Contents

1. Scope & Who We Are

2. Information We Collect

3. How We Use Your Information

4. How We Share Information

5. Cookies & Tracking Technologies

6. Do Not Track

7. California Privacy Rights (CCPA)

8. Data Security

9. Third-Party Links

10. Changes to This Policy

11. Contact Us

1. Scope & Who We Are

This Privacy Policy describes how Andrey Dimitrashuk (NMLS #1583893), operating as Loans by Drey under the brokerage Lending Concepts (NMLS #1206623, CalDRE #01957794), collects, uses, and protects information gathered through this website, loansbydrey.com (the “Site”), and its related services.

“You” or “User” refers to any visitor or registered user of this Site. “We” or “Us” refers to Andrey Dimitrashuk, Lending Concepts, and their affiliates. Lending Concepts is a California-licensed mortgage brokerage operating under JPS Lenders, Ltd.

By using this Site, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the Site.

2. Information We Collect

A. Information You Provide Directly

When you contact us, submit a loan inquiry, complete a pre-qualification form, or register for our services, we may collect:

• Full name, date of birth, and government-issued identification numbers (for mortgage processing only)

• Contact details: address, city, state, ZIP code, phone number, and email address

• Financial information: income, assets, employment, and credit information required for loan origination

• Property information: property address, estimated value, and intended use

• Username, password, and account credentials if you register on the Site

• Messages, comments, or feedback you send us voluntarily

B. Information Collected Automatically

When you visit the Site, we automatically collect:

• IP address and approximate geographic location

• Browser type, version, and operating system

• Pages visited, time on site, and referring URL

• Device identifiers and screen resolution

• Cookie and session data (see Section 5)

C. Information from Third Parties

We may receive information about you from credit bureaus, real estate professionals, title companies, or other parties involved in the mortgage process, as permitted by applicable law including the Gramm-Leach-Bliley Act (GLBA) and California Financial Code.

D. Survey & Contest Information

We may occasionally conduct optional online surveys or offer contests. Participation is voluntary. Survey responses are kept anonymous unless you expressly consent otherwise. Contest entries may require contact and demographic information for prize fulfillment.

3. How We Use Your Information

We use the information we collect to:

• Process and evaluate your mortgage loan application or inquiry

• Communicate with you about your loan, account, or services

• Respond to your questions, comments, or feedback

• Send you service updates, informational content, or promotional communications (you may opt out at any time)

• Improve Site functionality, content, and user experience

• Comply with legal and regulatory obligations, including NMLS reporting, RESPA, TILA, and California Financial Code requirements

• Detect fraud, enforce our Terms of Use, and protect the security of our Site and users

• Fulfill contest prizes or survey incentives where applicable

We will not use your information for purposes materially different from those described here without first notifying you and, where required by law, obtaining your consent.

4. How We Share Information

We do not sell or rent your personally identifiable information to third parties. We may share your information in the following limited circumstances:

• Wholesale lenders and service providers: As a mortgage broker, we submit your loan application to wholesale lenders on your behalf. This sharing is necessary to fulfill the services you request.

• Affiliated service providers: We may share data with vendors who assist us in operating the Site or conducting our business (e.g., CRM platforms, email providers, analytics), subject to confidentiality agreements.

• Legal and regulatory requirements: We may disclose information when required by law, regulation, court order, or government authority, including NMLS reporting obligations.

• Business transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to a successor entity, subject to the same privacy protections.

• With your consent: We may share information for other purposes with your prior consent, such as posting a testimonial or review with your permission.

5. Cookies & Tracking Technologies

We use cookies and similar technologies (web beacons, pixels) to enhance your experience, analyze Site traffic, and support marketing efforts.

Types of Cookies We Use

• Essential cookies: Required for the Site to function correctly (e.g., form submissions, session management).

• Analytics cookies: Help us understand how visitors use the Site (e.g., Google Analytics). Data is aggregated and anonymized.

• Preference cookies: Remember your settings and preferences across visits.

• Marketing cookies: Used to deliver relevant advertising and track campaign performance.

Your Cookie Choices

You may disable cookies at any time through your browser settings. Please note that disabling certain cookies may reduce Site functionality. You can also opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-on.

6. Do Not Track

Some web browsers transmit “Do Not Track” (DNT) signals to websites. Because there is currently no universally accepted technical standard for honoring DNT signals, our Site does not alter its data collection or use practices in response to DNT signals. We will update this section if an industry standard emerges and we adopt it.

If you have questions about our tracking practices, please contact us at the information in Section 11.

7. California Privacy Rights (CCPA / CPRA)

California Residents: The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you specific rights regarding your personal information.

Your Rights

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.

• Right to Delete: You may request deletion of personal information we collected, subject to certain exceptions (e.g., completing a transaction, legal obligations).

• Right to Correct: You may request correction of inaccurate personal information we maintain about you.

• Right to Opt Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising.

• Right to Limit Use of Sensitive Personal Information: We use sensitive personal information (e.g., financial data, Social Security numbers) only as necessary to provide mortgage services and as required by law.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

How to Submit a Request

To exercise your California privacy rights, contact us by phone at (916) 909-5640 or by email at [email protected]. We will verify your identity before processing your request. We will respond within 45 days of receipt, with a possible extension of an additional 45 days when reasonably necessary.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require written proof of authorization and may verify your identity directly before fulfilling a request submitted by an agent.

8. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personally identifiable information from unauthorized access, disclosure, alteration, or destruction. These include encrypted data transmission (SSL/TLS), access controls, and secure server environments.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. If you have reason to believe your interaction with us is no longer secure, please contact us immediately.

We retain your personal information only as long as necessary to fulfill the purposes described in this policy or as required by law, including applicable federal and California record-retention requirements for mortgage records.

9. Third-Party Links

This Site may contain links to third-party websites, including lender portals, real estate platforms, and industry resources. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policy of any website you visit before providing personal information.

Our inclusion of a link does not imply endorsement of, or affiliation with, the linked site.

10. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will update the “Last Updated” date at the top of this page. For significant changes, we may provide additional notice (such as a banner on the Site or an email notification). Your continued use of the Site after any change constitutes your acceptance of the updated policy.

We encourage you to review this policy periodically to stay informed about how we protect your information.