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Privacy Notice

Last Updated: Jun 28, 2023
This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Notice is not a contract, however, and does not create any legal rights or obligations not otherwise provided by law.

Table of Content

Who Are We?

Aspire offers eligible consumers the ability to access some of their trapped home equity in the form of cash. Aspire is a home equity investment platform owned by Redwood Trust, Inc. (“Redwood”). When we use the terms “Aspire”, “we”, “us”, or “our” in this Privacy Notice, we are referring to Aspire RWT, LLC and affiliates providing and administering Aspire HEI agreements.

This Privacy Notice does not cover Redwood or its subsidiaries and affiliates operating outside of the Aspire brand, such as CoreVest, Redwood Residential, or RWT Horizons. For more information about Redwood, please visit the Redwood website at www.redwoodtrust.com, and for more information about CoreVest, please visit the CoreVest website at www.corevestfinance.com.

Our Services

When we use the term “services” in this Privacy Notice, we mean the services that we offer through which we process the personal information of:

  • visitors to this website, aspireHEI.com; and
  • representatives of businesses with whom we interact.

The term “services” does not include, and this Privacy Notice does not cover:

Inquiries you make with us regarding your eligibility for a home equity investment (“HEI”), the personal information we process regarding your application for an HEI, or other personal information processed in the Aspire customer portal or throughout the course of administering your HEI. The information we obtain from these activities is covered by a federal privacy law known as the Gramm-Leach-Bliley Act (“GLBA”), which applies to your financial information. You may view our GLBA notice here.

Consumer report information that we receive and provide to a consumer reporting agency, such as Experian, Equifax and TransUnion. This information is covered by another federal privacy law known as the Fair Credit Reporting Act. If we would like to obtain such information from you, we will request your authorization.

When we act as a service provider processing personal information on behalf of another business (our contract with the business governs those activities).

Personal information we process about our job applicants, employees, and personnel (we maintain a separate notice for such “HR data”).

What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or reasonably linked to you.

Our Collection and Use of Personal Information

The personal information we collect, the way we collect it and how we use it depend on our relationship with you and how you interact with us.

Website Visitors

Collection of Personal Information

We and our third-party partners and providers collect certain personal information you choose to provide us through our website, which may include:

  • Newsletters and Email Communication: Our website allows you to subscribe to email communications by providing your email address in the available web form or via a chat bot. We use your email address to keep you informed about the latest residential property tips, trends, and best practices and to communicate with you about our products and services, which may include marketing communications. You may ask us not to send you marketing communications by following the instructions provided in the Your Communication Preferences section below.
  • Contact Us or Chat Bot: Our website allows you to connect with us through an online web form or via Chat Bot that collects contact information (such as your name, email address, and phone number) and/or a custom message from you. You may also choose to contact us at one of the designated addresses or phone numbers identified on our website and provide us personal information in connection with your message. We use this personal information to communicate with you in connection with your request, including corresponding with you about our services and products.

As is true of most digital platforms, we and our third-party partners and providers also collect certain personal information automatically when you visit or interact with our website or our email communications, which may include:

  • Log Data, including your internet protocol (IP) address, internet service provider, operating system, browser type, browser id, language, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our services.
  • Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and objects you view, click, or otherwise interact with (also known as “Clickstream Data”).
  • Location Data, including your general geographic location based on the Log Data we collect or more precise location to the extent permitted by law.

For information about our and our third-party providers’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to this collection, please review the Cookies and Related Technologies section below.

Use of Personal Information

We use the personal information we collect from our website visitors to:

  • Administer and improve our services;
  • Test different configurations of our services;
  • Diagnose errors and problems with our services;
  • Conduct research and analytics on visitor usage and activity trends relating to our services;
  • Remember you and the choices you have made in relation to our services;
  • Identify how you use our services, determine products/services that may be of interest to you and customize our personalized offerings and marketing efforts accordingly;
  • Provide you with news about products and services we offer;
  • Deliver marketing communications and advertisements based on your interests and interactions with us;
  • Assess the performance of marketing campaigns and facilitate remarketing efforts;
  • Administer or provide requested products and services;
  • Respond to your comments and questions and provide you support.

Please note we link the personal information we collect through our website with the other personal information we collect, and we may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Representatives of Businesses

Collection of Personal Information

When you interact with us on behalf of a business we engage or interact with, we collect certain personal information from you and about the business you represent, which may include:

  • Contact Information, such as your name, address, email address, and telephone number;
  • Professional/Employment Information, such as your employer, company you are doing business as, and your job title;
  • Diligence Information, such as work history, educational history, references or other information that you may provide on a resume, statement of work, agreement or similar document in connection with the negotiation, evaluation and/or fulfillment of our engagement with the business you represent.

Use of Personal Information

We use the personal information we collect from business representatives to:

  • Administer and improve our services;
  • Facilitate and maintain the relationship between us and the business you represent;
  • Conduct due diligence and risk management relating to our engagement with the business you represent;
  • Fulfill and facilitate our obligations and the obligations of the business you represent;
  • Process payment for goods or services we may receive or purchase from the business you represent.

Other Collection of Personal Information

In addition to the personal information collected above, we may also collect your personal information as follows:

  • Social Media: If you choose to interact with us on social media, we may collect personal information about you from your social media account that you make public or share with us. We use personal information collected in connection with your social media account to communicate with you and better understand you and the business you represent.
  • Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with you.
  • Inquiry Information: If you choose to contact us, we will collect personal information in connection with your inquiry and correspondence with us. We may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
  • Publicly Available Information: We may collect personal information from publicly available sources, such as government records or publicly available websites, to supplement the personal information identified above.

Other Uses of Personal Information

In addition to the uses of personal information identified above, we use the personal information we collect to:

  • Facilitate our day-to-day business operations, such as providing our products and services to you;
  • Respond to your comments and questions and provide you support;
  • Develop new services and offerings, and improve existing services and offerings;
  • Aggregate information we receive from you and third parties to help understand your needs and provide you better service;
  • Facilitate and improve our marketing and promotional efforts;
  • Conduct research and analytics designed to understand the third parties we interact with and improve our services and offerings;
  • Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
  • Enforce and carry out contracts and agreements;
  • Facilitate business transactions and reorganizations impacting the structure of our business; and
  • Comply with legal obligations.

Our Disclosure of Personal Information

We disclose personal information in the following ways:

  • Within Aspire and With Our Parent Company: Aspire and its parent company, Redwood Trust, are made up of many legal entities that are responsible for different aspects of our relationships with individuals we interact with and the services we engage in. To facilitate these interactions and services, Aspire entities disclose personal information to other Aspire and Redwood Trust entities for purposes and uses that are consistent with this Privacy Notice.
  • With Businesses You Represent: We may disclose personal information to businesses you represent in furtherance of the relationship between us and the business for which you are a representative.
  • With Transaction Partners: We may disclose your personal information to other entities and third parties involved in a transaction we are undertaking with you and/or the business you represent.
  • With Data Analytics Providers: We disclose personal information to data analytics providers who analyze statistics and trends relating to the usage of and activity relating to our services. These data analytics providers produce reports and make suggestions for our business strategy based on the personal information and other information analyzed.
  • With Marketing Partners: We coordinate with and disclose personal information to our marketing partners, including advertisement networks, social networks, retargeting partners and marketing communication providers, to communicate with you about our services and products and market our services and products to you.
  • With Vendor Management Providers: We disclose personal information to third parties we engage to assist in our vendor management process, including maintaining vendor records on our behalf.
  • With Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the use of personal information described in the Our Collection and Use of Personal Information section above, including website hosting, communications, identity verification, information technology support, and fraud monitoring. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
      to comply with laws and regulations or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
    • to detect, suppress, or prevent fraud;
    • to reduce credit risk and collect debts owed to us;
    • to protect the health and safety of us, our customers, or any person; or
    • as otherwise required by applicable law.
  • Otherwise with Consent or Direction: We may disclose personal information about you to certain other third parties with your consent or at your direction.

Cookies and Other Related Technologies

Overview of Cookies

When you interact with our website, we and our third-party partners and providers may use (i) cookies or small data files that are stored on your computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect personal information and use or disclose the personal information for the purposes described in the sections above. For example, our website uses Google Analytics and/or Google Tag Manager, web analytics services provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our online services. You can obtain more information on the use of Google Analytics by visiting Google’s privacy policy here and you can view Google’s currently available opt-out options here.

Our third-party partners and providers may also directly collect personal information about your online activities over time and across different websites after visiting our website, including for the purposes of providing online behavioral or interest-based advertising services to third parties.

Choice Relating to the Use of Cookies on Our Website

If you would prefer not to accept cookies on the aspireHEI.com website, you may adjust your Cookie Preferences by clicking the green cookie icon in the lower left-hand corner of your screen. Alternatively, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that rejecting cookies may negatively impact your experience using our website, as some features and offerings may not work properly.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use.

You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Additional Choice Relating to Third-Party Advertising Cookies

In addition to providing you the ability to adjust your cookie preferences as outlined above, we support the self-regulatory principles for online behavioral advertising published by the Digital Advertising Alliance (“DAA”). These principles and related programs allow individuals to exercise choice regarding the collection of information about their online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at  www.aboutads.info. 

If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and the related Network Advertising Initiative (“NAI”) program, please follow the instructions at  www.aboutads.info/choices and  www.networkadvertising.org/choices/  to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements from advertisers and third parties that participate in the DAA program on mobile apps, an individual can follow the instructions at  www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA and NAI program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our website, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s principles and other program requirements.

Your Communication Preferences

In connection with our services, we may send you email messages, posted mail or other communications, including communications regarding our services. You may ask us not to send you marketing communications:

  • By following any available opt-out instructions in the marketing communications, such as by clicking the unsubscribe link located at the bottom of a marketing communication email; or
  • Sending a request to not receive posted mail marketing communications to [email protected] or Aspire HEI Marketing Opt Out, 1 Belvedere Place, Suite 300, Mill Valley, CA 94941, which must include your name and mailing address.

If you request to opt out of marketing communications, please note that we may continue to send you non-marketing communications such as those directly related to the products or services we are providing you, the maintenance of your account, or the status of our ongoing business relations.

Children’s Personal Information

Our website is not directed to or intended for children under 13 years of age, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, do not use this website or otherwise provide us with any personal information. If we learn we have collected or received personal information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under the age of 13, please contact us at [email protected].

Region Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states or regions. Please refer below for disclosures that may be applicable to you:

If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.

Third-Party Websites

Our website may include links to third-party websites, plug-ins and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn more about the personal information practices of third parties, please visit their respective privacy notices.

Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting on this website or through other appropriate communication channels. All modifications will be effective upon their posting to our website unless we indicate otherwise in the post; it is therefore important that you review this Privacy Notice regularly.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].

Alternatively, inquiries may be addressed to:

Aspire HEI
Attn: General Counsel
1 Belvedere Place, Suite 300
Mill Valley, CA 94941

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Aspire RWT, LLC – NMLS #2506505
1 Belvedere Pl # 300, Mill Valley, CA 94941

Aspire HEI agreements are provided and administered by Aspire RWT, LLC and affiliates. Aspire is a home equity investment platform owned by Redwood Trust, Inc. For more information about Redwood Trust, please visit www.redwoodtrust.com.

California DRE #02215315 (RWT Home Options, Inc.)