Protecting Your Personal Information
Reverse Mortgage Solutions, Inc. recognizes the importance of your privacy and protecting your personal information while you are visiting our websites. It is our goal to provide our customers with the opportunity to access and use our products and services in a secure environment.
WE RECOGNIZE YOUR EXPECTATION OF PRIVACY
We understand that you expect us to maintain proper safeguards to protect your confidential information, and we recognize the need for security in the protection of your privacy. Thus, we have established policies and procedures to prevent misuse of your information.
WE COLLECT, USE, AND RETAIN INFORMATION ABOUT YOU ONLY FOR LEGITIMATE BUSINESS PURPOSES
We gather, use and keep information about you only if required by law, or we believe that the information is necessary to administer our business, and/or to serve your interests by providing you with products, services, and other opportunities. Your information is processed through secured servers certified as such by Verisign, an independent internet security company. We retain any email you send us only until such time as your question has been answered to your satisfaction.
“Cookies” are small files that are stored on your computer. They contain website addresses and codes that your browser sends to websites every time you visit them. We may send cookies to your computer to enhance your online experience, primarily by allowing us to recognize you as a customer or previous visitor and to store your personal preferences.
“Web beacons” are small graphics images, usually invisible, embedded in webpages or emails. We may use web beacons (1) on our websites to track website use; for example, to note how long a webpage was viewed and (2) when we send you HTML emails; for example, to let us know if you received and/or opened the email.
Although cookies and web beacons do not store personally identifiable information, if you choose to provide personally identifiable information through our website, that information can be linked to the technical information stored in cookies and web beacons. You may set your browser to reject cookies from us and/or any other website. In addition, you may set your browser to display HTML emails as text only, which may prevent the use of some web beacons.
Note that some areas of our website may be accessed, now or in the future, only in conjunction with cookies or web beacons; thus, disabling cookies or web beacons might prevent you from accessing content in those areas. Consult the “Help” section of your browser for more information.
WE MAINTAIN ACCURATE INFORMATION
We have procedures in place for maintaining and updating information about our customers in accordance with commercial standards. We provide 800 numbers on all applications and other financial documents used by those visiting our websites, for your convenience. If at any time you would like to change information you have provided to us online, call the number provided on the form or write to us at the address provided to you on the form you sent to us online.
WE HAVE POLICIES AND PROCEDURES LIMITING EMPLOYEE ACCESS TO YOUR PERSONAL INFORMATION
We maintain procedures and security levels to limit employee access to your personally identifiable information to those employees with a business reason for knowing such information. Our employees are trained on customer confidentiality and privacy. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
WE MAINTAIN SECURITY PROCEDURES TO PROTECT YOUR PERSONAL INFORMATION
We maintain appropriate security standards and procedures to protect your personal information from unauthorized access. We periodically upgrade and test these security procedures and safeguards.
WE RESTRICT THE DISCLOSURE OF ACCOUNT INFORMATION
We do not reveal specific information about you or your accounts or other personally identifiable data outside of Security 1 Lending and Reverse Mortgage Solutions, Inc. unless (1) the information is provided to help complete a transaction initiated by you; (2) you request it; (3) the disclosure is required or allowed by law; or (4) you have been informed about the possibility of such disclosure for marketing or similar purposes and we have given you the opportunity to decline.
WE MAINTAIN YOUR PRIVACY IN BUSINESS RELATIONSHIPS WITH THIRD PARTIES
We do not sell personal information to third parties. However, sometimes it is necessary to provide your personably identifiable information to third parties such as vendors or service companies that we hire to assist us in the preparation and handling of your account.
WE DISCLOSE OUR PRIVACY COMMITMENT TO OUR CUSTOMERS
We want our customers to understand our commitment to privacy issues and our use of confidential customer information. Furthermore, we want our customers to feel confident that their privacy is protected.
ATTENTION NEVADA RESIDENTS
Reverse Mortgage Solutions, Inc. (RMS) collects through its website and/or online services the following categories of information (“Information”) about consumers who use or visit its website and/or online services:
- A consumer’s first and last name
- A consumer’s home or other physical address that includes the name of a street and the name of a city or town
- A consumer’s e-mail address
- A consumer’s telephone number
- A consumer’s Social Security number
- An identifier that allows a specific person to be contacted either physically or online and
- Other information (for example, a consumer’s birth date) that, in combination with an identifier, makes the information personally identifiable.
RMS may share this Information with affiliates and/or non-affiliates, as allowed by law.
Consumers who use or visit the RMS website or online service can review and request changes to any of their Information that is collected through the website or online service, via the website or online service. Consumers can review and request changes by contacting RMS at 1-866-503-5559.
RMS may permit a third party to collect Information about consumers’ online activities over time and across different Internet websites or online services when the consumers use the RMS website or online service.
CALIFORNIA PRIVACY RIGHTS NOTICE
At RMS, we are mindful of our responsibilities under the California Consumer Protection Act (CCPA) (Cal. Civ. Code § 1798.100 et seq.) regarding the collection, use, and disclosure of your personal information, both online and offline. This online notice applies only to California residents who are subject to the CCPA.
Most visitors of our website are either representatives of businesses seeking to interact with us as part of their jobs, or individuals engaging with us in connection with proving them a consumer financial product or service subject to the Gramm-Leach-Bliley Act (GLBA). Please note that personal information we obtain, use, or disclose through any business-to-business interactions and GLBA transactions is exempt from the CCPA.
How We Collect, Use, and Share Personal Information on California Residents
- Personal Information Collected in the Last Twelve Months
We collect information that identifies, relates to, describes, references, and is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, we have obtained the following categories of Personal Information on California residents within the last twelve months:
- Identifiers such as real name, alias, postal address, email address, IP address, unique personal identifier, online identifier, account name, social security number, and driver’s license number when you provide it during your reverse mortgage solution relationship with us, sign up to learn more about our consumer financial products and services, or sign up to learn more about becoming an RMS Partner.
- The following categories of personal information described in Cal. Civ. Code § 1798.80(e), not otherwise described herein, including signature, insurance policy number, education, income information, bank account number or any other financial information, or volunteered medical information.
- The following categories of protected classification characteristics under California or federal law: Age (40 years or older), citizenship, marital status, sex, gender, veteran or military status, or physical or mental disability, when you provide it to us.
- Commercial information such as records of products or services purchased, or obtained, or considered from us.
- Internet or other similar network activity information, including, but not limited to, browsing history on our websites, search history, and information on your interaction when you choose to visit our websites or applications.
- Audio information such as recordings of when you called into our call center.
- Current or past professional or employment-related information, including job history or performance evaluations.
For each of the above categories, most of the Personal Information we have obtained was provided by you as part of your mortgage loan origination process, which was then provided to us when we became your mortgage servicer or sub-servicer, and information we received from third parties in connection with processing, underwriting, funding, and servicing your mortgage loan. This information is necessary for us to service your mortgage loan in accordance with federal and state law.
Please note that Personal Information does not include:
- Publicly available information from government records;
- Deidentified or aggregated consumer information; and
- Information exempted from the CCPA’s scope, including without limitation, the GLBA, the Fair Credit Reporting Act (FCRA), California Financial Information Privacy Act (CFIPA), the Driver’s Privacy Protection Act of 1994, and certain information associated with business-to-business transactions.
- Our Use of Personal Information for Business Purposes in the Last Twelve Months
We use the Personal Information we obtain, identified in Categories A-G, for the business purposes listed below.
- Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
- Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
- Debugging to identify and repair errors in our systems;
- Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
- Conducting internal research to develop and demonstrate technology;
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
- Preparing statistics and performing analysis to support our operations;
- Conducting surveys regarding your satisfaction with our products and services; and
- Receiving and responding to inquiries.
We use your Personal Information to properly service your mortgage loan. In the event we would like to use your Personal Information in a way that is materially different, unrelated, or incompatible with the purposes described above, we will let you know in advance and give you an opportunity to decline.
- Our Sharing of Personal Information in the Last Twelve Months
- Disclosures of Personal Information for Business Purposes
Within the last twelve months, we have disclosed Personal Information identified in each of the categories listed above (i) when you request it; (ii) as part of an exempt business-to-business commercial transaction; (iii) in connection with providing you a consumer financial service or product subject to the GLBA; or (iv) to our service providers for the business purposes described herein.
When we disclose Personal Information for a business purpose, we execute a contract that describes the purpose and requires the recipient to keep your Personal Information confidential and not use it for any purpose except in performing the contract.
- No Sales of Personal Information
We do not sell Personal Information within the meaning of the CCPA nor do we plan to sell Personal Information. If that changes, we will let you know in advance and provide you with information so that you may understand and exercise your right to opt-out of the future sale of your Personal Information.
We do not collect, use, sell or disclose Personal Information of individuals we know to be under the age of 18 to business partners or third parties.
Privacy Rights and Choices For California Residents
If you are a California resident, the CCPA provides you with certain rights related to your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
- Access to Personal Information or Data Portability Request
You have the right to know what Personal Information we have obtained and disclosed about you for a business purpose in the last twelve months. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following:
- the categories of Personal Information we collected about you;
- the categories of sources from which the Personal Information was collected;
- 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 (or “portability request”); and
- if we disclosed your Personal Information for a business purpose, a disclosure identifying the categories of Personal Information that each category of recipient obtained.
We are not required to comply with a verifiable consumer request for access or data portability twice within a 12-month period.
- Deletion Request
You have the right to request that we delete (and direct our service providers to delete) Personal Information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with 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;
- comply with the California Electronic Communications Privacy Act;
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- comply with a legal obligation; or
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Non-Discrimination for Exercise of a California Privacy Right
We will not discriminate against you for exercising any of your CCPA rights. This means that we may not deny you goods or services, charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
- Exercising Your CCPA Rights
To exercise one or more of the above rights, you or someone you authorize, may submit a request by:
- Calling us toll-free at 1-866-503-5559
- Emailing us at email@example.com
- Writing us at 14405 Walters Rd., Suite 200, Houston, Texas 77014
However, as discussed above, the CCPA does not apply to all or nearly all information we obtain, use, or share as part of certain business-to-business transactions or in our role as a financial institution in servicing your mortgage loan, and we will not include any of that information in responding to your request.
Please note that we are not responsible for requests that are not labelled or sent properly, or that do not have complete information. We will provide you with information on how to submit the request or remedy any deficiencies with the request, if applicable. We will deliver our response in the same manner that we received it.
- Verifiable Request and Timing
As required under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. You must provide us with enough information to allow us to reasonably verify you are the person about whom we collected Personal Information, or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Please include the statement “Attention: California Privacy Rights Request” in the body of any written request, as well as your name, loan number, loan S/KEY number, email address, property address, and phone number. We may limit our response to your exercise of the above rights as permitted under applicable law.
We will review each request carefully and respond accordingly within the timeframe established by the CCPA.
- Agent Authorization and Disability Access
You may designate an authorized agent to make a CCPA request for personal information on your behalf. To designate an authorized agent to act on your behalf, you must provide the agent with written permission to do so and provide proof of your identity. Written permission may include a power of attorney sufficient under California Probate Code §§ 4121 to 4130.
You may also make a verifiable consumer request on behalf of your minor child, but you must provide proof that you are that child’s parent or legal guardian.
Consumers with disabilities may access this notice in an alternative format by calling our toll-free call center at 1-800-877-8339.
Contact Information Regarding this California Notice and CCPA
You may contact us with questions or concerns regarding the rights listed above by emailing us at firstname.lastname@example.org or calling us toll-free at 1-866-503-5559. You may also contact us by postal mail at 14405 Walters Rd., Suite 200, Houston, Texas 77014.