Legal
Effective Date: August 4, 2026 · Last Updated: August 4, 2026
This Privacy Policy explains how Peter Irungu, doing business under Groves Capital Inc ("Peter Irungu," "Groves Capital," "we," "us," or "our") collects, uses, discloses, and otherwise processes personal information in connection with mortgage-related communications, lead-generation activities, social-media interactions, mortgage-readiness services, and mortgage-application services.
This Privacy Policy applies to personal information processed in connection with:
This Privacy Policy is intended to address consumers in states where services may be offered, including the states shown as active lending states in the business-provided map:
Alabama, Arizona, Arkansas, California, Colorado, Florida, Idaho, Illinois, Indiana, Iowa, Michigan, Minnesota, Nebraska, New Mexico, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, Washington, and Wyoming.
[Confirm that this list accurately reflects every state in which Peter Irungu and Groves Capital are currently authorized to offer or arrange mortgage services. Confirm whether services are offered in any additional states on a case-by-case basis.]This Privacy Policy does not necessarily govern the independent privacy practices of Meta, Facebook, Home Qualifiers, LendingPad, lenders, credit-reporting agencies, financial institutions, or other third parties. Those organizations may process information under their own privacy policies and legal obligations.
Business: Peter Irungu doing business under Groves Capital Inc
Business Address: 4883 Ronson Court, Suite A/B, San Diego, CA 92111
Privacy Email: peter.irungu@grovescapital.com
Privacy Phone: 253-361-7260
Depending on how a consumer interacts with us, we may collect the following information directly:
We may receive information through:
This information may include the content of communications, questions about mortgage financing, preferred appointment times, and information necessary to respond to an inquiry.
A consumer may voluntarily provide preliminary information about:
Consumers should not send Social Security numbers, bank-account credentials, complete financial account numbers, passwords, copies of identity documents, or other highly sensitive information through Facebook Messenger, ordinary email, social-media comments, or unsecured text messages.
We may direct consumers to third-party platforms that collect and process additional information. The information collected through those platforms may be received by Groves Capital, Peter Irungu, the platform provider, lenders, credit-reporting agencies, verification providers, or other parties involved in evaluating or processing a mortgage transaction.
Website: partner.homequalifiers.com
Purpose: Credit evaluation and homebuyer-readiness services.
Information processed through Home Qualifiers may include:
Home Qualifiers is a third-party platform. Its collection, use, retention, security, and disclosure of information may also be governed by its own privacy policy, terms, consumer authorizations, and contractual obligations.
[Confirm whether Home Qualifiers obtains a consumer report, performs a soft credit inquiry, receives consumer-supplied credit information, or uses another credit-evaluation method.]
Website: LendingPad application portal
Purpose: Completing and processing a mortgage application.
Information processed through the LendingPad mortgage application portal may include:
LendingPad is a third-party technology provider. The platform's independent processing activities may be governed by its own privacy policy, terms, security practices, agreements with Groves Capital, and applicable legal requirements.
Mortgage-related services may involve information considered sensitive under federal or state law. Sensitive personal information may include:
We may process sensitive personal information when reasonably necessary to:
We do not intend to use sensitive personal information to infer characteristics about a consumer for purposes unrelated to providing mortgage-related services.
[Confirm whether sensitive personal information is used for any advertising, audience creation, profiling, lead scoring, automated decision-making, or secondary purpose.]We may receive personal information from:
We may collect, use, or otherwise process personal information to:
We may disclose personal information when reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted or required by law.
Information may be disclosed to authorized Groves Capital personnel, including loan officers, processors, managers, compliance personnel, information-security personnel, and other individuals who need the information to perform mortgage-related or business functions.
Information may be disclosed to:
Information may be disclosed, as appropriate, to:
Disclosure to these parties will depend on the transaction, the consumer's authorization, and applicable legal restrictions.
Information may be disclosed to or obtained from:
Use of a consumer report generally requires a legally permissible purpose and, where applicable, consumer authorization. The Fair Credit Reporting Act regulates consumer-reporting agencies, users of consumer reports, and certain rights relating to credit-report information.
We may disclose information to companies that provide:
These providers may process information on behalf of Peter Irungu, Groves Capital, or another transaction participant, subject to their contractual and legal responsibilities.
We may disclose information:
Information may be disclosed in connection with a proposed or completed merger, acquisition, financing, sale, transfer, reorganization, bankruptcy, or other business transaction, subject to applicable legal requirements.
Information may be disclosed when a consumer requests, authorizes, or directs the disclosure.
The terms "sell," "share," "targeted advertising," and "cross-context behavioral advertising" have specific meanings under certain state privacy laws and may include some disclosures that do not involve payment of money.
We do not sell personal information for monetary or other valuable consideration, and we do not share personal information for cross-context behavioral advertising or process it for targeted advertising, as those terms are defined by applicable state privacy laws.
[This statement reflects that no Meta Pixel, retargeting, or cross-context advertising sharing is currently in use. If that changes — for example, if a Meta Pixel, Conversions API, or similar advertising/retargeting technology is added to this Site or any linked landing page — this section must be revised before continued use, and an opt-out mechanism may become required. Confirm this remains accurate any time advertising or analytics tools on this Site are changed.]Our Facebook page, advertisements, messages, or communications may contain links to websites or services operated by third parties, including Home Qualifiers and LendingPad.
We do not control all aspects of a third party's independent collection, use, disclosure, retention, or security practices. Consumers should review the privacy policy, notices, terms, and authorization language presented by each third party before submitting personal information.
A link to a third-party service does not necessarily mean that Peter Irungu or Groves Capital controls, endorses, or is responsible for all activities of that third party.
When a third-party provider processes information on behalf of Groves Capital, its responsibilities may be governed by a contract and applicable law. When it processes information for its own purposes, its independent privacy policy may apply.
Facebook and Meta may collect information about users' interactions with Facebook pages, advertisements, lead forms, Messenger, and other Meta services. Meta may process that information under its own terms and privacy disclosures.
Our websites, landing pages, third-party platforms, or marketing services may use cookies, software-development kits, pixels, tags, local storage, device identifiers, server-side tracking, conversion tools, or similar technologies to:
Browser settings may allow users to block or delete cookies, although doing so may affect website functionality. Third-party platforms may provide their own privacy and advertising controls.
We retain personal information for only as long as reasonably necessary for the purposes for which it was collected, including to:
Different categories of information may be retained for different periods. Mortgage applications, disclosures, credit authorizations, communications, loan records, and compliance records may be subject to legally mandated retention periods.
When information is no longer reasonably necessary, it may be deleted, deidentified, anonymized, or retained in a restricted form, subject to applicable law and technical limitations.
[Identify the actual retention schedules used by Peter Irungu and Groves Capital for Facebook leads, declined leads, incomplete applications, completed mortgage files, text messages, emails, call records, credit information, and documents.] [Confirm whether Meta, Home Qualifiers, LendingPad, lenders, and other third parties retain copies under their own retention schedules.]Because mortgage information can be highly sensitive, reasonable administrative, technical, and physical safeguards should be used to protect personal information against unauthorized access, acquisition, disclosure, alteration, loss, or destruction.
Depending on the system and the party responsible for it, safeguards may include access controls, authentication, workforce training, vendor oversight, system monitoring, secure document-transfer methods, incident-response procedures, and other security measures appropriate to the nature of the information.
No method of electronic transmission, storage, or security is completely risk-free. We therefore cannot guarantee that personal information will always remain secure or that a security incident will never occur.
Consumers should avoid sending Social Security numbers, complete bank-account numbers, tax returns, identity documents, passwords, or similar sensitive information through social-media messages, public comments, ordinary text messages, or other channels not designated for secure document transmission.
The federal Gramm-Leach-Bliley Act may require covered financial institutions to explain certain information-sharing practices and safeguard consumer financial information. The FTC's Safeguards Rule requires covered financial institutions under its jurisdiction to maintain measures for protecting customer information and to address service-provider safeguards.
[Confirm which entity maintains the written information-security program applicable to Peter Irungu's mortgage activities and whether Peter Irungu is covered under Groves Capital's program.]Privacy rights vary depending on a consumer's state of residence, the type of information involved, the reason it was collected, the entity processing it, and whether a legal exemption applies.
Depending on applicable law, an eligible consumer may have the right to:
These rights are not absolute. A request may be denied or limited when an exception applies, including when information must be retained to:
California law may provide qualifying consumers with rights to know, delete, correct, opt out of sale or sharing, and receive nondiscriminatory treatment. California also recognizes browser-based opt-out signals, including the Global Privacy Control, for covered processing.
Information governed by federal financial-privacy laws may be wholly or partly excluded from certain state privacy-law provisions. The scope of those exclusions varies by state and may apply to particular data, particular entities, or both.
[Confirm whether Groves Capital meets the applicability thresholds under the comprehensive privacy laws of any state in which it operates.] [Confirm whether Peter Irungu is treated as part of Groves Capital for purposes of responding to privacy requests.]Depending on applicability thresholds, exemptions, and the consumer's state, additional rights may exist under the privacy laws of California, Colorado, Oregon, Texas, Virginia, and other states in which services are offered.
Some states listed in this Privacy Policy may not currently have a generally applicable comprehensive consumer-privacy law, but may have laws governing:
This Privacy Policy does not expand legal rights beyond those provided by applicable law.
A consumer may submit a privacy request using either of the following methods:
Email: peter.irungu@grovescapital.com
Telephone: 253-361-7260
A request should include:
Consumers should not include Social Security numbers, complete financial-account numbers, passwords, or copies of sensitive identity documents in an initial email request.
[Confirm whether Groves Capital has a separate online privacy-request form or toll-free telephone number that must be used.] [Confirm which party is responsible for receiving, logging, verifying, and responding to privacy requests.]To protect consumers and reduce the risk of unauthorized disclosure or deletion, we may need to verify the identity and authority of the person submitting a privacy request.
Verification may involve:
We will not request more information than reasonably necessary for verification. Information provided for verification will be used for verification, security, fraud prevention, and legal compliance.
We may be unable to fulfill a request when identity or authority cannot be reasonably verified.
Where applicable law permits, a consumer may authorize another person to submit a privacy request on the consumer's behalf.
We may require:
Residents of certain states may have the right to appeal a decision concerning a privacy request.
An appeal may be submitted to:
Email: peter.irungu@grovescapital.com
Subject Line: Privacy Request Appeal
The appeal should explain why the consumer believes the original decision should be reconsidered.
[Confirm the internal appeals process, response deadlines, and any state-specific attorney-general complaint disclosures that must be provided.]Where applicable law provides a right to limit the use or disclosure of sensitive personal information, an eligible consumer may submit a request using the contact methods listed above.
This right may not apply when sensitive information is used only for purposes permitted without a limitation option, such as:
Mortgage-readiness tools, lenders, credit models, underwriting systems, fraud tools, or verification services may use automated processing to evaluate information.
Peter Irungu may receive or review the results of such systems but may not control the methods used by a lender, consumer-reporting agency, technology provider, or other independent third party.
[Confirm whether Peter Irungu or Groves Capital independently conducts profiling, lead scoring, automated eligibility determinations, or automated decision-making that produces legal or similarly significant effects.]A mortgage-readiness result is not necessarily a final credit decision, loan approval, commitment to lend, or guarantee of financing.
Mortgage services are not directed to children under 13, and we do not knowingly seek to collect personal information directly from children under 13 through Facebook lead forms, mortgage-readiness services, or mortgage-application activities.
A parent or legal guardian who believes that a child provided personal information may contact us using the information in this Privacy Policy.
Information about dependents or family members may be collected from an adult applicant when relevant to a mortgage application or required by law. Such information should be provided only when lawful and necessary.
Some browsers provide a "Do Not Track" setting. Because no uniform legal or technical standard applies to all Do Not Track signals, websites associated with these services may not respond to every such signal.
Where required by applicable law, a qualifying website must process recognized browser-based opt-out preference signals, such as the Global Privacy Control, as a request to opt out of covered sale or sharing activities.
[Confirm whether any website controlled by Peter Irungu or Groves Capital recognizes Global Privacy Control or other opt-out preference signals.] [Confirm whether any sale, sharing, or targeted-advertising processing occurs that would require an opt-out mechanism.]Consumers may request that marketing emails or text messages stop by:
Opting out of marketing communications may not prevent communications that are necessary to:
A person who provides information about a spouse, co-borrower, dependent, employee, landlord, accountant, real estate agent, or other individual should provide that information only when authorized and appropriate.
Where required, the person providing the information should inform the other individual that the information may be submitted for mortgage-related purposes.
We may update this Privacy Policy to reflect changes in:
The updated policy will display a revised "Last Updated" date. Where required by law, additional notice may be provided before a material change takes effect.
Consumers should review the Privacy Policy periodically.
Questions, concerns, or privacy requests may be directed to:
Peter Irungu doing business under Groves Capital Inc
4883 Ronson Court, Suite A/B
San Diego, CA 92111
Email: peter.irungu@grovescapital.com
Telephone: 253-361-7260
This online Privacy Policy is separate from any privacy notice, credit authorization, mortgage disclosure, application disclosure, adverse-action notice, servicing notice, or other document required under federal or state financial-services law.
A mortgage application or transaction may be subject to additional privacy notices provided by:
The Gramm-Leach-Bliley Act and its implementing rules may require covered financial institutions to provide notices describing their collection and disclosure of nonpublic personal information and, in some circumstances, an opportunity to opt out of certain disclosures to nonaffiliated third parties. Mortgage brokering is identified by FTC guidance as a financial activity that may be covered when the business is significantly engaged in it.
Those separate notices may describe practices, rights, disclosures, and opt-out choices that differ from or supplement this Privacy Policy. When a transaction-specific financial privacy notice applies, consumers should review that notice carefully.
This Privacy Policy does not alter a lender's underwriting standards, a consumer-reporting agency's responsibilities, a consumer's credit-report rights, or the terms of any mortgage application or loan.
This Privacy Policy is intended to provide general information about privacy practices. It is not legal advice and does not create a contractual right or obligation beyond those imposed by applicable law.
Privacy, mortgage, consumer-reporting, advertising, record-retention, and financial-services laws are complex and may apply differently depending on:
This Privacy Policy should be reviewed and approved by qualified privacy and mortgage-industry counsel before it is published or linked to a Facebook lead form, website, advertisement, or mortgage platform.