Privacy Policy

Customer service is very important to all of us. As we continue to improve and expand our services, we recognize our customers' need and desire to preserve their privacy and confidentiality. Safeguarding our customers' privacy is also very important to us. We have adopted standards that help maintain and preserve the confidentiality of customers' nonpublic personal information. The following Statement affirms our continued efforts to safeguard customer information.

Information We Collect

We gather nonpublic personal information about our customers as may be necessary to conduct business with our customers.We collect nonpublic personal information about you from the following sources:

  • Information we receive from you on applications or other forms, over the telephone or in face-to-face meetings, and via the Internet. Examples of information we receive from you include your name, address, telephone number, social security number, credit history and other financial information.
  • Information about your transactions with us or others. Examples of information relating to your transactions include payment histories, account balances and account activity.
  • Information we receive from a consumer reporting agency. Examples of information from consumer reporting agencies include your credit score, credit reports and other information relating to your creditworthiness.
  • From employers and others to verify information you have given to us. Examples of information provided by employers and others include verifications of employment, income or deposits.

Information We Disclose

Your personal information will only be retained for the purpose of providing you with our response to your query and will not be made available to any third party except as necessary to be disclosed to any related entity for the purpose intended or as required to be disclosed under law.

By submitting data on our website, the visitor is providing explicit consent to transmission of data collected on the website.

We treat data as confidential within our firm and require a strict adherence of all our employees to data protection and our confidentiality policies.

All visitors, however, should be aware that our website may contain links to other sites that are not governed by this or any other privacy statement.

We reserve the right to amend (that is, add to, delete or change) the terms of this Privacy Statement from time to time.

Additional Privacy Notice for California Residents

Overview

This Privacy Notice for California Residents (this “Privacy Notice”) is for California residents only and supplements, and does not replace, the above information contained in the Privacy Policy.

It applies to visitors, client’s, users, and others who reside in the State of California (“consumers” or “you”). This notice contains a description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

While we believe that much of the personal information we collect is exempted under the Gramm-Leach-Bliley Act exemption of the California Consumer Privacy Act of 2018 (“CCPA”), we are providing this notice to recognize certain rights of consumers under the CCPA. For example, this Privacy Notice does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. In limited circumstances, we may collect information that identifies, describes, or is reasonably capable of being associated with you that is not related to your use of our financial products and services.

Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Information We Collect

When you use our Website, we may collect personal information about you, such as your name, address, Social Security number, telephone number, email address, asset information, income information, or any other information that you submit on applications or other forms made available through the Website. We collect this information when you request a rate quote, begin an application, or make an inquiry.

As part of our business, and in our efforts to serve you, we collect this information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

What is Collected:

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Personal information categories listed in the California Customer Records statute

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status.

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data

Physical location or movements.

Sensory data

Audio recordings of your contact with our customer service team.

Professional or employment-related information

Current or past job history or performance evaluations.

What is Not Collected:

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Non-public education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Inferences drawn from other personal information

Audio, electronic, visual, thermal, olfactory, or similar information.

Personal Information DOES NOT Include:

  • Publicly available information from federal, state, or local government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our customers or their agents. For example, from documents that our customers provide to us related to the services that we are asked to perform.
  • Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
  • Directly and indirectly from activity on our Website. For example, from submissions through our Website portal or Website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform. For example, credit reporting agencies, appraisers, and other service providers.
  • From our affiliates.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide personal information to apply for a loan, we will use that information to process your application, payment, and facilitate loan closing. We may also save your information for legal or regulatory purposes, loan fulfillment, and/or loan servicing.
  • To provide, support, personalize, and develop our websites, products and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our response.
  • To personalize your website experience and to deliver relevant content and product and service offerings, including targeted offers and other communications (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our business websites, products and services, databases and other technology assets.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or for other business purposes or that are otherwise set forth in the CCPA.
  • To respond to audits or state or federal examinations by our regulators.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. We limit the information that we send service providers, and require that our service providers only use shared personal information to perform the services requested in accordance with our Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

We may share personal information with third parties:

  • Such as vendors who provide employment verification, degree verification, title, document import, or other necessary services;
  • Such as our subsidiary and affiliated businesses that provide quality services or products you may be interested in;
  • For any purpose to which you expressly consent;
  • To protect our rights or the rights or safety of others; and
  • As may be required by law or regulation.

Sale of Personal Information

In the preceding 12 months, we have not sold to another business or any third party any personal information subject to the CCPA.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

Access to Information

Unless your personal information is excluded from the scope of the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, you have a right to know:

  • The categories of personal information we have collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Requests Rights

Unless your personal information is excluded from the scope of the CCPA, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to exceptions.

Please note that the Gramm-Leach-Bliley Act and the CCPA allows us to keep certain forms of data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information.
  • Provide a good or service that you requested and take actions reasonably anticipated within the context of our ongoing business relationship with you.
  • Perform a contract between us and you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights

If you are a California resident, you can submit a request to us by:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the California resident about whom we collected personal information or an authorized representative of such a resident.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically (provided we can do so securely). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Non-discrimination

You have the right to not receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

Information for Parents or Guardians

We do not knowingly collect or maintain information about children under the age of 16, unless that information is provided by a parent, legal guardian, or authorized adult.

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time to reflect changes in our business, legal or regulatory obligations. Any changes will be immediately effective upon the posting of the updated Privacy Notice.

Contact Information

If you have any questions or comments about this Privacy Notice or our privacy practices, please do not hesitate to contact us at:

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