Privacy Policy for Shouldirefi.app

Last updated: July 9, 2026 Effective date: July 9, 2026

This Privacy Policy describes how [OPERATOR LEGAL ENTITY NAME] ("Shouldirefi," "we," "us," or "our") collects, uses, shares, and — in one specific circumstance described below — sells information when you use the Shouldirefi.app website, application, and related services (collectively, the "Service").

By using the Service, you agree to the practices described in this Policy. If you do not agree, do not use the Service.

1. Who We Are

Shouldirefi.app is a set of tools that help users analyze whether refinancing a mortgage or other loan makes sense for their financial situation, and — if a user chooses — connect that user with third-party lending partners. The Service is operated by [OPERATOR LEGAL ENTITY NAME]. You can contact us at [email protected].

Shouldirefi.app is not a lender, mortgage broker, loan originator, or financial advisor.

2. Information We Collect

We collect the following categories of information:

a. Information you provide directly

• Account information: name, email address, and authentication identifiers when you sign up or sign in (handled via Firebase Authentication, including any social sign-in providers you choose).
• Financial inputs: loan balances, interest rates, monthly payments, property values, income figures, loan terms, closing costs, and other figures you enter to receive an analysis. We do not ask for Social Security numbers, full bank account numbers, or government-issued ID numbers.
• Uploaded documents: if you use a document-upload feature (for example, uploading a mortgage statement, loan estimate, or account statement so we can extract figures for you), the document you upload may itself contain sensitive identifiers such as account numbers. We use uploads only to extract the figures needed for your analysis (see Section 5). We recommend redacting account numbers and other identifiers before uploading.
• Get Rates inquiry information: if you submit a "Get Rates" inquiry, your contact details, mailing address, and the financial details described in Section 7.
• Payment information: if you purchase a paid feature, payment details (card number, billing address, etc.) are collected and processed by Stripe. We do not store full card numbers on our servers; we receive only a token, the last four digits, card brand, and transaction status.
• Communications: any information you send us through support emails, forms, or feedback.

b. Information collected automatically

• Usage data: pages visited, features used, clicks, session duration, referring URL, and timestamps.
• Device data: IP address, browser type and version, operating system, device type, language, and approximate location derived from IP.
• Cookies and similar technologies: see Section 9. Analytics and advertising technologies load only with your consent.

c. Information from third parties

• Authentication providers (e.g., Google, if you use social sign-in) provide us with your name, email, and a unique identifier.
• Stripe provides payment status, fraud signals, and dispute information.

3. How We Use Information

We use the information we collect to:

• Provide the core analysis tools and display results to you;
• Create and maintain your account and authenticate you;
• Process payments and manage subscriptions through Stripe;
• Transmit your Get Rates inquiry to lending partners when you direct us to (Section 7);
• Generate AI-assisted explanations, summaries, or figure extraction using Google's Generative AI services (via Google Genkit) — see Section 5;
• Maintain an internal index that associates the inquiries and accounts belonging to the same person and summarizes the financial details they entered. We use this index for customer support and to prepare and prioritize the inquiries we share with lending partners at your direction (Sections 6 and 7). We do not use this index to send you our own marketing;
• Improve and debug the Service, including monitoring performance and errors;
• Communicate with you about your account, your inquiries, and security or service notices. We do not currently send first-party marketing emails; if we introduce them, they will be sent only to users who separately opt in, and every such email will include an unsubscribe link;
• Detect, prevent, and address fraud, abuse, and security incidents;
• Comply with legal obligations.

4. Legal Bases (EEA/UK Users)

If you are in the European Economic Area or the United Kingdom, we rely on the following legal bases under the GDPR:

• Performance of a contract — to provide the Service you requested;
• Legitimate interests — to operate, secure, and improve the Service;
• Consent — for optional cookies, marketing emails, transmission of your inquiry to lending partners, and certain AI processing where required;
• Legal obligation — to meet tax, accounting, and other statutory duties.

You may withdraw consent at any time without affecting prior processing.

5. AI Processing

The Service uses Google's Generative AI models (via Google Genkit) to extract figures from documents you upload and to look up public property-value estimates. Analysis and any figures we present are produced by our own deterministic calculators, not by AI. When you upload a document or request a property-value estimate:

• The relevant inputs (your figures, uploaded document, or property address — but not your name or email) are sent to Google's Generative AI API for processing;
• We do not use your inputs to train AI models, and per Google's terms for paid API usage, your inputs are not used by Google to train its foundation models;
• AI-generated output is informational only and is not financial, legal, or tax advice;
• AI does not decide which lending partners you see or which partners receive your inquiry. Lender matching is determined by the neutral, non-AI process described in Section 17.

6. How We Share — and When We Sell — Information

Outside of the Get Rates tool, we do not sell your personal information. Using the Service to model scenarios, save scenarios, or view AI explanations does not send your information to any lender or marketer.

When you submit a Get Rates inquiry, we sell that inquiry. Lending partners pay us a fee to receive inquiries. Under the California Consumer Privacy Act (CCPA) and similar state laws, that transfer is a "sale" of personal information. It happens only when you affirmatively submit the Get Rates form after checking the consent boxes described in Section 7 — never in the background. The categories of personal information sold are: identifiers (name, email, phone), mailing address, and the financial information described in Section 7. The categories of recipients are licensed lenders and loan brokers ("lending partners").

We also share information with:

• Authorized Shouldirefi personnel (administrators). A limited number of administrators can access user profiles, saved scenarios, and submitted inquiries on a need-to-know basis for customer support, account recovery, debugging, security and abuse investigations, billing, and other internal operations. Administrator access is governed by role-based access controls and confidentiality obligations.
• Service providers acting on our behalf, including:
  • Google Firebase (authentication, Firestore database, hosting) — Google LLC;
  • Stripe (payment processing) — Stripe, Inc.;
  • Google Cloud / Generative AI (AI inference) — Google LLC;
  • Google Analytics (usage analytics) and Google AdSense (advertising to free-tier users) — Google LLC — loaded only with your consent (Section 9);
• Legal and safety recipients when required by law, subpoena, or to protect rights, property, or safety;
• Successors in the event of a merger, acquisition, financing, or sale of assets, subject to this Policy.

Advertising cookies (Google AdSense), where you consent to them, may constitute "sharing" for cross-context behavioral advertising under the CCPA. You can opt out at any time — see Section 11 and the "Do Not Sell or Share My Personal Information" link in the site footer.

7. The "Get Rates" Tool — What Is Sent to Lending Partners

Shouldirefi.app is not a lender. As an optional feature, you may use the in-app "Get Rates" tool to ask one or more of our third-party lending partners to contact you about the loan scenario you have selected.

This only happens if you choose to initiate it. Lending partners receive your inquiry only because you submitted it, and they do not have standing or background access to your Shouldirefi profile or other account data.

When you submit the Get Rates form — after affirmatively checking each consent box — we transmit to one or more lending partners:

• Contact information: first and last name, email address, phone number, and your preferred contact method (email, call, or text);
• Mailing address: street, city, state, and ZIP;
• Selected loan scenario: loan type, loan amount, term, and estimated monthly payment;
• Your financial snapshot: the financial details you entered in the analysis tools at the time you submitted — such as property values, mortgage balances and rates, other debts and their balances, income figures, and monthly expenses — so the receiving lender can respond to your inquiry without re-asking for the same numbers.

We do not transmit your Shouldirefi account password or payment card details.

Depending on the products and pricing lenders have signed up for, your inquiry may be sold to one lender exclusively or to a small number of lenders (currently up to three) who may each contact you. Where available, the specific partners eligible to receive your inquiry are shown to you at the consent step.

By submitting the Get Rates form you acknowledge and agree that:

• Our lending partners are independent third parties, are not controlled by Shouldirefi, and will process your information under their own privacy policies and terms;
• A lending partner may contact you directly by phone, text message, or email regarding your inquiry, including using automated dialing systems and prerecorded or artificial voice messages where you have consented (message and data rates may apply). Consent to be contacted is not a condition of using the Service or of obtaining any loan;
• Submitting an inquiry is not an application for credit and does not guarantee any loan offer, rate, or approval;
• Once your information has been transmitted to a lending partner, we cannot recall it from that partner. Every lending partner must accept our Marketplace Partner Terms before activation; those terms prohibit reselling your information and require partners to use it only to respond to your inquiry. To exercise privacy rights against a lending partner (including deletion or do-not-contact requests), contact that partner directly; we will, on request, identify the partner(s) to whom your inquiry was sent.

You may withdraw consent for future Get Rates submissions at any time simply by not submitting the form. To stop contact from a lending partner you have already been connected with, tell that partner directly, reply STOP to text messages, or use the unsubscribe link in emails.

Where the Get Rates tool is available. The Get Rates tool is available only in states where we are permitted to operate it. If you live in a state we have not yet opened, the form will tell you and your information will not be sent to any lender.

8. Data Retention

• Account data is retained while your account is active and for up to 24 months after deletion, unless a longer period is required by law.
• Financial scenarios you save are retained until you delete them or delete your account.
• Get Rates inquiries and consent records are retained for 5 years from submission — including after you delete your account — as business and compliance records (for example, to prove the consent you gave), as permitted by applicable law. Records of inquiries already sold to a lending partner are likewise retained for this period and cannot be recalled from the partner.
• Payment records are retained for at least 7 years to comply with tax and accounting laws.
• Server logs are typically retained for 30–90 days.

You can request earlier deletion of anything not covered by a legal retention duty at any time (see Section 11).

9. Cookies, Analytics, and Advertising

We use essential cookies to keep you signed in, remember preferences, and secure the Service. These are always active; blocking them may break sign-in and core features.

We use two optional technologies, both from Google LLC, and neither loads until you consent via the cookie banner:

• Google Analytics — usage measurement (pages visited, features used);
• Google AdSense — advertising shown to free-tier users (Pro subscribers never see ads).

You can decline in the banner, change your mind later via the "Do Not Sell or Share My Personal Information" link in the footer, or use a browser that sends the Global Privacy Control (GPC) signal — we treat GPC as an automatic opt-out and will not load analytics or advertising for your browser.

10. Security

We use industry-standard safeguards, including TLS in transit, encryption at rest provided by Google Cloud / Firestore, scoped Firestore security rules, role-based access controls, and secrets management on production systems. We maintain a written information security program and an incident response plan. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Your Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete data;
• Delete your data ("right to be forgotten"), subject to the retention periods in Section 8;
• Export your data in a portable format;
• Object to or restrict certain processing;
• Withdraw consent;
• Lodge a complaint with a supervisory authority.

California residents. Under the CCPA/CPRA you additionally have the right to know, delete, and correct your personal information; the right to opt out of the sale or sharing of your personal information; the right to limit use of sensitive personal information; and the right not to be discriminated against for exercising these rights.

• Opting out of sale/sharing: use the "Do Not Sell or Share My Personal Information" link in the site footer, or enable Global Privacy Control in your browser — we honor GPC automatically. Opting out stops advertising-related sharing and analytics for your browser. The Get Rates tool remains available after you opt out because a Get Rates submission is a disclosure you personally direct with fresh, affirmative consent each time; if you do not want your information sold to a lender, do not submit the form.
• We do not knowingly sell or share the personal information of consumers under 18.

To exercise any right, email [email protected]. We will verify your request and respond within the timeframe required by applicable law. You may use an authorized agent where the law allows.

12. International Transfers

Shouldirefi uses providers (Google, Stripe) that store and process data in the United States and other countries. Where required, we rely on Standard Contractual Clauses or other lawful transfer mechanisms.

13. Age Requirement

The Service is intended for adults. You must be at least 18 years old to use the Service, and the Get Rates form requires you to confirm that you are. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact us and we will delete it.

14. Third-Party Links

The Service may link to third-party websites (lenders, calculators, articles). We are not responsible for the privacy practices of those sites. Review their policies before providing information.

15. Changes to This Policy

We may update this Policy from time to time. When we do, we will update the "Last updated" date above and, for material changes, provide a more prominent notice (such as an in-app banner or email). Continued use of the Service after changes take effect constitutes acceptance.

16. Refer & Earn Program — Commissions Paid to Users

Shouldirefi.app operates a referral program. Under this program, a user who refers a new user to Shouldirefi.app may receive a commission from Shouldirefi.

• Commissions are paid only on Shouldirefi.app subscription revenue. A referring user earns a commission only when the user they referred purchases a paid Shouldirefi.app subscription through Stripe. Commissions are not tied to whether you use the Get Rates tool, whether your inquiry is sold to a lending partner, or whether you take out a loan.
• What a referrer can see about you. If you sign up using another user's referral link or code, we associate your account with that referrer so we can attribute any qualifying subscription. The referrer is shown only limited, aggregated information needed to administer the program (for example, that a referred sign-up or qualifying subscription occurred, and timing). The referrer does not receive your contact information, financial inputs, saved scenarios, Get Rates inquiries, or any other account content.
• How to opt out. If you do not want your sign-up attributed to a referrer, sign up without using a referral link or code, or contact us at [email protected] to disassociate your account from a referrer.

17. How Shouldirefi Is Paid, and How Lenders Are Presented

You should understand how Shouldirefi.app makes money from the Get Rates tool:

• Lending partners pay a flat, pre-set fee per inquiry. When your inquiry is sold to a lending partner (Section 7), that partner pays Shouldirefi a flat fee that was fixed before your inquiry existed. For mortgage-secured products (refinances, home equity loans, and HELOCs), the fee is never contingent on whether a loan is offered, approved, funded, or closed, and Shouldirefi never accepts compensation tied to a funded mortgage loan.
• The amount you pay is not increased by this compensation. Fees paid by a lending partner to Shouldirefi do not change the loan terms, interest rate, or fees a lender offers you. Evaluate any loan offer on its own merits and compare it with offers from lenders you find independently.
• Lender presentation is neutral. Wherever lending partners are listed in the Service — the public lender marketplace and the Pro lender-selection step — they are ordered by borrower survey scores (feedback from real borrowers we connected), with alphabetical order as the tiebreaker and for partners without scores yet. Ordering is never based on how much a partner pays us. The Service is not a comprehensive marketplace of all lenders, and we do not represent that any partner will offer the best available rate or terms for your situation.
• The refinance analysis itself is independent. Our calculations, scenario rankings, and AI-generated explanations are based on the inputs you provide and the methodology described in the Service. They are not adjusted, weighted, or re-ordered based on lender payments.
• You are never required to use Get Rates. You can use the Service to model and compare scenarios without ever submitting an inquiry.
• Shouldirefi.app is not a lender, broker, or financial advisor. We do not originate loans, do not negotiate loan terms on your behalf, and do not provide financial, legal, or tax advice.

If our compensation arrangements change in a way that materially affects this disclosure, we will update this Section and provide notice as described in Section 15.

18. Contact Us

Questions, requests, or complaints? Contact:

[OPERATOR LEGAL ENTITY NAME] [MAILING ADDRESS] Email: [email protected]