Last revised: July 1, 2019

1. INTRODUCTION

Purpose. The purpose of this Privacy Policy is to describe how ClosingMark Home Loans (“ClosingMark”) collects, uses and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.closingmarkhome.com (collectively referred to herein as the “Site”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us as described at the end of this Policy.

Our Privacy Policy explains:

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Site. Our Site also contains links to third party sites that are not owned or controlled by ClosingMark. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

Other Privacy Policies. For information about how we collect, use and share your financial information, please refer to our Financial Privacy Notice.

Terms of Use. Please note that your use of our Site is also subject to our Terms of Use.

2. INFORMATION THAT WE COLLECT

Information You Provide to Us
We collect information you provide to us, for example when you create or modify your account, register to use our Site, make payments to us, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This information may include name; address; work address; email address; telephone number; bank account number (collected and processed by our third party payment processor service provider); date of birth; Social Security number; salary or other personal financial information; racial or ethnic origin; and other information you choose to submit to us. For additional information about how we handle your financial information please consult our Financial Privacy Notice.

Cookies; Information We Collect Automatically Through Your Use of our Site
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site.

Google Analytics We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on how your online activity.

Information Collected Through Cookies and Similar Technologies We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. (See, “Advertising” below.)

No Information from Children Under Age 13
If you are under the age of 13, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please contact us as described at the end of this policy.

3. HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. We collect information from you in order to provide products and services that you purchase using the Site; process your mortgage loan and related payments; provide information that you request from us; contact you about your orders; send you promotional materials or advertisements about our products and services, as well as new features and offerings; administer surveys, sweepstakes, promotions and contests.

Sharing with Third Parties. We may provide information to third party service providers that help us operate and manage our Site, process orders, provide advertising for us, and fulfill and deliver products and services that you purchase from us. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service. We may also share your personal information with third parties who may contact you about their products and services that may be of interest to you.

Third Party Advertising & Marketing. From time to time with your consent, we may disclose information with other companies, including our affiliates such as title insurance companies, other mortgage companies, and other ClosingMark affiliated companies who may offer you products and services of interest. You may opt out of this sharing by using the contact information set forth below, or by contacting us on our webpage. We may share contact information, salary information, and any other information we collect that may help our affiliates and other third parties market their products and services to you. Our affiliates include mortgage and title service entities. If you have consented to our sharing your personal information with these third parties, you may subsequently opt-out by using the contact information set forth below, or by contacting us on our webpage.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of ClosingMark when we have your consent to do so.

Legal Proceedings. We will share personal information with third party companies, organizations or individuals outside of ClosingMark if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
  • Enforce applicable Terms of Use, including investigation of potential violations.
  • Detect, prevent, or otherwise address fraud, security or technical issues.
  • Protect against harm to the rights, property or safety of ClosingMark, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

4. ACCESS TO YOUR INFORMATION AND CHOICES

If you have questions about personal information we have about you or need to update your information, you can contact us as described below. You can opt-out of receiving marketing and promotional emails from ClosingMark by contacting us as described below going, and by using the opt-out or unsubscribe feature contained in the emails.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking).

5. SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

6. CALIFORNIA PRIVACY RIGHTS

Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to customerservice@closingmark.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

7. CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES

This Site and Services are not intended for and are not directed to residents of the European Union. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

8. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

9. QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please email us at customerservice@closingmark.com call us at (800) 455-6973 or contact us by US postal mail at the following address:

ClosingMark Home Loans Attention: Privacy Opt Out 100 Pacifica, Suite #100 Irvine, CA 92618 United States of America