevent fraud; provide customer support; market Hearth’s products and services to the Contractor; and comply with applicable law.

16.3 How We Share Contractor Information.

We share Contractor information with lending partners to facilitate financing offers to the Contractor’s customers, with the service providers described in Section 3 of this Privacy Policy, and, where authorized by the Contractor, with other personnel or sub-accounts associated with the Contractor’s business. We do not sell Contractor personal information.

16.4 Retention.

We retain Contractor information for as long as necessary to provide the Services and maintain the business relationship, and thereafter as necessary to comply with applicable legal, tax, and recordkeeping requirements.

16.5 Contractor Rights.

Contractors who are individuals, and personnel of business Contractors, located in California or another state with an applicable consumer privacy law may have rights similar to those described in Section 13 of this Privacy Policy with respect to their personal information. Contractors may submit a request to exercise such rights using the contact methods described in Section 11.

17. ADDITIONAL NOTICE FOR CALIFORNIA EMPLOYEES AND JOB APPLICANTS

This Section 17 is provided in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), and applies to California-based current, former, and prospective employees of Hearth (collectively, “California Personnel”). This Section 17 supplements, and to the extent of any conflict supersedes, the consumer-directed provisions of Sections 1 through 15 as applied to California Personnel.

17.1 Categories of Personal Information Collected.

In the past twelve (12) months, we have collected the following categories of personal information about California Personnel: identifiers (name, address, email, phone number, Social Security number); characteristics protected under California or federal law (e.g., date of birth, veteran status, disability status, to the extent voluntarily provided or required for benefits administration); commercial information (compensation and benefits elections); internet and electronic network activity on Hearth systems; professional and employment-related information (job title, employment history, performance information); education information; and inferences drawn from the foregoing. We also collect sensitive personal information, including Social Security numbers, driver’s license numbers, financial account information (for payroll and direct deposit purposes), and, where applicable, precise geolocation and health information collected in connection with benefits administration. We use sensitive personal information only for the limited business purposes permitted under the CPRA, such as administering payroll, benefits, and tax withholding, and do not use it to infer characteristics about California Personnel.

17.2 Sources of Personal Information.

We collect personal information about California Personnel directly from them; from our human resources, payroll, and benefits administration vendors; from our background check vendor; from healthcare and benefits providers; and, for job applicants, from references and prior employers.

17.3 Purposes for Collection and Use.

We collect and use California Personnel personal information to administer employment, payroll, benefits, and equity programs; to comply with applicable employment, tax, and labor laws; to maintain workplace safety and security, including through IT access and security monitoring; and to conduct background checks in connection with hiring.

17.4 Disclosure of Personal Information.

We disclose California Personnel personal information to our human resources, payroll, and benefits vendors, and to our IT and security vendors each for the business purposes described above, and to government agencies where required by law. We do not sell or share (as “share” is defined under the CPRA) California Personnel personal information, and we do not use or disclose sensitive personal information of California Personnel for purposes beyond those permitted under the CPRA.

17.5 Retention.

We retain California Personnel personal information for the duration of the employment relationship and thereafter for the period necessary to comply with applicable legal, tax, and recordkeeping obligations or to establish, exercise, or defend legal claims, consistent with our internal data retention policy.

17.6 Your Rights.

Subject to certain exceptions under the CPRA applicable to employment records, California Personnel have the right to: (a) know what personal information we have collected, used, disclosed, and retained about them; (b) request deletion of their personal information; (c) request correction of inaccurate personal information; (d) limit the use of sensitive personal information beyond what is necessary to perform services reasonably expected in the employment relationship; and (e) not be discriminated or retaliated against for exercising any of these rights.

17.7 How to Submit a Request.

California Personnel may submit a request to exercise the rights described in this Section 17 by contacting Hearth’s People Operations team or by using the contact methods described in Section 11 of this Privacy Policy. We will verify the identity of the requestor before responding, consistent with the verification procedures described in Section 13.