Privacy Policy

1. Information We Collect

We collect various types of information to provide and improve our mortgage brokerage services. The information we collect includes:

1.1 Personal Identification Information

• Full legal name (including maiden name if applicable)
• Date of birth
• Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)
• Driver's license or state-issued ID number
• Current and previous residential addresses
• Phone numbers (mobile, home, work)
• Email addresses
• Citizenship or residency status
• Marital status

1.2 Financial Information

• Employment history and current employer information
• Income information (wages, self-employment income, investment income, etc.)
• Asset information (bank accounts, investment accounts, retirement accounts)
• Liability information (credit cards, loans, mortgages)
• Credit reports and credit scores
• Bank statements and tax returns
• Pay stubs and W-2/1099 forms
• Gift letter information (if applicable)
• Bankruptcy or foreclosure history

1.3 Property Information

• Property address and legal description
• Property type and intended use
• Purchase price or estimated value
• Down payment amount and source
• Property tax information
• Homeowners insurance information
• HOA information (if applicable)

1.4 Transaction Information

• Loan application details
• Loan type and amount requested
• Loan purpose (purchase, refinance, cash-out)
• Communication history with our company
• Documents submitted for loan processing
• Underwriting decisions and conditions

1.5 Technical and Usage Information

• IP address and device identifiers
• Browser type and version
• Operating system
• Pages visited on our website
• Time and date of visits
• Referring website or source
• Click-stream data
• Cookies and similar tracking technologies
• Geolocation data (with your consent)

1.6 Government Monitoring Information (HMDA)

To comply with the Home Mortgage Disclosure Act (HMDA), we collect demographic information including:

• Race and ethnicity
• Sex
• Age or date of birth

Important: Providing this information is voluntary and is used solely for government monitoring purposes. It will not affect your loan application or approval. We are required by law to collect this information to help the federal government monitor compliance with anti-discrimination laws.

2. How We Collect Information

We collect information through various methods:

2.1 Direct Collection

• Application Forms: When you complete a loan application, pre-qualification form, or inquiry form
• Phone Conversations: When you call us or we call you (calls may be recorded for quality and training purposes)
• Email Communication: When you email us or respond to our emails
• In-Person Meetings: When you meet with our loan officers
• Document Submission: When you provide supporting documentation for your loan
• Text/SMS Messages: When you communicate with us via text message

2.2 Third-Party Sources

• Credit Bureaus: We obtain credit reports from Experian, Equifax, and/or TransUnion
• Employment Verification Services: We may verify your employment through third-party services
• Asset Verification Services: We may verify your assets through third-party services
• Public Records: We may obtain information from public records (e.g., property records, bankruptcy filings)
• Title Companies: Information about property ownership and liens
• Appraisers: Property valuation information
• Real Estate Agents: Information related to your property transaction

2.3 Automated Collection

• Cookies: Small text files stored on your device (see Section 10)
• Web Beacons: Small graphic images used to track page views
• Analytics Tools: Google Analytics and similar services to understand website usage
• Session Recording: We may use tools to record user sessions for improving user experience

3. How We Use Your Information

We use your information for the following purposes:

3.1 Loan Processing and Servicing

• Processing and evaluating your loan application
• Verifying the information you provide
• Conducting creditworthiness assessments
• Underwriting and making credit decisions
• Preparing loan documents and closing
• Funding and delivering your loan
• Communicating with you about your loan status
• Responding to your inquiries and requests

3.2 Legal and Regulatory Compliance

• Complying with federal and state laws and regulations
• Reporting to government agencies as required (e.g., HMDA reporting)
• Responding to regulatory inquiries and examinations
• Preventing fraud, money laundering, and other illegal activities
• Complying with court orders, subpoenas, and legal processes
• Maintaining records as required by law

3.3 Business Operations

• Improving our website and services
• Analyzing customer behavior and preferences
• Conducting market research and surveys
• Training our employees
• Quality assurance and monitoring
• Protecting against security threats and fraudulent activity
• Managing and improving our internal operations

3.4 Marketing and Communication

• Sending you information about our products and services
• Providing you with promotional offers (with your consent)
• Sending newsletters and educational content
• Contacting you about refinance opportunities
• Soliciting feedback and reviews

Note: You may opt out of marketing communications at any time (see Section 5).

3.5 Automated Decision-Making

We may use automated systems and algorithms to:

• Perform initial credit assessments
• Calculate loan-to-value ratios and debt-to-income ratios
• Generate pre-approval letters
• Identify potential compliance issues

Important: All automated decisions are subject to human review. You have the right to request human intervention and to contest automated decisions.

4. How We Share Your Information

We share your information with third parties only as necessary to provide our services and as permitted by law:

4.1 Lenders and Investors

Why we share: To place your loan with appropriate lenders and facilitate loan funding

Type of information shared: All information on your loan application, credit reports, and supporting documentation

Your opt-out rights: You cannot opt out of this sharing if you want to obtain a loan through us

4.2 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Technology Providers: Website hosting, data storage, and IT services
• Verification Services: Employment verification, asset verification, income verification
• Credit Bureaus: Credit reports and monitoring services
• Document Management: Secure document upload and storage
• Communication Services: Email delivery, SMS services, call center services
• Marketing Services: Analytics, advertising, and customer relationship management
• Legal and Compliance: Legal counsel, compliance consultants, auditors

Contractual Requirements: All service providers are bound by confidentiality agreements and are required to use your information only to provide the services we've requested.

Service Provider Vetting and Oversight

We carefully vet all third-party service providers who have access to your personal information. Our process includes:

• Due Diligence: Background checks, reference verification, and review of security practices and certifications
• Contractual Protections: Written confidentiality and data protection agreements that meet or exceed industry standards
• Ongoing Monitoring: Regular audits of compliance with our privacy and security standards
• Incident Response: Immediate notification requirements for any security incidents or data breaches
• Termination Rights: Right to immediately terminate relationships for security breaches or non-compliance

All service providers are contractually obligated to:

• Use your information only for specified, authorized purposes
• Maintain the confidentiality and security of your information
• Implement appropriate technical and organizational security safeguards
• Notify us immediately of any data breaches or security incidents
• Delete or return your information when services are complete or upon our request
• Comply with all applicable privacy laws and regulations

4.3 Transaction Parties

We share information with parties involved in your real estate transaction:

• Title companies and escrow agents
• Real estate agents and brokers
• Appraisers and inspectors
• Homeowners insurance providers
• Attorneys representing you or other parties
• Sellers or buyers (as applicable)

4.4 Credit Bureaus

We report loan activity to credit bureaus, which may include:

• Loan approval or denial
• Credit inquiry information
• Account status and payment history (if we service your loan)

4.5 Government Agencies and Regulators

We share information with government agencies as required by law:

• Federal Housing Finance Agency (FHFA)
• Consumer Financial Protection Bureau (CFPB)
• Department of Housing and Urban Development (HUD)
• California Department of Financial Protection and Innovation (DFPI)
• Internal Revenue Service (IRS)
• State licensing authorities
• Law enforcement agencies (when required by law)

4.6 Legal Obligations

We may disclose your information when required or permitted by law:

• To comply with court orders, subpoenas, or legal processes
• To respond to government requests
• To protect our legal rights and interests
• To prevent fraud or other illegal activity
• To protect the safety of our employees, customers, or others
• In connection with a business transaction (merger, acquisition, sale of assets)

4.7 What We Do NOT Do

We do not:

• Sell your personal information to third parties for monetary consideration
• Share your information with non-affiliated third parties for their own marketing purposes without your consent
• Share your information with parties outside of the United States except as necessary for loan processing

5. Your Privacy Rights

You have the following rights regarding your personal information:

5.1 Right to Access

You have the right to request access to the personal information we have collected about you. We will provide you with a copy of your information in a readable format.

5.2 Right to Correct

You have the right to request that we correct inaccurate information about you. Please note that some information (such as credit reports) may need to be corrected directly with the source.

5.3 Right to Delete

You may request deletion of your personal information, subject to certain exceptions. We may retain information when required by law, to complete transactions, or to exercise our legal rights.

5.4 Right to Opt Out of Marketing

You may opt out of receiving marketing communications from us by:

• Clicking the "unsubscribe" link in our emails
• Replying "STOP" to text messages
• Calling us at (510) 589-4096
• Emailing us at info@agoodlender.com

Note: Even if you opt out of marketing, we will still send you transactional communications about your loan.

5.5 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights.

5.6 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information in Section 14. We will respond to your request within 30 days (or 45 days for California residents under CCPA).

Verification Requirement: To protect your privacy, we must verify your identity before responding to access, correction, or deletion requests.

6. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

6.1 Right to Know

You have the right to request that we disclose:

• The categories of personal information we have collected about you
• The categories of sources from which we collected the information
• The business purpose for collecting the information
• The categories of third parties with whom we share the information
• The specific pieces of personal information we have collected about you

6.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions under CCPA.

6.3 Right to Opt Out of "Sale" or "Sharing"

We do not sell your personal information. However, under CCPA's broad definition, some data sharing may be considered a "sale" or "sharing." You have the right to opt out of such sharing. To exercise this right, visit our Do Not Sell or Share My Personal Information page.

6.4 Right to Limit Use of Sensitive Personal Information

We use sensitive personal information only as necessary to provide mortgage brokerage services and as permitted by law. You have the right to limit our use of sensitive personal information, subject to exceptions.

6.5 Right to Correct Inaccurate Information

You have the right to request correction of inaccurate personal information we maintain about you.

6.6 Authorized Agent

You may designate an authorized agent to make a request on your behalf. The authorized agent must provide proof of authorization.

6.7 California "Shine the Light" Law

Under California Civil Code Section 1798.83, California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not currently share personal information with third parties for their direct marketing purposes.

7. Credit Report Information (FCRA)

Under the Fair Credit Reporting Act (FCRA), you have important rights regarding credit reports:

7.1 Credit Report Authorization

Before obtaining your credit report, we must obtain your written authorization. By signing a loan application or authorization form, you consent to our obtaining credit reports about you.

7.2 Your Rights Under FCRA

You have the right to:

• Obtain a copy of your credit report from the credit bureaus (you are entitled to one free credit report annually from each bureau at www.annualcreditreport.com)
• Dispute inaccurate information on your credit report with the credit bureau
• Know if adverse action was taken based on your credit report
• Limit prescreened offers by opting out at www.optoutprescreen.com

7.3 Adverse Action Notice

If we take adverse action (such as denying your loan application) based in whole or in part on your credit report, we will provide you with an adverse action notice that includes:

• The name, address, and phone number of the credit bureau that provided the report
• A statement that the credit bureau did not make the decision
• Your right to obtain a free copy of your credit report within 60 days
• Your right to dispute inaccurate information with the credit bureau

7.4 Credit Inquiry Impact

When we obtain your credit report, it results in a "hard inquiry" on your credit file, which may temporarily affect your credit score. Multiple credit inquiries for mortgage shopping within a short period (typically 14-45 days) are generally treated as a single inquiry for credit scoring purposes.

8. Data Security and Protection

We take the security of your information seriously and implement comprehensive security measures to protect it:

8.1 Technical Safeguards

• Encryption: We use industry-standard SSL/TLS encryption to protect data transmitted over the internet
• Secure Storage: Personal information is stored on secure servers with access controls
• Firewall Protection: Our networks are protected by firewalls and intrusion detection systems
• Regular Security Audits: We conduct regular security assessments
• Malware Protection: We use anti-malware and anti-virus software
• Data Backups: We maintain secure backups of your information

8.2 Administrative Safeguards

• Access Controls: Only authorized employees have access to personal information on a need-to-know basis
• Employee Training: All employees receive privacy and security training
• Background Checks: We conduct background checks on employees with access to personal information
• Confidentiality Agreements: All employees sign confidentiality agreements
• Vendor Management: We require vendors to maintain appropriate security measures

8.3 Physical Safeguards

• Secure facilities with restricted access
• Locked file cabinets for paper documents
• Secure disposal of documents (shredding)

8.4 Data Breach Response

In the event of a data breach that affects your personal information, we will:

• Notify you as required by applicable law
• Describe the nature of the breach
• Explain the steps we are taking to address the breach
• Provide recommendations for protecting yourself

Important: While we implement reasonable security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

9. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations:

9.1 Retention Periods

• Active Customers: Duration of our business relationship
• Closed Loans: At least 5 years as required by federal law (TILA, RESPA)
• Denied or Withdrawn Applications: At least 25 months as required by ECOA
• Legal Holds: Longer when required by law or legal hold
• Marketing Lists: We retain your contact information on a suppression list to honor opt-out preferences

9.2 Secure Disposal

When information is no longer needed, we securely dispose of it by:

• Shredding paper documents
• Electronically wiping or destroying electronic media
• Using secure data deletion methods for digital files

10. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience on our website:

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help us recognize your device and remember your preferences.

10.2 Types of Cookies We Use

Essential Cookies (Required)

These cookies are necessary for the website to function properly (session management, security features, form submissions). You cannot opt out of essential cookies.

Functional Cookies (Optional)

These cookies enhance your experience by remembering your preferences and language selection.

Analytics Cookies (Optional)

These cookies help us understand how you use our website through Google Analytics and similar services.

Advertising Cookies (Optional)

These cookies are used to deliver relevant advertisements through platforms like Google Ads and Facebook.

10.3 How to Control Cookies

You can control cookies through:

• Browser Settings: Most browsers allow you to block or delete cookies
• Cookie Consent Tool: Use our cookie consent banner to manage preferences
• Opt-Out Tools: Use industry opt-out tools like NAI Consumer Opt-Out

Note: Blocking cookies may affect website functionality.

11. Third-Party Links and Services

Our website may contain links to third-party websites, including lender websites, government agency websites, and social media platforms.

Important: This Privacy Policy does not apply to third-party websites. We are not responsible for the privacy practices of third-party sites. We encourage you to read their privacy policies before providing any information.

12. Children's Privacy

Our services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at info@agoodlender.com. We will delete such information as soon as reasonably possible.

Note: Individuals must be at least 18 years old to enter into a mortgage contract.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

13.1 Notice of Changes

When we make significant changes to this Privacy Policy, we will:

• Update the "Last Updated" date at the top of this policy
• Post a notice on our website homepage
• Send an email notification to customers with active loan applications

13.2 Your Acceptance

Your continued use of our website and services after changes to this Privacy Policy constitutes your acceptance of the updated policy.

13.3 Annual Privacy Notice (GLBA Requirement)

As required by the Gramm-Leach-Bliley Act, we will provide you with an annual privacy notice each year as long as you maintain an ongoing customer relationship with us. This notice will:

• Describe our current privacy practices
• Explain your rights and options regarding information sharing
• Provide updated contact information
• Notify you of any material changes to our privacy practices

You may receive this annual notice by mail, email, or through our secure online portal. If you prefer a specific delivery method, please contact us.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

14.1 Response Time

We will respond to your privacy inquiries within:

• General inquiries: 5 business days
• CCPA requests: 45 days (with possible 45-day extension)
• FCRA disputes: 30 days

14.2 Regulatory Contacts

If you have a complaint about our privacy practices, you may also contact:

Consumer Financial Protection Bureau (CFPB)

Website: www.consumerfinance.gov/complaint/
Phone: 1-855-411-2372

California Department of Financial Protection and Innovation (DFPI)

Website: dfpi.ca.gov/file-a-complaint/
Phone: 1-866-275-2677