You are a valued customer and we at Hamilton Home Mortgage powered by Lower, LLC (“Lower” or “Company”) strongly believe in protecting the confidentiality and security of the information we collect about you as a customer, potential customer, or former customer. We have adopted the following policy to safeguard the personal information about you in our possession. Hamilton Home Mortgage powered by Lower, LLC requires that its organization, employees, and its DBA/Other Trade Names, comply with all requirements of this policy.
Our Privacy Pledge
- We do not sell or rent customer information. Period.
- We share customer information with certain employees and with companies providing services on our behalf to service your needs.
- We may share your personal information with non-affiliates to assist in your application and mortgage process.
- We may share information for marketing and/or joint marketing purposes.
- Our policy requires all employees and companies providing services on our behalf to keep customer information safe and to comply with our company’s customer information security expectations.
- You may have other privacy protections under applicable state laws. To the extent the state laws apply, we will comply with them when we share information about you, and in some cases may be limited by you in what we can share.
Safeguarding Personal Information
We have adopted policies and procedures designed to protect your personal information from unauthorized use or disclosure.
- We have implemented physical, electronic, and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access.
- Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing, or developing our products or services.
- Our policy, which governs the conduct of all our employees, requires employees to safeguard personal information about the consumers and customers we serve or have served in the past.
Information We Collect About You
We collect information about you to help us serve your financial needs to provide you with quality products and services and fulfill legal and regulatory requirements. We consider all information about you in our possession to be personal information, even if you cease to be a customer. The personal information we collect about you may include among other things:
- Identifying information, such as your name, age, address, phone number, and social security number.
- Employment information.
- Financial information such as your income, assets, and liabilities, as well as information about your savings, investments, insurance, and business.
Typically, we collect this information on applications and other forms you complete, through conversations you may have with our loan professionals, with our other representatives, and in some cases, over our website. We may also collect information from a wide range of other sources to process and/or underwrite your loan. These sources may include among others, employers, attorneys, banks, lenders, title insurers, insurance companies, credit reporting agencies, our Company’s mobile services, and online web applications.3
Sharing Information with Entities That Provide Services to, or Regulate, our Company
All financial companies need to share customers’ personal information with third-party companies to run their everyday business. In addition, we may share transactional information with our state and federal regulators. Hamilton Home Mortgage powered by Lower, LLC may share your personal information for our day-to-day business purposes, such as to:
- Respond to court orders and legal investigations
- Maintain your existing account or application
- Process your transaction
- Report to the credit bureaus
- Service and/or sell your mortgage transaction
- Respond to our Company’s prudential state and federal regulators routine requests
Third parties may include, among others, title companies, appraisers, insurance companies, underwriting services, processing services, loan servicers, printing companies, software providers, data federal and state regulators, marketing services, and purchasers of loans.
Hamilton Home Mortgage powered by Lower, LLC adheres to all applicable state laws with respect to the sharing of information.
Sharing Information with Affiliates
Hamilton Home Mortgage powered by Lower, LLC may share personal information about you with its affiliated service providers to assist our company in running day-to-day business activities and operations. Your personal information may also be shared with our affiliates for marketing or joint marketing purposes. The personal information shared by our company may allow our affiliates to market its services and products to you.
Through our Hamilton Home Mortgage powered by Lower, LLC app we offer you the option to import your bank account and other information to facilitate the functionality of our app, and we use third party affiliates to accomplish this. By using this app, you accept that we may share your information with these data partners so that you can use the app in all the ways it is intended. With the help of our data partners, we’ll have access to your financial accounts and information as it relates to our app functionality and purposes.
Your personal information shared may include the following: Your Name, Subject Property Information; Transactional Details (for example Estimated Closing date, Loan Status, and Loan Amount); and Contact Information. Our affiliates and third party service providers are required to enter into confidentiality agreements with us, prohibiting them from using any personal information they obtain for any purpose other than those for which they were retained or as required by law. See “To Limit our Sharing” below.
You may want to make a copy of any document for your records when requested to share your information.
Sharing Information with Non-Affiliates
Hamilton Home Mortgage powered by Lower, LLC may share personal information about you to non-affiliated financial service providers to assist our company in running day-to-day business activities and operations. Your personal information may also be shared with such entities for marketing or joint marketing purposes. Your personal information shared may include the following: Your Name, Subject Property Information; Transactional Details (for example Estimated Closing date, Loan Status, and Loan Amount); and Contact Information. Hamilton Home Mortgage powered by Lower, LLC is not permitted, directly or indirectly, to disclose your account number to any non-affiliated third party for marketing purposes. See “To Limit our Sharing” below.
Unless otherwise permitted by this policy, Hamilton Home Mortgage powered by Lower, LLC may not, directly or indirectly, disclose your nonpublic personal information to a non-affiliated third party unless:
- You were provided a privacy notice;
- You have the opportunity to “opt-out”;
- You were allotted a reasonable opportunity to opt-out; and
- You elected to not opt-out.
You may want to make a copy of any document for your records when requested to share your information.
We want you to stay informed about our new or existing products! As such, we may directly market our products and services to you through various advertising channels, such as direct mailers and e-mail. To submit requests to limit our direct marketing, please call us at (833) 920-2273. See “To Limit our Sharing” below for additional information and opt-out details.
Mobile numbers provided for SMS texting programs will not be shared with non-affiliated financial service providers. We will not use consumer phone numbers solely for lead generation on behalf of, nor share information with, third parties.
To Limit Our Sharing
To limit the sharing of your information (or opt-out), as permissible by federal and state law, please contact us at (833) 920-2273 or email firstname.lastname@example.org.
We can begin sharing your information 30 days from the date we sent this notice unless you authorized us to begin sharing immediately. When you are no longer our customer, we may continue to share your information as described in this notice. You can contact us at any time to limit our sharing.
If you limit your sharing for an account you jointly hold with someone else, your choices will apply to everyone on the account.
Federal law gives you the right to limit only the following:
- Sharing for affiliates’ everyday business purposes – information about your creditworthiness.
- Affiliates from using your information to market to you.
- Sharing for non-affiliates to market to you.
You have the right to see what specific pieces of data we have about you, and to get this data in a portable and easily accessible format. You also have the right to request that we delete your data. We’re legally required to keep some data about you, but we’ll delete everything we can in accordance with state and federal law. Keep in mind that we might reacquire some of our data if we purchase data from a third party. To exercise this right please contact us at (833) 920-2273.
State laws and individual companies may give you additional rights to limit sharing.
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
Non-affiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies
Joint Marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.
Opt-out: A direction by you that the financial institution not disclose certain personal information about you to a non-affiliated third party, except as permitted by law.
Cookies: Text files with small pieces of data that are used to identify and keep track of a website user’s visits and activity.
California Residents: We will not share your information with companies outside of our company, except for our everyday business purposes, for marketing our products and services to you, or with your consent.
Vermont Residents: Vermont is an “opt in” state; not an “opt out” state. Non-public personal financial information may not be shared with others except as permitted by law unless the Vermont consumer specifically consents to the disclosure. In addition, Vermont law prohibits the sharing of credit reports and/or creditworthiness information with affiliates unless the consumer has consented to (“opted-in”) to such sharing.
Important Notice about Credit Reporting: We may report information about your account(s) to credit bureaus and/or consumer reporting agencies. Late payments, missed payments, or other defaults on your accounts(s) may be reflected in your credit report and/or consumer report.
Telephone Communications: All telephone communications with us or our authorized agents may be monitored or recorded for quality control purposes.
Do Not Call: Hamilton Home Mortgage powered by Lower, LLC maintains an internal Do Not Call preference list and complies with the provisions of the Telephone Consumer Protection Act (TCPA) for all consumers. Do Not Call requests will be honored within 30 days and will be effective for at least five (5) years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers that appear on Hamilton Home Mortgage powered by Lower, LLC Do Not Call List.
What personal information is being collected?
The following information may be collected when you use this web site: – your server address; – the date and time of your visit to the web site; – the pages you accessed and the documents downloaded; – the previous web site you visited; and – the type of browser you are using. This information is collected for statistical purposes and to enable us to improve the navigation functions of our web site. Where permitted by applicable law, third parties may be used from time to time to collect the above listed information and information on your online activities. Additionally, this web site may ask for specific personal information in order to respond to requests for information or to register users for particular services. This can include but may not be limited to:
- A first and last name.
- A home or other physical address which includes the name of a street and the name of a city or town.
- An electronic mail address.
- A telephone number.
- A social security number.
- An identifier that allows a specific person to be contacted either physically or online.
- Other pieces of information that may be personally identified to you.
Who is collecting personal information?
Where this web site specifically asks for your personal information (for example to respond to requests for information or to register users for particular services), your personal information will only be collected by staff of Hamilton Home Loans or by third parties engaged by Hamilton Home Loans who have responsibility for responding to such requests or administrating such registrations.
Is your personal information shared?
Your personal information will not be forwarded to any unaffiliated third party for marketing or used for any similar purpose without your consent. To the extent allowed or required by applicable law, personal information collected on this web site may be shared with third parties as necessary for Hamilton Home Loans to provide requested services and shared with affiliated third parties for their operational purposes.
Cookies can be either “persistent” or “session” based. Persistent cookies are stored on your computer, contain an expiration date, and may be used to track your browsing behavior upon return to the issuing web site. Session cookies are short-lived, are used only during a browsing session, and expire when you quit your browser. Upon closing your browser, the session cookie set by this web site is destroyed and no personal information is maintained which might identify you should you visit our web site at a later date.
Security of personal information collected on this web site
This web site does not provide facilities to guarantee the secure transmission of information across the Internet. While reasonable efforts are used to provide security, users should be aware that there are inherent risks in the transmission of information across the Internet.
This web site may on occasion provide links to other web sites for your convenience or additional information. Hamilton Home Loans is not responsible for any content or practices of these web sites.
You can request access to the personal information (if any) that we keep on record. If you believe any information that we keep on record is incorrect or out of date you may request that it be corrected. There is no fee for requesting access to your information, however, we may charge you the reasonable cost of processing your request.
How consumers are notified of material changes to this policy
*California Residents Notice
California residents can get more information regarding the categories of personal information Hamilton Home Loans collects and uses by clicking here.
Effective date of this policy
This policy is effective from October 1, 2018.