Last Revised: March 15, 2019
Privacy Policy
Welcome to the website (“Site”) of Homepoint and its affiliates and subsidiaries (“Homepoint,” “we,” “our,” or “us”). Homepoint offers a simple and transparent process that enables you to use your home equity to consolidate debt, pay for home improvements, or fund your goals.
This Privacy Policy explains what personal and other data we collect through the Site, our mobile application (“App”), email, e-notary service, and call center (collectively the “Services”), how we use and share that data, and your choices concerning our data practices. This Privacy Policy forms part of our Terms of Service, which are available at: https://homepointheloc.com/terms/.
By providing us with your personal data when using the Services you agree to the data practices described in this Privacy Policy. If you do not agree to these practices, please do not access or use the Services. Before you submit any Personal Data (as defined below) to Homepoint through the Services, please review this Privacy Policy carefully, and contact us if you have any questions. For details on sharing your personal information see “Sharing and Disclosure” section below. Please also review the Gramm-Leach-Bliley Act Privacy Notice here.
Information We Collect
Personal Data You Voluntarily Provide Us
Personal Information. When you interact with our Services, apply for a financial product, contact us with inquiries or create an account to access the Services, we collect information you voluntarily give us that alone (e.g., your name, email address, social security number, date of birth, bank account and routing numbers, and marital status, household income, credit report data), or in combination with other information could be used to identify you (“Personal Data”).
Other Information. In order to help us determine if you qualify for financial products or services, we may obtain credit reports from consumer credit reporting agencies. If required by law, we will provide notice and/or obtain your consent to do so. When you voluntarily provide it to us, we may also use the information you use to login to your accounts with your financial institutions (such as the username and password you use to access your bank's website) so we can evaluate your transaction history to identify financial products and services that might interest you and evaluate your eligibility for our products and services.
Information We Receive Automatically from Your Use of the Site and App
When you visit, use and interact with the Site or App, we may receive certain information about your visit, use or interactions that alone cannot identify you. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation patterns. In particular, the following information is created and automatically logged in our systems:
- Log data. Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.
- Cookies, Pixel Tags and other technologies. Information from cookies, pixel tags and/or other technologies. Please see the “Cookies” section below to learn more about how we use cookies and other technologies.
- Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information. We collect information about how you use our Site and App, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
Cookies
In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. In order to personalize your use of the Site, we use local shared objects, also known as Flash cookies, to display content based upon what you view. Flash cookies are different from browser cookies (discussed above) because of the amount and type of information they generate, and how they store that information. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here.
When you visit the Site or view one of our emails, we will use pixel tags or “clear” gifs to track links and/or similar technology to note some of the pages you visit on our Site and to personalize your experience. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.
Analytics and Tracking Technologies. We may, and we may allow third party service providers, to use cookies (as noted above) or other tracking technologies (e.g., Google Analytics), to help us understand your use of our Site and collect information about your browsing activities over time and across different websites. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners.
How We Use Your Information
We use Personal Data and other information for the following purposes:
- To provide you with the Services and related customer service, including communicating with you as necessary in connection with your application for financial products and services;
- To market our products and services to you;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Services, and changes to our terms, conditions, and policies;
- To analyze how users interact with our Services so we can provide, maintain and improve the content and functionality of the Services;
- To prevent fraud, criminal activity, or misuses of our Services and to ensure the security of our IT systems, architecture and networks;
- To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties;
- To conduct and publish market research, e.g., consumer surveys, polls, statistics etc;
- To publish user-generated content for use on our Site, social media, or other marketing platforms.
Marketing
We may use your information to contact you in the future to tell you about products or services we believe may be of interest to you. If we do, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
We use web beacons to tell when a user is redirected to the Site because of an advertisement that we ran was clicked on or otherwise interacted with and to better target our advertisements (known as “retargeting”). Our service providers may track Site visitors across multiple websites and social media services to retarget Site visitors. Users logged in to social media programs may be tracked by service providers who track such users across multiple websites and who may disregard the privacy settings in your web browsers.
Information Access and Choice
You can contact us at +1 (888) 891-2310 or privacy@homepointheloc.com to do the following at any time:
- See what data you provided through the Services, if any.
- Change/correct any data you provided through the Services.
- Express any concern you have about our use of your data.
Sharing and Disclosure
We may share personal information with certain third parties without further notice to you unless required by law in the following circumstances:
Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, bankruptcy, or similar event, Personal Data may be part of the transferred assets.
We may also share your Personal Data with our affiliates for business purposes, including marketing, as described in this Privacy Policy. However, we will never sell your data to others.
Agents, Consultants, Vendors, and Service Providers. Like many businesses, we sometime hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements. We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) protect against legal liability. You can review our Gramm-Leach-Bliley Act Privacy Notice for more information here.
California Privacy Rights
California residents may request information regarding the types of personally identifiable information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. As noted above, we do not provide Personal Data to third parties for their direct marketing purposes.
Residents of California may have rights under the California Consumer Privacy Act (“CCPA”) as described in this section of our Privacy Policy. We note, however, that much of the Personal Data that we collect is exempt from the following provisions of the CCPA, which do not apply to Personal Data collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act. The CCPA also includes certain exceptions related to certain information in a business-to-business context and information collected about employees, job applicants, and contractors.
You can review our Gramm- Leach-Bliley Act Privacy Notice for more information on how we share information here.
Access Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request access to certain information about the Personal Data we collect about you. In particular, these individuals have a right to request that we provide the following information:
- The categories of Personal Data that Homepoint has collected about you.
- The categories of sources from which Homepoint collected the Personal Data.
- The business or commercial purposes for which Homepoint collected and/or sold the Personal Data.
- The categories of any third parties with which Homepoint shared the Personal Data.
- The specific pieces of Personal Data Homepoint collected over the past year.
- The categories of Personal Data, if any, Homepoint has sold about you, categories of third parties to which Homepoint sold that Personal Data, and the categories of Personal Data sold to each type of third party.
- The categories of Personal Data that we have disclosed for a business purpose.
Our responses to such requests will cover the 12-month period preceding our receipt of the request.
To request access to this information, you may contact Homepoint at +1 (888) 891-2310 or email us your request via privacy@homepointheloc.com. You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and relationship with Homepoint. You may also designate an agent to submit a request on your behalf. We will likewise need to verify the agent.
Deletion Requests: If you are a California resident whose information is covered by the CCPA, you have a right to request that we delete certain personal information from our records, subject to certain exceptions. We are not required to delete information that is necessary for us to: complete the transaction for which we collected the information; provide you with a good or service you requested; perform a contract Homepoint entered into with you; detect security incidents; maintain the functionality or security of Homepoint's systems; comply with or exercise rights provided by the law; or use the information internally in ways that are comparable with the context in which you provided the information to Homepoint or that are reasonably aligned with expectations based on your relationship with Homepoint, among other things. We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies.
To submit a deletion request, you may contact Homepoint at +1 (888) 891-2310 or email us your request via privacy@homepointheloc.com. You may need to submit certain information in order for us to verify your identity or request before we process your request including your name, address, email address, phone number, attestation that you are a California resident and relationship with Homepoint.
We will respond to requests for access or deletion as soon as practicable and in any event generally not more than within 45 days after receipt of your request. We may extend this period to 90 days in some cases.
Household Information: There may be some types of Personal Data that can be associated with a household (a group of people living together in a single home). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above. If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request.
Non-Discrimination: If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than other consumers.
Accessibility: We are committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this policy in alternative formats by contacting us at the address, phone, or email address below.
This website is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us by either:
- Calling us at +1 (888) 891-2310
- Emailing privacy@homepointheloc.com
Do Not Track Signals.
Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received.
Links to Other Websites
This Privacy Policy only applies to information collected by Homepoint through our Services. The Homepoint Services may contain links to other web sites, apps or online services not operated or controlled by Homepoint (“Third Party Sites”). The policies and procedures described here do not apply to Third Party Sites. By providing links to Third Party Sites or services we do not imply that we endorse or have reviewed such websites or services. We suggest that you contact those sites directly for information about their data practices and policies.
Security
You use the Services at your own risk. We use industry-standard precautions, including technical and administrative measures, to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us in connection with the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or e-mail. Please keep this in mind when disclosing any Personal Data to us via the Internet.
Contact Information
Please feel free to contact us if you have any questions about this Privacy Policy or information practices:
Telephone: +1 (888) 891-2310
Email: loans@homepointheloc.com