Privacy Policy

MINA Pro LLC (“MINA Pro,” “MINA,” “we,” “us,” or “our”) provides technology used by mortgage professionals and their customers.

1. MINA’s Role

MINA operates in different capacities depending on the information and relationship involved.

For information collected directly through MINA’s public website for MINA’s own business purposes—such as demo requests, business inquiries, account administration, security, and MINA customer relationships—MINA determines how that information is used.

For borrower and mortgage-loan information processed through a Customer Organization’s MINA workspace, MINA generally processes that information to provide technology and services to the applicable mortgage broker, lender, processing company, or other organization (“Customer Organization”).

The Customer Organization generally controls the underlying mortgage relationship and determines why borrower information is collected and used.

Certain processing may also be performed by MINA as necessary to operate, secure, maintain, improve, and comply with legal obligations relating to the Services.

2. Information We Collect

Depending on how the Services are used, MINA may process the following categories of information.

Account and Identity Information

This may include:

• name;
• email address;
• telephone number;
• username and account identifiers;
• organization and job role;
• authentication information; and
• account permissions.

Borrower and Mortgage Information

Information submitted in connection with a mortgage application or loan file may include:

• name and contact information;
• residential and mailing addresses;
• date of birth;
• Social Security number or other government identifiers;
• citizenship or residency information when required for the mortgage process;
• employment and employment history;
• income and compensation;
• assets and liabilities;
• banking and financial information;
• property information;
• mortgage and housing information;
• loan-request information;
• credit-related information;
• insurance-related information;
• declarations and application responses;
• co-borrower information; and
• other information contained in a mortgage application.

Documents

MINA may process documents uploaded or transmitted in connection with a mortgage transaction, including:

• identification documents;
• pay statements;
• bank and asset statements;
• tax documents;
• employment documentation;
• mortgage documents;
• property records;
• insurance documents;
• disclosures and authorizations;
• signed or acknowledged documents; and
• other documents requested by an authorized mortgage professional.

Communications

MINA may process communications associated with the Services, including:

• email;
• email attachments;
• text-message information;
• support communications;
• document-related communications; and
• communications associated with a loan file.

Connected Email Accounts

Authorized Customer Organization users may connect supported email accounts, including Google/Gmail accounts, to MINA.

When connected, MINA may process messages and attachments in the connected mailbox to identify and associate communications with loan files and authorized workflows.

This process may analyze messages that ultimately are determined not to relate to a loan. Messages that cannot automatically be associated with a loan may be presented to authorized users as unmatched communications for review.

Usage and Technical Information

MINA may automatically collect information such as:

• IP address;
• browser type;
• device information;
• operating system;
• login activity;
• dates and times of access;
• pages or features accessed;
• audit and activity logs;
• security events; and
• diagnostic information.

Business and Demo Inquiries

When someone requests a demonstration or contacts MINA regarding its services, MINA may collect information such as:

• name;
• business email;
• telephone number;
• company;
• job title; and
• information submitted with the inquiry.

MINA may use this information to respond by email or telephone and discuss MINA products or services.

3. Sensitive Personal Information

Mortgage transactions inherently involve sensitive information.

MINA may process sensitive personal information including Social Security numbers, financial information, account information, government identification, income, employment information, credit-related information, authentication information, and contents of communications.

MINA processes this information for purposes reasonably necessary to provide, secure, support, and administer the Services and authorized mortgage workflows, or as otherwise permitted or required by law.

MINA does not use sensitive borrower information for unrelated consumer advertising.

4. How We Use Information

MINA may use personal information to:

• provide and operate the Services;
• create and administer accounts;
• support mortgage applications and loan workflows;
• receive and organize documents;
• associate documents and communications with loan files;
• facilitate communications;
• support electronic acknowledgments and signatures;
• generate workflow tasks and alerts;
• provide customer and technical support;
• authenticate users;
• maintain audit trails;
• protect against fraud and unauthorized access;
• troubleshoot and improve platform reliability;
• develop and improve MINA functionality;
• comply with legal obligations;
• enforce agreements;
• investigate security incidents; and
• protect MINA, Customer Organizations, borrowers, and others.

MINA may also use business-contact information to respond to inquiries and communicate with prospective and existing business customers.

5. Artificial Intelligence

MINA uses or may use artificial intelligence and automated technologies as part of the Services.

These technologies may process borrower information, documents, communications, and other loan information to:

• extract and organize data;
• classify documents;
• generate summaries;
• identify inconsistencies or potentially missing information;
• validate data formatting;
• assist with loan conditions or workflow tasks;
• associate information with loan files;
• analyze communications and attachments; and
• generate alerts, suggestions, or other assistance for authorized mortgage professionals.

For example, automated systems may examine information contained in a document or application to determine whether a field appears incomplete or inconsistent.

AI-generated information is intended to assist authorized mortgage professionals. MINA does not use AI to independently approve or deny a mortgage loan.

MINA may use third-party AI technology providers to perform authorized processing on MINA’s behalf, subject to applicable contractual and security requirements.

MINA will update this Privacy Policy if its practices regarding the use of identifiable borrower information for development or training of AI models materially change.

6. How We Disclose Information

MINA may disclose personal information as necessary to provide the Services.

Customer Organizations and Authorized Users

Borrower and loan information may be available to authorized users within the applicable Customer Organization.

A Customer Organization may authorize employees, loan officers, processors, administrators, contract processors, or other users to access specified information.

Access permissions are controlled according to the organization’s configuration and authorized roles.

Service Providers

MINA may provide information to companies that perform services supporting MINA, such as:

• cloud hosting and infrastructure;
• data storage;
• email services;
• artificial intelligence processing;
• communications and messaging;
• security;
• document processing;
• electronic-signature technology;
• customer support; and
• other technical services.

These providers may process information only as appropriate to provide their services and subject to applicable agreements and legal requirements.

MINA’s current technology environment may include services provided by Amazon Web Services (AWS), Google/Gmail, and OpenAI.

Providers and infrastructure may change as the Services develop.

Customer-Enabled Integrations

Customer Organizations may enable integrations with third-party providers. These may include:

• lenders and wholesale lenders;
• loan origination systems;
• credit and data providers;
• communications providers;
• electronic-signature providers;
• document providers;
• pricing services;
• settlement or mortgage service providers; and
• other authorized technology services.

When an integration is enabled, MINA may transmit information to or receive information from the provider as necessary to perform the requested function.

Legal, Security, and Corporate Purposes

MINA may disclose information when reasonably necessary to:

• comply with law, regulation, subpoena, court order, or lawful governmental request;
• protect rights or property;
• detect or investigate fraud;
• respond to security incidents;
• enforce agreements;
• protect users or the public; or
• complete a merger, acquisition, financing, reorganization, or sale of business assets, subject to applicable legal requirements.

7. We Do Not Sell Borrower Personal Information

MINA does not sell borrower personal information.

MINA does not disclose borrower personal information to third parties for those third parties’ independent advertising or marketing purposes.

MINA does not use borrower mortgage information to advertise unrelated products directly to borrowers.

8. Mobile/SMS Privacy

Where SMS messaging is offered, a borrower may voluntarily provide a mobile telephone number and separately consent to receiving loan-related text messages from or on behalf of the applicable Customer Organization.

SMS consent is not required to apply for a mortgage, use the borrower portal, or obtain services.

Mobile information will not be shared with third parties or affiliates for their own marketing or promotional purposes.

Information may be provided to service providers and subcontractors that assist in delivering or supporting requested messaging services.

Text-message originator opt-in data and consent will not be sold or shared with third parties or affiliates for their own marketing or promotional purposes.

Users may withdraw SMS consent by replying STOP. Additional instructions may be provided at the point of consent.

9. Email Communications

Loan-related and account-related emails may be necessary to administer a mortgage transaction or provide the Services.

MINA and Customer Organizations may therefore send or facilitate transactional or service communications concerning applications, documents, requested actions, account security, and loan status.

Marketing communications, if any, will be handled separately as required by applicable law.

10. MINA Personnel Access

MINA does not limit all borrower-data processing solely to automated systems.

Authorized MINA personnel may access or view borrower information, loan information, documents, or communications when reasonably necessary for purposes such as:

• technical support;
• troubleshooting;
• security;
• investigation of platform issues;
• system maintenance; or
• authorized platform operations.

Access is intended to be limited according to job responsibilities and authorization.

MINA personnel are not authorized to modify borrower loan data or borrower documents as part of ordinary MINA support access.

MINA may maintain logs or audit records of administrative access and activity.

11. Data Retention and Archived Loan Files

MINA retains information for periods appropriate to the purpose for which it is processed and according to:

• Customer Organization instructions;
• applicable federal and state record-retention requirements;
• mortgage-industry requirements;
• contractual obligations;
• security and fraud-prevention requirements;
• backup and disaster-recovery procedures;
• dispute or litigation requirements; and
• other legitimate business or legal needs.

Loan files may be archived rather than immediately deleted.

Because mortgage record-retention obligations vary based on the transaction, organization, jurisdiction, and type of record, MINA does not apply a single universal deletion period to all mortgage records.

Customer Organizations may retain access to archived loan records according to applicable retention requirements and MINA’s retention policies.

12. Borrower Requests Concerning Loan Information

The Customer Organization generally controls the underlying mortgage file.

If you are a borrower and want to access, correct, or request deletion of information in your mortgage file, you should ordinarily contact the mortgage broker, lender, or other Customer Organization with which you are working.

MINA may assist that organization in responding to an appropriate request.

Deletion requests may be subject to legal and regulatory record-retention obligations and other exceptions permitted by law.

13. State Privacy Rights

Residents of certain U.S. states may have privacy rights under applicable state law.

Depending on the law and the information involved, these may include rights to:

• know or access personal information;
• correct inaccurate information;
• request deletion;
• obtain a portable copy of certain information;
• opt out of certain sales or sharing of personal information;
• limit certain uses of sensitive personal information; or
• appeal certain privacy-request decisions.

These rights are subject to applicable exceptions.

Mortgage and financial information may also be subject to specialized federal and state financial privacy laws, and some state consumer privacy laws exempt certain information governed by those laws.

Where MINA acts as a service provider or processor for a Customer Organization, privacy requests concerning borrower loan information should generally be directed to that Customer Organization.

MINA will assist Customer Organizations with valid requests as required by applicable law and contractual obligations.

MINA will not discriminate against an individual for exercising a privacy right protected by applicable law.

14. California Residents

California residents may have additional rights under California privacy law where that law applies to MINA and the particular information involved.

These may include rights to know, access, correct, or delete certain personal information and rights relating to the sale or sharing of personal information and certain uses of sensitive personal information.

MINA does not sell borrower personal information and does not share borrower personal information for cross-context behavioral advertising.

Certain information processed in connection with financial services may be governed by or exempt under laws such as the Gramm-Leach-Bliley Act or other financial privacy laws.

California residents may contact MINA using the information below regarding privacy requests involving information for which MINA is responsible.

Requests concerning a mortgage file controlled by a Customer Organization should ordinarily be directed to that Customer Organization.

15. Cookies and Similar Technologies

MINA may use cookies and similar technologies that are necessary or useful for:

• authentication;
• session management;
• security;
• user preferences;
• platform functionality;
• diagnostics; and
• understanding operation of the Services.

MINA does not currently represent that borrower information is used for behavioral advertising.

If MINA introduces materially different analytics, advertising, or tracking practices, this Privacy Policy and any required consent mechanisms will be updated.

16. Security

MINA uses administrative, technical, and organizational safeguards designed to protect personal information appropriate to the nature and sensitivity of the information processed.

No information system can be guaranteed to be completely secure.

Users and Customer Organizations are responsible for protecting their credentials and promptly reporting suspected unauthorized access.

MINA may restrict access to the Services when reasonably necessary to investigate or address security threats.

17. Third-Party Services

Third-party integrations and websites may have their own privacy practices.

When a Customer Organization chooses to transmit information to a lender, credit provider, loan origination system, or other third party, that third party’s processing may be governed by its own privacy policy and legal obligations.

18. Children

MINA’s borrower and mortgage Services are intended for adults age 18 and older.

MINA does not knowingly provide borrower portal accounts to individuals under 18.

19. Business Transfers

If MINA is involved in a merger, acquisition, financing, restructuring, bankruptcy, or sale of some or all of its business or assets, information may be transferred as part of that transaction, subject to applicable law and appropriate protections.

20. Changes to This Privacy Policy

MINA may update this Privacy Policy as its technology, business practices, integrations, or legal obligations change.

The revised policy will display an updated effective date.

Where required by law or appropriate because of a material change, MINA may provide additional notice.

21. Contact Us

Questions about this Privacy Policy or MINA’s privacy practices may be directed to:

MINA Pro LLC
1942 W. Gray #454
Houston, TX 77019
Email: [email protected]

Borrowers with questions about their mortgage application or loan file should generally contact their mortgage broker, lender, or other Customer Organization directly.