Online Privacy Policy

Finance of America Holdings LLC

Finance of America Holdings LLC: Online Privacy Notice

Last updated: November 6, 2023

We at Finance of America Holdings LLC, including its subsidiary Finance of America Reverse LLC, including its d/b/a AAG, (collectively, “Finance of America Companies”) respect your concerns about privacy. This Online Privacy Notice describes the types of personal information we obtain, how we may use the information, with whom we may share it and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

This Online Privacy Notice applies to personal information we obtain through this website and other sites, applications and other data collection points that link to this Online Privacy Notice (collectively, the “Site”). Other privacy principles or policies could apply depending on how you interact with us, the financial products or services you may ultimately obtain from us, or the jurisdiction in which we are doing business with you.

If you apply for or obtain financial products or services from some of our businesses, our financial consumer privacy notice applies to information collected throughout that application and loan process. A copy of the notice can be found here.

If you are a California consumer and would like information about our online and offline privacy practices and how to exercise your rights, please see our “State Privacy Rights Addendum found below.

We may obtain the following types of personal information when you choose to provide it through our Site:

• Contact information, such as your name, telephone number, postal address and email address;
• your loan number and Social Security number when you register with us;
• login credentials, such as your username and password;
• financial account information when you make a payment to us;
• information about your education, work and military history, legal work eligibility status; and
• any other personal information in content you provide on our Site.

In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is a tiny graphic image that may be used on our Site. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.

We may have obtained personal information about you from various sources, including as described below:

• Directly from you, such as when you provide the information, connect to us via social media, or send us questions, requests or comments
• From your devices, such as when you visit our Site
• Your family or friends, such as when they provide us with your contact information
• Our affiliates
• Vendors who provide services on our behalf (such as data analytics and lead providers)
• Social media networks
• Business partners (such as loan officers and brokers)
• Consumer data resellers
• Public databases

We use the information we obtain through the Site to:

• create and manage your account;
• offer products and services to you;
• assess your eligibility for, administer and service a loan;
• communicate with you about, and administer your participation in, surveys, events, programs, contests, promotions and other offers;
• display content on our Site;
• respond to and communicate with you about your requests, questions and comments;
• operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Site; and performing accounting, auditing, billing, reconciliation and collection activities);
• perform data analyses and other processing (including market and consumer research, trend analysis, financial analysis, anonymization, encryption and tokenization of personal information);
• protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards and our policies.

In addition, we use information collected online through cookies, web beacons and other automated means (collectively “cookies”) for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content (including advertising) tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our business. We also use this information to help diagnose technical and service problems, administer our Site, and identify users of our Site. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We may use third-party web analytics services on our Site, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyze your use of the Site. To learn more about Google Analytics and how to opt out, please visit support.google.com/analytics/answer/181881?hl=en.

We may share information we collect about you with advertisers and publishers to serve ads for our products and services that we think might be interesting to you. You may see these ads when you use multiple devices or visit websites that are not owned by Finance of America Companies. Currently, only our Finance of America Reverse and AAG organizations engage in this type of targeted advertising practice.

If you would prefer not to accept advertising cookies, your browser may allow you to change your settings to disable existing cookies or automatically reject cookies. You will need to replicate your chosen settings on each browser and each device where you wish to change your cookie settings. These settings only apply when the targeted advertising we show you is accomplished through cookies, web beacons, and similar online technologies. Please note that even if you take these steps, you may continue to see ads from us, but the ads will not be based on your interactions with us.

Our Site is not designed to respond to “do not track” signals received from browsers.

We do not sell for money or otherwise share personal information about you, except as described in this Online Privacy Notice. We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share the personal information we obtain with our affiliates and joint marketing partners. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. This includes affiliate or business partners. The Opt-In is not transferable to another party involved in the process.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We reserve the right to transfer a copy of any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). We may continue to use or share any information we retain in ways that are consistent with this Online Privacy Notice.

We offer you certain choices about how we communicate with you and what information we collect from you.

Email

To remove yourself from the email marketing list for Finance of America Reverse, please click the unsubscribe link in the footer of marketing emails you receive, or contact us as listed in the How To Contact Us section of this Online Privacy Notice.

To remove yourself from the email marketing list for AAG, you may click here to unsubscribe.

Phone Calls

To be placed on our internal do not call list for Finance of America Reverse, please call us at 1-888-488-8471.

To be placed on our internal do not call list for AAG, please call us at 1-866-576-6074.

Other Inquiries

To update your preferences, ask us to remove your information from our email or call marketing lists or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice.

Please know that, even if you opted out of receiving marketing communications from us by email or over the phone, we may still contact you for transactional or informational purposes.

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Finance of America Companies. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Finance of America Companies, any use of those websites, or the privacy practices of those websites.

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

We retain your personal information for as long as reasonably necessary to fulfill the business purposes that we describe in this privacy policy, unless a longer retention period is required or permitted by law.

Our Site is designed for a general audience and is not directed to children. We do not knowingly collect or solicit personal information from children under thirteen (13) years of age through our Site. If we become aware that we have collected personal information from a child under thirteen (13) years of age, we will promptly delete the information from our records. If you believe a child under thirteen (13) years of age may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Online Privacy Notice.

This Online Privacy Notice will be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated.

If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@financeofamerica.com or write to us at:

Finance of America Companies
c/o Finance of America Holdings LLC
Attn: Legal
5830 Granite Parkway, Suite 400
Plano, TX 75024

Or

Finance of America Reverse LLC
Attn: Legal
8023 East 63rd Place
Suite 700
Tulsa, OK 74133

1. Collection, Use, and Disclosure of Personal Information

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

   • Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier, cookies, beacons, pixel tags, mobile ad identifiers and similar technology), telephone number, online identifier, internet protocol address, email address, Social Security number, driver’s license number, passport number, and other similar identifiers
   • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
   • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
   • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
   • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
   • Geolocation Data: information about your location, such as your physical location.
   • Sensory Information: audio, electronic, visual or similar information
   • Employment Information: professional or employment-related information
   • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
   • Sensitive Personal Information: social security number, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, the contents of mail, email, and text messages, and information concerning sex life or sexual orientation

   We may collect, use, or disclose your personal information for the purposes described in our Online Privacy Notice. In addition, we may collect, use, or disclose your personal information for certain business purposes specified in CCPA, including as described below:

   • Performing Services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
   • Auditing: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
   • Short Term Use: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
   • Security Purposes: Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
   • Debugging: Debugging to identify and repair errors that impair existing intended functionality
   • Undertaking Internal Research: Undertaking internal research for technological development and demonstration
   • Undertaking Other Activities: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

2. Our Prior Collection, Use and Disclosure of Personal Information

   We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this Addendum. For the personal information collected during that timeframe, we describe below information regarding our disclosure of personal information with third parties.

   Disclosure of Personal Information for Specific Business Purposes

   We may have disclosed your personal information with certain categories of third parties, including as described in our Online Privacy Notice and below, including for the business purposes described above.

   Categories of Third Parties	Categories of Personal Information
   Our affiliates	Identifiers Additional Data Subject to Cal. Law Protected Classifications Commercial Information Online Activity Geolocation Data Sensory Information Employment Information Inferences Sensitive Personal Information
   Third-party vendors who provide services on our behalf (such as data analytics providers)	Identifiers Additional Data Subject to Cal. Law Protected Classifications Commercial Information Online Activity Geolocation Data Sensory Information Employment Information Inferences Sensitive Personal Information
   Corporate business partners (such as parties involved in a transfer of our assets)	Identifiers Additional Data Subject to Cal. Law Protected Classifications Commercial Information Online Activity Geolocation Data Sensory Information Employment Information Inferences Sensitive Personal Information
   Professional services organization, such as auditors and law firms	Identifiers Additional Data Subject to Cal. Law Protected Classifications Commercial Information Sensory Information Employment Information Inferences Sensitive Personal Information
   Marketing partners (including network advertising companies, publishers and business partners)	Identifiers Protected Classifications Commercial Information Online Activity Geolocation Data Employment Information Inferences
   Social Networks	Identifiers Online Activity
   Law enforcement agencies and government entities, as described in our Online Privacy Notice	Identifiers Additional Data Subject to Cal. Law Protected Classifications Commercial Information Online Activity Geolocation Data Sensory Information Employment Information Inferences Sensitive Personal Information

   We do not sell your personal information in exchange for money. We do not have actual knowledge that we sell personal information of minors under sixteen (16) years of age.

3. California Consumer Privacy Rights

   You have certain choices regarding your personal information, as described below:

   • Request to Know:You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold or shared about you, including:
     1. The categories of personal information we collected about you
     2. The categories of sources from which we collected your personal information,
     3. The business or commercial purposes for collecting and sharing your personal information,
     4. The categories of third parties to whom we disclosed your personal information, and
     5. The specific pieces of personal information we collected about you.

   To submit a request to know, please complete the webform here or call us at 1-888-488-8471.

   • Request to Delete: You have the right to request that we delete certain personal information we have collected from you, subject to certain exceptions under applicable law. To submit a request to delete, please complete the webform here or call us at 1-888-488-8471.
   • Do Not Sell or Share My Personal Information: You have the right to request that we do not sell or share your personal information.  California defines a “share” of personal information for which you may opt-out as the transfer of information for cross-context behavioral advertising.

   We do not sell your personal information to third parties for money, but we do share your personal information with third parties for cross-context behavioral advertising and you have the right to opt out of this sharing. This choice only applies to Finance of America Reverse LLC, including its d/b/a AAG, as others in Finance of America Companies do not engage in cross-context behavioral advertising.

   Categories of Third Parties	Categories of Personal Information
   Marketing partners (including network advertising companies, publishers and business partners)	Identifiers Protected Classifications Commercial Information Online Activity Geolocation Data Inferences
   Social Networks	Identifiers Online Activity

   To submit an opt-out request, please navigate to our Finance of America Reverse websites (www.far.com, www.farwholesale.com, and www.fareverse.com) and AAG websites (www.aag.com, www.aagmortgage.com, www.americanadvisorsgroup.com/, and solutions.aag.com) and record your opt-out wishes using the “Do Not Sell or Share My Personal Information” link in the footer of the website. We also treat the Global Privacy Control signal as an opt-out request. Please note that your request to opt-out of the sale or share of your personal information can only be linked to the browser you use when you make the request or have enabled the Global Privacy Control signal.

   • Request to Correct: You have the right to request that we correct your personal information if you believe it is inaccurate. To submit a request to correct, please complete the webform here or call us at 1-888-488-8471.
   • Limit the Use of My Sensitive Personal Information: CCPA’s definition of sensitive personal information includes the following: social security number, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, the contents of a mail, email, and text messages, and information concerning sex life or sexual orientation. While we do collect, use, and share your sensitive personal information, we only do so for the following business purposes:
     1. Purposes covered under the GLBA, such as funding and servicing loans
     2. Helping to ensure security and integrity of our systems and information
     3. Short-term, transient use
     4. Performing services for you on behalf of the business, including maintaining or servicing accounts, providing customer service, and financing

   California law provides its residents a right to opt-out of the processing of sensitive personal information in certain circumstances. Each of the limited business purposes for which we process your sensitive personal information are exempt from this opt-out right.

   • Shine the Light Request: Subject to certain limitations under California Civil Code § 1798.83, you may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To submit a Shine the Light request, email us at privacy@financeofamerica.com

   Authorized Agents.To submit a request as an authorized agent on behalf of a consumer please email your request to privacy@financeofamerica.com and include a signed authorization from the consumer. You may also call us at 1-888-488-8471 to submit this request.

   Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, to delete your information or to correct your information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

   Financial Incentives. From time to time, our American Advisors Group business may offer financial incentives in connection with the collection or use of personal information related to our consumer surveys. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at aagcares@aag.com or by calling us at 866-219-7753.

   Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Addendum is available in alternative formats upon request by emailing privacy@financeofamerica.com or calling 1-888-488-8471.