LEGAL

Privacy policy

Effective July 14, 2026

Scope and roles

ExactClose is operated by Spotbo Inc. For customer loan data, the customer determines the purpose and means of processing and ExactClose acts as its service provider/processor. For account, billing, security, and website data, ExactClose acts as controller/business.

Data processed

We process account identity, organization settings, billing identifiers, support messages, security logs, loan-file metadata, uploaded mortgage documents, extracted fields, findings, reviewer notes, reverification status, reports, and API activity. Structured extraction is designed to retain SSN/TIN last-four only, although encrypted source documents may contain full NPI.

Purposes

We use data to provide and secure the service, process files at customer direction, generate deterministic QC output, support users, bill accounts, prevent abuse, meet legal obligations, and improve reliability. Customer loan data is not used to train general-purpose models.

Service providers

Depending on configuration, subprocessors may include hosting, storage, email, billing, authentication, monitoring, and document-extraction providers. The production DPA and subprocessor schedule control customer-specific use.

Retention and deletion

Workspace data remains until deleted by the customer or the agreement ends, subject to configured retention, backups, legal holds, and audit obligations. Backup copies expire on the documented schedule. Customers should set retention consistent with their regulatory and investor duties.

Security and incidents

See the security architecture. No system is risk-free. Contractual incident notice and cooperation terms are defined in the DPA/security exhibit.

Rights and requests

Account users may request access, correction, export, or deletion at privacy@vcorp.co. Borrowers should contact the lender controlling their file; we will route verified requests to that customer.

International access

The product is intended for US mortgage operations. Customers must not enable access or transfers inconsistent with their contracts, privacy notices, or applicable law.

Contact

Spotbo Inc · privacy@vcorp.co. Add the final registered mailing address to the production legal package before public launch.