California Privacy Rights & Do Not Sell Notice

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This SUPPLEMENTAL PRIVACY NOTICE is intended to apply solely to visitors, users, and persons who are residents of the State of California ("consumers" or "you").

This notice is an addendum to the existing Privacy Statement of THL Holdings LLC and its affiliates (collectively, "we," "us," or "our").

We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect 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").

We have collected the following categories of personal information from consumers within the last twelve (12) months:

Category: "Identifiers" — which may include: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

Category: "Personal Information" — which may include: a name, signature, address, telephone number, employment status, financial information relevant to a home loan inquiry. Some personal information in this category may overlap with other categories.

Category: "Commercial Information" — records of products or services considered for purchase, including mortgage products and loan inquiries.

Category: "Protected Classification Characteristics" — which may include: age, race, color, ancestry, national origin, citizenship, marital status, sex, and veteran or military status.

Category: "Internet or Other Similar Network Activity" — which may include: browsing history, search history, and information on a consumer's interaction with a website, application, or advertisement.

Category: "Professional or Employment-Related Information" — which may include employment status (e.g., employed, self-employed, or retired).

Category: "Geolocation Data" — location of Internet Service Provider.

The above categories of personal information are obtained from the following sources:

  • Directly from you, through your interactions on this platform and the information you provide in any forms you submit.
  • Information you provide in connection with a product or service offered by our affiliates, partners, or vendors.
  • Information you provide for communication permissions and consents.
  • From third parties that interact with us in connection with the platform or services we perform — for example, ActiveProspect's TrustedForm, which is used to independently document users' consent to be contacted and collects: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, IP address, time on the page, date and time the TrustedForm Script was loaded, and HTTP headers from the user's browser. For more information, see the ActiveProspect Privacy Policy at https://activeprospect.com/privacy-policy/.
  • Information you provide us through telephone, website, customer service correspondence, and general feedback.

    • Use of Personal Information

    We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To facilitate your introduction to a single, matched licensed Mortgage Loan Originator through our Mortgage Matchmaking process.
  • To provide you with personalized email, SMS, or telephone communications concerning mortgage products or services you have expressed interest in (with proper consents, where required by law).
  • To carry out our obligations and enforce our rights arising from contracts entered into between us, our Mortgage Loan Originators, and any affiliates or vendors.
  • To improve our platform and the services offered.
  • For testing, research, analysis, and product development.
  • To help maintain and protect the rights, safety, security, and integrity of our platform, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, or other sale or transfer of some or all of our assets.
  • As described to you when collecting your personal information or as otherwise permitted by the CCPA.

    • We will not collect additional categories of personal information or use personal information for materially different purposes than described herein without first providing you notice.

    Sharing Personal Information

    Trust Home Loan is a Mortgage Matchmaker — not a shared lead distributor. Your personal information is shared exclusively with the single licensed Mortgage Loan Originator matched to your inquiry. We do not simultaneously distribute your information to multiple competing lenders or loan officers.

    We may share personal information with third parties for the following limited business purposes, under contracts that describe the purpose and require confidentiality:

  • Our affiliates.
  • Service providers who assist in operating our platform.
  • Consent documentation providers (e.g., ActiveProspect).
  • The licensed Mortgage Loan Originator to whom you are matched.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with the mortgage products or services you have expressed interest in.

    • Per California CCPA Section 1798.140(t): A business does not sell personal information when a consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided that third party does not also sell the personal information.

    In the preceding twelve (12) months, we have shared your information with your matched Mortgage Loan Originator and as otherwise described above.

    Your Rights and Choices

    Access to Specific Information and Data Portability Rights —

    You have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will provide:

  • The categories of personal information we collected about you.
  • The categories of sources from which we collected your personal information.
  • 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 (data portability request).

    • Deletion Request Rights —

    You have the right to request that we delete any personal information you provided to us and that we have retained, subject to certain exceptions. Upon receipt and confirmation of your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

    We may retain your information despite a deletion request if retention is necessary to:

  • Complete the introduction for which you provided your personal information.
  • Detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity.
  • Debug products to identify and repair errors in existing platform functionality.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information consistent with the context in which you provided it.

    • Exercising Your Rights

    To exercise your rights as described above, please submit a verifiable consumer request by emailing: support@trusthomeloan.com with "Consumer Rights Request" in the subject line, or by using the consumer request link at the top of this page.

    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 or on behalf of your minor child.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person (or authorized agent) who provided personal information on the platform.
  • Describe your request with sufficient detail for us to accurately understand, evaluate, and respond.

    • Response Timing and Format

    We will respond to a verifiable consumer request within 45 days of its receipt. If more time is required (up to 90 days), we will inform you of the reason and extension period in writing. The information provided will cover the 12-month period preceding the receipt of your verifiable consumer request.

    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

    We will not discriminate against you for exercising any of your CCPA rights. We will not deny you services, charge you different prices or rates, or provide you a different level or quality of services as a result of exercising your rights. Please note: We do not charge consumers for use of these services.

    Changes to This Notice

    We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes, we will notify you by email or through a notice on this platform.

    Contact Information

    For questions or comments regarding this notice, please contact us at:

    support@trusthomeloan.com

    THL Holdings LLC — Attention: Consumer Services

    [ADDRESS]