Privacy Notice

Last Updated:  February 14, 2020

Longbridge Financial, LLC is committed to providing you, our customers, with outstanding products and services while protecting your personal information. This Privacy Notice applies to this website or mobile application and the websites or mobile applications of Longbridge Financial, LLC and our affiliates (collectively “we”, “us” or “our”) that link to this Privacy Notice (each a Site and collectively, the Sites), and to any online services that may be available on or through the Sites (the “Services”). This Privacy Notice describes the personal information we collect on the Site and through the Services, and how we use and protect that information.  Our Sites and Services are intended for a U.S. audience.

Depending on how you interact with us, and the products and services you obtain from us (collectively “Products”), additional privacy practices and disclosures may also be applicable.  For example, if you have a financial Product with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which describes how we use and share the personal information that we collect about you in the course of providing you with that Product.  We will limit sharing of your data to the extent required and in accordance with these additional notices.

In addition, if you are a resident of California, please see our Additional Notice for California Residents, which provides additional information about our privacy practices.

Collection and Use of Personal Information

We collect data about you from a variety of sources, including the following:

  • Information we receive from you at the Sites or in connection with your use of Services or Products, including on applications, online forms and calculators, surveys and other communications. For example, we collect information from you when you:
    • purchase or request a quote for a Service or Product;
    • manage, update or ask questions about a Service or Product;
    • conduct searches on the Sites; access applications and Services from the Sites;
    • participate in surveys or other promotions;
    • use tools and resources available on the Site;
    • request information from us;
    • make data available to us via social networking logins.

This data may include your name, address, phone number, email address, social security number, date of birth, employment information, assets, income and debt, banking data, driver’s license numbers and other data, such as passport number, Medicaid or Medicare information and marital status, in connection with administering and delivering our Products and Services.

  • Information about your transactions with us, our affiliates or others, such as your account balances and payment history;
  • Information from third party sources. We may also collect information about you from consumer reporting agencies, including your credit history and creditworthiness.  We may also collect information from companies that collect or analyze information about consumers or users, such as demographic data, or data provided from sources that you have authorized to share such data with us, either on our Site or via third party applications or websites.
  • Information regarding use of the Site. We may collect data regarding your use of this Site through the use of cookies and other automation. This data may include your IP address; date and time you access the Site and the pages and content you access during your visit; websites that you link to or from; emails from us that you open and the links you click on within those emails;
  • Cookies. We may use automated technologies, such as cookies and web beacons, to collect information on the Site.  Cookies are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. Cookies may also be used to personalize your visit by storing your preferences or displaying content based upon what you have viewed on the Sites and other websites.  Web beacons or pixel tags connect web pages to web servers and their cookies.  We may use these technologies on this Site and other websites and mobile applications.  Third parties, including advertisers, may also use cookies to collect information on the Sites.  We do not control these third party cookies.

Combined Data. We may combine the data we collect from you with information from other sources.

We may use data we collect for a variety of purposes, including, but not limited to, the following:

  • To operate our business;
  • To provide Products and Services to you;
  • To provide customer support;
  • To evaluate your eligibility for Services and Products;
  • To communicate with you about the Products and Services we provide to you, including sending you required disclosures, updates to terms and conditions and messages regarding your account, such as security alerts and verification requests;
  • To develop and evaluate products and services;
  • To conduct internal research;
  • To deliver content and marketing communications that we think may interest you;
  • To comply with law and satisfy our compliance obligations;
  • To detect and prevent fraud and other prohibited or illegal activity
  • To audit and provide reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
  • To provide you with advertising, search results, and other personalized content; and
  • For other purposes permitted by law or to which you consent.

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any specific individual) for various business purposes, where permissible under applicable laws and regulations.

Maintaining Accurate Personal Information

We have established policies and procedures to assist in keeping your personal information accurate, current and complete. We will work to correct inaccurate personal information in a timely manner. If you have any reason to believe that your personal information is incorrect, please contact your customer service or account representative at the toll free number listed on your account statement, or you may contact us here or at one of the methods noted here: https://longbridge-financial.com/contact/ so that we may update our records accordingly.

Protection of Information

We maintain policies and procedures to protect the security of your information and to safeguard against unauthorized access to or use of your data. Of course, despite these measures, no network or system is ever entirely secure and we cannot guarantee the security of networks and systems we operate or that are operated on our behalf.

Personal Information We May Disclose or Share

We  may share your information within our corporate family and with third parties as permitted or required by law, or as directed or authorized by you. For example, we may disclose your information under the following circumstances:

  • To Marketing Service Providers and Joint Marketing Partners. This includes companies that perform marketing services for us, or for us and other financial institutions jointly, as well as other financial institutions with which we have joint marketing agreements. Our joint marketing partners agree to keep your information confidential.
  • Third-Party Service Providers that we have engaged to help deliver our services and products to you, and that have agreed to keep your information confidential.
  • We may share your information within our corporate family.
  • With banking regulators, law enforcement, governmental authorities, as requested or required.
  • With auditors, legal counsel and other third parties in order to comply with our obligation or protect our interests, property or legal rights, or those of our customers or other third parties.
  • In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
  • With consumer reporting agencies and fraud detection service providers.

What Choices do I Have?

You may choose not to provide your data, even though that might impact your ability to receive a particular Product.  In addition, if you do not want to receive marketing email from us, you can follow the unsubscribe link provided in those emails.

You have a number of choices regarding certain Cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our Sites may not function properly or at all as a result.

If you have a Product with us, we will use and share any data that we collect from or about you in accordance with the consumer privacy notice applicable to that Product. 

Links to Third Party Sites

We may provide links to websites that are owned or operated by other companies. When you use a link to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should review the Privacy Notice, terms of use and security practices of the linked third-party website to understand how that site may use your data and/or information. We are not responsible for the privacy or security of these third party sites, or the accuracy, completeness, or reliability of the information they provide.

Children’s Privacy Rights

Our online services are not directed to children under the age of 13. We do not knowingly collect data from children under age 13 without parental consent.

Updates to Our Privacy Notice

We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the “Last Updated” date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated.

 


 

Effective Date:  January 1, 2020

Additional Notice for California Residents

This section of our Privacy Notice applies to residents of California.

Personal Information about California Consumers

The information we have collected from California consumers in the previous twelve months consists of the information listed below.

  • Identifiers, which include name, postal address, email address, social security number, bank account data and other financial identifiers, unique personal identifiers, online identifiers, IP address, and other similar identifiers.  We collect identifiers such as name, address and contact information in order to provide you with our products and services.  We may collect your IP address and unique device identifiers when you visit our websites. We may also receive information about a disability, where relevant to the services we provide, such as when a custodian is acting on your behalf.
  • The following categories of personal information described in California Civil Code §1798.80(e): the Identifiers listed above; signature (if you correspond with us), and telephone number.
  • Protected classification characteristics under California or federal law (such as race, ancestry).
  • Commercial information about your transactions and experiences with us and others, including loan status and payment history
  • Geolocation data.
  • Audio information from calls made to us, which may be recorded, and electronic information in the form of Internet or other electronic network activity information as described above.
  • Professional or employment-related information, in the form of business contact information. We may also obtain information such as education or employment history from credit bureaus, which we use to help prevent and detect fraud and to offer certain services.
  • Inferences drawn from (1) the information we collect when you visit our websites, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on our websites or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, and attitudes.

We collect the above personal information directly from consumers, as well as from other sources, including credit bureaus, fraud-detection services, public databases, social media platforms, and third-party partners such as analytics or marketing providers. We use personal information in the above categories for the following business purposes:

  • To provide information and respond to your requests;
  • For our core business purposes, such as providing quotes for loans, processing applications, establishing and servicing your mortgage, responding to your inquiries and providing customer support;
  • To operate, evaluate and improve our business, including developing new products and services, and analyzing and enhancing our products, services and websites
  • To perform data analyses (including market and consumer search and analytics, trend analysis and profiling, financial analysis and anonymization of personal information)
  • To protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities
  • To comply with applicable legal requirements and our policies
  • To establish, exercise and defend legal claims
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity; and
  • To maintain and enhance the security of our systems and data;
  • To conduct marketing activities and communicate with you regarding products and services of Longbridge Financial and our partners that we think may interest you
  • To undertake internal research for technological development;
  • To deliver website and mobile app content (including advertising) based on your interests and browsing history;
  • To enable you to interact with us through social media platforms;
  • For other purposes permitted by law or to which you consent.

We disclose the above categories of personal information for the business purposes identified above to service providers in connection with their provision of services to us. We may also share the above categories of personal information with affiliates.  In addition, we may disclose information (i) when required by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, or (iii) when necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; and (iv) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

For additional information regarding the categories of personal information we have disclosed and the categories of entities with which we have disclosed this, please see “Personal Information We May Disclose and Share” above.

Sales of Personal Information

We have not sold personal information to third parties for a business or commercial purpose in the 12-month period preceding the Effective Date of this Additional Notice for California Residents.

Your California Privacy Rights

If you are a California resident, you have: (1) the right to know what personal information we collect, use, disclose and sell; and (2) the right to request that we delete your personal information. We will honor your request to the extent required by applicable law.

You may designate an authorized agent to make a request to know or request to delete on your behalf.  An agent may be an individual, or a business entity registered with the California Secretary of State.  To designate an authorized agent, you must provide the agent with written permission to submit the request.  We may still require you to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.

We may not discriminate against you for exercising any of your rights under the CCPA.  This means that we may not deny you services, or 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.  However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

How to Exercise These Rights

You may request to exercise the foregoing rights by:

– Calling us toll-free at 888-756-8676.

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.

Alternative Format

This policy can be accessed in an alternative format by contacting us at compliance@longbridge-financial.com.

 


 

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