Effective Date: January 1, 2020
Information We Collect
Our Websites may collect 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, our Websites may have collected the following categories of personal information from consumers since January 1, 2020, the effective date of the CCPA:
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
OneTrust Home Loans obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Websites.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- From third-party business partners such as social media sites, ad networks, and analytics providers.
Use of Personal Information
We use information to offer products and services to you, fulfill your requests, improve the quality of our products and services, engage in research and analysis relating to our products and services, personalize your experience, track usage of our Website, market our products and services, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of our Website, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.
We also use information that we collect about you or that you provide to us, including any Personal information:
- To present the content of our products and services to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
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 you provided the information. For example, if you share your name and contact information to request a consultation or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders.
- 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 responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Websites, 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 as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of OneTrust Home Loans’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by OneTrust Home Loans about our Website users is among the assets transferred.
OneTrust Home Loans 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
OneTrust Home Loans may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Subsidiaries and affiliates.
- Service providers.
- Third parties with whom we partner with to offer products and services to you.
- Data aggregators.
Disclosures of Personal Information for a Business Purpose
Since January 1, 2020, OneTrust Home Loans has disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
- Category I: Current or past job history or performance evaluations.
Sales of Personal Information
We Do not Sell Your Information:
OneTrust does not sell personal information. We do not sell or otherwise disclose personal information we collect on our Sites, except as described here. We may share the information with our service providers who perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We may also provide personal information to third parties such as technology providers to enable such third parties to perform business, professional and technical support functions for us, our Sites or for you. On certain Sites, we provide tools to allow real estate agents to communicate with each other to negotiate transactions. In the course of these communications, they may use our tools to share personal information about the parties they represent.
OneTrust can and does disclose your personal information to third-parties for a business purpose. When we disclose personal information to a non-governmental entity, we enter a contract that describes the purposes and requires the recipients to both keep that personal information confidential and not use it for any purpose except for the performance of the contract. We may disclose your personal information to the following categories of third-parties: (a) our affiliates; (b) vendors; (c) third-parties whom you or your agent has authorized to receive your personal information; (d) third-parties who provide marketing services for us; and (e) regulatory agencies, courts and other authorities who have requested your personal information pursuant to applicable law.
In the preceding 12-month period, we have disclosed, for a business purpose, the following categories of personal information to third-parties: (a) Personal Identifiers; (b) Personal Information Categories in the California Customer Records Statute; (c) Protected Classification Characteristics Under California and/or Federal Law; (d) Employment-Related Information; and (e) Internet Activity.
Your California Privacy Rights
We do not share personal information (as defined by California Civil Code § 1798.83) with other people or non-affiliated businesses for their direct marketing purposes. Our websites do not respond to browser do-not-track signals.
Under the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:
- The deletion of the personal information we have about them.
- Additional information about whether and how we have collected, used, disclosed, and sold personal information about them.
- The specific pieces of personal information we have about them.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above.
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.
You may submit a privacy rights request to us by:
- Visiting our Data Subject Access Request (“DSAR”) portal here.
- Calling us at 888-974-0646
Changes to Our Privacy Notice
OneTrust Home Loans reserves the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Websites and update the Notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which OneTrust Home Loans collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Sending a letter to us at:
OneTrust Home Loans
Attn: Compliance Officer
3131 Camino Del Rio North. Suite 1680
San Diego, CA 92108
DISCLOSURE FOR CALIFORNIA USERS: GRA AND OTHER PARTIES NOT AFFILIATED WITH US MAY COLLECT PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOUR ONLINE ACTIVITIES OVER TIME AND ACROSS DIFFERENT WEBSITES WHEN YOU USE OUR WEBSITE OR THE SERVICES OFFERED ON OUR WEBSITE. WE DO NOT HAVE ANY PROTOCOL THAT OFFERS YOU THE CHOICE TO OPT-OUT OF INTERNET TRACKING. AT PRESENT TIME, THE GRA WEBSITE IS UNABLE TO RESPOND TO “DO NOT TRACK” SIGNALS FROM YOUR INTERNET BROWSER. IF YOU HAVE ANY QUESTIONS REGARDING OUR INTERNET TRACKING METHODS PLEASE EMAIL US AT COMPLIANCE@ONETRUSTHOMELOANS.COM.