Privacy Policy

Last Updated: December 1, 2025

Company Address:

2823 E Fountain St.

Mesa, AZ 85213

Phone: 1-714-868-0616

1. Introduction

Infinity Lending Services, Inc. DBA nuFlip and KP RE Capital Group (“we,” “us,” “our”) provide mortgage lending, financial analysis, underwriting, asset verification, and related real‑estate financing services nationwide. This Privacy Policy is written to comply with federal privacy laws (GLBA, FCRA, ECOA, TILA, RESPA), state‑level data protection laws, including California’s CCPA/CPRA, and financial-data requirements necessary for integration with Plaid. It describes the categories of information we collect, how we use it, how we share it, and your rights.

2. Information We Collect

We collect the following categories of information:

- Personal Identifiers: Legal name, aliases, physical address, mailing address, email, date of birth, phone number, and government‑issued identification numbers.

- Financial and Lending Information: Income, employment history, bank statements, direct deposit data, assets, liabilities, tax returns, property information, mortgage payoff statements, insurance documents, and loan application data as defined under the Uniform Residential Loan Application (URLA).

- Sensitive Personal Data: Social Security numbers, driver’s license numbers, financial account numbers, credit information, biometric identifiers (if used for authentication), and other sensitive information as covered under CPRA.

- Credit Information: Credit scores, reports, tradeline data, derogatory accounts, public records, and credit inquiries from consumer reporting agencies.

- Automated Data: Device identifiers, IP address, session data, login metadata, cookies, geolocation (if enabled), and behavioral analytics.

- Plaid‑Connected Data: Bank balances, account ownership details, transaction history, account numbers (tokenized when possible), income verification data, and identity confirmation data.

3. How We Use Your Information

We use your information for the following purposes:

- Loan Origination & Underwriting: Verifying assets, liabilities, credit profile, employment, and identity; performing risk assessments; determining eligibility; and underwriting mortgage loans.

- Regulatory Compliance: Satisfying GLBA, FCRA, ECOA, HMDA reporting, anti‑fraud obligations, OFAC checks, AML monitoring, and investor guidelines.

- Customer Communication: Sending application updates, disclosures, adverse action notices, verification requests, consent forms, and transaction documentation.

- Fraud Prevention & Security: Identity verification, detection of suspicious activity, anti‑money laundering review, and cybersecurity monitoring.

- Servicing & Post‑Closing Requirements: Record retention, loan audits, post‑closing verification, regulatory inspection preparation, and secondary market transfers.

- Operational Improvement: Testing systems, improving user experience, analytics, training, and quality control as permitted by law.

4. How We Share Your Information

We share your information only as permitted by federal and state laws:

- With Plaid: For secure account aggregation, identity verification, income verification, and transaction analysis.

- With Service Providers: Appraisal companies, credit bureaus, VOE/VOI vendors, LOS systems, compliance engines, auditors, pricing engines, insurance verification providers, document preparation companies, and closing agents.

- With Government Agencies: FHA, VA, USDA, FNMA, FHLMC, CFPB, HUD, state banking regulators, and agencies requiring reporting or audits.

- With Investors and Secondary Market Participants: When required for loan sale, pooling, securitization, or investor review.

- For Legal and Risk Management: If required by subpoena, court order, regulatory inquiry, or to protect against fraud, financial loss, or security threats.

We do not sell your personal information and do not share data for cross‑context behavioral advertising.

5. California Privacy Rights (CCPA/CPRA)

California residents may exercise:

- Right to Know categories, sources, and recipients of personal data

- Right to Access information collected about them

- Right to Correction of inaccurate data

- Right to Deletion (subject to lending exemptions)

- Right to Opt‑Out of sale/share (not applicable—we do not sell data)

- Right to Limit Use of Sensitive Personal Information

- Right to Non‑Discrimination for exercising privacy rights

To submit a California request, email support@nuflip.com.

6. Use of Plaid

We use Plaid Inc. to verify financial accounts securely. By using Plaid, you authorize Plaid to access and transmit your financial information. Plaid’s privacy policy governs how Plaid uses your information.

7. Data Security

We employ:

- Encryption in transit and at rest

- Multi‑factor authentication

- Role‑based access control

- Network segmentation and intrusion detection

- Data minimization protocols

- Compliance logging and monitoring

- Vendor due‑diligence reviews

No system is completely secure, and you acknowledge inherent risks of digital transmission.

8. Retention of Information

We retain data according to:

- Federal lending regulations (typically 3–7 years)

- Fraud monitoring requirements

- Investor audit requirements

- HMDA reporting standards

- Financial and tax audit obligations

9. Children’s Privacy

We do not knowingly collect information from individuals under age 18.

10. Changes to Policy

We may update this Privacy Policy and will post revisions with updated effective dates.

Terms of Service

1. Acceptance of Terms

By accessing products or services provided by Infinity Lending Services, Inc. DBA nuFlip and KP RE Capital Group (“Company”), you agree to these Terms. These Terms apply to all users, applicants, and site visitors.

2. Services Provided

Our services include mortgage lending, underwriting, property analysis, credit review, automated financial verification, LOS‑based application management, escrow coordination, and digital document execution.

3. Eligibility

You must be at least 18 years old, reside in a U.S. state where we are licensed or permitted to operate, and provide accurate and verifiable information.

4. User Responsibilities

You agree to:

- Provide accurate, truthful, and up‑to‑date information.

- Refrain from misrepresenting financial data.

- Maintain confidentiality of login credentials.

- Not engage in fraudulent or unlawful activity.

- Respond to verification and documentation requests promptly.

Failure to comply may result in application denial.

5. Use of Third‑Party Services

We use external vendors (Plaid, credit bureaus, appraisal management companies, verification providers, signing providers, etc.). You authorize these third parties to process and transmit your data.

6. Limitation of Liability

We make no warranty that services will be uninterrupted or error‑free. To the fullest extent permitted by law, we are not liable for:

- Loss of data

- Unauthorized access due to user negligence

- Delays caused by third‑party providers

- Indirect or consequential damages

7. Governing Law

These Terms are governed by federal law and the laws of Arizona, unless overridden by consumer‑protection requirements of your state.

8. Dispute Resolution

Disputes will be resolved through binding arbitration, except where prohibited. Claims involving regulatory rights may proceed through appropriate channels.

Disclosures

Required Disclosures

1. Equal Credit Opportunity Act (ECOA)

We do not discriminate based on race, color, religion, national origin, sex, marital status, age, receipt of public assistance, sexual orientation, gender identity, or disability.

2. Fair Credit Reporting Act (FCRA)

We may obtain your credit report to evaluate your application. You may dispute inaccurate information by contacting the credit bureau(s) directly or notifying us.

3. Electronic Communications Disclosure (E‑Sign Act)

By using our digital services, you consent to electronic delivery of disclosures, statements, and documents. You can request paper copies at any time.

4. RESPA/TILA Integrated Disclosures (TRID)

You will receive Loan Estimates, Closing Disclosures, and applicable federal notices as required.

5. Licensing & Regulatory Disclosure

We comply with federal, state, and NMLS licensing regulations. Licensing information is available upon request.

Compliance Statements

1. Anti‑Money Laundering (AML)

We comply with the Bank Secrecy Act. We verify identities, monitor transactions, and file Suspicious Activity Reports (SARs) when required.

2. Data Protection Compliance

We comply with:

- GLBA Safeguards Rule

- CCPA/CPRA

- FCRA

- E‑Sign Act

- FHFA and investor data‑security requirements

3. Fair Lending Compliance

We maintain fair lending policies, conduct statistical monitoring, provide training to employees, and test for discriminatory patterns.

4. Recordkeeping Compliance

We maintain records according to:

- CFPB regulations

- HUD/FHA requirements

- FNMA/FHLMC guidelines

- Federal lending audits

- State-specific retention laws