Privacy Policy

 

Effective Date: 01/2024

We take our clients’ privacy very seriously. We understand that your privacy is important. This Privacy Policy describes how we collect and use the personal information that we collect about you on www.homefrontloans.com (the "Website").

By continuing to use the Website, you agree to this Privacy Policy and the collection, use, disclosure, and storage of your personal information as described by this Privacy Policy.

 

Information We Collect

When you use the Website, we and/or our subsidiaries (collectively referred to herein as “we”, “us” or “our”) 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 may also collect personal information about you from third party sources, which we may combine with information that you provided to us or we previously collected. For example, we may receive information from a social media service about you if you use a social media account to log into the Website.

We also automatically collect certain information related to you and your activities on the Website when you visit the Website. This information includes information such as your IP address, your internet browser and operating system type, the date and time of your visit, and the website that referred you to us.

 

Cookies and Other Tracking Technologies

Our Website uses cookies and other tracking technologies, such as web beacons (otherwise known as pixel tags). A "cookie" is a small file placed on your computer that helps us to recognize your browser. We use both first and third-party cookies and tracking technologies on the Website. These cookies and tracking technologies may collect your personal information. We may use cookies and tracking technologies to monitor how the Website is used, customize content, serve advertisements and evaluate the effectiveness of our advertising campaigns, identify problems with the Website, improve the Website, analyze Website traffic and other analytics purposes, monitor the security of the Website, and gauge the effectiveness of our communications. Most web browsers allow you to adjust your preferences to reject cookies or to receive notifications before they are placed. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

 

Tracking

Our first-party cookies and tracking technologies do not track users over time and across third-party websites, and therefore the Website does not respond to web browser do-not-track signals.

We also use third-party cookies to serve targeted advertisements on both the Website and on third-party websites. These cookies may track users over time and across third-party websites and services. Please note that if you opt-out of advertising cookies, you may still see our advertisements on third-party websites and services.

 

How We Use Collected Information

We use personal information and anonymous information for the following purposes:

                  • To complete and fulfill your loan application;
                  • To respond to and fulfill your requests;
                  • For our marketing efforts, such as to send you marketing communications that we believe may be of interest to you;
                  • For our business purposes, such as for analysis and to develop new products and services;
                  • To improve the Website and for analytics purposes; or
                  • For any other purpose to which you consent.

The Fair Credit Reporting Act gives you the opportunity to limit the sharing of “non-experience information” among our affiliates. “Non-experience information” includes information that is used, expected to be used, or collected for the purpose of establishing your eligibility for consumer credit, insurance or deposit accounts, and is not related solely to your transactions or other experiences with us, including information:

                  • From your applications, such as your income or marital status
                  • From a credit report, such as your credit history
                  • From sources used to verify representations made by you, such as your open lines of credit or employment history

Within our family of companies, we may share the customer information we collect with:

Our subsidiary and affiliated businesses, providing financial and other services such as:

                  • Residential mortgage products
                  • Insurance and real estate brokerage
                  • Home security products
                  • Residential homebuilding

How We Share Personal Information

We will only share personal information with third parties as described in this Privacy Policy. 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 Home Front Mortgage and Finance Holding Company affiliated businesses that provide quality services or products you may be interested in (unless you’ve opted out);

Such as to other partners with which we have marketing arrangements or to others that may want to provide information to you about the products and services that they offer (unless you’ve opted out); 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.

Please note, we do not share SMS text opt-in data with any third parties.

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 this Privacy Policy and have adequate security measures in place to protect any of your shared personal information.

For example, after you authorize us to verify your credit history, we send the minimal set of information needed (potentially including your social security number) to ensure we are requesting the correct record in an encrypted form to the relevant credit bureaus with the sole purpose of retrieving your credit report and associated credit history data. We would not send the same level of information to a service provider where it is not essential to perform their services.

For retrieving bank information (transactions, accounts, and other information), we use Plaid and AccountChek by FormFree as third-party service providers. Their respective privacy policies are available here: Plaid and AccountChek.

In the event that we enter into a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), personal information that we have collected may be transferred in the course of that corporate transaction to the relevant third party purchaser, joint venture partner, merged entity, assignee or similar party.

 

Access to and Control Over Information

You may opt-out of any future marketing contacts from us at any time. You can do the following by contacting us at 800-707-8845 or by sending an email to info@homefrontloans.com:

                  • See what data we have about you, if any;
                  • Change/correct any data we have about you;
                  • Delete any information about you that we are not required by law to keep; and
                  • Express any concern you have about our use of your data.

How We Protect Personal Information

We use reasonable physical, technical, and administrative security measures to protect personal information we collect from loss, misuse, unauthorized access, or improper disclosure. For example, we use encryption technologies when transmitting information to and from the Website and with our third-party service providers. Please understand that no security technology is completely secure, and remember that when communicating with us, email is not a secure form of communication when transmitting sensitive or personal information.

Links to Other Websites

The Website may contain links to third-party websites, such as social media websites. This Privacy Policy is only applicable to this Website, and we have no control of these third-party websites' information practices. Please be sure to review these third-party websites' privacy policies before visiting these third-party websites.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain, or use personal information from children under the age of 13. If we become aware that a child under the age of 13 has submitted personal information to us through the Website, we will immediately delete such information.

Updates to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be immediately effective upon the posting of the updated policy. Your continued use of the Website after these updates are posted represents your consent to the terms of the new Privacy Policy. Please regularly check this Privacy Policy for any such updates.

 

Additional Privacy Notice for California Residents

Overview

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

Please note, we do not share SMS text opt-in data with any third parties.

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:

          • Calling us at 800-707-8845

          • Emailing us at info@homefrontloans.com

          • 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:

Additional State Privacy Notice Addendum (Colorado, Utah, Virginia, Connecticut, Vermont & Other States)

Definitions

As used in this Addendum: (a) “Applicable State Data Protection Laws” means (i) the Colorado Privacy Act of 2021, the Virginia Consumer Data Protection Act of 2021, the Utah Consumer Privacy Act of 2022, ,or the Connecticut Data Privacy Act of 2022 (CTDPA) as amended, or (ii) any other applicable US state Law enacted for the purpose of protecting Personal Data.

Consumer Data Rights

Subject to certain limitations, to the extent that Home Front Mortgage is processing any of your Personal Data in scope of the Applicable State Data Protection Laws, you have the right to (1) request to know more about the categories and specific pieces of Personal Data we collect, use, disclose and sell, and to access your information, (2) request deletion of your Personal Data, (3) request correction of your Personal Data and (4) not be discriminated against for exercising these rights.

You may make these requests by starting a request online via info@homefrontloans.com or calling 800-707-8845. We'll verify your request by asking you to provide information related to your recent interactions with us.

If we receive your request from an authorized agent, we may ask for evidence that you've provided such an agent with a power of attorney, or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you're an authorized agent seeking to make a request, please contact us as set out above.

To the extent that Home Front Mortgage is processing any of your Personal Data in scope of the Applicable State Data Protection Laws, Home Front Mortgage will ensure that each person processing Personal Data is subject to a duty of confidentiality with respect to the data.

Information Security

Home Front Mortgage shall maintain appropriate technical and organizational measures with regard to Customer Personal Data to ensure a level of security appropriate to the risk in accordance with this Addendum and as otherwise expressly stated.

Compliance Information

Upon the reasonable request of Customer, Home Front Mortgage shall make available to Customer reasonable information, consistent with and in accordance with applicable Laws, in Home Front Mortgage's possession necessary to demonstrate Home Front Mortgage compliance with Home Front Mortgage obligations in this Addendum.