Privacy Policy

This Privacy Policy explains how Erhart Industry Solutions LLC ("Erhart," "we," "us"), 4337 E Vallejo Ct, Gilbert, AZ 85298, handles information in connection with our products (Dromi, Dromi processing, Defenestro Marketing Solutions direct mail, and Defenestro Marketing Solutions lead services) and the Dromi application at app.crstflowcrm.com.

Our role

For our customers' account and billing information, we act as the data controller. For borrower and loan data that a customer processes inside Dromi on behalf of their borrowers, we act as a service provider and processor. The customer, a mortgage business, remains responsible for its relationship with its borrowers and for the lawful basis of processing.

Information we collect

• Account and billing. Name, company, email, phone, and payment details you provide to open and pay for an account.
• Mobile phone numbers and SMS consent. If you opt in to text notifications, we collect your mobile phone number and a record of your consent to receive SMS messages.
• Borrower and loan data. Documents and data that customers upload or that borrowers submit through the branded portal, such as mortgage statements, payoff statements, insurance declarations, identification, and loan details.
• Usage and call data. Product usage, pipeline events, and call records (including inbound and outbound call activity and dispositions) generated as you use the products.
• Mail data. Lists and campaign information used to run Defenestro Marketing Solutions direct mail drops and to attribute responses.

How we use information

We use information to provide and operate the products, send account and platform notifications, process documents and balance files, attribute calls and campaigns, bill for the services, provide support, maintain security, and comply with law. We do not sell personal information.

Text messaging (SMS)

We use SMS to send account and platform notifications to registered Dromi users who have opted in, such as new lead assignments, loan pipeline updates, task reminders, and account or security alerts. This is not consumer marketing. Message frequency varies, and message and data rates may apply. You can opt out at any time by replying STOP, and you can get help by replying HELP or contacting davis@erhartindustrysolutions.com. See our SMS Terms & Conditions for full program details.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

How we share information

We share information only with service providers that help us operate the products (for example, hosting, telephony, and payment processing), under agreements that limit their use of the data, and as required by law. We do not sell data or share it for third-party advertising. Consistent with the section above, we do not share text-messaging opt-in data or consent with third parties.

Security

We build to the expectations of the Gramm-Leach-Bliley Act (GLBA) and review our architecture against the FTC Safeguards Rule. Protections include multi-tenant isolation enforced by signed claims, server-mediated document access with short-lived signed links, and an identity-verified borrower portal with lockout. Mobile numbers and SMS consent are stored with the same account-level protections. No system is perfectly secure, and we cannot guarantee absolute security.

Data retention

We retain account and loan data for as long as an account is active and as needed to provide the services, meet legal and recordkeeping obligations, and resolve disputes. We retain SMS consent records as needed to document opt-in and opt-out. Customers may request export or deletion of their data as described below, subject to legal retention requirements.

Your choices and rights

You can opt out of SMS at any time by replying STOP to any message. Depending on your location, you may also have rights to access, correct, or delete personal information, or to object to certain processing. Because much of the borrower data in Dromi is controlled by our customers, borrower requests are generally directed to the mortgage business that holds the relationship. Contact us and we will route or assist with requests as appropriate.

Children

The products are for business use by mortgage professionals and are not directed to anyone under 18.

Changes and contact

We may update this Policy; material changes take effect when posted. Privacy questions or requests can be sent to davis@erhartindustrysolutions.com or Erhart Industry Solutions LLC, 4337 E Vallejo Ct, Gilbert, AZ 85298, phone 480-848-2864.