Privacy Policy

This Privacy Policy explains how BluStar Digital Media (“BluStar,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards information when you visit our website, book a system demo, download a resource, or use our mortgage client acquisition system. By using our website or Services, you consent to the practices described here.

1. Information We Collect

Depending on how you interact with BluStar, we may collect the following categories of information:

Information you provide directly. This may include your name, business name, email address, phone number, NMLS ID, brokerage or lender affiliation, licensing information, geographic coverage, loan volume, average loan size, website and social media information, payment and billing information, and information you submit through forms, applications, surveys, onboarding materials, support requests, or other communications.

Client information. When you become a BluStar client, we may collect business, operational, campaign, account, billing, contact, calendar, CRM, advertising, and other information necessary to provide the Services.

Borrower and prospect information processed on behalf of Clients. When BluStar provides borrower acquisition, advertising, CRM, automation, lead nurturing, appointment booking, or related Services to a Client, we may process information about borrowers and prospects on that Client's behalf. This may include names, phone numbers, email addresses, qualification information, conversations, appointment information, pipeline status, notes, and other information provided through the Client's campaigns, forms, funnels, CRM, or communication systems.

Such borrower or prospect information is processed for the purpose of providing the Services to the applicable Client and is not treated as BluStar's own independent marketing database.

Automatically collected information. We may automatically collect information such as IP address, device type, browser type, operating system, referring URLs, pages viewed, time spent on pages, clicks, interactions, approximate location information, and other website or usage information through cookies, pixels, web beacons, session technologies, analytics tools, and similar technologies.

Communications. Depending on how you communicate with us and the functionality being used, we may collect or retain emails, SMS messages, call information, call recordings, meeting or video-session information, support communications, and related records where permitted by applicable law.

Information from third parties. We may receive information from advertising platforms such as Meta and Google, CRM and telephony providers, scheduling and payment providers, analytics providers, publicly available business or licensing sources, and other service providers used to operate our business or provide the Services.

We do not knowingly collect personal information directly from children under 18.

BluStar is a marketing and technology provider. We are not a consumer reporting agency, do not independently obtain consumer credit reports for underwriting purposes, and do not make mortgage credit decisions.

2. How We Use Information

We may use personal information for the following purposes:

• To provide, build, operate, maintain, optimize, and support the Services.
• To set up and manage advertising campaigns, funnels, forms, CRM systems, automations, lead qualification, follow-up systems, and appointment booking systems on behalf of Clients.
• To communicate with Clients and prospects regarding onboarding, support, account administration, services, training, events, updates, and other business-related matters.
• To process payments, invoices, refunds, and other financial transactions.
• To review eligibility for any performance commitment or limited refund provided under an applicable Terms of Service agreement.
• To capture and maintain, where applicable and supported by the relevant systems, records of consent, opt-in status, opt-out requests, communication preferences, and related communication records.
• To operate SMS, email, calling, appointment, and other communication workflows.
• To monitor, troubleshoot, secure, and improve our website, systems, and Services.
• To detect and prevent fraud, abuse, unauthorized access, security incidents, or violations of law or our agreements.
• To create anonymized and aggregated statistics, analytics, benchmarks, and performance insights that do not identify individual Clients or borrowers.
• To comply with applicable legal, regulatory, tax, accounting, recordkeeping, and governmental requirements.
• To establish, exercise, or defend legal claims and enforce our agreements.

Where BluStar processes borrower or prospect information on behalf of a Client, we generally process that information in accordance with the Client's instructions and the applicable service arrangement.

3. How We Share Information

BluStar does not sell personal information for money.

We may disclose or make information available to the following categories of recipients when reasonably necessary to operate our business or provide the Services:

Service providers and subprocessors. These may include CRM providers, hosting providers, email and messaging providers, telephony providers, scheduling platforms, analytics providers, payment processors, cloud-storage providers, software providers, and other technology vendors that help us provide the Services.

Advertising and platform providers. Information may be shared with advertising platforms such as Meta, Google, and other platforms where necessary to create, deliver, measure, optimize, or troubleshoot advertising campaigns.

Professional advisors. We may disclose information to attorneys, accountants, consultants, insurers, auditors, or other professional advisors where reasonably necessary.

Legal and safety disclosures. We may disclose information where required by law, legal process, subpoena, court order, governmental request, or where reasonably necessary to protect our rights, property, systems, users, or others.

Business transactions. If BluStar participates in a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction, information may be transferred as part of that transaction, subject to applicable law.

When we use service providers to process information on our behalf, we seek to use providers that are appropriate for the Services and that are subject to reasonable contractual or operational requirements.

For borrower or prospect information processed on behalf of a Client, BluStar does not intentionally sell, resell, or disclose that information to unrelated mortgage professionals for their independent marketing purposes.

4. Cookies, Pixels, and Advertising Technologies

BluStar uses cookies, pixels, web beacons, tags, session technologies, analytics tools, and similar technologies to operate and improve the website and Services.

These technologies may be used to:

• Remember preferences and settings.
• Understand website usage and performance.
• Measure advertising performance.
• Track conversions and interactions.
• Improve our marketing and website experience.
• Support retargeting or interest-based advertising where applicable.

Our website may use technologies provided by third parties, including advertising and analytics providers such as Meta and Google.

Depending on your location and applicable law, certain sharing of information with advertising partners may be considered targeted advertising, cross-context behavioral advertising, or a similar regulated activity.

You can manage certain cookies and similar technologies through your browser settings and, where available, through tools provided by the applicable advertising or technology platform.

Where required by applicable law, BluStar will honor recognized privacy preference signals, including Global Privacy Control (“GPC”), to the extent technically supported and legally required.

5. SMS, Calling, and Communication Consent

If you provide your phone number directly to BluStar and separately provide any consent required by applicable law, we may contact you by phone, SMS, or other communication methods regarding your inquiry, account, onboarding, support, or BluStar Services.

Where applicable, communications may be sent using automated technology. Message and data rates may apply, and message frequency may vary.

You may opt out of SMS communications by replying STOP to an applicable message or using another available opt-out mechanism. You may request assistance by replying HELP where supported.

Email marketing communications may include an unsubscribe mechanism.

Where applicable, BluStar may capture and maintain records relating to consent, opt-in status, opt-out requests, communication preferences, and related communication activity for purposes of operating communication systems, maintaining records, and supporting applicable compliance requirements.

When BluStar provides Services to a mortgage Client and processes borrower information on that Client's behalf, the applicable Client is responsible for the legal basis, consent, disclosures, and authorization required for communications with its borrowers and prospects. BluStar provides and operates the technical communication systems, workflows, and controls used to facilitate those communications in accordance with the Client's instructions and applicable platform functionality.

BluStar does not sell or disclose mobile opt-in information or consent records to third parties for their independent marketing purposes.

6. Client Data and Borrower Information

When BluStar provides Services to a mortgage broker, lender, loan originator, or other business Client, we may process borrower and prospect information on behalf of that Client.

In those circumstances:

• The Client generally determines why the information is collected and how it is used in connection with its business.
• BluStar processes the information as necessary to provide the agreed Services.
• BluStar may store, organize, route, analyze, communicate with, or otherwise process the information through the CRM, advertising, telephony, messaging, scheduling, and other systems used to provide the Services.
• BluStar may implement approved consent language, disclosures, opt-out mechanisms, suppression workflows, and communication controls as part of the Services.
• BluStar will not intentionally sell, resell, or distribute campaign-generated borrower or prospect information to unrelated mortgage professionals for their independent marketing purposes.
• BluStar may use anonymized and aggregated information that does not identify the Client or individual borrowers for analytics, benchmarking, quality improvement, and service development.

The applicable Client remains responsible for providing lawful instructions, required notices, disclosures, and legally sufficient consent where required, as well as for its underlying mortgage, advertising, and regulatory obligations.

Where required by applicable law, BluStar will reasonably assist a Client with requests relating to borrower or prospect information processed on that Client's behalf.

7. Data Retention

BluStar retains personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide the Services, maintain business and financial records, comply with legal or regulatory obligations, resolve disputes, enforce agreements, support performance or refund reviews, prevent fraud, and protect our legitimate business interests.

For Client Data and borrower information processed on behalf of a Client, retention may also depend on the Client's instructions, the applicable service arrangement, and the capabilities and retention policies of the relevant third-party platforms.

Clients are responsible for exporting or obtaining copies of their Client Data before terminating a third-party CRM or other service where the applicable platform makes such export functionality available.

When personal information is no longer reasonably required for the applicable purpose, BluStar may delete, anonymize, aggregate, or otherwise dispose of it in accordance with applicable law and operational requirements.

8. Security

BluStar uses commercially reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

Depending on the system involved, these safeguards may include:

• Encrypted transmission.
• Access controls and authentication measures.
• Restricted administrative access.
• Vendor and service-provider review.
• Monitoring and operational security controls.
• Reasonable procedures for handling and protecting Client and borrower information.

No method of transmission, storage, or electronic processing can be guaranteed to be completely secure.

Accordingly, BluStar cannot guarantee absolute security of information.

You are responsible for maintaining the security of your account credentials and for implementing reasonable security practices for your own employees, contractors, Authorized Users, devices, and systems.

Third-party platforms used in connection with the Services may independently store or process information under their own security practices, terms, and privacy policies. BluStar is not responsible for security incidents occurring outside systems under BluStar's reasonable control.

9. Your Choices and Privacy Rights

Depending on where you live and the laws that apply to you, you may have certain privacy rights relating to your personal information.

These may include, where applicable:

• The right to request access to personal information.
• The right to request correction of inaccurate information.
• The right to request deletion of personal information.
• The right to withdraw consent where processing is based on consent.
• The right to opt out of certain marketing communications.
• The right to opt out of certain targeted advertising or similar activities where required by applicable law.
• The right to object to or restrict certain forms of processing.
• The right to submit a privacy complaint or request.

For personal information that BluStar controls and processes for its own business purposes, you may contact us at:

team@blustardigitalmedia.com

For borrower or prospect information that BluStar processes on behalf of a mortgage Client, your privacy request may need to be directed to the applicable Client because that Client may control the underlying relationship and processing of the information.

Where required by applicable law, BluStar will reasonably assist the applicable Client in responding to such requests.

We may need to verify your identity before completing certain requests. We may also retain information where necessary to comply with legal obligations, establish or defend legal claims, prevent fraud or abuse, maintain required records, or otherwise as permitted by applicable law.

10. International Data Processing and Third-Party Services

BluStar is based in India and uses technology and service providers that may operate or process information in India and other jurisdictions.

As a result, personal information may be transferred to, stored in, or processed in jurisdictions outside the country in which you reside.

Our third-party providers may include CRM, cloud, hosting, advertising, communication, scheduling, analytics, payment, and other technology providers.

These third parties may process information under their own terms, privacy policies, and security practices.

BluStar takes reasonable steps appropriate to the Services and applicable legal requirements when selecting and using third-party service providers.

11. Third-Party Links

Our website and Services may contain links to or integrations with third-party websites, applications, platforms, software, advertising networks, payment processors, scheduling systems, and other services.

BluStar does not control the privacy practices, security practices, content, or policies of third parties.

Your use of a third-party service is governed by that provider's own terms and privacy policy.

We encourage you to review the privacy policies of third-party services before providing them with personal information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business, technology, Services, legal requirements, or privacy practices.

When we make changes, we will update the “Last modified” date at the beginning of this Privacy Policy and post the updated version on this website.

Unless otherwise required by law, changes become effective when the updated Privacy Policy is posted.

For material changes where notice is required by applicable law, we may provide additional notice through appropriate means.

Nothing in an updated Privacy Policy automatically modifies the terms of an executed client agreement unless that agreement expressly permits such modification.

13. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or the handling of your personal information, you may contact us at:

MavenRed d/b/a BluStar Digital Media
143, 2nd Street Ashwath Nagar, Marathahalli, Bangalore, IN 560100
Email: team@blustardigitalmedia.com