Privacy Policy

Margie — Pre-Underwriting Analysis Platform

Effective Date: March 22, 2026

Last Updated: October 25, 2026

Margie (“we,” “us,” “our”) operates the pre-underwriting analysis platform available at getmargie.com (the “Platform”). This Privacy Policy describes how we collect, use, disclose, and protect information when licensed Illinois mortgage brokers (“you,” “your,” “Users”) use our Platform to process borrower documents through our forensic analysis engine.

This Privacy Policy is designed to comply with the Gramm-Leach-Bliley Act (“GLBA”), the Illinois Personal Information Protection Act (815 ILCS 530), and other applicable federal and state privacy laws.

1. Information We Collect

1.1 Account Information

When you register for the Platform, we collect:

• Full name and professional contact information (email address, phone number, business address)
• Illinois mortgage broker license number and NMLS identifier
• Company name and business details
• Billing and payment information (processed by Stripe; we do not store full payment card numbers)

1.2 Borrower Document Data

When you upload borrower documents for analysis, the Platform processes the following document types and the data contained within them:

• W-2 forms: Employer information, wages, tax withholdings, Social Security numbers
• Pay stubs: Employer details, earnings, deductions, pay frequency
• Bank statements: Account numbers, transaction history, balances, institution details
• 1003 Uniform Residential Loan Applications: Comprehensive borrower financial and personal data including Social Security numbers, income, assets, liabilities, employment history, and property details
• Federal tax returns (Form 1040 and schedules): Adjusted gross income, tax liability, withholding, self-employment income and business expenses from Schedules C, E and SE, and partnership or S-corporation income from Schedule K-1
• Forms 1099 and 1099-SSA: Non-employee compensation, payer details, and Social Security benefit income
• Form 1098: Mortgage interest, property tax and insurance amounts
• Government-issued identification (driver's licence or state ID): Name, address, date of birth, document number and expiration date

This borrower data constitutes “nonpublic personal information” (“NPI”) as defined under the GLBA and is handled in accordance with the safeguards described in this Policy and our GLBA Compliance Statement.

1.3 Usage and Technical Data

We automatically collect certain technical information when you use the Platform:

• IP address, browser type, operating system, and device identifiers
• Pages viewed, features used, and timestamps of activity
• Error logs and performance data (used for reliability and debugging purposes)
• Rate-limiting metadata (request counts and identifiers used to enforce API rate limits)

1.4 Information from Third-Party Services

We use Microsoft Entra External ID to manage sign-in via the OAuth 2.0 authorization code flow with PKCE. Account creation requires an invitation code issued by Margie.

2. How We Process and Use Information

2.1 Borrower Document Processing Architecture

Margie's forensic analysis engine processes borrower documents through a six-stage pipeline. Understanding our processing architecture is critical to understanding how we protect borrower data:

• Memory only, and only during the analysis. Uploaded borrower documents are processed in server memory. Margie does not write them to disk, local storage, or cloud object storage. The results extracted from documents are kept in memory between the stages of one analysis for at most 30 minutes. What each stage read from them is also saved, with no page text, beside that stage's result, so the stage can be re-run later without the documents.
• OCR extraction. Document content is extracted using Azure Document Intelligence, which receives the documents over encrypted channels. Microsoft states that Document Intelligence stores the submitted documents and analysis results for 24 hours after an analysis completes and then deletes both automatically.
• AI-assisted analysis. Document text and extracted data are analyzed using Microsoft Azure OpenAI, in Margie's own Azure account and processed in the United States: Margie's notes on each stage and Stage 6's plain-language explanation (from each stage's results), the stage notes (which receive the text of the documents in that stage), the borrowers' names at intake (from document headers), and reading a field the typed models could not read. Every call uses gpt-6-luna; gpt-6-sol, a second model in the same account under the same terms, is the standby. Before any text is sent, Social Security numbers, numbers of eight or more digits and labelled dates of birth are masked first. Data is sent over encrypted channels. Microsoft states that prompts and completions are not available to OpenAI and are not used to train any generative AI foundation model without Margie's permission, and that those its abuse monitoring flags may be stored in the United States for review by authorized Microsoft employees, for no stated period. Margie does not use Anthropic or Google for any AI service.
• What is stored. In Azure Cosmos DB, encrypted by Margie (AES-256-GCM): every analysis result, note and review; the borrower details read from documents (names, addresses, employers, property and loan figures, incomes, assets, credit score and ratios); the session list; every saved version; and each value a broker confirms, withdraws or cannot confirm on a file, with who, when, the document and page it is printed on, and what Margie had read. Beside each stage's result, the reads that stage used, so it can be re-run later without the documents: the figures, names, dates and lines read from them, among them a pay stub's deduction lines with their amounts and the fraud screen's short quoted matches (a few characters of a document either side of each); never a page of a document's text, and with Social Security, account and identification numbers and dates of birth masked. They are deleted with the analysis. Left readable, so the database can find a record and check who may open it: record, user and brokerage ids, dates and times, how many stages ran, and document types. The audit log is encrypted the same way: what stays readable is whose entry it is, which analysis it belongs to, the kind of event, its stage and time, and its place in the chain. Original documents and document images are not stored.

2.2 Purposes of Use

We use collected information for the following purposes:

• Providing the Platform: Processing borrower documents, generating pre-underwriting analyses, and delivering results to you
• Account management: Maintaining your account, authenticating your identity, and managing your subscription
• Billing: Processing payments, tracking file usage against your plan, and issuing invoices via Stripe
• Platform improvement: Analyzing aggregate usage patterns to improve performance, reliability, and features
• Security and fraud prevention: Detecting unauthorized access, monitoring for abuse, and enforcing rate limits
• Legal compliance: Complying with applicable laws, regulations, and legal processes
• Communications: Sending transactional notifications, service updates, and responding to support requests

2.3 Use Limitations

We do not use borrower NPI for marketing purposes. We do not sell, rent, or lease borrower NPI to any third party. We do not use borrower document data to train machine learning models. Microsoft states that prompts and completions sent to Azure OpenAI are not used to train any generative AI foundation model without Margie's permission.

3. Third-Party Service Providers

We share information with the following categories of service providers, each of which processes data solely to perform services on our behalf:

Each third-party provider is contractually obligated to protect the confidentiality of data they process and to use it solely for the services they provide to us, under that provider's published data processing terms. We keep a dated copy of each provider's data processing addendum: Microsoft, Stripe, and Resend. Broker clients may request the list.

4. Data Retention

• Borrower documents: Not retained by Margie. Held in server memory during the analysis; Azure Document Intelligence deletes its copy after 24 hours.
• Analysis results: Retained in Azure Cosmos DB for as long as your account remains active, or as required to provide the services, unless deleted sooner: the user who ran an analysis, or an administrator of your brokerage, can delete it from its session page; it is deleted at once, with its notes, document and version records and audit-log entries, and the deletion is recorded in your brokerage's audit log. They are deleted when you close your account, or within 30 days of a deletion request, which closes the account. If we terminate your account, they are deleted within 30 days of termination. Copies in Azure Cosmos DB's automatic backups remain until those backups expire.
• Each stage's saved reads: Kept with the analysis they belong to, to re-run a stage without the documents, and deleted with it at the same times.
• Account information: Retained for the duration of your account and deleted with it, on the same timing as analysis results, except records required for legal, tax, or audit purposes. Your Microsoft Entra sign-in is disabled; its directory entry remains until it is removed.
• Usage and technical data: Usage counters are kept on your brokerage's record and deleted with it. Error and request telemetry in Azure Application Insights, from which personal data is scrubbed, is kept under its retention setting.
• Payment records: Retained as required by applicable tax and financial recordkeeping laws.

5. Data Security

We implement administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of information processed through the Platform:

• Encryption in transit: All data transmitted between your browser, our servers, and third-party services uses TLS 1.2 or higher.
• Encryption at rest: Everything stored in Azure Cosmos DB is encrypted at rest by Microsoft (AES-256). In addition, Margie encrypts (AES-256-GCM) every stored field of an analysis that could identify or describe the borrower, leaving readable only what the database needs to find and authorize a record, in the analyses and the audit log alike. (Section 2.1)
• In-memory processing: Borrower documents exist only in volatile memory during processing, significantly reducing the attack surface for data exposure.
• Access controls: Access to production systems and stored data is limited to the founder.
• Authentication security: User authentication is managed through Microsoft Entra External ID using the OAuth 2.0 authorization code flow with PKCE, with server-side sessions independently signed and validated on every request.
• Rate limiting: The Platform enforces sliding-window rate limits on API endpoints and authentication actions to prevent brute-force attacks and abuse.
• Monitoring: Error-monitoring instrumentation includes data-scrubbing controls designed to exclude borrower NPI from error payloads.
• Vendor security: We choose providers that publish recognized security certifications; copies of their reports are being collected.

For additional detail on our security program, see our GLBA Compliance Statement.

6. Your Rights and Choices

6.1 Account Information

You may access, update, or correct your account information at any time by logging into the Platform. To request deletion of your account, contact us at the address below.

6.2 Analysis Results

Stored analysis results are deleted when you close your account, which you can do in the account settings, or within 30 days of a deletion request sent to us, which closes the account. While the account remains open, the user who ran an analysis, or an administrator of your brokerage, can delete it from its session page; it is deleted at once.

6.3 Communications

You may opt out of non-transactional communications at any time. Transactional communications related to your account, billing, and service operations are not subject to opt-out.

6.4 Illinois Residents

Under the Illinois Personal Information Protection Act, if we become aware of a data breach affecting your personal information, we will notify you in accordance with applicable law.

7. Borrower Rights

Margie processes borrower data on your behalf, as you are the mortgage broker with the direct customer relationship. As between you and Margie, you are the data controller responsible for providing any required privacy notices to your borrowers. We will cooperate with you in responding to any borrower requests regarding their data.

8. Children's Privacy

The Platform is a B2B professional tool designed for use by licensed mortgage brokers. We do not knowingly collect information from individuals under the age of 18. If we learn that we have collected information from a minor, we will delete it promptly.

9. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy on the Platform with a revised “Last Updated” date and, where appropriate, by email notification. Your continued use of the Platform after any changes constitutes acceptance of the revised policy.

10. Governing Law

This Privacy Policy is governed by the laws of the State of Illinois, without regard to conflict-of-law principles.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Margie
Email: contact@getmargie.com
Website: getmargie.com