Last updated January 21, 2022
Welcome to Tovodata.com
- Information Collection and Use
- Information Sharing Related to Loan Products, Insurance Products, or Service Requests
- Children’s Privacy
- Anti-Span Policy
- Confidentiality and Security
- Your Rights and Choices
- California Privacy Notice
- Contact Us
A Note About Our Network
This policy applies only to our Network, and specifically excludes websites maintained by other companies or organizations to which we link. This policy shall only apply to information that we collect online, not off.
1. Information Collection and Use
We collect, and use personal information about you, to respond to your request for products and services offered through this website. Further, we will also collect information from you in order to notify you about products, services, or other opportunities which we feel will be of interest to you. Additionally, even though information that we may collect about you may be considered publicly available (through government records or available through widely distributed media), we will treat all personal information submitted by you as non-public personal information. We may collect information about you from (but not be limited to) the following sources:
- Information provided by you in connection with obtaining financial products or services such as mortgage loans (such as full name, telephone number, self-assessed property value, and social security number) and insurance quote requests (such as personal information, personal physical characteristics, personal medical information). Additionally, we may also collect demographic information from these sources.
- Information you provide us when you register to receive communications from us (such as your email address, or phone number).
- Information you may provide us through surveys, feedback, or other forms hosted on our website, our Network, or the pages of an iLeads.com ® partner.
In addition, we might receive information about you from other sources (such as service providers) for tracking purposes.
2. Information Sharing Related to Loan Products, Insurance Products, or Service Requests
If you submit a request for a loan product, insurance product, or service offered through this website, we will share the personal information contained in your request form (such as your full name, physical address, physical characteristics, telephone number, property location, self-assessed property value, social security number, or other personal information) with lenders and/or agents within our provider network to process and fulfill your request. In regards to loan products or service requests, we may obtain additional information about you and we may share that information with lenders within our provider network. For example, we may use your social security number to obtain your credit score to help us connect you with a lender. In addition, lenders that receive your personal information may use your social security number to pull your credit score and/or credit report in order to process and fulfill your request. All lenders in our provider network (which include banks, mortgage lenders and brokers) have entered into marketing agreements with iLeads.com ® and are required to comply with federal and state privacy regulations. iLeads.com ® and all participating lenders or agents do not guarantee a response to your service request.
In regards to insurance products or service requests, we may obtain additional information about you and we may share that information with agents, brokers or insurers within our provider network. For example, we may use your physical characteristics (height / weight) to help connect you with an agent that can effectively help you with your service request. All agents, brokers, and insurers within our provider network have entered into marketing agreements with iLeads.com ®, and are required to comply with federal and state privacy regulations. iLeads.com ® and all participating agents, brokers, and insurers do not guarantee a response to your service request.
All lenders or agents within our provider network may contact you by telephone, email, or mail, based on the information you have provided to us, in order to process and fulfill your request, even if you have opted into the National Do Not Call List administered by the Federal Trade Commission, any state equivalent Do Not Call List, or the Do Not Call List of an internal company. If one of the lenders or agents contacts you by telephone, and you wish not to be contacted again by that lender or agent, (with respect to your inquiry), then you should specifically make a request to that lender or agent not to contact you again. If the lender or agent disregards your request and contacts you again, please let us know immediately by sending an email to iLeads.com ® Client Services. Please note that the lenders or agents may maintain the information you provided whether you elect to use their services or not.
For information about how to opt-out of certain sharing of your information, please see our Your Rights and Choices section.
3. Children’s Privacy
This site is not intended for use by minors (those under 18 years of age). You must be at least 18 years old to use this website. We will not knowingly collect, use or disclose personal information about visitors under 18 years of age. If you are under 18 years of age, you can use the services offered on our website only in conjunction with your parents or guardians.
4. Anti-Spam Policy
You will not receive iLeads.com ® email communications unless you submit your email address to us to receive them. We do employ third party companies to advertise services and products that we offer. From time to time, you may also receive emails that advertise iLeads.com ® services from third party publishers. We require all third party publishers to be Can-Spam compliant for all mailings that are sent on behalf of iLeads.com ®. If you wish to stop receiving any email from iLeads.com ® or a third party publisher, you should follow the opt-out instructions included in the email.
- Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and
- Usage data, such as browsing history, time spent on the Sites, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Site.
- Necessity. To enable features that are necessary for providing you the services on our Sites, such as keeping you signed in, improving security, and preventing and detecting fraud.
- Preference. To allow us to remember your preferences and identify you when you return to our Sites.
- Analytics. To allow us to understand how our Sites are being used, track site performance and content views, and make improvements to the content, products or services.
- Advertising. To deliver targeted advertising based on your preferences, location, and/or interests across different services and devices and measuring effectiveness of ads.
- Social media. To enable the sharing of content from our Sites through social networking and other sites.
You can manage cookies by using features and functions available on most Internet browsers. For example, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. You can find instructions for managing cookie controls on websites for particular browsers.
- Microsoft Internet Explorer browsers
- Apple Safari browsers
- Mozilla Firefox browsers
Please note that disabling cookies may prevent you from using specific features on our sites and other websites.
If you wish to opt out of our sharing of the data that is gathered when you visit our Site for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements. Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings. You may also visit these websites for more information on how you can opt back in to the sharing of data. Please note that iLeads.com ® does not maintain this web tracking data in an identifiable manner.
iLeads and third-party advertisers may use web beacons. Some iLeads websites and advertisements contain web beacons in the form of clear .gif files, which are electronic images that allow for the collection of information about your interactions on our sites. Web beacons may be used to place advertisements, to understand website traffic patterns and the number of visitors to our website, and to measure the effectiveness of advertisements or email advertising messages.
6. Confidentiality and Security
The security of your personal information is very important to iLeads.com ®, and we take a number of steps to safeguard it. For example:
- We limit access to personal information to those employees or agents who assist us in providing requested products and services to you. Employees are required to comply with our strict policies and procedures regarding the handling of your personal information. Employees who violate these policies are subject to our normal disciplinary process. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard personal information about you.
- We use industry standard data encryption technologies within the iLeads.com ® system.
7. Your Rights and Choices
Opt-out notice. If you prefer that we not share with our partners your information, you may “Opt Out” — that is, you may direct us not to make those disclosures (except as permitted by law). To “opt out” please email us at: Client Services.
Your Nevada privacy rights. Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please contact us using the information in the Contact Us section at the end of this Policy, and provide “Nevada Privacy Rights” in the subject line. You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond.
9. California Privacy Notice
For purposes of this Notice only, “personal information” shall mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It includes personal information collected by iLeads.com ® online, offline, or by any other means.
A. Your Privacy Rights
If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:
Right to Know. You have a right to know:
- The categories of personal information we have collected about you.
- The categories of sources from which we collected your personal information.
- The business or commercial purpose for collecting or sharing your personal information.
- The categories of third parties with whom we have shared your personal information.
- The specific pieces of your personal information we have collected.
Right of Deletion. You have a right to request that we delete the personal information we have collected about you.
Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information to third parties.
Right of Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights by denying goods/services, charging a different price for goods/services, imposing penalties, providing different levels of service/quality or suggesting any of the above.
The above rights are subject to various exclusions and exceptions under applicable laws.
How to Submit a Request
To exercise any of the above rights, please submit a verifiable consumer request to us by:
Only the person whose information is requested (expect in the case of a minor) may make a verifiable request twice within any 12-month period. The request must provide sufficient information to allow us to reasonably verify you are the person for whom we have collected personal information and describe the information requested in enough detail for us to properly respond. This includes your name, address, email address, and/or phone number.
We will respond in the timeframe as allowed by law. We do not require account creation and will only use the information provided with the request to verify the identity of the requestor. We cannot respond to a request without reasonable identity verification. We may deny your deletion request if retaining the information is necessary as allowed by law or for another authorized purpose by California law. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to Client Services.
We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.
B. Categories of Personal Information We Collect
We may have, or has, collected the following categories of personal information within the last twelve (12) months.
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
C. Categories of Sources from Which We Collected Personal Information.
- Consumer Directly
- Public Records
- Business Partners
D. Business or Commercial Purpose for Collecting/Sharing Personal Information
- To fulfill or meet the reason for which the information is provided
- To provide you with information, products, or services that you request from us or a business partner
- To provide you with email alerts and other communications concerning products, services, or information, from us or our business partners
- To perform services on behalf of our business partners
- Advertising or marketing purposes
- To carry out our obligations and enforce our rights
- To improve our website, products and services
- For testing, research, analysis and product development.
- To help maintain or improve the safety, security, quality and integrity of our websites, products and services, databases and other technology assets, and businesses.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
E. Categories of Third Parties with Whom We Shared Personal Information
|Category of Personal Information||Categories of Third Parties Disclosed To||Categories of Third Parties Sold To|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).|
|C. Protected classification characteristics under California or federal law.|
|D. Commercial information.|
|F. Internet or other similar network activity.|
|I. Professional or employment-related information.|
|K. Inferences drawn from other personal information.|
We do not knowingly sell the personal information of individuals under 16 years of age.
F. Notice of Right to Opt-Out
G. Direct Marketing by Third Parties
iLeads.com ® discloses personal information to third parties for their own direct marketing purposes. California residents have the right to request information regarding such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please contact us at Client Services.
10. Contact Us
Questions and Suggestions
By sending an email to:
By sending a letter to:
Attn: Consumer Support
567 San Nicolas Drive Suite 180, Newport Beach, CA 92653
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