Privacy Policy

Last Modified: July 26, 2026

Contents

1. Overview

Mortgage Capital Trading, Inc. and its affiliates, successors and/or assigns (collectively, “MCT,” “we,” “our” or “us”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Policy”).

This Policy describes the types of information we may collect from you or that you may provide when you visit www.mct-trading.com (our “Website”), our social media pages, and/or any of our products and services (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. MCT customers should also refer to their Master Services Agreement and any other customer agreements, which may state additional terms governing their use of our Services.

If you have any questions regarding this Policy or our information collection and use practices, please contact us using the information in the “Contact Us” section below.

Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our Website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Policy. This Policy may be revised from time to time, so please ensure that you check this Policy periodically to remain fully informed.

2. Personal Data We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this Policy.

Categories of Personal Data We Collect and How We Collect It

MCT collects information from Website visitors and users of our Services in a variety of manners and obtains information from third parties while providing our Services to customers. This information includes:

  • Information You Provide in Sales Inquiries. When you request information through the Website, we ask you to provide your name, company, address, email and telephone number. If you choose to contact us through the contact information available through the “Contact Us” link on the Website, we will collect your email address or your telephone number, and other identifying information you may provide.
  • Registration Information. When you register to use one of MCT’s Services, we may collect certain information from you, including your name, email address, and other information that we use to contact you or provide Services to you.
  • Usage Information. Like most online services, we collect standard technical information when you use our Services, including, but not limited to, unique device identifiers, internet protocol (IP) addresses, browser types, internet service providers (ISPs), the number and duration of page visits and the number of clicks.
  • Information We Collect Automatically Through Cookies and Other Tracking Technologies. We collect certain information using “cookies” (also called “HTTP cookies” or “browser cookies”) and other tracking technologies. Cookies are small files that your browser places on your computer. We may use session cookies, persistent cookies, and other tracking technologies to better understand how you interact with our Services, to monitor usage by our users and web traffic routing on our Services, and to improve and personalize our Services. We may also use web beacons — transparent graphic images on a webpage or within the body of one of our marketing emails — to measure visitor actions and assess the effectiveness of our Services or email marketing campaigns; for example, we use web beacons in our email marketing to track instances where a user clicks through a link in the email. Please see “Cookies, Tracking Technologies, and Your Choices” below for information on how to control these technologies.
  • Borrower Information. During the delivery of our hosted Services we receive information about our customers’ borrowers (which may include personal data), which is provided by our customers. We process this information on behalf of our customers. Our customers are responsible for providing notice and obtaining appropriate consents to collect data from their borrowers and to provide it to us as their service provider.
  • Transactional Information. MCT may also create transactional records of each of the transactions or other events occurring through our Services. This transactional information is generally collected for the purpose of managing interest rate risks associated with mortgage loan applications and closed loan inventory for sale into the secondary mortgage markets, to enable MCT to provide its Services, to enable the services provided by third parties (including determinations of qualification for loans or the best execution price for sale of the customer’s mortgage loans into the secondary mortgage markets), and to enable MCT to comply with various legal obligations.
  • Information from the MCT Network. Within the “Services” menu of MCTlive, MCT customers may connect with qualified investors and other third parties to transmit and receive information to achieve the best possible loan sales price and terms. If you select a third party through our network, we may collect (and share with the third party) select and relevant information about the loan, property, and borrower directly with the third party (the “Input Data”). We may also collect certain information about your company from you to connect to the third party on your behalf (“Company Information”). We share your Input Data, Company Information, and login as you may require. If you select a third party who is not directly connected to our network, you will be directed to log into or otherwise access that third-party site to transact your business. In this circumstance, the privacy policy and terms of service presented on the third-party website will apply to your transactions, and MCT has no control over or responsibility for the information sent or other communications between you and the third-party provider.

How We Use Personal Data

We use information we collect through our Services in a variety of ways to provide our Services and to operate our business, including the following:

  • To provide our Services, including (i) to operate, test, maintain, enhance and provide features of our Services; (ii) to provide services and information that you request; and (iii) to provide support to customers, users, and site visitors.
  • To improve, analyze, and personalize our Services, including (i) to understand and analyze usage trends and preferences; (ii) to monitor and analyze the effectiveness of our Services; (iii) to improve our Services and develop new products, services, features, and functionality; (iv) to personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our Services; and (v) to provide customized content and information.
  • To communicate with you by email, mail, text message (SMS, MMS), telephone, and other methods of communication, about products, services, and information tailored to your requests or inquiries.
  • To market our Services to you, including sending you messages about the Services we offer.
  • To aggregate and de-identify data collected through our Services and use it for purposes such as creating and publishing reports about the use of our Services, including loan sale terms, prices, usage patterns, and trends.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Who We Share Your Personal Data With

We may share, transfer, or disclose your information if you consent to us doing so, as well as in the following circumstances:

  • To Our Customers. Transactional Information collected through our Services may be available to customer account administrators or other customer account managers and may be shared with investors and third parties to support optimizing the returns from secondary marketing activities and management purposes. MCT customers may use certain information they collect through MCT Services to improve mortgage loan pipeline data quality and loan manufacturing processes.
  • To Our Vetted Network Partners. We may make certain information available for various purposes to third parties who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them, including (i) for compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, usage patterns, and trends.
  • Compliance with Laws and Law Enforcement; Protection of Our Rights. We may disclose your information (including your personal information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of our Website or Services, (d) to protect the property, rights, and safety of MCT, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.

Cookies, Tracking Technologies, and Your Choices

Managing Cookies

Most Internet browsers automatically accept cookies. You can instruct your browser to stop accepting cookies or to prompt you before accepting cookies from the websites you visit. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or may not function properly.

Google Analytics

We may use Google Analytics to help us understand how visitors use our Services. Google provides additional privacy options relating to Google Analytics, described at www.google.com/policies/privacy/partners/. You can opt out of being tracked by Google Analytics across websites by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track Signals

Some web browsers and mobile operating systems include a “Do-Not-Track” (“DNT”) feature or setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, and as California law requires us to disclose, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we are required to follow in the future, we will inform you about that practice in a revised version of this Policy.

Global Privacy Control and Other Universal Opt-Out Signals

Where required by applicable state privacy law, we recognize and honor the Global Privacy Control (“GPC”) and other universal opt-out mechanisms. If you use a browser or extension that transmits a GPC signal, we will treat it as a valid request to opt out of the sale or sharing of your personal data for targeted advertising purposes for that browser or device. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

3. Your Rights Regarding Personal Data

You have certain rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Policy, or by following instructions provided in this Policy or in communications sent to you.

Your rights vary depending on the laws that apply to you, but may include:

  • The right to know whether, and for what purposes, we process your personal data;
  • The right to be informed about the personal data we collect and/or process about you;
  • The right to learn the source of personal data about you we process;
  • The right to access, modify, and correct personal data about you (see the “Accessing, Modifying, Rectifying, and Correcting Collected Personal Data” section below for more information);
  • The right to know with whom we have shared your personal data, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);
  • The right to withdraw your consent, where processing of personal data is based on your consent; and
  • The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

We strive to maintain the accuracy of any personal data collected from you and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us and notify us as soon as possible of any updates or corrections.

Depending on the laws that apply to you, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, please contact us at the information provided at the end of this Policy. We reserve the right to deny access as permitted or required by applicable law.

California Notice of Collection and Use of Personal Data

This California Notice of Collection and Use of Personal Data (“California Notice”) supplements this Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and not defined here have the same meaning when used in this California Notice.

Categories of Personal Information

In the last twelve (12) months, we have collected the following categories of Personal Information:

  1. Identifiers such as a real name, postal address, internet protocol address, email address, or other similar identifiers.
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as education, employment, employment history, and financial information.
  3. Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  4. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  5. Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

How We Share Your Personal Data

In the past 12 months, we have disclosed personal data for a business purpose with the following categories of third parties:

  • Our service providers.
  • Third parties such as our customers and network partners.
  • Our affiliated entities.
  • Our partners or prospective partners, in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services, to allow us to enter into new business relationships, and to allow us to market products or services on their behalf.
  • Advertising networks, social media platforms, and analytics providers, for cross-context behavioral (targeted) advertising and measurement.

For purposes of cross-context behavioral advertising, we share categories of personal data such as identifiers and internet or other electronic network activity information with advertising, social media, and analytics partners. We consider this activity to be “sharing,” rather than a “sale,” under the CCPA. You may opt out of this sharing as described in “Your CCPA Rights” below and in “Cookies, Tracking Technologies, and Your Choices” above.

Finally, we may also share personal data with government entities, agencies or regulators when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, health, or safety, and/or that of our users, visitors and others.

Your CCPA Rights

If you are a California resident, you have the following CCPA rights:

  1. Right to Know: You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, sold, and shared about you in the past 12 months. This includes a request to know the categories of personal data collected about you; the categories of sources from which we collected your personal data; the categories of personal data that we have sold, shared, or disclosed about you for a business purpose; the categories of third parties to whom your personal data was sold, shared, or disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose; our business or commercial purpose for collecting, selling, or sharing your personal data; and the specific pieces of personal data we have collected about you.
  2. Data Portability: You have the right to request a copy of personal data we have collected and maintained about you in the past 12 months.
  3. Right to Deletion: You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions.
  4. Right to Opt-Out of Sale/Sharing: We do not sell your personal data. However, we do share certain personal data (such as identifiers and internet or other electronic network activity information) with advertising, social media, and analytics partners for cross-context behavioral (targeted) advertising, which is considered “sharing” under the CCPA. You have the right to opt out of this sharing at any time. To exercise this right, email us at canderson@mctrade.net or enable a Global Privacy Control (GPC) signal as described in “Cookies, Tracking Technologies, and Your Choices” above, which we will treat as a valid request to opt out of sharing for the applicable browser or device.
  5. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  6. Right to Correct: You have the right to correct inaccurate personal data about you. Once we receive and verify your request, we will use commercially reasonable efforts to correct the inaccurate personal data about you.
  7. Right to Restrict or Limit the Use of Sensitive Personal Data: You have the right to restrict the use and disclosure of Sensitive Information to certain purposes related to the offering of goods or services as listed in the CCPA.

Some of our Services, however, may require your personal data. If you choose not to provide your personal data that is necessary to provide any aspect of our Services, you may not be able to use those Services.

Submitting a Verified Consumer Request

To exercise your rights, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by emailing us at canderson@mctrade.net.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal data. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative (we will need to verify your identity with at least two (2) pieces of information, such as name and email address), and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Consumer Request by an Authorized Agent

If an authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require an email be sent to canderson@mctrade.net, along with one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney. To verify the identity of the California resident for whom the request is being made, provide two or more of the following: (1) valid government-issued ID (not expired); (2) utility bill; (3) bank statement; (4) email address; or (5) last four digits of the SSN.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. We will use personal data provided in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will cover only the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California “Shine the Light” Law

California’s “Shine the Light” law permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

Your Nevada Privacy Rights

Nevada law permits our users who are Nevada consumers to request that their personal data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to the email address below, and are free of charge.

Your Other U.S. State Privacy Rights

If you are located in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and/or Virginia, you have certain rights regarding your personal information.

This section describes how we collect, use, and share your personal information under the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Delaware Personal Data Privacy Act (the “DPDPA”), the Indiana Consumer Data Protection Act (the “ICDPA”), the Iowa Consumer Data Protection Act (the “Iowa CDPA”), the Kentucky Consumer Data Protection Act (the “KCDPA”), the Maryland Online Data Privacy Act (the “MODPA”), the Minnesota Consumer Data Privacy Act (the “MCDPA”), the Montana Consumer Data Privacy Act (“MTCDPA”), the Nebraska Data Privacy Act (the “NDPA”), New Hampshire SB 255 (the “NH Act”), New Jersey SB 332 (the “NJ Act”), the Oregon Consumer Privacy Act (“OCPA”), the Rhode Island Data Transparency and Privacy Protection Act (the “RIDTPPA”), the Tennessee Information Protection Act (the “TIPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”), and your rights with respect to that personal information.

As a resident of one of the foregoing states, you have some or all of the rights listed below. However, these rights are not absolute, and we may decline your request as permitted by law. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

  • Right to Access and Portability. You have the right to access your personal information and/or receive a copy of the personal information that we have collected about you.
  • Right to Correct. You have the right to correct inaccurate personal information that we have collected about you.
  • Right to Delete. You have the right to delete the personal information we have obtained about you or that you have provided to us, with certain exceptions.
  • Right to Opt-out of Tracking for Targeted Advertising Purposes. You have the right to opt out of certain tracking activities for targeted advertising purposes.
  • Right to Opt-out of Profiling. If we process your personal information for profiling purposes as defined by the foregoing state privacy laws (other than the ICDPA), you can opt out of such processing.
  • Right to Opt-Out of Sales. You have the right to opt out of the sale of your personal information to third parties.
  • Right to Opt-In for Sensitive Data Processing. To the extent we process any of your sensitive personal information (as defined under applicable state law), you have the right to opt in before we can process any such data.
  • Right Against Automated Decision-Making. You have the right to opt out of certain automated decision-making about you.
  • Right to Non-Discrimination. You have the right to be free from discrimination as prohibited by the foregoing state laws.

To exercise any of these rights, please contact us using the information in the “Contact Us” section below. As described in “Cookies, Tracking Technologies, and Your Choices” above, where required by applicable law we also recognize and honor the Global Privacy Control and other universal opt-out signals for opt-out of sale/sharing and targeted advertising.

4. Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information through the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information through the Services or through any of their features, or otherwise provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the email address provided at the bottom of this Policy.

5. Privacy Policies of Linked Sites and Advertisers

As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access such third-party services at your own risk. This Policy does not apply to any third-party services; please refer to the privacy notices or policies for such third-party services for information about how they collect, use, and process personal data. If you have any questions about how such other sites or services use your information, you should contact the relevant third parties directly.

6. Security

MCT has physical, administrative and technical measures in place to maintain the security, confidentiality and integrity of the information gathered through the MCT Website and the MCT Services, and to help protect against the loss, misuse and alteration of such information. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

7. International Visitors

Our Services are hosted in the United States and are intended for use in connection with the United States secondary mortgage markets. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.

8. Changes to Our Privacy Policy

This Policy replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Policy. We will use reasonable efforts to notify you in the event material changes are made to this Policy, such as by sending a notice to the primary email address provided to us and/or by placing a notice on our Website. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy.

9. Applicability of This Privacy Policy

Notwithstanding any other provision of this Policy, this Policy is subject to any contracts with MCT, including any Master Services Agreement and other customer agreements, that govern your use of the Services. This Policy applies regardless of the means used to access or provide information through the Services.

This Policy does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. As provided above, the collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

10. Contact Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an email to canderson@mctrade.net or write to:

Chris Anderson
Chief Administrative Officer
Mortgage Capital Trading, Inc.
406 9th Avenue, Suite 314
San Diego, CA 92101

If you need to access this Privacy Policy in an alternative format due to a disability, please contact us at the email address above and we will work with you to provide the information in a format that meets your needs. We strive to follow generally recognized accessibility standards, including the Web Content Accessibility Guidelines (WCAG).