Effective Date: January 1, 2020
Homestead Funding Corp. (“HFC”) is dedicated to the protection and transparent use of your personal information. HFC is a residential loan origination company and we collect certain personal information in connection with that service. We do not sell or license your data to third-party organizations; however, we do share this information with vendors and other entities during your mortgage loan origination process and after the closing. This policy will outline how your data is used and your rights and choices associated with the use of HFC’s products and services.
How We Use Your Personal Data
During the loan origination process, we contract with various service providers, including appraisers, title companies, credit organizations, attorneys and others to facilitate certain parts of the transaction. The information shared with these organizations is only the necessary data they need to carry out their function of the service. HFC has established vendor management policies and requirements for the use and retention of the data that is shared and select our vendors based in no small part on their ability to adequately protect and process the data responsibly.
Types of Data Collected
Over the course of your use of HFC’s service, we will collect various types of non-public personal information (“NPI”) as part of our lending process. This type of information may include but is not limited to:
- Email address
- Social Security Number
- Phone Number
- Passport and/or Driver’s License Information
- Employment Information
- Financial Information, which may include income, assets, liabilities and business information.
- Credit Information
- Usage Data
- IP Address
Disclosure of Personal Data
HFC makes every effort to limit the frequency and scope of data shared with third parties. However, there are instances in which we are required to make such disclosures, either for business or legal purposes.
Occasionally, we will be required by legal or compliance-related circumstances to disclose data to law enforcement, government entities or to the courts under the following circumstances:
- To comply with a lawful court order or subpoena
- To protect or defend the rights of HFC
- To investigate possible misconduct in connection with the use of the service
- To comply with federal and/or state licensing and/or compliance requirements
- At the lawful discretion of HFC
HFC contracts with service providers for a number of services completed during the loan process. These organizations have access to your personal data only for the purpose of performing these tasks on HFC’s behalf. They are obligated not to disclose this information without authorization or to use the information for any other purpose. The service providers are also required to implement adequate measures to safeguard NPI while it is in their possession.
HFC Does Not Sell Data
All of the personal information and data collected by HFC is used solely for the purposes of carrying out our transactional and compliance responsibilities. We do not sell, license or otherwise transfer your data to outside companies for profit.
HFC uses the Google platform for internet advertising and analysis. We would encourage you to visit Google’s Privacy Policies for Google Analytics and Google AdWords for more information about how their services process and track your data.
HFC uses the Facebook platform for certain advertising functions. We do not, however, purchase targeted ads for housing and credit services based on protected class characteristics, geolocation or other criteria that may lead to discriminatory advertising practices.
HFC prides itself on a robust data security program. While we are confident that we are using commercially acceptable controls and data privacy resources to maintain the security of your personal information in a manner that complies with relevant state and federal regulation, it is important to remember that no method of data transmission or storage is 100% secure.
Compliance with State and Federal Law
HFC complies with all data protection and compliance requirements in the states in which it is licensed. HFC is governed by the laws of the United States and it intended for the use of residents of the United States only and makes no representation of compliance with laws of any other nation.
Links to Other Websites
HFC websites and other online resources may at times link to websites or mobile application that are not operated by HFC. If you click on one of these links, you will be directed to that third party’s website or application. For your privacy protection, we would encourage you to read the privacy policies of non-HFC web locations you may visit, as we have no control over the content, policies or practices of these services.
Changes to Your Personal Data
During your use of HFC’s services, you will interact with your data in several different locations. In the event you observe incorrect or outdated information, please contact our Sr. VP of Operations, Jane Borbee at firstname.lastname@example.org.
Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”), provides specific privacy rights to California Residents. In this section you will find your rights as a consumer in California, the process for which you can request changes or other benefits of those rights, and the categories of data collected and their disclosure.
Right to Request Disclosure
- You have a right to request that HFC disclose the categories of your data it collects and the specific piece of personal information it has collected.
Right to Notification
- At or before the time of data collection, you have the right to know the categories or personal information to be collected and the purpose for which the information will be used. HFC does not collect information beyond that needed to perform the requested services.
Verified Consumer Requests
- Upon receipt of a verified consumer request, you have the right to receive the personal information required under the CCPA.
- In order to complete a verified consumer request, a consumer must, either through our toll-free number or web capture form, submit the request and respond to the representative’s request for verifying information.
Right to Deletion
- Upon receipt of a verified consumer request you have the right to request deletion of the personal information you have provided to HFC.
Right to Third-Party Deletion
- Upon receipt of a verified consumer request, you have the right to request that HFC direct any service providers to delete the consumer’s provided information.
Exemptions to the Right of Deletion
- A business is not required to comply with a consumer’s request for deletion if it is necessary for the business to:
- Complete the transaction for which the information was provided.
- Detect security incidents, protect against fraudulent or illegal conduct or prosecute those responsible.
- Debug to identify or repair errors that impair functionality.
- Comply with the California Electronic Communications Privacy Act.
- To enable solely internal uses that are consistent with the consumer’s relationship to the business.
- Comply with a legal obligation.
Categories of Disclosure
- You have the right to request the following categories of disclosure from HFC:
- Categories of information collected.
- Categories or sources from which the information is collected.
- Business or commercial purpose of collection.
- Categories of third parties with whom information is shared.
- Specific pieces of personal information collected.
Sale of Data/Right to Opt-Out
- You have a right to be informed by HFC if your information may be sold and that you have a right to opt-out of such a sale. However, HFC does not sell consumer data.
Right to Non-Discrimination
- You have a right to non-discrimination in the event that your rights are exercised under the CCPA. This includes denial of goods or services, changing prices or rates or providing differing product quality levels.
How We Respond to Do Not Track Requests
- The California Online Privacy Protection Act (“CalOPPA”) requires businesses to inform California residents about online tracking habits and whether or not the company honors “Do Not Track” requests. HFC utilizes a number of internet advertising tools, including Google Analytics, AdWords and Facebook advertising functions. As HFC has no control over the tracking practices of those third parties, we do not currently respond to “Do Not Track” requests.
- Businesses are not required under CCPA to retain personal information collected for a single, one-time transaction. HFC does not view our transactions in this manner.
When submitting a request exercising any of your rights listed above, it is HFC’s responsibility to ensure that any request is verified to be the same consumer that the requested information identifies. For consumers who have applied for a loan with us, the requesting party will be required to provide three identifying pieces of information to your HFC representative.
If you have not gone through the formal application process, you will be required to provide two pieces of identifying information to your HFC representative.
As discussed above, requests may be submitted via our toll free number, 1-888-203-5432, or via our web capture form located at www.homesteadfunding.com/forms/data-request
Categories of Data
Under the CCPA, we are required to disclose the categories of data that are collected during your use of the service. These categories may include:
- Characteristics of Protected Classification
- Commercial Information
- Internet or Other Electronic Network Activity
- Geolocation Data
- Audio, Visual or Similar Information
- Profession or Employment Related Information
Disclosure of Data Categories
During the loan process, any of the above categories of data may be disclosed to third parties solely for the transactional services necessary to carry out the responsibilities consistent with the intention of the original collection. In other words, HFC does not disclose any of the above data categories for any reason than our normal mortgage-related business activities.
Under Section 1798.145(e) of the CCPA, many of the rights listed above do not apply to HFC due to our federally required compliance with the Gramm-Leach-Bliley Act (Public Law 106-102) and its implementing regulations. However, HFC still encourages California residents to exercise their rights and will be informed promptly if any request may not be processed due to this or any other applicable CCPA exemption.