What Is Your “Personal Information”?
“Personal information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked (directly or indirectly) with you or your household, but does not include public information that is lawfully made available from federal, state, or local government records. A statutory definition of “personal information,” together with examples of personal information, can be found at Cal. Civ. Code § 1798.140(o)(1).
What Are My Rights in My Personal Information?
Under the California Consumer Privacy Act of 2018 (CCPA), you have the following rights in relation to the collection, use or sale of your personal information:
1. Right to Know
You have the right to know and right to request that we disclose to you the following information regarding your personal information that we collect, use, disclose or sell:
- the categories of personal information that we have collected about you;
- the categories of sources from which we collected your personal information;
- the specific pieces of personal information that we have collected about you;
- the categories of your personal information that we have sold, the categories of third parties to whom we have sold your personal information, and the categories of your personal information that were sold to each category of third parties;
- the business* or commercial purpose for which we collected or sold your personal information;
- the categories of third parties with whom we share your personal information;
- the categories of your personal information that we disclose about you for a business purpose.*
2. Right to Delete
You have the right to request that we delete any personal information about you which we have collected from you or maintain about you. However, we will not be required to comply with your deletion request if it is necessary for us or our service providers to maintain your personal information in order to carry out the activities listed in Cal. Civ. Code § 1798.105(d).
3. Right to Opt-out of Sale
You have the right, at any time, to direct us not to sell your personal information. However, we do not sell your personal information to third parties, so you do not need to request an opt-out of the sale of your personal information.
4. Right to Non-discrimination
You have the right not to receive discriminatory treatment from us for the exercise of any of your rights conferred by the CCPA. We will not deny goods or services to you, charge you different prices or rates for goods or services, or provide a different level or quality of goods or services to you because you have exercised any of your rights under the CCPA.
What Do We Do with Personal Information?
We do not sell consumer personal information. In the preceding 12 months, we have not sold personal information about consumers to third parties.
In the preceding 12 months, we have collected personal information about consumers in the following categories: consumers’ full names, addresses, emails, social security number or tax identification number, driver license information, dates of birth, phone numbers, employment information, real estate owned, account information for banks and other financial institutions, and credit account information. We collect this information directly from customers or their authorized agents, and may gather it through one or more of the following channels: social media, website forms, telephone, paper applications, web applications, and mobile applications.
Your information may be collected for the following business* and/or commercial purposes: to verify customer creditworthiness and eligibility for mortgage loan products; to verify customers’ identity when speaking to borrowers or applicants about sensitive loan or loan application data; to accept loan payments; or to notify or market products and services to existing or past customers.
Your information may be shared with the following categories of third parties: for a business purpose*: Mortgage insurers, title companies, attorneys, outside auditors and examiners, regulatory agencies, and credit card vendors (if payment is made through a third-party credit card processor, your credit card information will be stored with that vendor and not with us).
If you have further questions or concerns about our privacy policies and practices, please contact us as firstname.lastname@example.org or 844-542-5626. You may print a printer-friendly version of this policy by clicking here**.
How Do I Make Requests Regarding My Personal Information?
You may submit any of the above-described requests to us in any of the following ways: (1) Call toll-free at 844-542-5626; (2) Send an e-mail to email@example.com; or (3) Submit a written request at any of our physical locations. Responses to requests for information will cover the 12-month period preceding our receipt of your request. You have the right to make two requests every 12 months.
We may require verification or authentication of your identity prior to processing the request. We will deliver a written response to your request within 45 calendar days,*** either through your account if you have an account with us, or if you do not have an account with us, we will deliver a written response by mail or electronically at your option.
For requests regarding categories of personal information, in order to verify your identity with a reasonable degree of certainty, we may require that you provide two data points that match at least two of the data points we have for you in our system.
For requests regarding specific pieces of information we may have about you, in order to verify your identity with a reasonably high degree of certainty, we may require that you provide three data points that match at least three of the data points we have for you in our system.
We may also require that you sign a declaration, under penalty of perjury, affirming your identity.
You may designate an authorized individual to make a request on your behalf, however, in order to do so, you must provide us with a valid power of attorney or other notarized authorization from you, and a valid copy of the authorized individual’s government-issue identification.
Personal information about our customers that is regulated by the following federal or state privacy laws and to which we are subject and with which we comply are exempt from most of the CCPA’s requirements:
- Gramm-Leach-Bliley Act and its implementing regulations
- California Financial Information Privacy Act
- Fair Credit Reporting Act
- Health Insurance Portability and Accountability Act (HIPAA)
- California Confidentiality of Medical Information Act
- Driver’s Privacy Protection Act of 1994
* A “business purpose” is broadly defined as use of consumer personal information for our internal operational purposes. A list of statutorily defined business purposes can be found at Cal. Civ. § 1798.140(d).
*** Our response time to a verified consumer request may be extended by up to 45 additional calendar days, where necessary, taking into account the complexity and number of requests. We will notify you in the event of any such extension, together with the reasons for the extension.