REVERSE MORTGAGE COUNSELING ASSOCIATION

Effective as of July 2010

Reverse Mortgage Counseling Association (“RMCA” or "we") has developed this policy statement to assist end users of the www.rmcounseling.org Web site ("you" or "user") with protecting their personal privacy within its Web site (the "Privacy Policy"). The following information summarizes the personally identifiable information gathering and use practices for RMCA's United States Web site located at the URL, rmcounseling.org (collectively, the “Site”). Personally identifiable information ("PII") includes information that can be linked to a specific individual, such as a name, address, phone number, or e-mail address. RMCA reserves the right to change this Privacy Policy at any time. If RMCA makes changes to this Privacy Policy, RMCA will post those changes at this location and provide notice of any material changes so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Please review this Privacy Policy on a periodic basis.

What Information Does RMCA Collect?

PLEASE NOTE: THE TYPE OF DATA COLLECTED BY RMCA WILL VARY WITH YOUR USE OF THE SITE AND THAT MOST DATA SUBMISSION IS VOLUNTARY. Below, we provide specific examples of the types of PII RMCA may collect through the Site.

Contact Information: RMCA may request or require contact information, such as your name, address, phone number, facsimile number, and e-mail address.

Demographic Information: RMCA may collect demographic and general profile data related to home-ownership or financing.

Transactional Information: RMCA may maintain a database of aggregated information about the transactions on the Site (e.g., tool or feature (and related database) utilization, registration information, and article, program, activity, or content selection data).

Technical Information: RMCA may also collect Internet Protocol (IP) addresses from all users of our Site as well as the date and time of access and the Web page(s) accessed. RMCA may also catalog your log-in information and the type of computer, browser, or operating system used by the user.

How Does RMCA Use that Information?

To improve the quality of the information and services RMCA offers to you and to otherwise operate the Site and provide certain of its features, tools, and functionality, RMCA collects various PII (as described above) from different parts of its Site. RMCA gathers most information during the registration processes it utilizes to allow for membership and/or to enable use of certain online tools or certain information, forums, directories, materials, and/or services. But, RMCA may request PII at other times, including, but not limited to, when you report a problem with our Site, when you complete application forms, when you sign up for a program or event, or when you request to receive communications from RMCA.

The Site offers two different levels of access and service: (1) publicly available information areas and (2) registered member areas where an individual can access particular features, applications, courses, and tools (the "Registered Member Section(s)"). Most of the Site is informational in nature and publicly available to all users. Consequently, until you register, participate in an application process, sign up for a program or event, or request to receive information from RMCA, you are able to browse the Site without providing any PII, although your browser may tell us what type of computer and operating system you are using as well as other kinds of technical information.

When you provide PII to RMCA, you share that information only with RMCA, unless it is specifically stated otherwise or you are using a service or completing a transaction involving third party products, applications, and/or services, such as initiating the application process for credit counseling, registering for an event, or processing a membership fees. In such instances, information sharing will be necessary to enable the transaction to take place.

Below, is more detail on how RMCA uses your PII.

Contact Information: RMCA may use your contact information in connection with the provision of its services and content and to enable you to participate in the Site's activities, applications, and offerings. RMCA may also use your contact information to facilitate registration with RMCA or with a particular program or event, to assist with the initiation of credit counseling by a third party provider, to advertise its services and the goods and services of third parties, to create a personalized experience for you, to provide you with news and information, to contact you regarding a survey, and to get in touch with you when necessary with respect to transactions conducted through the Site, material changes in our Site's policies and agreements, new services RMCA may offer, or otherwise. Please also note that certain PII on RMCA member contacts may be made available for public review on the Site in connection with the Site's directory. We also share your contact information with our agency members, as is necessary to assist with the initiation of credit counseling and to allow for the on-line registration for events, for advertising purposes, for analysis, and for internal business purposes. But, except for sharing arrangements with RMCA's business partners, we do not share your contact information with other types of third parties for any other purpose, except to a court or governmental agency if required by law.

Demographic Information: RMCA may use demographic information for administrative, management, and monitoring purposes in order to continue to improve the Site and the quality of RMCA's on-line services. In addition, RMCA may share, license, and/or sell survey results and aggregated demographic data collected through the Site with its business partners, the general public, the news media, and with the U.S. Government and state governments, not only as may be required by law, but also for advertising purposes, for release to third parties, and to participate in government programs and initiatives. But, such information will not identify any particular user.

Transactional Information: RMCA may share, license, and/or sell transactional data on an aggregated basis, which will not identify any particular user, with advertisers or other third parties, including our business partners, for business purposes.

Technical Information: RMCA may use technical information, such as your IP address or browser type, to help diagnose problems with our servers, analyze Site usage trends, track user movements on the Site, and to otherwise manage and monitor our Site.

Legal Action. RMCA may disclose PII when legally required to do so in accordance with government requests or regulations or legal proceedings. We may also disclose PII to protect against misuse or unauthorized use of the Site or as is otherwise required to limit legal liability, protect or defend our rights, property, or interests, or protect the safety, rights, or property of our users.

What About the Use of Cookies?

RMCA may use cookies and/or other programming techniques to enhance and/or monitor your experience while using our Site. Cookies and other related techniques are generally pieces of information, which RMCA uses for record-keeping purposes, which the Site transfers to us and/or your computer's Web-browser for storage on your computer's hard drive. Cookies and other related techniques enable RMCA to manage and/or customize your experience on the Site. Cookies and other related techniques also make Web-surfing easier by automatically performing certain functions such as saving your personal preferences and by ensuring that you don't see the same advertisement repeatedly. RMCA, however, will not use cookies to record passwords or credit card information. Moreover, you can delete any cookies residing on your hard drive by following the instructions for your Web browser.

Many consider the use of cookies to be an industry standard. Consequently, your Web browser is likely set to accept cookies. If you would prefer not to receive cookies, however, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, you should understand that it is possible that some areas of our Site will not function properly when you view them.

What About External or Third Party Web Sites?

To the extent hyperlinks or gateways (whether through banner advertisements or otherwise) are utilized to access external or third party sites, you should be aware that these external or third party sites may collect PII and are not controlled by RMCA and therefore, are not subject to this Privacy Policy. RMCA suggests that you check the privacy policies of these sites to determine how the proprietors of these third party sites will utilize your PII.

What About Security?

As is appropriate for the nature of PII collected and stored by RMCA, this Site has industry standard security measures or safeguards in place to protect against the loss, misuse, and alteration of the information under RMCA's control. Although RMCA has endeavored to create a secure and reliable Site, the confidentiality of any communication or material transmitted via the Internet cannot be guaranteed. Accordingly, you should consider carefully if you want to submit sensitive information via the Internet. RMCA urges you to take every precaution to protect your PII when on-line.

What About “Opting-Out” of Data Collection and Use?

The collection, use, and distribution of your PII is necessary for RMCA to provide certain features, applications, and services and to otherwise operate the Site. For example, all users who register for the Registered Member Section(s), initiate the application process for credit counseling, sign up for a program or event, and/or seek to receive information or newsletters from RMCA will need to agree to RMCA's use and collection of PII. Once registered with the Registered Member Section(s), RMCA maintains your information so long as you are registered as a member and/or for RMCA's services at this Site.

But, most of RMCA's other programs are completely voluntary and as you are otherwise permitted to browse through and access the non-restricted areas of the Site, you can decide on your own if you wish to provide your PII or opt-out of doing so. For example, if RMCA conducts a survey, you do not have to participate unless you agree to do so.

RMCA also provides you with the opportunity to opt-out of certain RMCA business practices where your PII may be used. Specifically, users my opt-out of including the PII they provide to RMCA in connection with the following activities: (i) inclusion in user mailings, (ii) e-mail communications sent by RMCA, (iii) facsimile communications sent by RMCA, (iv) future donation programs, and (v) sharing arrangements with RMCA's business partners.

Thus, to a large extent, you can control the information you provide or share with RMCA and/or its business partners. Moreover, even when RMCA contacts you, from time to time, regarding its products/services, this Site, or otherwise, if RMCA sends you such a communication, RMCA specifically provides you with the opportunity to opt-out of receiving similar future correspondence by sending an e-mail to info@rmcounseling.org.

What About Correcting, Deleting, or Updating Information?

At any time, you may contact RMCA to correct, modify, or delete the information you provide to RMCA through this Site, namely, your name, e-mail address, phone number, address, and contact preferences. Moreover, when you cease to use RMCA's services or no longer wish to be included in RMCA database, you may contact RMCA at info@rmcounseling.org to request to have your information removed from our database. In the event that RMCA receives such a request or change, RMCA may require you to confirm or verify any change to your record. Please note, however, that the collection and uses of certain PII is necessary to provide certain services, functionality, or information through the Site and the deletion of such necessary PII, e.g., an e-mail address, may render a particular service or functionality or RMCA's ability to provide it inoperable.

What About Children?

RMCA cares about the safety of children on its Site and encourages parents and guardians to monitor their children's use of the Internet. Although the Site is suitable for a general audience, this Site is intended for use only by users who are over 18 years of age or the legal age of majority. Accordingly, RMCA does not knowingly solicit PII from children or send them requests for personal information.

What About Any Other Questions?

If you have any questions about this Privacy Policy, the information collection and dissemination practices of this Site, or RMCA's use of your PII, you can contact RMCA at info@rmcounseling.org.