This Privacy Policy applies to Solmira, LLC, doing business as Mortgage With Hector and Solmira Home Loans (Company NMLS #2870116, FL Mortgage Broker License #MBR8713). Hector Hiraldo (NMLS #1492718) is the Mortgage Broker and Owner. In this policy, "we," "us," and "our" mean Solmira, LLC d/b/a Mortgage With Hector.

Last Updated: September 24, 2026

1. Information We Collect

When you interact with us through our website, SMS, phone, email, or referral from a real estate agent, we may collect:

• Personal information: Name, email, phone number, mailing address, date of birth

• Financial information: Income, employment, credit history (only when you formally apply for a loan)

• Property information: Property address, value, type

• Communication preferences: SMS, email, and phone consent records

2. How We Use Your Information

We use your information to:

• Communicate with you via SMS, email, and phone (with your consent)

• Send appointment confirmations and rate-lock confirmations

• Provide loan status updates if you formally apply for a mortgage

• Notify referring real estate agents

• Comply with TCPA, RESPA, CFPB, and CTIA regulations

3. SMS Text Message Program — CTIA Compliance

If you opt in by checking the optional SMS consent box on our booking or contact form, Solmira, LLC d/b/a Mortgage With Hector may send you text messages including: appointment confirmations and reminders, application status updates (only if you formally apply), document requests, rate-lock confirmations, referral notifications, and, if you consent to marketing, messages about mortgage products, rates, pre-approvals, and refinance options. Consent is not a condition of any purchase or loan.

• Message frequency: typically 1-5 per week during active engagement

• Message and data rates may apply

• Reply STOP at any time to opt out — processed immediately and stored permanently in our suppression list

• Reply HELP or contact [email protected] or (407) 972-1460 for help

Your phone number collected through SMS sign-up is NEVER:

• Sold to third parties

• Rented to affiliates

• Shared with marketing partners

• Disclosed to lead buyers

• Transferred to any external party

Phone numbers are used exclusively for direct communication between you and Hector Hiraldo. SMS infrastructure is provided by Twilio under our contractual agreement (Twilio is a carrier infrastructure provider, not a data recipient).

4. How We Share Your Mortgage Application Information

IMPORTANT: This section applies ONLY to data you provide when you formally apply for a mortgage loan. It does NOT apply to your SMS opt-in phone number, which is governed by Section 3 above and is never shared with any third party.

When you submit a mortgage application, we share information ONLY with parties necessary to process your loan, including:

• Wholesale lenders and investors (the lenders we broker your loan to, for underwriting and funding)

• Credit reporting agencies (with your written authorization, for credit verification)

• Service providers under strict contractual obligations (for CRM, email delivery, and document storage — these providers process data on our behalf and are bound by privacy obligations)

• Government bodies (only when required by law or regulatory authority)

We DO NOT sell your personal information or phone number under any circumstances.

5. Cookies, Tracking Technologies, and Analytics

Our website uses cookies and similar tracking technologies to:

• Maintain your session and form data

• Analyze website traffic (Google Analytics)

• Improve user experience

You can control or disable cookies through your browser settings. Disabling cookies may affect some site functionality.

Third-party tools we use for website operation:

• HighLevel / LeadConnector (CRM platform — processes data on our behalf, NOT a recipient of your data)

• Google Analytics (anonymous traffic analysis)

• Google Fonts (typography)

• Meta Pixel (advertising attribution — you can opt out via Meta settings)

We respect Do Not Track (DNT) and Global Privacy Control (GPC) signals.

6. Data Security Practices

We take the security of your personal information seriously and implement industry-standard safeguards to protect it from unauthorized access, alteration, disclosure, or destruction.

Encryption:

- In transit: All data transmitted between you, our website, and our systems is encrypted using TLS 1.2 or higher.

- At rest: Personal and financial information is stored in encrypted databases hosted on SOC 2-compliant infrastructure.

Access Controls:

- Access to your personal information is strictly limited to Hector Hiraldo and authorized service providers under contractual confidentiality obligations.

- Multi-factor authentication is required for all systems containing customer data.

- Access logs are maintained and reviewed regularly.

Storage and Retention:

- We retain your information only as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations (such as RESPA and CFPB record-keeping requirements, typically 3-5 years for loan files), or resolve disputes.

- Phone numbers added to our SMS suppression list are retained permanently to honor opt-out requests.

- Loan application data is retained per federal record-keeping requirements.

Service Provider Security:

- All third-party service providers (CRM, email, SMS infrastructure, document storage) are vetted for SOC 2 Type II compliance or equivalent.

- Each provider is bound by written contractual obligations to maintain confidentiality and implement appropriate security measures.

Regulatory Compliance:

We comply with applicable data protection and financial privacy regulations including:

- Gramm-Leach-Bliley Act (GLBA) Safeguards Rule

- Telephone Consumer Protection Act (TCPA)

- Real Estate Settlement Procedures Act (RESPA)

- Consumer Financial Protection Bureau (CFPB) privacy guidelines

- CTIA SMS messaging standards

Breach Notification:

In the unlikely event of a data security incident affecting your personal information, we will notify you in accordance with applicable state and federal breach notification laws, typically within 30 days of confirmation of the breach.

Your Responsibility:

While we implement strong security measures, no method of transmission over the internet is 100% secure. We encourage you to:

- Use strong, unique passwords for any accounts

- Never share sensitive information via unsecured channels

- Notify us immediately at [email protected] if you suspect unauthorized access to your information

7. Children's Information

Our services are not directed to anyone under 18. We do not knowingly collect information from minors.

8. Your Rights

You have the right to:

• Access the personal information we hold about you

• Request correction of inaccurate information

• Request deletion of your information (subject to legal retention requirements)

• Opt out of SMS communications at any time (reply STOP)

• Opt out of marketing emails at any time (click unsubscribe in any email)

To exercise any of these rights, contact us at [email protected] or (407) 972-1460.

9. Updates to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. We encourage you to review periodically.

10. Questions

For privacy-related questions or concerns, contact:

Hector Hiraldo NMLS #1492718 Mortgage With Hector, powered by Solmira, LLC d/b/a Solmira Home Loans (Company NMLS #2870116 | FL MB #MBR8713) | Email: [email protected] Phone: (407) 972-1460