Privacy Policy

Information We Collect

We collect information you provide directly to us and through your use of our website and portal. Depending on how you interact with us, this may include your name, email address, phone number, company, account credentials and authentication information, commercial mortgage loan data, servicing or asset management data, property data, borrower and counterparty information, Trepp data, market data, CRM data, API credentials, API outputs, model inputs, model outputs, dashboards, analyses, recommendations, valuation materials, assumptions, portfolio information, and other business information of our clients or their counterparties. In many cases, we process business information submitted by or for our clients, including information about their borrowers, counterparties, portfolios, properties, loans, and transactions, as part of providing commercial mortgage advisory, analytics, modeling, portal, dashboard, and API support. We also collect information automatically, including IP address, device and browser identifiers, session identifiers, pages viewed, clicks, form submissions, traffic sources, campaigns, conversions, and other activity on the website or portal. Our website and portal may use cookies, pixels, analytics tags, session replay, and similar tracking technologies, including PostHog, Google Analytics, Google Tag Manager, and tags that Google Tag Manager may load. Session replay may create visual playbacks of website or portal interactions; we configure form fields and sensitive content to be masked or hidden by default. Cookies and Tracking Choices. Where required by law, we will request your consent before using certain analytics, session replay, advertising, or tracking technologies, and we will honor applicable browser-based, cookie-banner, or preference-center choices. If you disable cookies or tracking technologies, some website or portal features may not function properly. U.S.-Only Services. We operate and provide our services in the United States only. The website and portal are not directed to individuals outside the United States, and you should not use the services or submit personal information if you are located outside the United States.

How We Use Your Information

We may use the information we collect to provide commercial mortgage advisory, defeasance consulting, quote, valuation, analytics, modeling, portal, and related services; create and manage accounts; verify identity and support email-based authentication; generate, display, download, email, and share quotes or related materials; respond to inquiries and requests; create and manage CRM leads and client relationships; send updates and insights; analyze website and portal performance; monitor activity logs, shared-link opens, and user actions; maintain dashboards, models, analyses, recommendations, and assumptions; prevent fraud, misuse, and unauthorized access; comply with legal obligations; and improve our services, website, portal, and functionality.

Information Sharing

We do not sell personal information for monetary or other valuable consideration. We may disclose personal information and business information as described below. When we process personal information on behalf of our business clients, we do so as a service provider or processor subject to the terms of our agreements with those clients. Certain analytics, advertising, or tracking activities on our website may be considered a “sale,” “sharing,” or targeted-advertising disclosure under some U.S. state privacy laws. Where required, we will provide applicable notice, consent, opt-out, or preference-management mechanisms. We may share information with:

• Service providers, vendors, and sub-processors who assist in our operations, including hosting, analytics, session replay, tag management, CRM/Salesforce, email delivery, authentication, security, reporting, and support providers, subject to contractual confidentiality, privacy, and security obligations
• Legal authorities, regulators, courts, or other parties when required by law, legal process, or to protect rights, safety, property, or security
• Servicers, borrowers, counterparties, advisors, recipients of shared quote links, and other parties involved in a transaction, quote, valuation, request, or client-directed workflow, including when you choose to share a quote or request that we communicate with them

Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information and business information against unauthorized access, alteration, disclosure, or destruction. These safeguards may include encryption of names, email addresses, and similar details in activity and quote records; masking or hiding form fields and sensitive content in session replays; recipient-address validation and send-rate limiting for quote emails; expiring, unique, hash-based share links; access controls; logging; and email-based authentication. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Retention

We retain personal information and business information for as long as reasonably necessary to provide the services; maintain accounts, quotes, dashboards, analyses, activity histories, shared-link records, CRM records, and business records; comply with legal, accounting, tax, contractual, and regulatory obligations; resolve disputes; enforce agreements; and protect our rights and security. We may retain de-identified, aggregated, or anonymized information as permitted by law.

Your Rights

Depending on your state of residence and applicable law, you may have rights to request access to, correction of, deletion of, or portability of personal information; to opt out of certain sale, sharing, targeted advertising, profiling, or marketing activities; and to appeal a privacy-rights decision. We will not discriminate against you for exercising applicable privacy rights. To submit a request or exercise an applicable opt-out right, contact us at privacy@paragonla.com. We may need to verify your identity and authority before fulfilling a request. We will process opt-out preference signals, such as Global Privacy Control, where required by applicable law.

Children’s Privacy: The website, portal, and services are intended for business users and are not directed to children under 16. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will take steps to delete that information.

Contact Information

For questions about this Privacy Policy or our privacy practices, contact Paragon Loan Advisors by email at privacy@paragonla.com or call 800-940-2551.