Effective as of August 20, 2024
IntroductionThe Gravy mobile application (the “App”), along with the Gravy website (“Website”), is owned and operated by Clever Real Estate, Inc. (“Clever,” “Gravy,” “we,” “our,” or “us”). This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our application (“App”) and the services provided through our App (collectively, “Services”).
If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.
This Privacy Policy covers the following topics:
1. Collecting and Using Information
2. Cookies and Other Tracking Technologies
3. Third Party Processors
4. “Do Not Track” Signals
5. Choices About Your Personally Identifiable Information
6. Security
7. Third Party Links
8. Children’s Privacy
9. Notice to California Residents
10. How to Contact Us
1. Collecting and Using Information
Personally Identifiable Information We Collect Online
We collect Personally Identifiable Information from you through your use of the App and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide We may collect the following Personally Identifiable Information that you voluntarily provide to us:
• Create an Account. To create an account, you will provide us with your first and last name, phone number, and email address. You may also need to establish a username and password for future sign ins. If you decide to enroll in Gravy+, you will provide your payment information to Google or Apple through the mobile application stores. Google’s privacy policy is available
here and Apple’s privacy policy is available
here.
• Create a Virtual House Fund. We may collect, on your behalf, your account and other Personally Identifiable Information from third party sites that you register under your account via the App. We use Plaid to enable us to offer this banking service. Plaid’s privacy policy is available here:
https://plaid.com/legal/#consumers
• Join Rewards Program. To join the rewards program, you may provide us with your current rent payment amount, rent payment due date, lease end date, and rental address.
• Interact with our App or Services. When you send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you may need to provide us with your log-in information, name, and email address. We may collect, on your behalf, financial and other Personally Identifiable Information from the parties you have authorized us to share information with and from other parties (e.g., Consumer Reporting Agencies and other third party information providers). Where required by law, our data providers or otherwise, we will obtain your authorization before seeking Personal Information from such third parties. You may upload documents and files or self-report Personal Information (e.g. income, debt, assets, credit, home purchase goal, etc.) to the App, to allow us to provide more comprehensive services to you, and to enable us to share this information with other parties authorized by you. Depending on your use of the App, you also may submit information relating to your co-borrowers or other people.
• Schedule a Demo. To schedule a demo, you will provide us with your name and email address.
• Apply for a Job. To apply for a job, you will provide us with your name, email address, and any other Personally Identifiable Information that you may provide in your resume or featured on your LinkedIn profile.• Contact Us. To contact us, you will provide us with your name and email address.
Information as You Navigate Our App
We automatically collect certain Personally Identifiable Information through your use of the App and Services, such as the following:
• Usage Information. We collect information such as which of the pages on the App you access, the frequency of access, and what you click on while on the App.
• Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
• Mobile Device Information. In addition to the Device Information listed above, when you access our App on your mobile device, we collect and aggregate information about whether you are accessing the App via a mobile device or tablet, device type, and carrier.
• Location Information. We collect location information from App visitors on a city-regional basis.
Third Party Information
In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, as part of our account registration process, you may provide the name, email address, and phone number of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.
How We Use Your Personally Identifiable Information
We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and App, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
• Process your account registration;
• Provide the rewards program;
• Provide you with Gravy+ services and features;
• Provide you with the option to engage with lenders and pursue a mortgage;
• Provide you with the option to engage with real estate agents;
• Contact you regarding our products and services that we feel may be of interest to you;
• Advertise, market and promote our Services;
• Communicate with you about our App or Services or to inform you of any changes to our App or Services;
• Provide support;
• Maintain and improve our App and Services;
• Defend our legal rights and the rights of others;
• Efficiently maintain our business; and
• Comply with applicable law.
How We Share Your Personally Identifiable Information
We may share the information that we collect about you in the following ways:
• With service providers who perform data or App-related services on our behalf (e.g. hosting, maintenance, backup, analysis, etc.);
• With your account sponsor (e.g. our Clients);
• With mortgage lenders and/or real estate agents in connection with the Gravy Rewards program;
• With mortgage lenders and/or real estate agents who you may decide to contact through the App;
• To service providers to prepare, deploy and analyze advertising content;
• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
• To any other person or entity as part of any business or asset sale; and
• To any other person or entity where you consent to the disclosure.
2. Cookies and Other Tracking Technologies
How We Use CookiesLike many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).
We use Cookies to:
• Estimate audience size and usage patterns;
• Understand and save your preferences for future visits, allowing us to customize the App and Services to your individual needs;
• Advertise new content and services that relate to your interests;
• Keep track of advertisements and search engine results;
• Compile aggregate data about App traffic and interactions to resolve issues and offer better App experiences and tools in the future; and
• Recognize when you return to the App.
We set some Cookies ourselves and others are set by other entities. We use Cookies set by other entities to provide us with useful information to help us improve our App and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Crashlytics, and other similar companies.
How You Can Opt-Out of Cookies
Browser SettingsCookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the App.
You can find out more about Cookies and how to manage them by visiting
www.AboutCookies.org or
www.allaboutcookies.org.
Platform Controls You can opt out of Cookies set by specific entities by following the instructions found at these links:
Google:
https://adssettings.google.comFacebook:
https://www.facebook.com/about/adsTwitter:
https://twitter.com/personalization
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
We also use mobile advertising identifiers (e.g., Apple’s Identifier for Advertising (“IDFA”) or Google’s Android Advertising Identifier (“AAID”)). Most mobile devices include an identifier that allows application publishers, such as us, and marketers to track user activity on mobile devices for advertising purposes. We use mobile advertising identifiers for the same purposes for which we use cookies.
Google AnalyticsWe use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the App and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click
here.
3. Third Party ProcessorsTo ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use Plaid, a banking application programming interface, and Twilio, a cloud communications platform.
4. “Do Not Track” SignalsSome internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the App does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
5. Choices About Your Personally Identifiable InformationReview and Request Changes to Your Personally Identifiable Information
You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at
support@gravy.co.
Marketing Communications
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at
support@gravy.co.
6. SecurityWe maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
7. Third Party LinksThe App and Services may contain links that will let you leave the App and access another website. Linked websites are not under our control. This Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on this App and Services. We accept no responsibility or liability for these other websites.
8. Children’s PrivacyThe App and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
9. How to Contact UsTo contact us for questions or concerns about our privacy policies or practices please email us at
support@gravy.co or contact us at:
Clever Real Estate, Inc.
119 S Main Street
St. Charles, MO 63301
10. GLBA CONSUMER PRIVACY DISCLOSURE. The disclosure that follows directly below is only applicable to Gravy customers and those consumers who have previously attempted to sign up for Gravy products and services. It DOES NOT apply to any consumer visiting the Gravy website or mobile application who is not a Gravy customer or an individual who has previously attempted to sign up for Gravy products and services.
