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PGP, LLC d/b/a OfferMarket | OfferMarket Capital LLC (NMLS ID 2764447) | OfferMarket Insurance LLC (NPN 20545557)
Last Updated: October 6, 2026
Effective Date: October 6, 2026
When you use OfferMarket's services (the "Services"), we know you're trusting us with your data — sometimes including very sensitive financial information. We take that responsibility seriously. This Privacy Policy explains, in plain English where we can and in legal detail where we have to, what information we collect, why we use it, who we share it with, how we protect it, and the tools you can use to manage your privacy.
OfferMarket is a real estate investing platform. We offer an investment property marketplace; private lending through our wholly owned subsidiary OfferMarket Capital LLC; insurance through our affiliated agency, OfferMarket Insurance LLC; a referral program; and OfferMarket Rewards, a points-based rewards program.
This Privacy Policy is issued jointly by PGP, LLC d/b/a OfferMarket ("PGP"), which operates the OfferMarket platform; OfferMarket Capital LLC (NMLS ID 2764447), which makes or arranges loans offered on the platform; and OfferMarket Insurance LLC (NPN 20545557), a licensed insurance agency that offers insurance products on the platform. OfferMarket Capital LLC and OfferMarket Insurance LLC are wholly owned subsidiaries of PGP. OfferMarket Capital LLC is responsible for personal information collected in connection with loan applications and loans, and OfferMarket Insurance LLC is responsible for personal information collected in connection with insurance quotes, applications, and policies. In this policy, "OfferMarket," "we," "us," and "our" refer to PGP, OfferMarket Capital LLC, OfferMarket Insurance LLC, and our affiliates, except where we identify a specific entity.
If you have any questions about this policy, you can email us at privacy@offermarket.us or write to us at PGP, LLC d/b/a OfferMarket, OfferMarket Capital LLC, and OfferMarket Insurance LLC, Attn: Privacy, 627 S Hanover St, Baltimore, MD 21230.
This Privacy Policy applies to OfferMarket's website at offermarket.us, our subdomains, mobile applications, APIs, and all related products, features, content, tools, calculators, communications, and services that link to it (the "Services"). It also applies to information we collect when you interact with us by phone, text, email, or in person about the Services.
This policy does not apply to third-party websites, products, or services that we don't control, even if you reach them through the Services. Those third parties have their own privacy practices, and we encourage you to review them.
Four other documents work alongside this Privacy Policy:
If anything in this policy conflicts with a specific written agreement you have with us (such as a loan agreement, a loan participation agreement, or an insurance policy), the specific agreement controls for that specific transaction. This policy otherwise controls.
The information we collect depends on how you use the Services. If you only browse our listings, we collect less than if you apply for a loan, request an insurance quote, or list a property for sale. We collect information in three ways: (i) information you give us, (ii) information we collect automatically, and (iii) information we receive from third parties.
When you interact with the Services, we ask you for information about yourself and (sometimes) about other people. Examples include:
Account and contact information. Name, email address, mailing address, telephone number, password, profile information, and (for entity users) information about your borrowing entity and its principals.
Listing information. If you list a property or assign a contract on our Marketplace, we collect the property address, description, photographs, your relationship to the property, your asking price, and information necessary to coordinate closing.
Offer and transaction information. If you submit an offer for a Listing, we collect the offer terms, proof of funds documentation, and information necessary to qualify your offer.
Loan application information. If you apply for a Loan from OfferMarket Capital LLC, we collect information about you and any guarantors, your borrowing entity, your real estate investing experience, your assets and liabilities, your credit history, the subject property, and your intended use of proceeds. As your application progresses we may also collect bank statements, brokerage statements, photo identification, business formation documents, and additional financial information.
Insurance quote and application information. If you request an insurance quote or apply for a policy, OfferMarket Insurance LLC collects information about you, the property to be insured, your insurance history, and other information needed to quote, place, and service coverage. OfferMarket Insurance LLC shares this information with insurance carriers and wholesalers to obtain quotes and bind coverage on your behalf, as described in Section 4.1 and Section 14A.
Referral information. If you participate in our Referral Program, we collect information about you and about each Lead you refer. By submitting a Lead's information, you represent that you have obtained the Lead's consent, as described more fully in Sections 2.5 and 9 of our Terms of Service. The Referral Program is not offered in connection with California loans (see Section 14B).
Referral attribution and introductions. When you arrive through another member's referral link, we record which member referred you and associate that relationship with both accounts (the referrer and the referred member). Referrers can see the status and progress of loans they referred and will learn that a referred member's loan funded (but not its terms). If you use our "refer an investor" flow, it opens a pre-filled email from your own mail client; if you send it using the provided template, OfferMarket addresses are cc'd, which gives us the introduced person's email address and the content of your introduction.
OfferMarket Rewards information. If you participate in OfferMarket Rewards, we collect and generate information about your participation, including: your points ledger (points earned, redeemed, reversed, or adjusted, tied to your account and, where applicable, to specific loans, including the identity of the administrator who made any manual entry); your redemption elections against specific loans and their outcomes (applied at closing or cancelled); post-funding feedback you provide (such as thumbs-up/thumbs-down sentiment, optional free-text comments, and which staff members were shown to you); and the state of the feedback prompts we show you (how many times an ask was shown, on which channel, dismissals, and completion). Your program eligibility status and the date it was enabled are also recorded. OfferMarket Rewards is not offered in connection with California loans (see Section 14B).
Communications. When you contact us — by email, phone, text, chat, support form, or otherwise — we collect the content of those communications and information about them (date, time, channel). Telephone calls and videoconferences with OfferMarket may be recorded and transcribed, as described in our Terms of Service and in Section 8 below.
Information about other people. You may provide us information about people other than yourself (such as a co-borrower, a guarantor, a co-investor, an employee, or a Lead in our Referral Program). When you do so, you represent that you have authority and consent to share that information with us for the purposes described in this policy.
Like most online services, we and our service providers automatically collect information about your devices and your use of the Services. This includes:
Device and connection information. Browser type and version, operating system, device identifiers, IP address, mobile network information, time zone, language settings, screen size, and similar technical information.
Activity information. The pages and features you view, the searches you run, the listings you save, the calculators you use, your clickstream, the date and time of your visits, the referring or exit URL, and similar usage information.
Location information. If you grant permission, we collect precise geolocation (within approximately 1,850 feet) from your browser or device to deliver location-based features such as showing you nearby Listings. We always derive approximate location from IP address regardless of browser permissions.
Cookies and similar technologies. We use cookies, pixel tags, web beacons, software development kits, local storage, and similar technologies, as described in Section 5 and in our Cookie Policy. Optional (non-essential) technologies do not load until you make a cookie choice that permits them.
Session activity. We use product analytics tooling, including PostHog, that may capture interactions with the Services once you have consented to analytics cookies. Where reasonably feasible we suppress session capture on screens that collect sensitive financial information; however, you should not rely on this and should treat any information you enter into the Services as transmitted to OfferMarket.
Rewards review activity. If you participate in OfferMarket Rewards, we record whether you clicked a link to leave a public review (a timestamp only). We do not receive the content of any review you choose to leave on a third-party platform such as Google.
We receive information about you from third parties to verify your identity, evaluate loan applications, process transactions, prevent fraud, and improve the Services. Sources include:
Public records and government sources. County, state, and federal property records; tax records; deed and lien records; court records; and sanctions lists.
Consumer reporting agencies and other credit data providers. Credit reports, credit scores, fraud indicators, and identity-verification information. We use these consistent with the Fair Credit Reporting Act and only for permissible purposes such as evaluating a credit transaction you initiate with us.
Service providers and verification vendors. Background-check vendors, identity-verification vendors, anti-money-laundering and sanctions-screening vendors, and similar.
Settlement service providers. Appraisers, title companies, escrow agents, insurance carriers, flood-determination vendors, and similar service providers involved in a transaction.
Partners and lead sources. Capital Providers, insurance carriers and wholesalers, marketing partners, and referral sources may share information about you with us.
Authentication providers. If you sign in using a third-party account (e.g., Google, Facebook), we receive limited information from that provider, such as your name and email address, as authorized by you and the provider.
Social media and publicly available information. We may collect information you choose to make public, such as publicly available real estate transaction history, professional licensure information, or social media profile information you connect to us.
We use the information we collect for the following purposes:
To provide, operate, and deliver the Services. To create and manage your account; respond to your inquiries; process your offers, applications, transactions, and payments; coordinate closings; deliver products and services you request; and provide customer support.
To evaluate loan applications and process credit transactions. To verify your identity, assess your eligibility for a Loan, determine loan terms, prepare loan documents, fund and service Loans, and exercise rights and remedies under loan agreements. This includes pulling credit reports and using them for permissible purposes under the Fair Credit Reporting Act.
To deliver insurance products. To share your information with OfferMarket Insurance LLC and, through it, with insurance carriers and wholesalers, at your direction, so that quotes can be prepared, coverage bound, and policies serviced.
To operate the Marketplace. To display Listings, match buyers with sellers and wholesalers, route offers, and coordinate transactions.
To operate the OfferMarket Rewards program. To administer points earns, redemptions, reversals, and adjustments; determine program eligibility; measure service quality (CSAT) by loan team; calculate and verify internal staff compensation, including employee bonuses that accrue from member review click-throughs and funded referrals; identify members with redeemable balances for account management and sales outreach; and send program communications such as post-funding feedback requests.
To prevent fraud and protect security. To detect, investigate, and prevent fraud, unauthorized access, identity theft, and other unlawful activity; to enforce our Terms of Service; and to protect the rights, property, and safety of OfferMarket, our users, and others.
To comply with law and respond to legal process. To comply with applicable laws, regulations, court orders, subpoenas, and lawful requests from government authorities, and to respond to claims and disputes.
To communicate with you. To send you transactional communications (account notices, application status updates, payment reminders, service announcements), to respond to your questions, and — with appropriate consent — to send you marketing communications about our products and services and those of our partners.
To improve the Services. To understand how users interact with the Services, identify and fix problems, conduct research and analytics, develop new features, train OfferMarket-internal personnel, and improve the quality of the Services.
To personalize your experience. To remember your preferences, customize content, recommend Listings and products, and provide a more relevant experience.
To administer our business. To manage internal operations including accounting, audit, recordkeeping, vendor management, risk management, and corporate governance, and to exercise rights under contracts.
To support corporate transactions. To evaluate, negotiate, complete, and integrate mergers, acquisitions, financings, asset sales, reorganizations, and similar transactions involving OfferMarket.
We share information only when it's necessary to provide the Services, when you direct us to, when our partners need the information to deliver a product or service to you, when our service providers need it to perform a function on our behalf, or when sharing is required or permitted by law. We share information with the following categories of recipients:
When you submit an offer, apply for a Loan, request an insurance quote, refer a Lead, list a property, or otherwise direct us to share your information, we share it with the relevant counterparties, partners, and service providers necessary to fulfill your request. Examples:
We share information with service providers and contractors that perform functions on our behalf, including hosting, infrastructure, identity verification, fraud prevention, anti-money-laundering and sanctions screening, credit reporting, background checks, appraisal management, title and escrow services, settlement services, flood determination, document preparation, electronic signature, payment processing, loan servicing, communications (email, SMS, telephony), analytics, marketing-attribution, customer-relationship management, accounting, legal, audit, and similar services. Some of our service providers and contract personnel are located outside the United States, as described in Section 13.
We require our service providers by written contract to use information only to provide services to us, to protect it, and not to use it for their own marketing or to sell or share it with third parties for their own purposes.
We share information about Loans — including borrower information, loan terms, underwriting data, valuation data, and loan performance — with Capital Providers (who may originate or purchase the Loan) and with Loan Participants (who hold a participation interest in the Loan under our Loan Participation Program). This sharing is necessary to make, service, sell, securitize, and exercise rights under Loans. The Loan Participation Program is described in Section 2.8 of our Terms of Service. Participation interests are not offered in California loans, and no Loan Participant receives information about a California loan (see Section 14B).
In connection with each Loan and each transaction, we grant role-based access to our Loan File / Loan Origination System ("LOS") to additional users acting in specific transaction roles, including Capital Providers, Loan Participants, OfferMarket Insurance LLC, insurance carriers, title and escrow agents, settlement agents, attorneys, property managers, the selling and buying real estate agents, appraisers, draw inspectors, contractors, and accountants. Each Authorized User's access is limited to the information reasonably necessary for the Authorized User's role and is subject to confidentiality and information-security obligations described in Section 2.7 of our Terms of Service.
We share information among our affiliates, including OfferMarket Capital LLC, OfferMarket Insurance LLC, and any other entity under common control with PGP, LLC, to operate the Services, provide products to you, manage risk, prevent fraud, and conduct our business.
OfferMarket Capital LLC does not share information about loan applicants or borrowers with OfferMarket Insurance LLC for marketing purposes. It shares that information only when you request an insurance quote.
We work with analytics and advertising providers — currently Google (Google Analytics, Google Ads, and Google Tag Manager), Microsoft (Microsoft Advertising Universal Event Tracking, or "UET"), and PostHog (product analytics). We load Microsoft UET through Google Tag Manager, and it is gated behind your Advertising cookie choice just like our other advertising tags. The complete, current list of these tools is maintained in our Cookie Policy at offermarket.us/cookies.
We do not load these providers, and they do not receive information about your visit, until you have made a cookie choice that permits them (and, in U.S. state-privacy jurisdictions, have not opted out). When permitted, certain advertising partners may receive information about your visit and use it to measure campaigns and display advertisements to you on other websites and applications. This activity may constitute a "sale" or "sharing" of personal information under certain state privacy laws. Section 9 describes how you can opt out. We will update our Cookie Policy if we enable additional advertising technologies (for example, a social-media advertising pixel).
We share information when we believe it is reasonably necessary to (a) comply with a law, regulation, court order, subpoena, or lawful request from a government authority; (b) enforce our Terms of Service, agreements, or policies; (c) detect, prevent, or address fraud, security, or technical issues; (d) protect the rights, property, or safety of OfferMarket, our users, or others; or (e) respond to claims and disputes. Where we are permitted to do so, we will notify you before responding to legal process directed at your information.
If OfferMarket is involved in a merger, acquisition, financing, sale of assets, reorganization, bankruptcy, liquidation, or similar transaction or proceeding, we may share information in connection with that transaction or proceeding. We will require any acquirer or successor to honor this Privacy Policy with respect to information acquired from us, except as otherwise required by law.
We share information for other purposes with your consent or at your direction.
We may share aggregated or de-identified information that cannot reasonably be used to identify you. We commit not to attempt to re-identify de-identified information and to contractually require recipients of de-identified information to similarly refrain from re-identification.
To operate OfferMarket Rewards, we share certain information internally and, in limited ways, with other users. Free-text feedback you submit is shared internally with your loan team and is visible to administrators, who also use it to verify internal staff bonuses. If another member referred you, that member may see the status and progress of loans they referred and will learn that your referred loan funded (but not its terms); likewise, if you refer others, you may see similar status information about the loans you referred. Your redemption elections and points balances are visible to administrators and are reflected on relevant loan records and settlement statements. The Rewards program does not introduce any new sharing of your information with third parties for their own purposes; program emails are sent through our existing email provider.
We and our partners use cookies and similar technologies to operate the Services, understand how you use them, deliver and measure advertising, and remember your preferences. Our Cookie Policy at offermarket.us/cookies is the authoritative, always-current source for the specific tools we use and how to control each one; this section summarizes the key points and your choices.
We organize the technologies we use into four categories:
The specific tool that sits in each category is listed in our Cookie Policy.
We do not load any Functional, Analytics, or Advertising technology until you make a choice — in every region, for every visitor. When you first visit, we present a banner with three options: Accept all, Reject all (labeled "Do Not Sell or Share My Personal Information" for U.S. visitors), and Manage preferences, which lets you turn individual categories on or off. Strictly Necessary cookies are always on.
Your choice is stored on your device (a first-party cookie and local storage) for approximately twelve (12) months, and we keep an audit record of it. You can change your choice at any time through the preference center at offermarket.us/cookies or the "Your Privacy Choices" link in our footer.
Separately, our Mailchimp "Investor Update" newsletter includes open- and click-tracking that operates within your email app (not on our website); you can opt out by unsubscribing or by blocking images in your email client. See our Cookie Policy for details.
We honor the Global Privacy Control ("GPC") browser signal for all visitors as a valid request to opt out of the "sale" and "sharing" of personal information for cross-context behavioral advertising. If we detect a GPC signal, we automatically apply an opt-out of Analytics and Advertising technologies and record that choice. GPC does not affect (a) disclosures you specifically direct (such as submitting a loan application or insurance quote that requires sharing with partners), (b) disclosures to our service providers, (c) disclosures necessary to provide the Services or maintain your relationship with us, or (d) disclosures required by law.
Some browsers send a "Do Not Track" signal. There is no industry consensus on how to interpret it, and we do not respond to it differently than to ordinary browsing. We do honor GPC, as described above.
Some information we collect is considered "Sensitive Personal Information" under certain state privacy laws. The categories we collect include:
We use Sensitive Personal Information only for the purposes for which it was collected and as necessary to deliver the Services, process loan applications and insurance requests, comply with law, prevent fraud, and otherwise carry out the purposes described in Section 3. We do not use Sensitive Personal Information for cross-context behavioral advertising or for purposes that infer characteristics about you. You have the right to limit our use of Sensitive Personal Information to these necessary purposes; we already operate this way, so no separate request is required, but you may contact privacy@offermarket.us to confirm.
We use automated systems, including artificial intelligence and machine-learning tools, to deliver and improve the Services. This section describes those uses, the role that human review plays, and your rights.
We use automated systems to perform initial loan pre-qualification — including automated DSCR calculation, eligibility scoring, and indicative-rate quotes — based on information you provide and information we obtain from third parties. Loan pre-qualification outputs are informational and indicative; they do not constitute a final loan decision. Every final loan decision is made by a human underwriter who reviews the file, including the automated outputs, before approving, declining, or modifying terms.
If you are declined for a Loan, we will provide adverse action notices as required by applicable law, including specific reasons for the decision where required.
In addition to loan pre-qualification, we use automated systems and AI tools for the following purposes:
To the extent any automated processing produces a legal or similarly significant effect concerning you (such as a loan decision), you have the right to (i) request meaningful information about the logic involved, (ii) request human review of the decision, and (iii) contest the decision. Contact privacy@offermarket.us to exercise these rights.
Loan File Data is not used to train any third-party artificial-intelligence or machine-learning model. Our Authorized Users (as defined in Section 2.7 of our Terms of Service) are contractually prohibited from using Loan File Data to train AI/ML models.
When you provide a telephone number or email address to us, you consent to receive communications from OfferMarket, OfferMarket Capital LLC, OfferMarket Insurance LLC, and certain partners as described in Section 9 of our Terms of Service. Communications may include account servicing, loan applications and updates, insurance quotes and policy servicing, transaction coordination, debt collection, marketing, rewards-program messages, and legally required notices.
We record telephone calls and videoconferences with you for training, quality assurance, dispute resolution, evidentiary, and compliance purposes, as authorized by our Terms of Service. We retain transcripts and recordings of chat and SMS conversations. If you do not consent to recording, please communicate with us by email instead of by phone or videoconference.
Our marketing newsletter includes open- and click-tracking so we can measure engagement; you may opt out by unsubscribing. See Section 5 and our Cookie Policy for details. Some OfferMarket Rewards emails, such as post-funding feedback requests, contain a signed personal link that lets you submit feedback without logging in; anyone with that link can submit feedback for the associated loan, so please do not forward it.
You may opt out of marketing communications in any of the ways described in Section 9.4 of our Terms of Service, including by replying STOP to any marketing text message, clicking the unsubscribe link in any marketing email, or emailing privacy@offermarket.us. We will process your opt-out within ten (10) business days. We may continue to send non-marketing transactional, account, debt-collection, and legally required communications.
We believe everyone should have a meaningful baseline of privacy rights, regardless of where they live. While only some U.S. state privacy laws may technically apply to OfferMarket today, we offer the following rights to all of our users:
You have the right to ask us what categories of personal information we collect, the sources we collect it from, the purposes for which we use it, the categories of third parties with whom we share it, and — on request — the specific pieces of personal information we hold about you.
You have the right to ask us to delete personal information we hold about you. We will honor deletion requests unless an exception applies, including: (a) we need the information to complete a transaction or service you requested or to take steps reasonably anticipated within our ongoing business relationship with you; (b) we need the information to detect or prevent fraud or security incidents; (c) we need the information for internal uses reasonably aligned with your expectations; (d) we need the information to comply with a legal obligation, including federal and state recordkeeping requirements for lenders and insurance agencies (such as 7-year retention of closed loan files, 25-month retention of declined applications under Regulation B, 7-year retention of tax records, and state insurance recordkeeping requirements); (e) the information is subject to a legal hold, subpoena, or pending litigation; (f) the information relates to a current or recently completed credit transaction with OfferMarket Capital LLC, in which case we will retain the information as required by the Gramm-Leach-Bliley Act and applicable state law; (g) the information relates to an insurance quote, application, or policy with OfferMarket Insurance LLC, in which case we will retain the information as required by applicable insurance law; or (h) other exceptions provided by law.
Where an exception applies, we will explain why we cannot fully honor the request, and we will delete what we can.
You have the right to ask us to correct inaccurate personal information we hold about you. We will take reasonable steps to verify the inaccuracy and to correct or update the information.
You have the right to receive a copy of certain personal information we hold about you in a readily usable, structured, commonly used format.
You have the right to opt out of the "sale" and "sharing" of your personal information under state privacy laws. As described in Section 4.6, we engage in activities that may constitute "sale" or "sharing" — including cross-context behavioral advertising through Google Ads and Microsoft Advertising. You can opt out in any of the following ways:
Important: opt-out of "sale" and "sharing" does NOT apply to (a) disclosures you specifically direct (such as submitting a loan application, insurance quote request, or referral that requires sharing your information with partners to fulfill your request); (b) disclosures to our service providers and contractors who handle data on our behalf; (c) disclosures necessary to deliver a product or service you requested or to maintain your relationship with us; or (d) disclosures required by law, including under the Gramm-Leach-Bliley Act exceptions in 15 U.S.C. § 6802(e).
We use Sensitive Personal Information only for purposes that are reasonably necessary to deliver the Services, process transactions, prevent fraud, comply with law, and the other purposes described in Section 3. We do not use Sensitive Personal Information to infer characteristics about you for advertising. If you wish to confirm or expand this commitment, contact privacy@offermarket.us.
You have the right to opt out of automated decision-making that produces a legal or similarly significant effect concerning you (such as a loan decision), and to request human review of any automated decision. As described in Section 7, every final loan decision at OfferMarket Capital LLC is made by a human underwriter; however, you may also request human review of any automated pre-qualification or AVM output by contacting privacy@offermarket.us.
If we deny your request under this Section 9, you have the right to appeal that decision by emailing privacy@offermarket.us with the subject line "Appeal." We will review the appeal and respond within 45 days.
We will not discriminate against you for exercising any of the rights described in this Section 9. We will not deny you Services, charge you different prices, provide a different level or quality of Services, or retaliate against you for exercising your rights. However, if exercising a right (such as deletion of information necessary to provide a Service) prevents us from providing a particular Service, we may be unable to continue providing that Service to you.
To exercise any of the rights in this Section 9, contact us at privacy@offermarket.us or write to PGP, LLC d/b/a OfferMarket, OfferMarket Capital LLC, and OfferMarket Insurance LLC, Attn: Privacy, 627 S Hanover St, Baltimore, MD 21230. We will acknowledge your request within ten (10) business days and substantively respond within forty-five (45) days, extendable once by an additional forty-five (45) days for complex requests, with notice to you. We may need to verify your identity before honoring your request to protect against fraudulent or unauthorized requests; verification may include confirmation of information already on file with us, or, where reasonable, additional documentation.
You may use an authorized agent to submit a request on your behalf. We may require the authorized agent to provide written authorization from you and to verify their own identity.
We do not charge a fee for the first request in any 12-month period. We may charge a reasonable fee or decline to act on requests that are manifestly unfounded, excessive, or repetitive.
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to deliver the Services, comply with legal and regulatory obligations, resolve disputes, prevent fraud, and enforce our agreements. Specific retention periods depend on the category of information, the legal basis for retention, and any applicable legal holds. The following are our general retention guidelines:
Notwithstanding the foregoing, we may retain personal information for longer where required by a legal hold, subpoena, regulatory inquiry, pending or threatened litigation, or active fraud or security investigation, in each case until the matter is resolved.
OfferMarket Capital LLC is a "financial institution" within the meaning of the Gramm-Leach-Bliley Act and the FTC Safeguards Rule (16 C.F.R. Part 314). OfferMarket Insurance LLC maintains safeguards consistent with applicable state insurance data security laws. OfferMarket maintains a written Information Security Program designed to protect the security, confidentiality, and integrity of personal information, consistent with the Safeguards Rule and applicable state law. The Information Security Program includes administrative, technical, and physical safeguards, including without limitation: a designated Qualified Individual responsible for the program; periodic risk assessments; encryption of customer information in transit and at rest; multi-factor authentication for access to systems holding customer information; access controls and least-privilege principles; secure software development; change management; logging and monitoring; vendor risk management and contractual safeguards for service providers; an incident response plan; employee training; and periodic testing.
No security program can guarantee complete protection against unauthorized access, disclosure, alteration, or destruction. We continually monitor for threats and respond as appropriate, and we will notify you of any security incident affecting your personal information as described in Section 12.
You also play an important role in protecting your information. Keep your account credentials confidential, use strong unique passwords, enable multi-factor authentication where available, do not share your credentials with others, and notify us promptly at security@offermarket.us if you suspect any unauthorized access to your account.
If we confirm a security incident that we determine has affected or is reasonably likely to have affected your personal information, we will notify you within thirty (30) days of confirmation, unless a longer or shorter period is required by applicable law or one of the limited exceptions described below applies. Our notification will describe (where known) the nature of the incident, the categories of information involved, the steps we have taken to address the incident, what you can do to protect yourself, and how to contact us with questions.
We may delay notification (a) if a law enforcement agency notifies us that notification would impede a criminal investigation or jeopardize national security; (b) for a reasonable period to determine the scope of the incident and identify affected individuals; or (c) for a reasonable period to restore the integrity of systems and prevent further unauthorized access. Notification will be provided promptly after the delay is no longer necessary.
We will provide notice by email to the address associated with your account or by other reasonable means consistent with applicable law. Where state law requires substitute notice (such as a website posting, media notice, or notice to the state attorney general), we will also provide that notice as required.
We will also notify regulators as required by law, including the Federal Trade Commission within 30 days of a "notification event" affecting 500 or more consumers under the GLBA Safeguards Rule, state insurance regulators where required, and state attorneys general and other regulators as required.
OfferMarket is based in the United States, and our systems of record are located in the United States. Some of our service providers and contract personnel are located outside the United States and may access personal information from those locations to perform services on our behalf, subject to written confidentiality, information security, and use-limitation obligations. By using the Services or providing information to us, you understand and consent to the transfer of your information to, and processing and storage of your information in, the United States, and to access by our service providers and contract personnel as described in this section, where data protection laws may differ from those of your country of residence.
If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with cross-border data transfer restrictions, we rely on appropriate transfer mechanisms (which may include Standard Contractual Clauses or other lawful mechanisms) to transfer your information to the United States. By submitting information to us, you also expressly consent to that transfer to the extent permitted under applicable law.
For users located in the European Economic Area or the United Kingdom, the legal bases on which we process personal data may include (a) performance of a contract with you or steps prior to entering into a contract; (b) compliance with a legal obligation; (c) your consent (which you may withdraw at any time); and (d) our legitimate interests in operating, securing, and improving the Services, in each case balanced against your rights. You may exercise any rights you have under applicable European or UK data protection law (including access, correction, deletion, restriction, portability, objection, and lodging a complaint with a supervisory authority) by contacting privacy@offermarket.us. If you require an EU or UK Representative under Article 27 of the GDPR or UK GDPR, please contact us and we will provide current information.
The following GLBA Privacy Notice is provided in addition to this Privacy Policy and addresses how OfferMarket Capital LLC, our wholly owned lending subsidiary, treats nonpublic personal information about its customers. This notice is delivered separately to loan applicants and customers at the time of application and annually thereafter, and is also reproduced here for transparency. This notice is modeled on the Interagency Model Privacy Form issued under Regulation P (12 C.F.R. Part 1016) and applies to consumers and customers of OfferMarket Capital LLC.
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number, taxpayer identification number, income, account balances, credit history, credit scores, payment history, transaction history, account transactions, employment information, identification documents, and information from consumer reporting agencies.
How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons OfferMarket Capital LLC chooses to share; and whether you can limit this sharing.
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include PGP, LLC d/b/a OfferMarket, OfferMarket Insurance LLC, and other entities under common control. OfferMarket Capital LLC shares your information with OfferMarket Insurance LLC only if you request an insurance quote.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Examples of nonaffiliates with whom we may share information for everyday business purposes include Capital Providers, Loan Participants, title and escrow companies, appraisers, settlement service providers, and other vendors necessary to deliver Loans.
Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. OfferMarket Capital LLC does not currently have joint marketing partners.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards, secured files and buildings, and the elements of the Information Security Program described in Section 11 of this Privacy Policy.
We collect your personal information, for example, when you (i) apply for a loan or other financial product, (ii) provide identifying information, account information, or income information, (iii) give us employment information, or (iv) provide information about your real estate investing experience or the subject property. We also collect your personal information from others, such as consumer reporting agencies, settlement service providers, and other financial institutions.
Federal law gives you the right to limit only (a) sharing for affiliates' everyday business purposes — information about your creditworthiness; (b) affiliates from using your information to market to you; and (c) sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. As described above, we do not engage in the affiliate-creditworthiness sharing, affiliate marketing, or nonaffiliate marketing activities that would be subject to those limits, so there is nothing for you to limit under federal GLBA. Additional provisions for California loans are described in Section 14B.
Email privacy@offermarket.us, call 1-443-492-9941, or write to OfferMarket Capital LLC, Attn: Privacy, 627 S Hanover St, Baltimore, MD 21230.
The following GLBA Privacy Notice is provided in addition to this Privacy Policy and addresses how OfferMarket Insurance LLC, our affiliated insurance agency, treats nonpublic personal information about its customers. This notice is delivered separately to insurance customers as required by law and is also reproduced here for transparency.
Why? Financial companies, including insurance agencies, choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include: name, contact information, property information, insurance history, claims history, payment information, and information from consumer reporting agencies where permitted by law.
How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons OfferMarket Insurance LLC chooses to share; and whether you can limit this sharing.
Affiliates: Companies related by common ownership or control. Our affiliates include PGP, LLC d/b/a OfferMarket, OfferMarket Capital LLC, and other entities under common control.
Nonaffiliates: Companies not related by common ownership or control. Examples of nonaffiliates with whom we share information for everyday business purposes include insurance carriers, wholesalers, and other vendors necessary to quote, place, and service coverage.
Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. OfferMarket Insurance LLC does not currently have joint marketing partners.
Residents of certain states, including California, have additional rights under state insurance privacy laws, such as the right to access and request correction of recorded personal information collected in connection with an insurance transaction. To exercise these rights, contact us as described below.
Email privacy@offermarket.us, call 1-443-492-9941, or write to OfferMarket Insurance LLC, Attn: Privacy, 627 S Hanover St, Baltimore, MD 21230.
For loans secured by property located in California, or made to borrowers located in California:
(a) OfferMarket Capital LLC does not sell participation or fractional interests in California loans, and no Loan Participant receives information about a California loan.
(b) The Referral Program and OfferMarket Rewards are not offered in connection with California loans, and no referral compensation is paid in connection with a California loan.
(c) OfferMarket Capital LLC does not share nonpublic personal information about California applicants or borrowers with nonaffiliated third parties, including for joint marketing, without the applicant's or borrower's express written consent, except as permitted by the California Financial Information Privacy Act (Cal. Fin. Code § 4050 et seq.), such as with service providers performing services on our behalf and as necessary to process a transaction you request.
(d) OfferMarket Capital LLC does not share nonpublic personal information about California applicants or borrowers with OfferMarket Insurance LLC or any other affiliate for marketing purposes. It shares information with OfferMarket Insurance LLC only at the applicant's or borrower's request for an insurance quote.
The Services are intended for business and investment users and are not directed to or intended for children. We do not knowingly collect personal information from any child under the age of 13 in violation of the Children's Online Privacy Protection Act, 15 U.S.C. §§ 6501 et seq. ("COPPA"). If we become aware that we have collected personal information from a child under 13, we will delete that information promptly. If you believe we may have collected information from a child under 13, please contact us at privacy@offermarket.us.
Where applicable law affords additional privacy protections to minors aged 13 to 17, we honor those protections.
The Services may contain links to third-party websites, products, or services that we do not own or control. Examples include partner lender websites, insurance carrier websites, title-company portals, and social media platforms. This Privacy Policy does not apply to third-party websites, products, or services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party site or service before providing information to it.
For details on the cookies and tracking technologies we use, and to manage your choices, see our Cookie Policy at offermarket.us/cookies.
We may update this Privacy Policy from time to time. When we make material changes, we will provide notice on the Services and update the "Last Updated" date at the top of this policy. Where reasonable, we will also provide additional notice (such as email or in-product notification) when material changes affect the rights you have or the way we use information that is sensitive to you. Your continued use of the Services after the effective date of an updated policy constitutes your acceptance of the changes. If you do not agree, your sole remedy is to stop using the Services and close your account.
We will not change this policy in a way that materially reduces your rights with respect to information we previously collected from you without your consent or appropriate notice.
If you have any questions, concerns, or requests regarding this Privacy Policy or OfferMarket's privacy practices, please contact us:
Email (privacy requests, including data subject requests): privacy@offermarket.us
Email (security incidents): security@offermarket.us
Email (general inquiries): hello@offermarket.us
Telephone: 1-443-492-9941
Mail: PGP, LLC d/b/a OfferMarket, OfferMarket Capital LLC, and OfferMarket Insurance LLC, Attn: Privacy, 627 S Hanover St, Baltimore, MD 21230