Applied Business Software, Inc. (“ABS”) Privacy Policy

Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial institution, directly or through its affiliates, from sharing nonpublic information about you with a non-affiliated third party unless the institution provides you with a notice of its privacy policy and practices, such as the type of information that it collects about you and the categories of personal information or entities to whom it may be disclosed. Although ABS is not considered a “financial institution”, it may be considered an “affiliate” of a “financial institution”. In compliance with the GLBA, we are providing you with this document, which notifies you of the privacy policies and practices of our company.

The California Consumer Privacy Act (CCPA) provides consumers with specific rights regarding their personal information. Although ABS does not believe it is subject to the CCPA, it is important that you understand your rights under the CCPA. Under the CCPA you have the right to request that companies subject to the CCPA disclose certain information to you about their collection and use of your personal information over the past 12 months. Once a company receives and confirms your verifiable consumer request, that company will disclose to you:

• The categories of personal information collected about you

• The categories of sources for the personal information collected about you

• Their business or commercial purpose for collection or selling that personal information

• The categories of third parties with whom they share that personal information

• The specific pieces of personal information collected about you

• If they sold or disclosed your personal information for a business purpose

What information is collected?

ABS may collect information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.

Personal Information

As a loan origination and loan servicing software provider, we may receive, process or store certain information, including personal information, from Data Subjects. Data collection may include event logs, end user information (such as IP address, email address and computer name), and other data where relevant to a support or service request. ABS also collects Personal Information about you when you choose to provide such information to us. For example, you may provide us with Personal Information when you submit an online form, apply for a job, communicate with us by e-mail, or access client-specific content. This information may include your name; business or personal contact information, such as your address, email address or phone number; and any information that you provide as part of our website, products and services (collectively, “Personal Information”).

Data Collected Automatically

We automatically collect certain information about your use of our website and products and services. This information may include, for example, your IP address, your browser type and version, your device identifier, information about your computer and operating system, the length of your visit and the pages that you viewed on our website or products and services. We use cookies and similar technologies to collect this information. We also use cookies and similar technologies for other purposes such as to ensure authorized access to client-specific content, and to track client access to such content. Cookies are pieces of data stored on a user’s hard drive that contain information about a user. Please note that you may be able to view and delete these cookies using the features of your browser; however, deleting cookies may prevent you from being able to use the full functionality of the website.

Our website, products and services also automatically create logs regarding your activity on our website. These logs may identify the features that you use, the actions that you take, and the information that you access. We generally use this information in statistical and aggregate formats to assess the effectiveness of our Website and products and services and to better understand your priorities and interests.

Information Collected by Third Parties

We may permit third parties to use cookies or other technology to collect information about your online and products and services usage activities across our website, products and services and other websites and products and services over time for non-advertising purposes such as to help us analyze how visitors use our website, products and services.

What legal basis does ABS have for collecting processing my information?

ABS may process your information because:

• We have a contract with you

• You have given us permission to do so

• We must provide services to you after you have purchased something from us

• To comply with the law

All of these reasons are reasons ABS may legally process the information we have about you.

How is the collected information used?

We may use the Personal Information that you provide to us to operate and improve our business, including our websites and our products and services; to communicate with you; to provide you with information or services that you have requested; and for verification purposes. We may use and disclose any information that is aggregated or de-identified so that it does not identify you personally, in our discretion.

How is the information disclosed?

ABS may share your Personal Information as described below:

• With our vendors, consultants, agents, contractors, and other service providers that we use to support our business;

• To provide you with any information or services that you request;

• To respond to subpoenas, court orders, and other legal process, or as otherwise required by law;

• To exercise ABS’ legal rights or defend ABS against legal claims, to enforce our contracts, to investigate, respond to and resolve problems or inquiries (including governmental inquiries), or to permit us to pursue available remedies or limit the damages that we may sustain;

• In connection with an actual or potential merger, sale, acquisition, assignment, or transfer of all or part of our assets, affiliates, lines of business, or products and services, including at bankruptcy;

• With our affiliates, subsidiaries, or parent companies; and

• With your consent.

Third-Party Links and Services

Our websites, products and services may contain links to third-party websites and products and services. We do not control these linked websites and this Privacy Policy does not apply to those websites. We encourage you to read the privacy policy of any third-party website that you visit before you provide any information to that website’s owner.

Do we collect information about children?

We do not knowingly collect Personal Information from children under 16 years old.

How long will you keep my personal information?

We will keep your personal information:

• For as long as required by law

• Until we no longer have a valid reason for keeping it

We may keep just enough of your personal information to ensure that we comply with your request not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer.

If you have questions about our Data Retention Policy, please contact: legal@absnetwork.com.

How will you be notified of changes to this Privacy Policy?

We reserve the right to modify or update this Privacy Policy periodically. If we change our practices with respect to your information, we will notify you by posting a revised Privacy Policy on our website and accessible at www.themortgageoffice.com/privacy.aspx. We encourage you to revisit this Privacy Policy periodically to stay informed about our practices with respect to your information.

Whom can you contact if you have additional questions?

If you have questions regarding our Privacy Policy please contact us by email at legal@absnetwork.com

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