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Broadmark Realty Capital Privacy Policy

Broadmark Realty Capital Inc. (hereafter referred to as “Broadmark,” “us,” “we,” and “our”) is a leading mortgage real estate investment trust (REIT).  This privacy policy applies to the personal information that we collect.

Types Of Information We Collect

We receive personal information from our clients, potential clients, and employees.  The following provides examples of the type of information that we collect and how we use that information.

Context Types of Data Primary Purpose for Collection
and Use of Data
Information about Clients We collect the name, and contact information, of our clients and their employees with whom we interact. We have a legitimate interest in communicating with our clients concerning normal business administration such as projects, services, and billing.
Cookies and First Party Tracking We may use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.   Clear GIFs are near-invisible graphics that allow us to track when a webpage opens and displays. We have a legitimate interest in making our website operate efficiently and understanding how visitors interact with our websites.
Cookies and Third Party Tracking We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. Where required by law, we base the use of third party cookies upon consent.
Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages. We have a legitimate interest in understanding how you interact with the communications that we send to you.
Employment If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your Social Security Number.  Providing this information is required for employment. We use information about current employees to perform our employment obligations (e.g., to process paychecks).  In some contexts, we are also required by law to collect information about our employees.  We also have a legitimate interest in using employee-related information for efficient staffing and work force operations.  We have a legitimate interest in using information about job applicants to process employment applications.
Feedback/Support If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List We may offer you the ability to sign up for a mailing list.  If we do so we will collect your email address or postal address. We share information about our products and services with individuals that consent to receive such information.  We have a legitimate interest in sharing information about our products or services.
Surveys If you participate in a survey we will collect information that you provide through the survey.  If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Website interactions We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms.  This may also include information about your device or browser. We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful.  We also have a legitimate interest in detecting and preventing fraud.
Web logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our websites.

In addition to the information that we collect from you, or from our clients, directly we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.  For example, if you submit a job application, or become an employee, we may conduct a background check.

Use And Processing Of Information

In addition to the purposes and uses described above, we use information in the following ways:

  • To identify you when you visit our websites.
  • To provide our products and services, including commercial loans, construction loans, and land loans.
  • To provide our products and services to your business or employer.
  • To improve our services and product offerings.
  • To conduct analytics.
  • To respond to inquiries related to support, employment opportunities, or other requests.
  • To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
  • For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you execute a commercial loan with us on behalf of your company, we collect your information to execute that loan, but we also collect your information because we have a legitimate interest in understanding who our clients are and what services we perform on their behalf.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

  • Affiliates and Acquisitions. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or anticipates acquiring, our company, business, or our assets, we will also share information with that company.
  • Other Disclosures with Your Consent. We may ask if you would like us to share your information with unaffiliated third parties who are not described elsewhere in this policy.
  • Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, discovery requests, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
  • Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, provide technical support, and process applications.

Your Choices

You can make the following choices regarding your personal information:

  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service-related communications.
  • Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  • Access To Your Personal Information. We will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by contacting us at the address described below.
  • Changes To Your Personal Information. You can contact us at the address described below in order to request that your information be modified.
  • Deletion Of Your Personal Information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of information or request that we delete your personal information, by contacting us at the address described below.
  • Revocation Of Consent or Objections. You may revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below.  If you revoke your consent/object we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent/object if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
  • Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

Unless otherwise specified in this policy, please address written requests and questions about your rights to clientservices@broadmark.com or call us at 1-888-992-1312.

Note that, as required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, your business contact information, or your interaction history with Broadmark. We may also ask you to provide a signed declaration confirming your identity.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

  • A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
  • If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

To the extent you are utilizing a function of our website that permits you to create an account, you will be prompted to create a password for the account.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

Miscellaneous

The following additional information relates to our privacy practices:

  • Transmission Of Information To Other Countries. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States and Canada. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
  • Changes To This Privacy Policy. We may change our privacy policy and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.  Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
  • If you are visually impaired, you may access this notice through your browser’s audio reader.
  • We do not knowingly sell the personal information of minors under 16 years of age.
  • Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself.  California residents may be entitled in some cases to opt-out of having their information sold to third parties. We do not discriminate against California consumers who exercise any of their rights described in this policy.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

Broadmark Client Services

1420 Fifth Avenue, Suite 2000

Seattle, Washington 98101

1-888-992-1312

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Effective Date: January 1, 2021

Last Updated: January 1, 2021