Privacy Policy

Cleared by Kite, Inc. ("Cleared by Kite," "we," "us," or "our") operates this website and is developing services for the U.S. mortgage origination market. This Privacy Policy describes how we collect, use, share, and protect information in connection with our website and our pre-launch and future services. By using our website or services, you agree to the practices described here.

1. Information We Collect

Information you provide

We collect information you submit to us directly, including:

• Contact information (name, email address, phone number)
• Identity information (legal name, address, date of birth, Social Security number, government-issued identification) submitted as part of our services
• Financial information necessary for verification, including employment, income, and asset information
• Communications you send to us

Information from third-party data providers

We obtain information from third-party data providers as part of our verification services, including:

• Bank account, balance, and asset data via Plaid Inc.
• Income and employment data via providers such as Truework, Inc. and Argyle Systems Inc.
• Identity verification data via providers such as Persona Identities, Inc.
• Credit report data from consumer reporting agencies (Equifax, Experian, and TransUnion), subject to the Fair Credit Reporting Act
• Public records data, including bankruptcy, judgment, and lien filings

Technical information

When you visit our website, we automatically collect technical information such as IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. We use this information to operate, secure, and improve our website.

2. How We Use Information

We use the information we collect to:

• Provide, develop, and improve our services
• Verify identity, employment, income, assets, and credit standing
• Share verified information with third parties at your direction
• Communicate with you about our services and respond to inquiries
• Comply with legal obligations and regulatory requirements applicable to mortgage origination and consumer financial services
• Detect, prevent, and respond to fraud, security incidents, and other harmful activity

3. How We Share Information

With third parties at your direction

When you authorize us to share verified information with a third party such as a mortgage lender, we provide the verified information to that party for the purpose stated in your authorization. We share only the information necessary to fulfill your request and do not provide underlying source data (such as raw bank transactions or unprocessed records) to third parties.

With service providers

We share information with vendors that perform services on our behalf, including data providers, cloud infrastructure providers, identity verification services, fraud prevention services, and analytics providers. These vendors are bound by contractual obligations to handle information consistently with this Privacy Policy.

For legal reasons

We may disclose information if required by law, legal process, or government request, or where we believe disclosure is necessary to protect the rights, property, or safety of Cleared by Kite, our users, or others, or to investigate fraud or violations of our terms.

In business transfers

If Cleared by Kite is involved in a merger, acquisition, financing transaction, or sale of assets, your information may be transferred as part of that transaction, subject to the protections of this Privacy Policy.

4. Third-Party Data Providers

Our services rely on several third-party data providers. Each provider has its own privacy policy that may apply to information collected through their services:

• Plaid Inc. — bank account, balance, and asset verification
• Truework, Inc. — income and employment verification
• Argyle Systems Inc. — payroll and income verification
• Persona Identities, Inc. — identity verification
• Equifax, Experian, and TransUnion — consumer credit reporting

We encourage you to review the privacy policies of these providers for additional information about their practices.

5. Data Retention

We retain information for as long as necessary to provide our services, comply with legal and regulatory obligations (including those applicable to mortgage origination recordkeeping), resolve disputes, and enforce our agreements. Specific retention periods vary depending on the category of data and applicable law.

6. Your Rights

Depending on your state of residence, you may have rights to:

• Access the information we hold about you
• Request correction of inaccurate information
• Request deletion of your information, subject to legal retention requirements
• Opt out of certain uses of your information
• Receive a portable copy of your information

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what information we collect, the right to delete information, and the right to direct us not to sell or share their information. We do not sell personal information.

To exercise any of these rights, contact us at lily@clearedbykite.com.

7. Children's Privacy

Our services are not directed to individuals under 18, and we do not knowingly collect personal information from minors. If you believe we have collected information from a minor, please contact us so we can take appropriate action.

8. Security

We implement reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, use, disclosure, alteration, or destruction. No security measure is perfect, however, and we cannot guarantee the security of information transmitted to or stored by us.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through our website or by other reasonable means. Continued use of our services after changes constitutes acceptance of the revised policy.

10. Contact Us

For questions about this Privacy Policy, requests regarding your information, or complaints:

Cleared by Kite, Inc.
1314 East Las Olas Boulevard, 2166
Fort Lauderdale, FL 33301
lily@clearedbykite.com