Privacy Policy


LAST UPDATED: May 28, 2015

HomeTrek is owned and operated by InCharge Debt Solutions (“InCharge”).   Company’s and InCharge’s Privacy Policy is part of the Terms and Conditions of Use which shall govern your use of the Website.

Please read this Privacy Policy carefully before using the Website. By using our Website, you acknowledge that you have read this Privacy Policy, and you expressly accept and agree to abide by the terms outlined herein as well as other Terms and Conditions established by Company and InCharge and as modified from time to time. If you do not agree to any of the terms contained in this Privacy Policy, your sole remedy is not to use the Website.

This Privacy Policy does not apply to information collected by third parties including via websites that may be accessible from or linked to this Website. Company is not responsible for the content or privacy practices of any non- Company site to which this Website links.

1. Purpose. This Website serves as an education platform and reference guide for homebuyers. Homebuyers are able to take homebuyer education courses through the Website and obtain certificates of completion for completed courses.
2. Information We Collect and How We Collect It. Company collects different kinds of information from you in many different ways. This Privacy Policy tells you about our information gathering, use, and disclosure practices and applies to information gathered through your use of this Website and your electronic communications through this Website.

What Information Is Collected: We collect the following types of information on the Website:

  1. Non-personal Information” is any information which does not identify you individually (such as group demographics) or does not permit a direct association with an individual. Non-personal Information may include information derived from Personal Information that has been de-personalized by removing unique identifiers and combining it with information about other users to form aggregated data. For example, we may collect web browsing history related to the Website, dates and times of visits to the Website, dates and numbers of videos viewed through the Website, and IP address associated with your device(s)
  2. Personal Information” is your personally identifiable information, including first and last name together with email address, mailing address, and telephone number.To the extent we associate Non-personal Information with Personal Information, we treat the combination as Personal Information.

How Information Is Collected. We collect information in the Website in the following manner:

  1. Voluntarily Provided. In the course of visiting and using the Website, you may voluntarily provide information to us. For example, in order to use the Website, you will be asked to complete a form to create a Company online user account, including selecting a user name and password. You will also be required to complete registration forms on the Website in order to register for online homebuyer courses. In the course of performing these tasks, you will be asked for information about yourself. Any Personal Information voluntarily provided by you will be collected by Company. You may choose whether or not to disclose Personal Information, but you will not be able to use the Website and complete courses without providing the Personal Information. Company may collect information you provide to us and we may combine it with information from other users and de-personalize the information to make it Non-personal Information.
  2. Technologically Gathered. We collect some information automatically as you and other users navigate the Website. For example, we collect traffic data (such as information about how much time users spend on the Website or each page, etc.), collect and log “clickstream data” (such as internet protocol addresses, pages visited, clicks made, courses completed, and similar information), and information about your computer and internet connection (such as IP address, operating system, and browser type). This sort of information is generally considered Non-personal Information (unless it is combined with Personal Information that you or other sources provide to us). We may combine information about your use with information about other’s use to generate aggregated Non-personal Information about you and other users as a group. Company may collect information through “cookies” and other technology, such as clear GIF technology (also known as a “web beacon”), and we may combine this with your Personal Information or with other Non-personal information. This Website employs cookies and web beacons to speed your navigation of the Website, recognize you, and track your Website usage.
  3. “Cookies” are small pieces of information that are stored by a user’s internet browser on a user’s computer’s hard drive. Most internet browsers are initially set to accept cookies. You can set your browser to refuse cookies, but then you may not be able to access or use portions of this Website.
  4. “Web beacons” are small bits of code embedded in web pages or emails that assist in delivering cookies. Web beacons help Company determine whether a page on this Website has been viewed and, if so, how many times. For example, any electronic image on this Website, such as an ad banner, can function as a web beacon. We may also use web beacons in email messages to determine what the recipient has done with the message. Although you cannot decline to receive web beacons when visiting a web page, you can choose not to receive web beacons by email if you disable HTML images or refuse HTML email messages.
  5. Do Not Track Signals. The Website does not respond to do-not-track signals from browsers or other similar mechanisms. While Company (with the assistance of its service providers) does collect information about your use of the Website for Company’s own use, Company does not permit third party advertisers to collect personally identifiable information about your online activities for their own use when you use the Website. Except as described above, Company does not permit third-party behavioral tracking or any other third-party data collection through the Website.

3. How We Use the Information. Generally, Company uses information to improve our products and services; to improve, administer, customize, and maintain the Website; to manage transactions; to build relationships with you and other users; to provide you with information about Company; to fulfill other purposes for which you provide the information; to provide you with notices about your account; to carry out our obligations and enforce our rights; to allow you to participate in interactive features of the Website; and to conduct market research and analysis. We may contact you to obtain your input or have you provide information about our services and our courses. Company may identify you in connection with your use of certain aspects of this Website and may link information about your use of the Website with your Personal Information.

  1. Transactions. If you provide Personal Information to us in connection with taking courses available on the Website or engaging in another kind of transaction, we may use your information to process the transaction and communicate with you about the transaction.
  2. Marketing. We may use your Personal Information and Non-personal Information to offer, market and advertise to you via the Website and through email and U.S. mail. We may communicate with you about Company’s services or third party services that may interest you. We may use Non-personal Information to conduct market research and analysis for ourselves. Company does not place any restrictions on the use of Non-personal Information.

4. Data Security.

  1. Security Measures. Company takes steps to protect your Personal Information. Company restricts access to your Personal Information via the use of passwords and the servers on which your information is stored are kept in an environment protected by a secure firewall.
  2. Steps You Can Take. Where you have selected or received a password for use in connection with login information or accessing certain features of the Website, you are responsible for maintaining the confidentiality of the password and not sharing it with anyone.
  3. Caution. While Company will endeavor to safeguard your Personal Information, it cannot guarantee absolute security. You acknowledge and agree that Company shall not be liable for any security breach or damages to you which is a result of causes or events that are beyond Company’s control such as acts of God, hacking, terrorism, power outages, defects in third party (including dealer’s) security products and services, your own acts and omissions, and other similar events beyond Company’s control).

5. Disclosure to Third Parties.

  1. General Disclosures. Company may disclose your Personal Information in response to a subpoena or other court order, if otherwise required by law, or in an effort to cooperate with law enforcement. Company may disclose your Personal information when Company believes that doing so is necessary or desirable: (a) to enforce Company’s rights or defend against legal claims, (b) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving any threats to physical safety, allegations of intellectual property infringement or violations of privacy rights, and (c) as otherwise required by law. Company may disclose your Personal Information to third parties (including Company’s vendors and service providers) to enable them to provide services to you or the Company, process orders for you or the Company, process credit card transactions for you or the Company, provide research or analysis for the Company, provide data storage for the Company, or assist the Company in providing other content available through the Website and otherwise. Company may disclose your Personal Information in the event of a sale of substantially all of Company’s assets; the merger, dissolution, or reorganization of Company; or in connection with the transfer of a discrete portfolio of assets or information. If these events occur, the new company’s privacy policy shall govern the further protection, use, and disclosure of your Personal Information.
  2. Sharing Information. Company may share your information (including Personal Information) with third parties that provide services to the Company or you. Except as described above, we do not share, sell, or rent your Personal Information with non-affiliated third parties so that they may offer, market and advertise products and services directly to you. Company does not place any restrictions on the use or disclosure of Non-personal Information and Company may share Non-personal Information with anyone for any purpose.
  3. California Residents. California’s “Shine the Light” law, pursuant to California Civil Code Section 1798.83 (“Shine the Light law”), regulates the sharing of personal information about California customers with affiliated or unaffiliated third parties for third-party direct marketing purposes. Under the Shine the Light law, we will provide the following information to you upon request: (a) the categories of personal information disclosed to third parties for the third parties’ direct marketing purposes during the prior calendar year, and (b) the names and addresses of all of the third parties that received personal information during the preceding calendar year and, if the name does not indicate the nature of the third party’s business, a “reasonable indication” of the third party’s business. We may provide this information in a standardized format and this information does not need to be specific to you. You may make such a request for this information no more than once during each calendar year. To make such a request, please send an email to or write us at 5750 Major Blvd., Suite 300, Orlando, Florida 32819.

6. Managing Your Information.

  1. Information Access. Upon your request, Company will remove your Personal Information from Company’s records related to this Website. Removing your Personal Information from Company’s records related to this Website may prevent you from accessing and using the Website. If you wish to update or correct Personal Information you have already provided to us, or if you wish to remove your Personal Information from our records, please send your request to us via email at: or via postal mail at 5750 Major Blvd., Suite 300, Orlando Florida 32819

Opting Out.

  1. Email Marketing. You may choose to opt out of receiving marketing emails from us at any time by sending your request to us via email at: or via postal mail at 5750 Major Blvd., Suite 300, Orlando, Florida 32819, or by using the means provided in our marketing emails such as clicking “unsubscribe” on the Website. Please note, however, that your opt-out will apply only to marketing emails and not email communications about your Transaction or other non-marketing correspondence.
  2. Disclosure for Direct Marketing/Advertising Purposes. Except with respect to Company’s service providers, and as otherwise set forth in this Privacy Policy, we do not currently, although Company expressly reserves the right to do so in the future, share your Personal Information with non-affiliated third parties so that they may offer, market and advertise products and services directly to you.

7. COPPA. We do not knowingly collect Personal Information from children under the age of thirteen (13) on our Website. If we discover that any registration is made by child under the age of thirteen (13), such registration will be immediately and permanently canceled and removed from our Website, with or without notice.

8. Modifications to Privacy Policy. We may modify this Privacy Policy from time to time in Company’s sole discretion. If we make a material change to this Privacy Policy, we will notice said changes by posting such changes on our Website. We may also notify you of the changes via email. By continuing to use our Website after such notice, you expressly accept and agree to abide by the Privacy Policy as modified by Company.

9. Contact Information. If you have questions about this Privacy Policy, you may contact us via email at: or via postal mail at 5750 Major Blvd., Suite 300, Orlando, Florida 32819. We will use reasonable efforts to respond promptly to reasonable requests or questions you may have regarding our use of your Personal Information.