PRIVACY POLICY - LAST UPDATED 11/24/2019

The website ("Website") you are currently viewing is owned and controlled by Norwich Commercial Group, Inc. dba TPO GO (referred to as "TPO GO", "our", "us", or "we" in this Privacy Policy). This Privacy Policy describes our information collection and sharing practices that apply to the information collected on the websites on which this Privacy Policy is posted (each, a "Website"), any current or future mobile application associated with a Website (each, a "Mobile Application"), and any associated functionality contained on a Website or Mobile Application (collectively, the "Services" and, together with a Website and the Mobile Application, the "System").

This Privacy Policy applies to information we collect through the System only. If you are or become a TPO GO customer, we will provide you a privacy notice describing our privacy practices related to the collection and sharing of personal information about our customers, as required by law.

TPO GO takes your privacy seriously. Protecting the privacy and security of consumers' personal information is an important part of the way we take care of our customers and users of this Website. By providing this policy, we hope to demonstrate our trustworthiness as an organization and our commitment to your safety and security in using our website.

WHAT PERSONAL INFORMATION DOES TPO GO COLLECT?

The following information may be collected when you use this Website:

• Name
• Email address
• Phone number
• Zip code
• Your server address
• The date and time of your visit to the web site
• The pages you accessed and the documents downloaded
• The previous web site you visited
• The type of browser you are using

HOW DOES TPO GO USE THE INFORMATION COLLECTED?

We reserve the right to use personal information you provide online to process your request for services, products or information as requested by you, for statistical purposes, and to enable us to improve the navigation functions of our Website. Where permitted by applicable law, third parties may be used from time to time to collect the above listed information on your online activities. Additionally, this Website may ask for specific personal information in order to respond to requests for information or to register users for particular services.

We do not sell, rent or lease the information that you provide to third parties, except as permitted or required by applicable law. We may use certain aggregated, anonymized information, such as System usage data, to improve and optimize our website for user benefit.

We may need to exchange information about customers with reputable information reporting agencies and business partners, in accordance with industry practices and to verify the existence and/or condition of customers’ accounts.

DOES TPO GO SHARE THE INFORMATION COLLECTED?

For everyday business purposes, we may share some of the information obtained from you in order to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus. Any information shared in this regard is not shared for these third parties to market to you, but rather so they may provide services to you and us in connection with your transaction as requested by you. For instance, information collected from you may be shared in order to conduct a property appraisal or to perform a credit check in connection with a residential mortgage loan transaction. This sharing of information is necessary in order for us to conduct our everyday business purposes and in order to provide the products or services you have requested. As permitted by law, we may share information we collect from you with companies providing services to us through formal contractual agreements for our analysis, market research and marketing purposes. Any information shared in this regard is not shared for these companies to use for their own purposes. Additionally, we may disclose your personal information as otherwise permitted or required by law.

SOCIAL MEDIA PLATFORMS AND WEBSITES

We will limit the use and collection of consumer information to that which is necessary to fulfill its obligations and provide excellent customer service. We do not sell, rent or lease the information collected through social media platforms, except as required by applicable law. Personal information will not be forwarded to any unaffiliated third party for marketing or used for any similar purpose without consent. In addition, we may collect information volunteered by a customer during the follow-up or application process and that information is treated with the same protection as all consumer information.

Any submission to any of our public pages contained on social media platforms are subject to applicable terms of use contained on that platform. We encourage you to review the applicable terms of use on any such social media platform prior to making any submissions.

DO YOU USE COOKIES OR OTHER TECHNOLOGIES TO COLLECT INFORMATION?

We use small text files, called "cookies", on our Websites by which we passively gather information about visitors’ use of the System. The use of this information includes, but is not limited to log analysis, collect statistics of usage, understand form completion, and aid in your ease of use. We do not track individual users. When you browse or visit one of our web sites, we may store certain information on your computer. This can help us to tailor our sites to your individual preferences and save you time if you visit the site again. Through your browser, you may disallow cookies by making the appropriate selection to inform you when cookies are set or to prevent cookies from being set. However, setting browser options to disallow cookies, in certain circumstances, may limit the functionality we can provide when you visit our site and prevent you from taking full advantage of the System, or certain features, and its capabilities.

WHAT STEPS DOES TPO GO TAKE TO PROTECT INFORMATION?

We do not sell, rent or lease client information. We restrict access to the information obtained from our web sites and web pages to our employees and trusted affiliates. We maintain physical, electronic, and procedural safeguards designed to protect your personal information. Companies providing online services on our behalf are required by contract to protect customer information and are only allowed to use the information in order to service your needs.

OPT OUT POLICY

We may send you emails with promotional offers only if you opt in to receiving such emails. If you would no longer like to receive information, newsletters or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions, or alternatively you may contact us in order to unsubscribe or have your email address removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.

EXTERNAL LINKS

For your convenience, our web sites and web pages may contain hyperlinks to third party sites not controlled by TPO GO or covered by this Privacy Policy. We recommend that you check the privacy statement of other sites you visit before providing any personal information.

DOES TPO GO COLLECT INFORMATION FROM CHILDREN?

The Website and System is intended for a general audience and is not intended to attract children under the age of 13. We do not knowingly collect or maintain information provided on the Website by children under the age of 13 in comply Children’s Online Privacy Protection Act. For more information, visit the FTC website's section regarding COPPA

HOW CAN I CHANGE OR UPDATE THE PERSONAL INFORMATION YOU COLLECTED ABOUT ME ONLINE?

Please contact us with any questions or for changes you may require.

RESIDENTS OF CALIFORNIA

For residents of California, also see our CCPA Privacy Policy Addendum

WILL TPO GO MAKE CHANGES TO THIS PRIVACY POLICY?

TPO GO reserves the right to make changes to its Privacy Policy. If we make changes, we will update this Website and provide the date the policy was changed.