Privacy Policy

Last Updated: September 23, 2024

Your privacy is important to us. Baker Hill Solutions, LLC. and its subsidiaries and affiliates (“Baker Hill,” “we,” or “us”), understand your concerns regarding how information about you is used and shared, and we appreciate your trust that we will use and share information about you carefully and sensibly. 

Baker Hill provides financial services technology to banks and credit unions for their loan origination and risk management operations (the “Services”). For private information processed or stored within the Services, Baker Hill is the data processor. Baker Hill’s clients are the data controllers.  Data subjects are encouraged to contact their bank or credit union to exercise their privacy rights for the private information contained within the Services.  Information regarding the type of information and how it is used by the Services can be reviewed in Baker Hill’s Privacy Sheet.

To market and support its Services, Baker Hill relies on certain outreach technologies (the “Technologies”).  This Privacy Policy applies to information we collect through the Technologies and any other means by which we may collect information about you.  This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit technologies in general, and our practices for collecting, using, maintaining, protecting and disclosing that information.  

By accessing or using our Technologies, or contacting us, you acknowledge that you have read, understood, and agree to the practices as described in this Privacy Policy. Baker Hill may share your information, including personal information, with our marketing, advertising, and business partners as described in this Privacy Policy for the purpose of marketing and supporting the Services.  This Privacy Policy may change from time to time (see Changes to this Privacy Policy below). Your continued use of the Technologies after we make changes is deemed to be acceptance of those changes, so please check our Privacy Policy periodically for updates. 

When do we collect your information?

Baker Hill collects information relating to you and your use of the Technologies to market and support the Services. Baker Hill collects personal information in the following ways:

  • From you when you register an account and communicate with us. We collect information from you when you register an account with us, request information, send us email, send us postal mail, or speak with us on the telephone.
  • From third parties. Baker Hill occasionally receives contact information to support business-to-business (B2B) outreach.
  • Automatically as you navigate the marketing outreach Technologies. Information collected automatically may include usage details, email address, IP addresses, and information collected through cookies and other tracking technologies.

What information do we collect?

Information you provide to us

When you provide personal information to us, we use it for the purposes for which it was provided to us as stated at the point of collection or as obvious from the context of collection. For example, if you send us an email requesting information, we will use your personal information to respond to your request. We may collect the following information:

  • First and last name
  • Phone number
  • Email address
  • Mailing address
  • Biographical information
  • Title
  • Company
  • Photograph

Through our Technologies, we and our third-party service providers automatically collect information about how you access and use the Technologies and information about the device you use to access the Technologies. We typically collect this information through a variety of tools, including cookies, web beacons, pixels, social media widgets, other tools to enable data recording and indexing, and similar technology (collectively, “tracking technologies”). We and our third-party partners may automatically collect such information as:

  • IP address
  • Device type
  • Browser type
  • Operating system or platform
  • Name of Internet service provider
  • Referring website
  • Exiting website
  • Pages visited on the Apps
  • Frequency, time, data, and duration of your visit on our Apps
  • Your location
  • Whether you access our website from multiple devices
  • Other interaction you may have on our Apps
  • Device Unique Device Identifier (e.g., Unique Device Identifier (UDID) or International Mobile Equipment Identity (IMEI)
  • Mobile device MAC or IP address
  • Information about your mobile carrier
  • Communications relating to customer support, and information drawn from such communications, for statistical and reference 

How do we use your personal information?

Marketing and supporting Services for you

We process personal information to support Services for you and to suggest additional Services to you, as well as to respond to communications from you. The precise purposes for which your personal information is processed will be determined by the request, and by applicable laws, regulatory guidance, and professional standards.

Conducting data analytics and supporting our Technologies

We use information we collect from you and information that we collect automatically to assessing the effectiveness of our business outreach Technologies. We take steps to ensure that your rights and the legitimacy of Baker Hills’ activities are safeguarded.  For example, Baker Hill may use your de-identified information and combine it with the de-identified information of others to generate statistics as a source of data for our products.

Sometimes we may de-identify information by removing any identifier that can be associated with your personal information. De-identified information helps us develop reports and analyses about how our customers use our Technologies and for other research such as making behavioral inferences. We may share de-identified information and reports and analyses based on de-identified information publicly and with other companies. To further protect your privacy, de-identified information does not include contact information or any other information that would identify any specific individual or household.

Do we disclose any information to outside parties? 

We do not sell, trade, or transfer your personal information to third parties with respect to information that Baker Hill collects directly from you, except in the circumstances described below.

Within Baker Hill

We may share your personal information with other Baker Hill divisions to serve you, including for the activities listed above.

Third-Party Service Providers

We disclose personal information to advertisers, merchants, consumer and market research companies, service providers who help us provide Technologies and services, or to other third-party service providers who provide certain specialized services to us, to provide services on our behalf, or who co-operate with us on projects. These business partners operate as separate controllers, and are responsible for their own compliance with data protection laws. These third-parties are contractually restricted from using or disclosing the information except as necessary to perform services or to comply with legal requirements.  

We may disclose aggregated, de-identified information, and analyses and reports derived from such information to third parties including utilities, service providers, advertisers, merchants, consumer and market research companies and other organizations. If we have obtained your personal information from one of our clients, they may have the same access to your information as we do. 

Legal Requirements and Business Transfers

We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official requests, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that Baker Hill is subject to  mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third-party. 

What choices do you have about your personal information?

We offer certain choices about how we communicate with you and what personal information we obtain about you and share with others.  How can you update your information and communication preferences?

Profile

If you have created a profile or account on our Community Portal, you can update your contact information after you log into your account.

E-mail

You may unsubscribe from emails from us by clicking the Unsubscribe at the bottom of any promotional email from us.  You may also contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing, and your requested changes.

Cookies

We provide a variety of services on our Technologies using cookies. We place cookies on your device in order to provide you with personalized access to essential services, enhance functionality, and to show you offers and services tailored to your interests.

A cookie is a small piece of data that a website can send to your browser, which may then be stored on your hard drive as a “tag” that identifies your computer. Cookies help to navigate from page to page on a website, provide secure connections, gather statistics about the usage and effectiveness of our site, and remembers preferences from a previous visit, when you return. 

We use third-party services for analytics and interest-based advertising purposes. These service providers and ad partners may use cookies alone or in conjunction with unique identifiers, beacons, and other tracking technologies to collect information about you when you use our website, open our emails, or interact with our ads. We do not combine the information collected through the use of these services with information that directly identifies you. 

Most web browsers automatically accept cookies, but you can change your browser’s settings to disable all or certain cookies if you wish. Please note that by disabling or deleting cookies, you may not be able to access the full functionality of our Apps.  Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you previously set.  Technologies that incorporate non-essential cookies incorporate a cookie management utility that can be used to customize which cookies are enabled.

Do Not Track

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (“DNT”) signals, we do not respond to them at this time. 

Do we transfer your personal information across geographies?

If you are in a country outside the United States, we may transfer personal information across geographical borders to Baker Hill entities, authorized service providers, or business partners in the United States working on our behalf in accordance with applicable law. We, our affiliates, business partners, and other third parties are exclusively located within the United States. 

How long do we retain your personal information?

We will keep your personal information for the period necessary to fulfil the purposes described in this Privacy Policy or as required under applicable law. 

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our Technologies. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We urge you to read the privacy policies of other websites before submitting any information to those websites. 

How do we protect your information?

Baker Hill has implemented reasonable physical, technical, and administrative security standards to protect personal information from loss, misuse, alteration, or destruction. We strive to protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.

Our affiliates, business partners, and other third-parties are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose. Our clients may also impose additional data right and protection obligations depending on the law, regulations and rules that govern their data processing practices.

Individuals Within the European Union and United Kingdom

Processor of Personal Data

Baker Hill Solutions, LLC.
1320 City Center Dr.
Suite 300
Carmel, Indiana 46032
United States

Baker Hill is the data processor in most cases of the personal data processed through the Technologies. Note that Baker Hill does not currently have clients within the European Union or United Kingdom nor does it market its services in those regions.  However, this Privacy Policy acknowledges that there may be data subjects from the EU and UK who may interact with the Technologies.

Legal Bases for Processing Personal Data

If you are an individual bearing citizenship in the European Union (EU) or United Kingdom (UK), we may collect personal data and process personal data about you when you interact with the Technologies and we have a legal basis for doing so under applicable EU laws. This means we collect and process your data only when:

  • it is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, supporting our Services, and marketing outreach;
  • you have consented to this collection and processing for a specific purpose;
  • it is necessary to fulfil our contractual obligations; or
  • it is necessary to comply with a legal obligation.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Some examples of where we may on your consent to process your personal data include sending you marketing emails. If you wish to withdraw your consent, please contact us at privacy@BakerHill.com. 

Some examples of our legitimate interests for processing personal data include:

  • application and network security; 
  • customer support;
  • marketing outreach for our Services.

Where we rely on our legitimate interests to process your personal data, you may have the right to object. More information on exercising this right can be found in the Individual Rights section below.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at privacy@BakerHill.com.  

Individual Rights

If you are located in the EU or UK or are a citizen of the EU or UK living in the United States, you have certain rights under EU data protection law with respect to your personal data, including the right to request access to, correct, and delete your personal data. You may also have the right to receive a copy of your personal data in a commonly used and machine-readable format, and to transmit such data to another controller. You also may object to processing of your personal data, or ask that we restrict the processing of your personal data in certain instances. 

To request deletion of, access to, or to make changes to your personal data, or to otherwise any of the rights in this section, please contact us at privacy@bakerhill.com. Please note that not all requests can be honored. 

Transfers, Storage, and Processing 

Our Technologies are operated from and hosted on servers located in the United States. If you access and use our website from a location outside of the United States, any personal data you provide to us or that is otherwise collected may be transferred to and processed in the United States. Users of our Technologies should be aware that the laws that apply to the use and protection of personal data in the United States or jurisdictions to which we transfer, or in which we process, personal data may differ from those of your country of residence. Users who access or use our Technologies from jurisdictions outside of the United States do so at their own choice and risk and are solely responsible for compliance with local law. The level of protection provided in the United States or other non-EU countries and jurisdictions from which you may access our Technologies may not be as stringent as that under EU data protection standards or the data protection laws of some other countries, possibly including your home jurisdiction.

Unresolved Complaints

If you are a resident of the EU and your inquiry with us has not been satisfactorily addressed, or if you believe we are processing your personal data not in accordance with the law or this Privacy Policy, you may file a complaint with the supervisory authority in your country of residence.

Your California privacy rights

California Civil Code Section § 1798.83 permits users of our Apps that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@BakerHill.com or write us at: 

Baker Hill Solutions, LLC.
1320 City Center Dr.
Suite 300
Carmel, Indiana 46032
United States

In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.  

Pursuant to applicable California law, including the California Consumer Privacy Act (CCPA), Baker Hill makes the following disclosures regarding the personal information Baker Hill has collected within the last 12 months:

Baker Hill has not sold consumers’ personal information in the twelve (12) months preceding the Effective Date of this Privacy Policy.

If you are a California resident, pursuant to the CCPA, you have the right to request:

  • the categories of personal information Baker Hill has collected about you;
  • the categories of sources from which your personal information is collected;
  • the business or commercial purpose of collecting or selling your personal information;
  • the categories of third parties with whom Baker Hill shares your personal information;
  • the specific pieces of personal information Baker Hill has collected about you; 
  • the categories of personal information that Baker Hill has sold about you and the categories of third parties to whom the personal information was sold, if applicable;
  • deletion of your personal information; and 
  • an opt out of having your personal information disclosed or sold to third parties.

To submit a request, or designate an authorized agent to make a request under the CCPA on your behalf, please contact us at privacy@BakerHill.com, (800) 821-4455, or complete the web form located at https://connect.bakerhill.com/l/635721/2019-11-26/24632i. To verify your identity when you submit a request, we will match the identifying information you provide to us to the personal information we have about you. If you have an account with us, we will also verify your identity through our existing authentication practices for your account. 

Baker Hill will not be required to comply with your request to delete your personal information if it is necessary for Baker Hill to maintain your personal information in order to:

  • complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of Baker Hill’s ongoing business relationship with you, or otherwise perform a contract between you and Baker Hill;
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • debug to identify and repair errors that impair existing intended functionality;
  • exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
  • engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Baker Hill’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
  • to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Baker Hill;
  • comply with a legal obligation; or
  • otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Baker Hill will not discriminate against you in the event you exercise any of the aforementioned rights under CCPA, including, but not limited to, by:

  • denying goods or services to you;
  • charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • providing a different level or quality of goods or services to you; or
  • suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Do we collect information from children?

Our Technologies are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Technologies. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Technologies or on or through any of its features, use any of the interactive or public comment features of the Technologies or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@BakerHill.com. 

Contacting us

For any questions, or to request further information regarding this Privacy Policy, please contact us at privacy@BakerHill.com. 

Changes to this Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or possibly through a notice on the Baker Hill’s status page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting this Privacy Policy to check for any changes.