Acceptable use policy

This Acceptable Use Policy (the "AUP") is part of the Milestone Updates Terms of Service. It applies to everyone who uses the Service: loan officers, assistants, lenders, and anyone acting for them.

The Service exists for one purpose: to keep the people in a mortgage transaction informed about that transaction. It sends clear, accurate, timely milestone updates. Uses outside that purpose are not allowed. Capitalized terms not defined here have the meanings given in the Terms.

1. Messaging rules

You may not use the Service to:

• Send marketing. This includes promotional emails, newsletters, rate offers, refinance or cross-sell pitches, and bulk "blasts." Updates must be primarily about the status of a specific loan.
• Contact people outside the transaction. Recipients must be borrowers, co-borrowers, and transaction participants named in the loan record, such as agents and settlement or title contacts. Don't send updates to anyone else.
• Send without authority. Don't send updates, or copy agents or other third parties, unless you have the authorization required by law and your lender's policies to share that borrower's loan status with them.
• Use lists. Don't load, import, or send to purchased, rented, scraped, harvested, or shared lists of any kind.
• Ignore opt-outs. Don't send updates to anyone who has asked to stop receiving them. Add anyone who asks to stop to your opt-out list promptly, and in any event within ten (10) business days.
• Mislead recipients. Don't use false or misleading sender information, subject lines, or headers. Don't disguise who an update is from.
• Send outside the United States. Don't use the Service for loans on property outside the United States, or to send updates to recipients you know are outside the United States.
• Send texts or calls through workarounds. Don't send text messages or calls through the Service, or through any integration with it, unless we have released that feature and you have obtained the consent the law requires.

2. Content rules

You are responsible for the loan data, branding, and any text you add. You may not use the Service to create or send content that:

• Is false or misleading about a loan. This includes content that:
  • announces a milestone that has not occurred;
  • describes a conditional approval as final;
  • presents an update as a loan approval, commitment to lend, rate lock, or guarantee of closing.
• Includes loan terms or advertising. Don't add rates, APRs, payment amounts, down payment figures, fees, or other loan terms. Don't add promotional claims, or anything that turns an update into an advertisement.
• Communicates adverse decisions. Don't use updates to announce loan denials, counteroffers, suspensions, or other adverse actions. Those require specific legal notices from your lender.
• Includes sensitive data. Don't include Social Security numbers, dates of birth, account or loan numbers, credit, income, or asset information, or wiring or payment instructions.
• Is discriminatory. Don't create content that discriminates against, discourages, or treats anyone differently on the basis of a characteristic protected by fair lending or fair housing laws. Those characteristics include race, color, religion, national origin, sex, sexual orientation, gender identity, marital status, age, familial status, disability, and receipt of public assistance. Don't vary content, language, or cadence based on any such characteristic or on a guess about one.
• Is unlawful, harassing, or infringing. Don't create content that is unlawful, defamatory, threatening, harassing, or obscene. Don't create content that infringes someone else's intellectual property, privacy, or publicity rights.
• Removes required disclosures. Don't hide, alter, or remove NMLS identifiers, licensing statements, the wire-fraud warning, or any other notice the Service includes.
• Is unapproved where approval is required. Don't send content your lender's compliance team has not approved, if your lender requires approval.

3. Identity, impersonation, and AI voice

You may not:

• Impersonate anyone. Don't impersonate any person, lender, real estate brokerage, title company, or government agency. Don't misrepresent your affiliation with any of them.
• Use another's identity. Don't use another person's name, NMLS number, license, logo, or photo without authorization. This includes connecting a mailbox or loan system account that is not yours or that you are not authorized to use.
• Misrepresent AI narration. Don't present AI-generated narration as a live or personal recording, or otherwise mislead anyone about whether a voice is AI-generated. If a recipient sincerely asks whether a message used AI, answer truthfully.
• Use a voice without consent. Don't create or use a synthetic version of any real person's voice without that person's documented consent.
• Re-use updates as advertising. Don't download or re-share Milestone Pages or narration publicly, for example on social media or a website, or in any way that turns a private update into public advertising or exposes a borrower's information.

4. Referral partners (RESPA)

Updates are copied to real estate agents only so the people working on a transaction stay informed about it. You may not use the Service to give a referral source anything of value in exchange for referrals. In particular, you may not:

• add an agent's branding, photo, logo, or promotional message to updates;
• provide agents with updates, pages, or content they can use to market themselves;
• offer copies or access only to agents who refer business to you, or condition copies or access on referrals;
• use the Service to provide agents with services they would otherwise pay for.

5. Security and system integrity

You may not:

• Probe or test without permission. Don't probe, scan, or test the Service for vulnerabilities, or perform penetration testing, without our prior written permission. If you find a vulnerability, please report it to support@milestoneupdates.com and do not exploit it.
• Access what isn't yours. Don't access, or try to access, Milestone Pages, accounts, or data that are not yours. Don't guess, enumerate, or harvest page links.
• Get around limits or controls. Don't circumvent or interfere with:
  • authentication;
  • access controls;
  • rate or sending limits;
  • send holds;
  • opt-out suppression;
  • any other security or usage limit.
• Disrupt the Service. Don't introduce malware. Don't overload or disrupt the Service. Don't use automated means to access it except through features we provide.
• Copy or resell the Service. Don't reverse engineer, copy, or resell the Service. Don't use it to build a competing product.
• Share credentials. Don't share your account credentials or administrative keys. Don't let anyone use your account who is not authorized under your agreement with us.

6. Your responsibilities

• Licensing and approval. Keep your license and NMLS registration current. Use the Service only as your lender permits.
• Data accuracy. Keep loan data accurate in your loan origination system. Fix any data that causes a send to be held before releasing it.
• Recipient requests. Respond to recipients who ask questions, ask to stop updates, or report a problem.
• Recordkeeping. Keep any records your lender or the law requires.
• Reporting. Tell us promptly at support@milestoneupdates.com if you suspect misuse of your account, a security problem, or a message sent in error.

7. Enforcement

If we reasonably believe you or someone using your account has violated this AUP, or that a use creates legal, security, or reputational risk for recipients, lenders, or us, we may take any of the following actions:

• investigate, including by reviewing configuration, logs, and content related to the suspected violation;
• hold or cancel pending sends, disable or expire Milestone Pages, or remove content;
• disconnect integrations, including revoking stored Microsoft or loan-system authorizations;
• suspend or terminate your account or access to the Service, in whole or in part;
• notify your lender, if you use the Service on a lender's behalf;
• report suspected unlawful activity to the appropriate authorities and cooperate with them.

Where practical and lawful, we will tell you before we act and give you a chance to fix the problem. We may act immediately, without notice, to stop an ongoing harm, such as a compromised account, unauthorized sends, or a threat to the security of borrower data. We are not obligated to monitor your use of the Service. Not acting on a violation does not waive our right to act later.

8. Changes and questions

We may update this AUP from time to time. We will post the updated version here and change the "Last updated" date. For material changes, we will give notice as described in the Terms. Questions or reports can be sent to support@milestoneupdates.com.